Opinion

Menon v. Geovera Holdings, Inc.

Court: District Court, E.D. California
Filed: Sep 3, 2025
Cited by: 0 cases
Authority: More cited than 35.1%

finding “good cause” for protecting 7 information that “includes proprietary and technical information, financial information and 8 business strategy or marketing information which, if revealed to a competitor, would put a 9 company at a competitive disadvantage”

How later courts described this case

finding “good cause” for protecting 7 information that “includes proprietary and technical information, financial information and 8 business strategy or marketing information which, if revealed to a competitor, would put a 9 company at a competitive disadvantage”

Written by the judges who cited it.

The opinion

1 Robert W. Ottinger (SBN 156825)

robert@ottingerlaw.com

Melanie L. Proctor (SBN 228971)

melanie@ottingerlaw.com

THE OTTINGER FIRM, P.C.

4 2108 N Street, Suite N

Sacramento, CA 95816

5 Telephone: 415-262-0096

Facsimile: 212-571-0505

Attorneys for Plaintiff

DEEPAK MENON

SARAH ROBERTSON (SBN 142439)

srobertson@constangy.com

DEEPA KOLLIPARA (SBN 337455)

dkollipara@constangy.com

CONSTANGY, BROOKS, SMITH &

PROPHETE, LLP

601 Montgomery Street, Suite 350

San Francisco, CA 94111

Telephone: 415.918.3000

Attorneys for Defendant

GEOVERA HOLDINGS, INC. AND

GEOVERA INVESTMENT GROUP, LTD.

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

DEEPAK MENON, an individual, Case No. 2:24-cv-01819-TLN-SCR

Plaintiff, [Removed from Solano County Superior

Court, Case No. CU24-02953]

AMENDED STIPULATED

GEOVERA HOLDINGS, INC., a Delaware PROTECTIVE ORDER

corporation, GEOVERA INVESTMENT

GROUP, LTD., a Cayman Islands Exempt

Company, and DOES 1 through 50, inclusive, Complaint Filed: November 1, 2023

Trial: Not Set

Defendants.

Pursuant to Local Rules 141.1 and 143 of the United States District Court for the Eastern District

of California, the Plaintiff Deepak Menon (“Plaintiff”) and Defendants GeoVera Holdings, Inc.

and GeoVera Investment Group, Ltd. (together, “Defendants”) who have appeared in this action

(collectively, the “Parties”) hereby agree to this Amended Stipulated Protective Order and

request that it be entered by the Court. The Parties seek entry of this order to protect from

disclosure to others potentially confidential personnel, financial, sensitive, proprietary, and/or

privileged information that may be produced or otherwise disclosed by them or third parties

during the course of this action and which may be injurious to Plaintiff or Defendants, as is

contemplated by Federal Rule of Civil Procedure 26(c)(1). The Parties submit this Amended

Stipulated Protective Order in compliance with this Court’s September 10, 2024 minute order

whereby this Court ordered the following: “the [P]arties are invited to submit a revised

stipulation and proposed protective order with terms identifying what types of information are

expected to be designated as confidential and protected in this action.” [Docket No. 12].

1. PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are likely to involve production of

confidential, proprietary, or private information for which special protection from public

disclosure and from use for any purpose other than prosecuting this litigation is warranted. Good

cause under Federal Rule of Civil Procedure Rule 26(c) exists here. The information subject to

discovery in this lawsuit includes highly sensitive personnel records all implicating the privacy

interests of third parties. Discovery in this lawsuit also involves the production of highly

confidential private financial and business information, including but not limited to equity share

payouts, incentive share agreements with directors and officers of Defendants, which implicate

the personnel-related privacy of a number of GeoVera Individuals (as defined below) who are

not parties to this action. Finally, discovery is sought in this case related to details of a private

transaction that is subject to a non-disclosure agreement with third parties, involving the sale of

insurance companies in a complex financial deal overseen by various regulatory agencies and

government entities.

