even stipulated protective orders require good cause showing
How later courts described this case
- even stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 KENDRA S. CANAPE (SBN: 259641)
kcanape@grsm.com
2 JOEL D. BRODFUEHRER (SBN: 343092)
jbrodfuehrer@grsm.com
3 GORDON REES SCULLY MANSUKHANI, LLP
5 Park Plaza, Suite 1100
4 Irvine, CA 92614
Telephone: (949) 255-6950
5 Facsimile: (949) 474-2060
6 Attorneys for Defendant
I.Q. DATA INTERNATIONAL, INC.
7
8
UNITED STATES DISTRICT COURT
9
EASTERN DISTRICT OF CALIFORNIA
10
SACRAMENTO DIVISION
11
12 JAMES ROBERTSON and KARYN A. No.: 2:25-cv-0759-TLN-JDP
ROBERTSON,
13 STIPULATED PROTECTIVE
Plaintiffs, ORDER AS TO DISCOVERY
14 ONLY
v.
15
IQ DATA INTERNATIONAL, INC.;
16 EQUIFAX INFORMATION SERVICES,
LLC; EXPERIAN INFORMATION Complaint Filed: 2/3/25
17 SOLUTIONS, INC; TRANS UNION, LLC;
and DOES 1-10 inclusive,
18
Defendants.
19
20 1. INTRODUCTION
21 1.1 PURPOSES AND LIMITATIONS
22 Discovery in this action is likely to involve production of confidential,
23 proprietary, or private information for which special protection from public
24 disclosure and from use for any purpose other than prosecuting this litigation
25 may be warranted. Accordingly, the parties hereby stipulate to and petition the
26 Court to enter the following Stipulated Protective Order. The parties
27 acknowledge that this Order does not confer blanket protections on all
1 public disclosure and use extends only to the limited information or items that
2 are entitled to confidential treatment under the applicable legal principles.1
3 1.2 GOOD CAUSE STATEMENT
4 This action is likely to involve materials and information that I.Q. Data
5 International, Inc. (“IQ Data”) and Plaintiff maintain as confidential for
6 which special protection from public disclosure and from use for any
7 purpose other than prosecution of this action is warranted. IQ Data may be
8 producing documents to Plaintiff that consist of, among other things,
9 confidential business or financial information, trade secrets, information
10 regarding confidential business practices, or other confidential research,
11 development, or commercial information, information otherwise generally
12 unavailable to the public, or which may be privileged or otherwise protected
13 from disclosure under state or federal statutes, court rules, case decisions, or
14 common law. IQ Data has maintained this information as confidential due
15 to the sensitive nature of the information. IQ Data’s competitors would gain
16 an improper advantage if documents were made public, including but not
17 limited to customer information, account notes, intellectual property,
18 research, technical, commercial, or financial information, business plans,
19 business policies, training materials, and other business-related information
20 that are not generally available to the public. The debt collection industry
21 and consumer reporting agencies are highly competitive and require
22 confidentiality of very sensitive consumer information.
23 Plaintiff will also be producing materials relating to or regarding
24 Plaintiff’s debt(s), credit history, credit reports, documents containing
25 Plaintiff’s social security number and DOB. Plaintiff has alleged he has
26 suffered harm that could result in production of sensitive medical
27 information, banking records, personal identity information, income tax
1 returns (including attached schedules and forms), W-2 forms and 1099
2 forms, and personnel or employment records.
3 Accordingly, to expedite the flow of information, to facilitate the
4 prompt resolution of disputes over confidentiality of discovery materials, to
5 adequately protect information the parties are entitled to keep confidential,
6 to ensure that the parties are permitted reasonable necessary uses of such
7 material in preparation for and in the conduct of trial, to address their
8 handling at the end of the litigation, and serve the ends of justice, a
9 protective order for such information is justified in this matter. It is the
10 intent of the parties that information will not be designated as confidential
11 for tactical reasons and that nothing be so designated without a good faith
12 belief that it has been maintained in a confidential, non-public manner, and
13 there is good cause why it should not be part of the public record of this
14 case.
