even stipulated 16 protective orders require good cause showing
How later courts described this case
- even stipulated 16 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 NELSON MULLINS RILEY & SCARBOROUGH LLP
Monee Takla Hanna (SBN 259468)
2 19191 South Vermont Avenue, Suite 900
Torrance, CA 90502
3 Telephone: 424.221.7400
Facsimile: 424.221.7499
4 monee.hanna@nelsonmullins.com
5 John Q. Lewis (admitted pro hac vice)
Rachel N. Byrnes (admitted pro hac vice)
6 1100 Superior Ave., Suite 2000
Cleveland, Ohio 44114
7 Telephone: 216.304.6104
Facsimile: 216.553.4275
8 john.lewis@nelsonmullins.com
rachel.byrnes@nelsonmullins.com
9
10 Attorneys for Defendant
DECKERS OUTDOOR CORPORATION D/B/A HOKA
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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SHAWN CZERWIEN and GEORGE Case No.: 2:25-cv-09654-SVW-JC
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ATTIA, individually and on behalf of
17 all others similarly situated, Honorable Stephen V. Wilson
18 Plaintiffs,
STIPULATION AND PROPOSED
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v. PROTECTIVE ORDER
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DECKERS OUTDOOR DISCOVERY MATTER
21 CORPORATION D/B/A HOKA,
[CHANGES MADE BY COURT TO
22 Defendant. PARAGRAPHS 5, 10(C) & 11(C)]
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1 1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 2. GOOD CAUSE STATEMENT
12 This action is a consumer class action that is likely to involve trade secrets,
13 customer and pricing lists, and other valuable research, development, commercial,
14 financial, technical and/or proprietary information for which special protection from
15 public disclosure and from use for any purpose other than prosecution of this action
16 is warranted. Such confidential and proprietary materials and information consist of,
17 among other things, confidential business or financial information, information
18 regarding confidential business practices, customer data, or other confidential
19 research, development, or commercial information (including information
20 implicating privacy rights of third parties), information otherwise generally
21 unavailable to the public, or which may be privileged or otherwise protected from
22 disclosure under state or federal statutes, court rules, case decisions, or common law.
23 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
24 of disputes over confidentiality of discovery materials, to adequately protect
25 information the parties are entitled to keep confidential, to ensure that the parties are
26 permitted reasonable necessary uses of such material in preparation for and in the
27 conduct of trial, to address their handling at the end of the litigation, and serve the
28 ends of justice, a protective order for such information is justified in this matter. It is
1 the intent of the parties that information will not be designated as confidential for
2 tactical reasons and that nothing be so designated without a good faith belief that it
3 has been maintained in a confidential, non-public manner, and there is good cause
4 why it should not be part of the public record of this case.
5 3. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE
6 The parties further acknowledge, as set forth in Section 14.3, below, that this
7 Stipulated Protective Order does not entitle them to file confidential information
8 under seal; Local Civil Rule 79-5 controls and sets forth the procedures that must be
9 followed and the standards that will be applied when a party seeks permission from
10 the court to file material under seal. There is a strong presumption that the public has
11 a right of access to judicial proceedings and records in civil cases. In connection with
12 non-dispositive motions, good cause must be shown to support a filing under seal. See
13 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
14 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
15 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
16 protective orders require good cause showing), and a specific showing of good cause
17 or compelling reasons with proper evidentiary support and legal justification, must be
18 made with respect to Protected Material that a party seeks to file under seal. The
19 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
20 does not— without the submission of competent evidence by declaration, establishing
21 that the material sought to be filed under seal qualifies as confidential, privileged, or
22 otherwise protectable—constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion or trial, then
24 compelling reasons, not only good cause, for the sealing must be shown, and the relief
25 sought shall be narrowly tailored to serve the specific interest to be protected. See
26 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each
27 item or type of information, document, or thing sought to be filed or introduced under
28 seal, the party seeking protection must articulate compelling reasons, supported by
1 specific facts and legal justification, for the requested sealing order. Again, competent
2 evidence supporting the application to file documents under seal must be provided by
3 declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in
5 its entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting only
7 the confidential, privileged, or otherwise protectable portions of the document, shall
8 be filed. Any application that seeks to file documents under seal in their entirety
9 should include an explanation of why redaction is not feasible.