For all of the foregoing reasons, public disclosure of the “CONFIDENTIAL” information

as defined below very would cause irreparable harm to Parties. See e.g. Galanski v. Wal-Mart

Assocs., Inc., No. 1:23-CV-01270-JLT-CDB, 2024 WL 2701084, at *2-4 (E.D. Cal. May 24,

2024) (ordering a protective order of “information relating to employees’ complaints of sexual

harassment” because “[d]efendant has some privacy interest in protecting from disclosure details

of its internal ethics investigation” “to ensure it can effectively investigate allegations

implicating employee ethics and encourage responsible reporting”); see also In re Adobe Sys.,

Inc. Sec. Litig., 141 F.R.D. 155, 158 (N.D. Cal. 1992)(finding “good cause” for protecting

information that “includes proprietary and technical information, financial information and

business strategy or marketing information which, if revealed to a competitor, would put a

company at a competitive disadvantage”).

Accordingly, the Parties hereby stipulate to and petition the court to enter the following

Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket

protections on all disclosures or responses to discovery and that the protection it affords from

public disclosure and use extends only to the limited information or items that are entitled to

confidential treatment under the applicable legal principles. The Parties further acknowledge, as

set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file

confidential information under seal; Civil Local Rule 141 sets forth the procedures that must be

followed and the standards that will be applied when a party seeks permission from the court to

file material under seal.

2. DEFINITIONS

2.1 Challenging Party: a Party or Non-Party that challenges the designation of

information or items under this Order.

a) 2.2 “CONFIDENTIAL” Information or Items: “CONFIDENTIAL”

information consists of the following materials, categories of materials, or tangible

things: Any personnel or personal information of any current, or former employees,

directors, and officers of Defendants or of any affiliates, subsidiaries, parent

organizations, and successor organizations of Defendants (together, known as

“GeoVera Individuals”), including, but not limited to, personnel records of

GeoVera Individuals, information about the discipline or separation of employment

of any GeoVera Individuals, information about equity or shares held or paid out to

any GeoVera Individuals, and any information about investigations by GeoVera

Holdings, Inc. or GeoVera Investment Group, Ltd., of any conduct by GeoVera

Individuals or any information about the participation by GeoVera Individuals in

any such investigations;

b) Any confidential business records, including but not limited to,

confidential financial information, proprietary information, trade secrets,

information regarding confidential business practices, research and development,

commercial information, information regarding the timing and sale of Defendants to

any entity or entities, information provided by Defendants to any government

agency or regulatory authority, vendor agreements, board resolutions or board

meeting minutes of Defendants, claim/litigation information, non-public corporate

policies and procedures, pricing formulas, customer data, sales data, contracts or

agreements entered into with GeoVera Individuals and/or any third parties

(including, but not limited to, non-disclosure agreements with prospective buyers,

equity agreements, settlement agreements, or severance agreements), or any other

business information not known to the public;

c) Any privileged communications whereby Defendants have made a limited

disclosure of privilege for the purposes of facilitating this Court and Parties to

evaluate Plaintiff’s claims against Defendants, in the context of discovery in this

lawsuit;

d) Any information about communications between GeoVera Individuals or

communications between GeoVera Individuals, Defendants, and/or any individuals

representing third party entities seeking to purchase Defendants;

e) Any information otherwise generally unavailable to the public, or which

may be privileged or otherwise protected from disclosure under state or federal

statute, court rules, case decisions, common law, or the constitutions of the United

States and/or California (i.e., information implicating privacy rights of third

parties).

f) Notwithstanding the foregoing, the Parties shall not designate as

“CONFIDENTIAL” information that is already public knowledge.

2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as

well as their support staff).

2.4 Designating Party: a Party or Non-Party that designates information or items that

it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

2.5 Disclosure or Discovery Material: all items or information, regardless of the

medium or manner in which it is generated, stored, or maintained (including, among other things,

testimony, transcripts, and tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to

the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a

consultant in this action.

2.7 House Counsel: attorneys who are employees of a party to this action. House

Counsel does not include Outside Counsel of Record or any other outside counsel.

2.8 Non-Party: any natural person, partnership, corporation, association, or other legal

entity not named as a Party to this action.

2.9 Outside Counsel of Record: attorneys who are not employees of a party to this

action but are retained to represent or advise a party to this action and have appeared in this

action on behalf of that party or are affiliated with a law firm which has appeared on behalf of

that party.

2.10 Party: any party to this action, including all of its officers, directors, employees,

consultants, retained experts, and Outside Counsel of Record (and their support staffs).