15 1.3 Acknowledgment of Procedure for Filing Under Seal.
16 The parties further acknowledge, as set forth in Section 12.3, below, that
17 this Stipulated Protective Order does not entitle them to file confidential
18 information under seal; Civil Local Rules 141, 143, and 302 sets forth the
19 procedures that must be followed and the standards that will be applied when a
20 party seeks permission from the court to file material under seal.
21 There is a strong presumption that the public has a right of access to
22 judicial proceedings and records in civil cases. In connection with non-
23 dispositive motions, good cause must be shown to support a filing under seal.
24 See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir.
25 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–
26 11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577
27 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing),
and a specific showing of good cause or compelling reasons with proper
1 evidentiary support and legal justification, must be made with respect to
2 Protected Material that a party seeks to file under seal. The Parties’ mere
3 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
4 without the submission of competent evidence by declaration, establishing that
5 the material sought to be filed under seal qualifies as confidential, privileged, or
6 otherwise protectable—constitute good cause.
7 Further, if a party requests sealing related to any dispositive motions,
8 briefs, pleadings, deposition transcripts, other papers to be filed with the Court
9 incorporate documents or information subject to this Order, or trial, then the
10 party filing such papers shall designate such materials, or portions thereof, as
11 “Confidential,” and then compelling reasons, not only good cause, for the sealing
12 must be shown, and the relief sought shall be narrowly tailored to serve the
13 specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d
14 665, 677–79 (9th Cir. 2010). For each item or type of information, document, or
15 thing sought to be filed or introduced under seal in connection with a dispositive
16 motion or trial, the party seeking protection must articulate compelling reasons,
17 supported by specific facts and legal justification, for the requested sealing order.
18 Again, competent evidence supporting the application to file documents under
19 seal must be provided by declaration.
20 Any document that is not confidential, privileged, or otherwise protectable
21 in its entirety will not be filed under seal if the confidential portions can be
22 redacted. If documents can be redacted, then a redacted version for public
23 viewing, omitting only the confidential, privileged, or otherwise protectable
24 portions of the document, shall be filed. Any application that seeks to file
25 documents under seal in their entirety should include an explanation of why
26 redaction is not feasible.
27
1 2. DEFINITIONS
2 2.1 Action: James Robertson and Karyn A. Robertson, v. I.Q. Data
3 International, Inc.. (Case No: 2:25-cv-00759-TLN-JDP).
4 2.2 Challenging Party: a Party or Non-Party that challenges the
5 designation of information or items under this Order.
6 2.3 “CONFIDENTIAL” Information or Items: information (regardless
7 of how it is generated, stored or maintained) or tangible things that qualify
8 for protection under Federal Rule of Civil Procedure 26(c), and as specified
9 above in the Good Cause Statement.
10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
11 their support staff).
12 2.5 Designating Party: a Party or Non-Party that designates information
13 or items that it produces in disclosures or in responses to discovery as
14 “CONFIDENTIAL.”
15 2.6 Disclosure or Discovery Material: all items or information,
16 regardless of the medium or manner in which it is generated, stored, or
17 maintained (including, among other things, testimony, transcripts, and
18 tangible things), that are produced or generated in disclosures or responses
19 to discovery in this matter.
20 2.7 Expert: a person with specialized knowledge or experience in a
21 matter pertinent to the litigation who has been retained by a Party or its
22 counsel to serve as an expert witness or as a consultant in this Action.
23 2.8 Final Disposition: the later of (1) dismissal of all claims and
24 defenses in this Action, with or without prejudice; and (2) final judgment
25 herein after the completion and exhaustion of all appeals, rehearings,
26 remands, trials, or reviews of this Action, including the time limits for
27 filing any motions or applications for extension of time pursuant to
applicable law.