10 4. DEFINITIONS
11 4.1 Action: this pending class action lawsuit.
12 4.2 Challenging Party: a Party or Non-Party that challenges the
13 designation of information or items under this Order.
14 4.3 “CONFIDENTIAL” Information or Items: information
15 (regardless of how it is generated, stored or maintained) or tangible things that qualify
16 for protection under Federal Rule of Civil Procedure 26(c), and as specified above in
17 the Good Cause Statement.
18 4.4 Counsel: Outside Counsel of Record and House Counsel (as well
19 as their support staff).
20 4.5 Designating Party: a Party or Non-Party that designates
21 information or items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23 4.6 Disclosure or Discovery Material: all items or information,
24 regardless of the medium or manner in which it is generated, stored, or maintained
25 (including, among other things, testimony, transcripts, and tangible things), that are
26 produced or generated in disclosures or responses to discovery.
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1 4.7 Expert: a person with specialized knowledge or experience in a
2 matter pertinent to the litigation who has been retained by a Party or its counsel to
3 serve as an expert witness or as a consultant in this Action.
4 4.8 House Counsel: attorneys who are employees of a party to this
5 Action. House Counsel does not include Outside Counsel of Record or any other
6 outside counsel.
7 4.9 Non-Party: any natural person, partnership, corporation,
8 association or other legal entity not named as a Party to this action.
9 4.10 Outside Counsel of Record: attorneys who are not employees of a
10 party to this Action but are retained to represent a party to this Action and have
11 appeared in this Action on behalf of that party or are affiliated with a law firm that
12 has appeared on behalf of that party, and includes support staff.
13 4.11 Party: any party to this Action, including all of its officers,
14 directors, employees, consultants, retained experts, and Outside Counsel of Record
15 (and their support staffs).
16 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
17 Discovery Material in this Action.
18 4.13 Professional Vendors: persons or entities that provide litigation
19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
22 4.14 Protected Material: any Disclosure or Discovery Material that is
23 designated as “CONFIDENTIAL.”
24 4.15 Receiving Party: a Party that receives Disclosure or Discovery
25 Material from a Producing Party.
26 5. SCOPE
27 The protections conferred by this Stipulation and Order cover not only
28 Protected Material (as defined above), but also (1) any information copied or extracted
1 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
2 Protected Material; and (3) any testimony, conversations, or presentations by Parties
3 or their Counsel that might reveal Protected Material other than during a hearing or
4 trial. Any use of Protected Material during a hearing or at trial shall be governed
5 by the orders of the presiding judge and other applicable authorities. This Order
6 does not govern the use of Protected Material during a hearing or at trial.
7 6. DURATION
8 Once a case proceeds to trial, information that was designated as
9 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
10 as an exhibit at trial becomes public and will be presumptively available to all
11 members of the public, including the press, unless compelling reasons supported by
12 specific factual findings to proceed otherwise are made to the trial judge in advance
13 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
14 showing for sealing documents produced in discovery from “compelling reasons”
15 standard when merits-related documents are part of court record). Accordingly, the
16 terms of this protective order do not extend beyond the commencement of the trial.
17 7. DESIGNATING PROTECTED MATERIAL
18 7.1 Exercise of Restraint and Care in Designating Material for
19 Protection. Each Party or Non-Party that designates information or items for
20 protection under this Order must take care to limit any such designation to specific
21 material that qualifies under the appropriate standards. The Designating Party must
22 designate for protection only those parts of material, documents, items or oral or
23 written communications that qualify so that other portions of the material, documents,
24 items or communications for which protection is not warranted are not swept
25 unjustifiably within the ambit of this Order.