2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

Material in this action.

2.12 Professional Vendors: persons or entities that provide litigation support services

(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and

organizing, storing, or retrieving data in any form or medium) and their employees and

subcontractors.

2.13 Protected Material: any Disclosure or Discovery Material that is designated as

“CONFIDENTIAL.”

2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a

Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material

(as defined above), but also (1) any information copied or extracted from Protected Material; (2)

all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,

conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

However, the protections conferred by this Stipulation and Order do not cover the following

information: (a) any information that is in the public domain at the time of disclosure to a

Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as

a result of publication not involving a violation of this Order, including becoming part of the

public record through trial or otherwise; and (b) any information known to the Receiving Party

prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who

obtained the information lawfully and under no obligation of confidentiality to the Designating

Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.

24 4. DURATION

25 Even after final disposition of this litigation, the confidentiality obligations imposed by

26 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court

27 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all

claims and defenses in this action, with or without prejudice; and (2) final judgment herein after

the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this

action, including the time limits for filing any motions or applications for extension of time

pursuant to applicable law.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party

or Non-Party that designates information or items for protection under this Order must take care

to limit any such designation to specific material that qualifies under the appropriate standards.

The Designating Party must designate for protection only those parts of material, documents,

items, or oral or written communications that qualify – so that other portions of the material,

documents, items, or communications for which protection is not warranted are not swept

unjustifiably within the ambit of this Order.

Mass, indiscriminate, or routinized designations are prohibited. Designations that are

shown to be clearly unjustified or that have been made for an improper purpose (e.g., to

unnecessarily encumber or retard the case development process or to impose unnecessary

expenses and burdens on other parties) expose the Designating Party to sanctions.

If it comes to a Designating Party’s attention that information or items that it designated

for protection do not qualify for protection, that Designating Party must promptly notify all other

Parties that it is withdrawing the mistaken designation.

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order

(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,

Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so

designated before the material is disclosed or produced.

Designation in conformity with this Order requires:

(a) For information in documentary form (e.g., paper or electronic documents, but

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing

Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only

a portion or portions of the material on a page qualifies for protection, the Producing Party also

must clearly identify the protected portion(s) (e.g., by making appropriate markings in the

margins).

A Party or Non-Party that makes original documents or materials available for inspection

need not designate them for protection until after the inspecting Party has indicated which

material it would like copied and produced. During the inspection and before the designation, all

of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the

inspecting Party has identified the documents it wants copied and produced, the Producing Party

must determine which documents, or portions thereof, qualify for protection under this Order.

Then, before producing the specified documents, the Producing Party must affix the

“CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or

portions of the material on a page qualifies for protection, the Producing Party also must clearly

identify the protected portion(s) (e.g., by making appropriate markings in the margins).

(b) for testimony given in deposition or in other pretrial or trial proceedings, that the

Designating Party identify on the record, before the close of the deposition, hearing, or other

proceeding, all protected testimony.

tangible items, that the Producing Party affix in a prominent place on the exterior of the

container or containers in which the information or item is stored the legend

“CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection,

the Producing Party, to the extent practicable, shall identify the protected portion(s).

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

designate qualified information or items does not, standing alone, waive the Designating Party’s

right to secure protection under this Order for such material. Upon timely correction of a

designation, the Receiving Party must make reasonable efforts to assure that the material is

treated in accordance with the provisions of this Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of

confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality

designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic

burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to

challenge a confidentiality designation by electing not to mount a challenge promptly after the

original designation is disclosed.

6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

process by providing written notice of each designation it is challenging and describing the basis

for each challenge. To avoid ambiguity as to whether a challenge has been made, the written

notice must recite that the challenge to confidentiality is being made in accordance with this

specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in

good faith and must begin the process by conferring directly (in voice to voice dialogue; other

forms of communication are not sufficient) within 14 days of the date of service of notice. In

conferring, the Challenging Party must explain the basis for its belief that the confidentiality

designation was not proper and must give the Designating Party an opportunity to review the

designated material, to reconsider the circumstances, and, if no change in designation is offered,

to explain the basis for the chosen designation. A Challenging Party may proceed to the next

stage of the challenge process only if it has engaged in this meet and confer process first or

establishes that the Designating Party is unwilling to participate in the meet and confer process in

a timely manner.