1 2.9 In-House Counsel: attorneys who are employees of a party to this
2 Action. In-House Counsel does not include Outside Counsel of Record or
3 any other outside counsel.
4 2.10 Non-Party: any natural person, partnership, corporation, association,
5 or other legal entity not named as a Party to this action.
6 2.11 Outside Counsel of Record: attorneys who are not employees of a
7 party to this Action but are retained to represent or advise a party to this
8 Action and have appeared in this Action on behalf of that party or are
9 affiliated with a law firm which has appeared on behalf of that party, and
10 includes support staff.
11 2.12 Party: any party to this Action, including all of its officers, directors,
12 employees, consultants, retained experts, and Outside Counsel of Record
13 (and their support staffs).
14 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
15 Discovery Material in this Action.
16 2.14 Professional Vendors: persons or entities that provide litigation
17 support services (e.g., photocopying, videotaping, translating, preparing
18 exhibits or demonstrations, and organizing, storing, or retrieving data in
19 any form or medium) and their employees and subcontractors.
20 2.15 Protected Material: any Disclosure or Discovery Material and all
21 information derived therefrom (including, but not limited to, all testimony
22 given in a deposition, declaration or otherwise, that refers, reflects or
23 otherwise discusses any information designated “Confidential” that is
24 designated as “CONFIDENTIAL.”
25 2.16 Receiving Party: a Party that receives Disclosure or Discovery
26 Material from a Producing Party.
27
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial will be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9 4. TRIAL AND DURATION
10 Even after final disposition of this litigation, the confidentiality obligations
11 imposed by this Order will remain in effect until a Designating Party agrees
12 otherwise in writing or a court order otherwise directs. Final disposition will be
13 deemed to be the later of (1) dismissal of all claims and defenses in this Action,
14 with or without prejudice; and (2) final judgment herein after the completion and
15 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
16 including the time limits for filing any motions or applications for extension of
17 time pursuant to applicable law.
18 5. DESIGNATING PROTECTED MATERIAL
19 5.1 Exercise of Restraint and Care in Designating Material for
20 Protection. Each Party or Non-Party that designates information or items
21 for protection under this Order must take care to limit any such designation
22 to specific material that qualifies under the appropriate standards. The
23 Designating Party must designate for protection only those parts of
24 material, documents, items, or oral or written communications that qualify
25 so that other portions of the material, documents, items, or communications
26 for which protection is not warranted are not swept unjustifiably within the
27 ambit of this Order.
1 Mass, indiscriminate, or routinized designations are prohibited.
2 Designations that are shown to be clearly unjustified or that have been made for
3 an improper purpose (e.g., to unnecessarily encumber the case development
4 process or to impose unnecessary expenses and burdens on other parties) may
5 expose the Designating Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that
7 it designated for protection do not qualify for protection, that Designating Party
8 must promptly notify all other Parties that it is withdrawing the inapplicable
9 designation.
10 5.2 Manner and Timing of Designations. Except as otherwise provided
11 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as
12 otherwise stipulated or ordered, Disclosure or Discovery Material that
13 qualifies for protection under this Order must be clearly so designated
14 before the material is disclosed or produced.
15 Designation in conformity with this Order requires:
16 (a) for information in documentary form (e.g., paper or electronic
17 documents, but excluding transcripts of depositions or other pretrial or trial
18 proceedings), that the Producing Party affix at a minimum, the legend
19 “CONFIDENTIAL” to each page that contains protected material. If only
20 a portion or portions of the material on a page qualifies for protection, the
21 Producing Party also must clearly identify the protected portion(s) (e.g., by
22 making appropriate markings in the margins).
23 A Party or Non-Party that makes original documents available for
24 inspection need not designate them for protection until after the inspecting Party
25 has indicated which documents it would like copied and produced. During the
26 inspection and before the designation, all of the material made available for
27 inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has
identified the documents it wants copied and produced, the Producing Party must
1 determine which documents, or portions thereof, qualify for protection under this
2 Order. Then, before producing the specified documents, the Producing Party
3 must affix the “CONFIDENTIAL” legend to each page that contains Protected
4 Material. If only a portion or portions of the material on a page qualifies for
5 protection, the Producing Party also must clearly identify the protected portion(s)
6 (e.g., by making appropriate markings in the margins).