26 Mass, indiscriminate or routinized designations are prohibited. Designations
27 that are shown to be clearly unjustified or that have been made for an improper
28 purpose (e.g., to unnecessarily encumber the case development process or to impose
1 unnecessary expenses and burdens on other parties) may expose the Designating Party
2 to sanctions. If it comes to a Designating Party’s attention that information or items
3 that it designated for protection do not qualify for protection, that Designating
4 Party must promptly notify all other Parties that it is withdrawing the inapplicable
5 designation.
6 7.2 Manner and Timing of Designations. Except as otherwise
7 provided in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery
8 Material that qualifies for protection under this Order must be clearly so designated
9 before the material is disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic
12 documents, but excluding transcripts of depositions or other pretrial or trial
13 proceedings), that the Producing Party affix at a minimum, the legend
14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
15 contains protected material. If only a portion of the material on a page qualifies for
16 protection, the Producing Party also must clearly identify the protected portion(s)
17 (e.g., by making appropriate markings in the margins).
18 A Party or Non-Party that makes original documents available for inspection
19 need not designate them for protection until after the inspecting Party has indicated
20 which documents it would like copied and produced. During the inspection and before
21 the designation, all of the material made available for inspection shall be deemed
22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
23 copied and produced, the Producing Party must determine which documents, or
24 portions thereof, qualify for protection under this Order. Then, before producing the
25 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
26 to each page that contains Protected Material. If only a portion of the material on a
27 page qualifies for protection, the Producing Party also must clearly identify the
28 protected portion(s) (e.g., by making appropriate markings in the margins).
1 (b) for testimony given in depositions that the Designating Party
2 identifies the Disclosure or Discovery Material on the record, before the close of the
3 deposition all protected testimony.
4 (c) for information produced in some form other than documentary and
5 for any other tangible items, that the Producing Party affix in a prominent place on
6 the exterior of the container or containers in which the information is stored the legend
7 “CONFIDENTIAL.” If only a portion or portions of the information warrants
8 protection, the Producing Party, to the extent practicable, shall identify the protected
9 portion(s).
10 7.3 Inadvertent Failures to Designate. If timely corrected, an
11 inadvertent failure to designate qualified information or items does not, standing
12 alone, waive the Designating Party’s right to secure protection under this Order for
13 such material. Upon timely correction of a designation, the Receiving Party must
14 make reasonable efforts to assure that the material is treated in accordance with the
15 provisions of this Order.
16 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17 8.1 Timing of Challenges. Any Party or Non-Party may challenge a
18 designation of confidentiality at any time that is consistent with the Court’s
19 Scheduling Order.
20 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
21 resolution process under Local Rule 37-1 et seq.
22 8.3 Joint Stipulation. Any challenge submitted to the Court shall be
23 via a joint stipulation pursuant to Local Rule 37-2.
24 8.4 The burden of persuasion in any such challenge proceeding shall
25 be on the Designating Party. Frivolous challenges, and those made for an improper
26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other Parties)
27 may expose the Challenging Party to sanctions. Unless the Designating Party has
28 waived or withdrawn the confidentiality designation, all parties shall continue to
1 afford the material in question the level of protection to which it is entitled under the
2 Producing Party’s designation until the Court rules on the challenge.
3 9. ACCESS TO AND USE OF PROTECTED MATERIAL
4 9.1 Basic Principles. A Receiving Party may use Protected Material
5 that is disclosed or produced by another Party or by a Non-Party in connection with
6 this Action only for prosecuting, defending or attempting to settle this Action. Such
7 Protected Material may be disclosed only to the categories of persons and under the
8 conditions described in this Order. When the Action has been terminated, a Receiving
9 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
10 Protected Material must be stored and maintained by a Receiving Party at a location
11 and in a secure manner that ensures that access is limited to the persons authorized
12 under this Order.