6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court

intervention, the Designating Party shall file and serve a motion to retain confidentiality under

Civil Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days

of the initial notice of challenge or within 14 days of the parties agreeing that the meet and

confer process will not resolve their dispute, whichever is earlier. Each such motion must be

accompanied by a competent declaration affirming that the movant has complied with the meet

and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to

make such a motion including the required declaration within 21 days (or 14 days, if applicable)

shall automatically waive the confidentiality designation for each challenged designation. In

addition, the Challenging Party may file a motion challenging a confidentiality designation at

any time if there is good cause for doing so, including a challenge to the designation of a

deposition transcript or any portions thereof. Any motion brought pursuant to this provision must

be accompanied by a competent declaration affirming that the movant has complied with the

meet and confer requirements imposed by the preceding paragraph.

The burden of persuasion in any such challenge proceeding shall be on the Designating

Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose

unnecessary expenses and burdens on other parties) may expose the Challenging Party to

sanctions. Unless the Designating Party has waived the confidentiality designation by failing to

file a motion to retain confidentiality as described above, all parties shall continue to afford the

material in question the level of protection to which it is entitled under the Producing Party’s

designation until the court rules on the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed

or produced by another Party or by a Non-Party in connection with this case only for

prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be

disclosed only to the categories of persons and under the conditions described in this Order.

When the litigation has been terminated, a Receiving Party must comply with the provisions of

section 13 below (FINAL DISPOSITION).

23 Protected Material must be stored and maintained by a Receiving Party at a location and

24 in a secure manner that ensures that access is limited to the persons authorized under this Order.

25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

26 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may

27 disclose any information or item designated “CONFIDENTIAL” only to:

(a) the Receiving Party’s Outside Counsel of Record in this action, as well as

employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the

information for this litigation and who have signed the “Acknowledgment and Agreement to Be

Bound” that is attached hereto as Exhibit A;

(b) the officers, directors, and employees (including House Counsel) of the Receiving

Party to whom disclosure is reasonably necessary for this litigation and who have signed the

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

reasonably necessary for this litigation and who have signed the “Acknowledgment and

Agreement to Be Bound” (Exhibit A);

(d) the court and its personnel;

(e) court reporters and their staff, professional jury or trial consultants, mock jurors,

and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who

have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

(f) during their depositions, witnesses in the action to whom disclosure is reasonably

necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of

transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be

separately bound by the court reporter and may not be disclosed to anyone except as permitted

under this Stipulated Protective Order.

(g) the author or recipient of a document containing the information or a custodian or

other person who otherwise possessed or knew the information.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER

LITIGATION

26 If a Party is served with a subpoena or a court order issued in other litigation that compels

27 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that

Party must:

(a) promptly notify in writing the Designating Party. Such notification shall include a

copy of the subpoena or court order;

(b) promptly notify in writing the party who caused the subpoena or order to issue in

the other litigation that some or all of the material covered by the subpoena or order is subject to

this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;

and

Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served with the

subpoena or court order shall not produce any information designated in this action as

“CONFIDENTIAL” before a determination by the court from which the subpoena or order

issued, unless the Party has obtained the Designating Party’s permission. The Designating Party

shall bear the burden and expense of seeking protection in that court of its confidential material –

and nothing in these provisions should be construed as authorizing or encouraging a Receiving

Party in this action to disobey a lawful directive from another court.

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS

LITIGATION

20 (a) The terms of this Order are applicable to information produced by a Non-Party in

21 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in

22 connection with this litigation is protected by the remedies and relief provided by this Order.

23 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking

24 additional protections.