7 (b) for testimony given in depositions that the Designating Party identify
8 the Disclosure or Discovery Material on the record, before the close of the
9 deposition all protected testimony.
10 (c) for information produced in some form other than documentary and for
11 any other tangible items, that the Producing Party affix in a prominent place
12 on the exterior of the container or containers in which the information is
13 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
14 information warrants protection, the Producing Party, to the extent
15 practicable, will identify the protected portion(s).
16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
17 failure to designate qualified information or items does not, standing alone,
18 waive the Designating Party’s right to secure protection under this Order
19 for such material. Upon timely correction of a designation, the Receiving
20 Party must make reasonable efforts to assure that the material is treated in
21 accordance with the provisions of this Order.
22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
24 designation of confidentiality at any time that is consistent with the Court’s
25 Scheduling Order.
26 6.2 Meet and Confer. The Challenging Party will initiate the dispute
27 resolution process (and, if necessary, file a discovery motion) in accordance
with Judge Nunley’s Civil Procedures.
1 6.3 The burden of persuasion in any such challenge proceeding will be
2 on the Designating Party. Frivolous challenges, and those made for an
3 improper purpose (e.g., to harass or impose unnecessary expenses and
4 burdens on other parties) may expose the Challenging Party to sanctions.
5 Unless the Designating Party has waived or withdrawn the confidentiality
6 designation, all parties will continue to afford the material in question the
7 level of protection to which it is entitled under the Producing Party’s
8 designation until the Court rules on the challenge.
9 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1 Basic Principles. A Receiving Party may use Protected Material that
11 is disclosed or produced by another Party or by a Non-Party in connection
12 with this Action only for prosecuting, defending, or attempting to settle this
13 Action. Protected Material shall not be used, directly or indirectly, by any
14 person, for any business, commercial or competitive purposes or for any
15 purpose whatsoever other than solely for the preparation for and trial of this
16 action in accordance with the provisions of this Order. Such Protected
17 Material may be disclosed only to the categories of persons and under the
18 conditions described in this Order. When the Action has been terminated, a
19 Receiving Party must comply with the provisions of section 13 below
20 (FINAL DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the
23 persons authorized under this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating
26 Party, a Receiving Party may disclose any information or item designated
27 “CONFIDENTIAL” only to:
1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
2 well as employees of said Outside Counsel of Record to whom it is
3 reasonably necessary to disclose the information for this Action;
4 (b) the officers, directors, and employees (including House Counsel) of
5 the Receiving Party to whom disclosure is reasonably necessary for this
6 Action;
7 (c) Experts (as defined in this Order) of the Receiving Party to whom
8 disclosure is reasonably necessary for this Action and who have signed
9 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (d) the Court and its personnel;
11 (e) court reporters and their staff to whom disclosure is reasonably
12 necessary for this Action and who have signed the “Acknowledgment
13 and Agreement to Be Bound” (Exhibit A);
14 (f) professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and
16 who have signed the “Acknowledgment and Agreement to Be Bound”
17 (Exhibit A);
18 (g) the author or recipient of a document containing the information or
19 a custodian or other person who otherwise possessed or knew the
20 information;
21 (h) during their depositions, witnesses, and attorneys for witnesses, in
22 the Action to whom disclosure is reasonably necessary provided: (1) the
23 deposing party requests that the witness sign the form attached as
24 Exhibit A hereto; and (2) they will not be permitted to keep any
25 confidential information unless they sign the “Acknowledgment and
26 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the
27 Designating Party or ordered by the court. Pages of transcribed
deposition testimony or exhibits to depositions that reveal Protected
1 Material may be separately bound by the court reporter and may not be
2 disclosed to anyone except as permitted under this Stipulated Protective
3 Order; and
4 (i) any mediator or settlement officer, and their supporting personnel,
5 mutually agreed upon by any of the parties engaged in settlement
6 discussions.