13 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
14 otherwise ordered by the court or permitted in writing by the Designating Party, a
15 Receiving Party may disclose any information or item designated
16 “CONFIDENTIAL” only to:
17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
18 well as employees of said Outside Counsel of Record to whom it is reasonably
19 necessary to disclose the information for this Action;
20 (b) the officers, directors, and employees (including House Counsel) of
21 the Receiving Party to whom disclosure is reasonably necessary for this Action;
22 (c) Experts (as defined in this Order) of the Receiving Party to whom
23 disclosure is reasonably necessary for this Action and who have signed the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (d) the court and its personnel;
26 (e) court reporters and their staff;
27 ///
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1 (f) professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in
7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
9 will not be permitted to keep any confidential information unless they sign the
10 Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
11 by the Designating Party or ordered by the court. Pages of transcribed deposition
12 testimony or exhibits to depositions that reveal Protected Material may be separately
13 bound by the court reporter and may not be disclosed to anyone except as permitted
14 under this Stipulated Protective Order; and
15 (i) any mediators or settlement officers and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 9.3 Artificial Intelligence. The Parties agree that the receiving party
18 shall not use any documents, electronically stored information, or other materials
19 produced or exchanged in the course of this litigation and designated as
20 “CONFIDENTIAL” under this Protective Order for prompts (inputs), completions
21 (outputs), or embeddings that are used to train, improve, re-train, or otherwise develop
22 any artificial intelligence, foundation model, or large language model (collectively
23 “AI Models”). This prohibition applies regardless of whether the AI Models are
24 proprietary, open-source, or provided by a third party, and regardless of whether the
25 use is for commercial, research, or any other purpose. The Parties further agree to take
26 reasonable steps to ensure that their employees, counsel, agents, consultants,
27 contractors, and any other persons or entities who may have access to such materials
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1 comply with this prohibition. Any violation of this provision may be addressed by the
2 Court through appropriate remedies, including, but not limited to, sanctions.
3 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
4 IN OTHER LITIGATON
5 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification
9 shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the subpoena
12 or order is subject to this Protective Order. Such notification shall include a copy of
13 this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 pursued by the Designating Party whose Protected Material may be affected. If the
16 Designating Party timely seeks a protective order, the Party served with the subpoena
17 or court order shall not produce any information designated in this action as
18 CONFIDENTIAL” before a determination by the court from which the subpoena or
19 order issued, unless the Party has obtained the Designating Party’s permission or
20 unless otherwise required by the law or court order. The Designating Party shall bear
21 the burden and expense of seeking protection in that court of its confidential material
22 and nothing in these provisions should be construed as authorizing or encouraging
23 a Receiving Party in this Action to disobey a lawful directive from another court.
24 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a
27 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
28 produced by Non-Parties in connection with this litigation is protected by the
1 remedies and relief provided by this Order. Nothing in these provisions should be
2 construed as prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is
5 subject to an agreement with the Non-Party not to produce the Non-Party’s
6 confidential information, then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-
8 Party that some or all of the information requested is subject to a confidentiality
9 agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 specific Description of the information requested; and
13 (3) make the information requested available for inspection by the
14 Non-Party, if requested.
15 (c) If the Non-Party fails to seek a protective order within 14 days of
16 receiving the notice and accompanying information, the Receiving Party may
17 produce the Non-Party’s confidential information responsive to the discovery
18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
19 not produce any information in its possession/control that is subject to the
20 confidentiality agreement with the Non-Party before a court determination unless
21 otherwise required by the law/court order. Absent an order to the contrary, the Non-
22 Party shall bear the burden/expense of seeking protection of its Protected Material.
23 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
28 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
1 persons to whom unauthorized disclosures were made of all the terms of this Order,
2 and (d) request such person or persons to execute the “Acknowledgment an
3 Agreement to Be Bound” attached hereto as Exhibit A.
4 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection,
8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\
9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without prior
11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12 parties reach an agreement on the effect of disclosure of a communication or
13 information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement In the stipulated protective order submitted
15 to the court.
16 14. MISCELLANEOUS
17 14.1 Right to Further Relief. Nothing in this Order abridges the right of
18 any person to seek its modification by the Court in the future.
19 14.2 Right to Assert Other Objections. By stipulating to the entry of
20 this Protective Order, no Party waives any right it otherwise would have to object to
21 disclosing or producing any information or item on any ground not addressed in this
22 Stipulated Protective Order. Similarly, no Party waives any right to object on any
23 ground to use in evidence of any of the material covered by this Protective Order.