25 (b) In the event that a Party is required, by a valid discovery request, to produce a

26 Non-Party’s confidential information in its possession, and the Party is subject to an agreement

27 with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:

(1) promptly notify in writing the Requesting Party and the Non-Party that some

or all of the information requested is subject to a confidentiality agreement with a Non-Party;

(2) promptly provide the Non-Party with a copy of the Stipulated Protective Order

in this litigation, the relevant discovery request(s), and a reasonably specific description of the

information requested; and

(3) make the information requested available for inspection by the Non-Party.

days of receiving the notice and accompanying information, the Receiving Party may produce

the Non-Party’s confidential information responsive to the discovery request. If the Non-Party

timely seeks a protective order, the Receiving Party shall not produce any information in its

possession or control that is subject to the confidentiality agreement with the Non-Party before a

determination by the court. Absent a court order to the contrary, the Non-Party shall bear the

burden and expense of seeking protection in this court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

Material to any person or in any circumstance not authorized under this Stipulated Protective

Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the

unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

Protected Material, (c) inform the person or persons to whom unauthorized disclosures were

made of all the terms of this Order, and (d) request such person or persons to execute the

“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED

MATERIAL

When a Producing Party gives notice to Receiving Parties that certain inadvertently

produced material is subject to a claim of privilege or other protection, the obligations of the

Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This

provision is not intended to modify whatever procedure may be established in an e-discovery

order that provides for production without prior privilege review. Pursuant to Federal Rule of

Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a

communication or information covered by the attorney-client privilege or work product

protection, the parties may incorporate their agreement in the stipulated protective order

submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to

seek its modification by the court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective

Order no Party waives any right it otherwise would have to object to disclosing or producing any

information or item on any ground not addressed in this Stipulated Protective Order. Similarly,

no Party waives any right to object on any ground to use in evidence of any of the material

covered by this Protective Order.

12.3 Filing Protected Material. Without written permission from the Designating Party

or a court order secured after appropriate notice to all interested persons, a Party may not file in

the public record in this action any Protected Material. A Party that seeks to file under seal any

Protected Material must comply with Civil Local Rule 141. Protected Material may only be filed

under seal pursuant to a court order authorizing the sealing of the specific Protected Material at

issue. A sealing order will issue only upon a request establishing that the Protected Material at

issue is privileged, protectable as a trade secret, or otherwise entitled to protection under the law.

If a Receiving Party's request to file Protected Material under seal pursuant to Civil Local Rules

of this Court 141 is denied by the Court, then the Receiving Party may file the information in the

public record unless otherwise instructed by the court.

13. FINAL DISPOSITION

Within 60 days after the final disposition of this action, as defined in paragraph 4, each

Receiving Party must return all Protected Material to the Producing Party or destroy such

material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,

compilations, summaries, and any other format reproducing or capturing any of the Protected

Material. Whether the Protected Material is returned or destroyed, the Receiving Party must

; submit a written certification to the Producing Party (and, if not the same person or entity, to the

Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all

° the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has

not retained any copies, abstracts, compilations, summaries or any other format reproducing or

capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

° legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work

product, and consultant and expert work product, even if such materials contain Protected

Material. Any such archival copies that contain or constitute Protected Material remain subject to

"2 this Protective Order as set forth in Section 4 (DURATION).

14 || IT ISSO STIPULATED, THROUGH COUNSEL OF RECORD.

15 || parep: 8/22/2025 Manne f: rihen

Attorney Sr Plaintiff

17 || DATED: 8/22/2025 /s/ Sarah Robertson

Attorney for Defendant

19 || PURSUANT TO STIPULATION, IT IS SO ORDEREP.

21 || DATED: September 2, 2025

ited StateS District/Magistrate Judge

28 15

LLP AMENDED STIPULATED PROTECTIVE ORDER sis

EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _____________________________ [print or type full name], of _________________ [print or

type full address], declare under penalty of perjury that I have read in its entirety and understand

the Stipulated Protective Order that was issued by the United States District Court for the

Northern District of California on [date] in the case of ___________ [insert formal name of the

case and the number and initials assigned to it by the court]. I agree to comply with and to be

bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that

failure to so comply could expose me to sanctions and punishment in the nature of contempt. I

solemnly promise that I will not disclose in any manner any information or item that is subject to

this Stipulated Protective Order to any person or entity except in strict compliance with the

provisions of this Order.

I further agree to submit to the jurisdiction of the United States District Court for the Northern

District of California for the purpose of enforcing the terms of this Stipulated Protective Order,

even if such enforcement proceedings occur after termination of this action.

I hereby appoint __________________________ [print or type full name] of

_______________________________________ [print or type full address and telephone

number] as my California agent for service of process in connection with this action or any

proceedings related to enforcement of this Stipulated Protective Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

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