7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
8 IN OTHER LITIGATION
9 If a Party is served with a subpoena or a court order issued in other
10 litigation that compels disclosure of any information or items designated in
11 this Action as “CONFIDENTIAL,” that Party must:
12 (a) promptly notify in writing the Designating Party. Such notification
13 will include a copy of the subpoena or court order;
14 (b) promptly notify in writing the party who caused the subpoena or
15 order to issue in the other litigation that some or all of the material
16 covered by the subpoena or order is subject to this Protective Order.
17 Such notification will include a copy of this Stipulated Protective Order;
18 and
19 (c) cooperate with respect to all reasonable procedures sought to be
20 pursued by the Designating Party whose Protected Material may be
21 affected.
22 If the Designating Party timely seeks a protective order, the Party served
23 with the subpoena or court order will not produce any information
24 designated in this action as “CONFIDENTIAL” before a determination by
25 the court from which the subpoena or order issued, unless the Party has
26 obtained the Designating Party’s permission. The Designating Party will
27 bear the burden and expense of seeking protection in that court of its
confidential material and nothing in these provisions should be construed as
1 authorizing or encouraging a Receiving Party in this Action to disobey a
2 lawful directive from another court.
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 9.1 Application. The terms of this Order are applicable to
6 information produced by a Non-Party in this Action and designated as
7 “CONFIDENTIAL.” Such information produced by Non-Parties in
8 connection with this litigation is protected by the remedies and relief
9 provided by this Order. Nothing in these provisions should be construed
10 as prohibiting a Non-Party from seeking additional protections.
11 9.2 Notification. In the event that a Party is required, by a valid
12 discovery request, to produce a Non-Party’s confidential information in
13 its possession, and the Party is subject to an agreement with the Non-
14 Party not to produce the Non-Party’s confidential information, then the
15 Party will:
16 (a) promptly notify in writing the Requesting Party and the Non-
17 Party that some or all of the information requested is subject to a
18 confidentiality agreement with a Non-Party;
19 (b) promptly provide the Non-Party with a copy of the Stipulated
20 Protective Order in this Action, the relevant discovery request(s), and
21 a reasonably specific description of the information requested; and
22 (c) make the information requested available for inspection by the
23 Non-Party, if requested.
24 9.3 Conditions of Production. If the Non-Party fails to seek a
25 protective order from this court within 14 days of receiving the notice
26 and accompanying information, the Receiving Party may produce the
27 Non-Party’s confidential information responsive to the discovery
request. If the Non-Party timely seeks a protective order, the Receiving
1 Party will not produce any information in its possession or control that
2 is subject to the confidentiality agreement with the Non-Party before a
3 determination by the court. Absent a court order to the contrary, the
4 Non-Party will bear the burden and expense of seeking protection in this
5 court of its Protected Material.
6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
7 If a Receiving Party learns that, by inadvertence or otherwise, it has
8 disclosed Protected Material to any person or in any circumstance not
9 authorized under this Stipulated Protective Order, the Receiving Party must
10 immediately (a) notify in writing the Designating Party of the unauthorized
11 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
12 Protected Material, (c) inform the person or persons to whom unauthorized
13 disclosures were made of all the terms of this Order, and (d) request such
14 person or persons to execute the “Acknowledgment and Agreement to Be
15 Bound” that is attached hereto as Exhibit A.
16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
17 PROTECTED MATERIAL
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other
20 protection, the obligations of the Receiving Parties are those set forth in
21 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended
22 to modify whatever procedure may be established in an e-discovery order
23 that provides for production without prior privilege review. Pursuant to
24 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an
25 agreement on the effect of disclosure of a communication or information
26 covered by the attorney-client privilege or work product protection, the
27 parties may incorporate their agreement in the stipulated protective order
submitted to the court.