24 14.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
26 only be filed under seal pursuant to in accordance with Local Civil Rule 79-5 or a
27 court order authorizing the sealing of the specific Protected Material. If a Party’s
28 request to file Protected Material under seal is denied by the court, then the Receiving
1 Party may file the information in the public record unless otherwise instructed by the
2 court.
3 15. FINAL DISPOSITION
4 After the final disposition of this Action, as defined in paragraph 6, within 60
5 days of a written request by the Designating Party, each Receiving Party must return
6 all Protected Material to the Producing Party or destroy such material. As used in this
7 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
8 summaries, and any other format reproducing or capturing any of the Protected
9 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
10 must submit a written certification to the Producing Party (and, if not the same person
11 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by
12 category, where appropriate) all the Protected Material that was returned or destroyed
13 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
14 compilations, summaries or any other format reproducing or capturing any of the
15 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
16 archival copy of all pleadings, motion papers, trial, deposition, and hearing
17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
18 reports, attorney work product, and consultant and expert work product, even if such
19 materials contain Protected Material. Any such archival copies that contain or
20 constitute Protected Material remain subject to this Protective Order as set forth in
21 Section 6 (DURATION).
22 16. VIOLATION
23 Any violation of this Order may be punished by appropriate measures
24 including, without limitation, contempt proceedings and/or monetary sanctions.
25 IT IS SO ORDERED.
26 DATED: Ja nuary 16, 2026 /s/
Honorable Jacqueline Chooljian
27 United States Magistrate Judge
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1
DATED: January 12, 2026 NELSON MULLINS RILEY &
2 SCARBOROUGH LLP
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4 By: /s/ Monee Takla Hanna
5 Monee Takla Hanna
Attorneys for Defendant
6 DECKERS OUTDOOR
CORPORATION d/b/a HOKA
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DATED: January 12, 2026 PEIFFER WOLF CARR KANE
9 CONWAY & WISE, LLP
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11 By: /s/ Brian J. Perkins
12 Brian J. Perkins
Dan Centner
13 Attorneys for Plaintiffs
SHAWN CZERWIEN and
14 GEORGE ATTIA
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1 EXHIBIT A
2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
3 The undersigned hereby acknowledges that he/she has read the Protective
4 Order dated _J_a_n_u_a_ry_ _1_6_, _2_0_2_6______________ in the above-captioned action and
5 attached hereto, understands the terms thereof and agrees to be bound by those terms.
6 The undersigned submits to the jurisdiction of the United States District Court for the
7 Central District of California, in matters relating to the aforementioned and attached
8 Protective Order and understands that the terms of the Order obligate him/her to use
9 materials designated as Confidential Material in accordance with the Order solely for
10 the purposes of the above-captioned action, and not to disclose any such Confidential
11 Material to any other person, firm or concern. The undersigned acknowledges that
12 violation of the Protective Order may result in penalties for contempt of court.
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Name (printed): ______________________________________
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15 Job Title: ______________________________________
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Employer: ______________________________________
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18 Business Address: ______________________________________
19 ______________________________________
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Date: ______________________________________
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22 Signature: ______________________________________
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1 SIGNATURE ATTESTATION
2 Pursuant to Local Rule 5-4.3.4(a)(2)(i-), I hereby certify that all signatories
3 have reviewed this document and concur in its content, and that all signatories
4 authorize the filing of this document.
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/s/ Monee Takla Hanna
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Monee Takla Hanna
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1 CERTIFICATE OF SERVICE
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I hereby certify that on January 12, 2026, I electronically filed the foregoing
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with the Clerk of Court using the CM/ECF system and I served a copy of the
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foregoing pleading on all counsel for all parties, via the CM/ECF system and/or
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mailing same by United States Mail, properly addressed, and first class postage
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prepaid, to all counsel of record in this matter.
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/s/ Monee Takla Hanna
9 Monee Takla Hanna
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