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of
3 any person to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order no Party waives any right it otherwise would have to
6 object to disclosing or producing any information or item on any ground
7 not addressed in this Stipulated Protective Order. Similarly, no Party
8 waives any right to object on any ground to use in evidence of any of the
9 material covered by this Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Civil Local Rule 141, 143, and 302.
12 Protected Material may only be filed under seal pursuant to a court order
13 authorizing the sealing of the specific Protected Material at issue. If a
14 Party's request to file Protected Material under seal is denied by the court,
15 then the Receiving Party may file the information in the public record
16 unless otherwise instructed by the court.
17 12.4 Neither the entry of this Order, nor the designation of any
18 information, document, or the like as “Confidential,” nor the failure to
19 make such designation, shall constitute evidence with respect to any issue
20 in this action.
21 13. FINAL DISPOSITION
22 After the final disposition of this Action, as defined in paragraph 4, within
23 60 days, each Receiving Party must return all Protected Material to the
24 Producing Party. As used in this subdivision, “all Protected Material”
25 includes all copies, abstracts, compilations, summaries, and any other
26 format reproducing or capturing any of the Protected Material. The
27 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
1 day deadline that (1) identifies (by category, where appropriate) all the
2 Protected Material that was returned and (2) affirms that the Receiving
3 Party has not retained any copies, abstracts, compilations, summaries or
4 any other format reproducing or capturing any of the Protected Material.
5 Notwithstanding this provision, Counsel are entitled to retain an archival
6 copy of all pleadings, motion papers, trial, deposition, and hearing
7 transcripts, legal memoranda, correspondence, deposition and trial exhibits,
8 expert reports, attorney work product, and consultant and expert work
9 product, even if such materials contain Protected Material. Any such
10 archival copies that contain or constitute Protected Material remain subject
11 to this Protective Order as set forth in Section 4 (DURATION).
12 14. VIOLATION
13 Any willful violation of this Order may be punished by civil or criminal
14 contempt proceedings, financial or evidentiary sanctions, reference to
15 disciplinary authorities, or other appropriate action at the discretion of the Court.
16
17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
18
19 DATED: October 7, 2025 /s/Todd M. Friedman (with permission)
Todd M. Friedman
20 Attorney for Plaintiffs
JAMES ROBERTSON
21
22
23 DATED: October 7, 2025 /s/Joel D. Brodfuehrer
Joel D. Brodfuehrer
24 Kendra S. Canape
Attorneys for Defendant
25 IQ DATA INTERNATIONAL, INC.
26
27
1 FOR GOOD CAUSE SHOWN,
3 IT IS SO ORDERED.
Dated: October 8, 2025 Q_———
5 JEREMY D. PETERSON
6 UNITED STATES MAGISTRATE JUDGE
8
10
11
12
a
13
bd
417
g
5 18
19
20
21
22
23
24
25
26
27
28
-17-
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [full name], of
4 _________________ [full address], declare under penalty of perjury that I have
5 read in its entirety and understand the Stipulated Protective Order that was issued
6 by the United States District Court for the Eastern District of California on [date]
7 in the case of ___________ [insert case name and number]. I agree to comply
8 with and to be bound by all the terms of this Stipulated Protective Order and I
9 understand and acknowledge that failure to so comply could expose me to
10 sanctions and punishment in the nature of contempt. I solemnly promise that I
11 will not disclose in any manner any information or item that is subject to this
12 Stipulated Protective Order to any person or entity except in strict compliance
13 with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District
15 Court for the Eastern District of California for the purpose of enforcing the terms
16 of this Stipulated Protective Order, even if such enforcement proceedings occur
17 after termination of this action. I hereby appoint
18 __________________________ [full name] of
19 _______________________________________ [full address and telephone
20 number] as my California agent for service of process in connection with this
21 action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23
24 Date: ______________________________________
25 City and State where signed: _________________________________
26 Printed name: _______________________________
27 Signature: ___________________