The opinion
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8 UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
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EBRAZ EXPORTADORA LTDA., Case No. 1:25-cv-00473-KES-SAB
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Plaintiff, ORDER REGARDING STIPULATED
12 PROTECTIVE ORDER
v.
13 (ECF No. 24)
TERRAFRESH ORGANICS LLC,
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Defendant.
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16 Plaintiff Ebraz Exportadora Ltda. (“Ebraz”) and Defendant TerraFresh Organics, LLC
17 (“TerraFresh”) hereby jointly submit the following Stipulated Protective Order.
18 1. INTRODUCTION
19 1.1. Purposes and Limitations. Discovery in this action is likely to involve the
20 production of confidential, proprietary, or private information for which special protection from
21 public disclosure and from use for any purpose other than prosecuting this litigation may be
22 warranted. Accordingly, the Parties hereby stipulate to and petition the Court to enter this
23 Stipulated Protective Order. The Parties acknowledge that this Order does not confer blanket
24 protections on all disclosures or discovery and that the protection it affords from public
25 disclosure and use extends only to the limited information or items that are entitled to
26 confidential treatment under applicable legal principles.
27 1.2. Good Cause Statement. This action is likely to involve trade secrets, customer
and pricing lists and other valuable research, development, commercial, financial, technical
1 and/or proprietary information for which special protection from public disclosure and from use
2 for any purpose other than prosecution of this action is warranted. Such confidential and
3 proprietary materials and information consist of, among other things, confidential business and
4 financial information, strategic business practices, and other confidential research, development,
5 and commercial information (including information implicating privacy rights of third parties),
6 information otherwise generally unavailable to the public, or which may be privileged or
7 otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or
8 common law. Accordingly, to expedite the flow of information, to facilitate the prompt
9 resolution of disputes over the confidentiality of discovery materials, to adequately protect
10 information the Parties are entitled to keep confidential, to ensure that the Parties are permitted
11 reasonable necessary uses of such material in preparation for and in the conduct of trial, to
12 address their handling at the end of the litigation, and to serve the ends of justice, a protective
13 order for such information is justified in this matter. It is the intent of the Parties that
14 information will not be designated confidential under this Order for tactical reasons and that
15 nothing will be so designated without a good faith belief that it has been maintained in a
16 confidential, non-public manner, and there is good cause why it should not be part of the public
17 record of this case.
18 1.3. Acknowledgment of Procedure for Filing Under Seal or Redacted. The Parties
19 acknowledge, as set forth below in Section 12.3, that this Stipulated Protective Order does not
20 entitle them to file confidential information under seal or in redacted form. This Court’s
21 Standing Order and Local Rule 141 set forth the procedures that must be followed and the
22 standards that will be applied when a party seeks permission from the Court to file material
23 under seal; this Court’s Standing Order and Local Rule 140 set forth the procedures that must be
24 followed and the standards that will be applied when a party seeks permission from the Court to
25 file redacted material.
26 2. DEFINITIONS
27 2.1 Action: The above-entitled proceeding, captioned Ebraz Exportadora Ltda. v.
1 States District Court for the Eastern District of California.
2 2.2 Challenging Party: A Party or Non-Party that challenges the designation of
3 information or items under this Stipulated Protective Order.
4 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how it is
5 generated, stored or maintained) or tangible things that qualify for protection under Rule 26(c) of
6 the Federal Rules of Civil Procedure, and, as specified above in the Good Cause Statement.
7 2.4 Counsel: Outside counsel of record, in-house counsel (as well as their respective
8 support staff), and Foreign Counsel.
9 2.5 Designating Party: A Party or Non-Party that designates information or items that
10 it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY
11 CONFIDENTIAL.”
12 2.6 Disclosure or Discovery Material: All items or information, regardless of the
13 medium or manner in which it is generated, stored, or maintained (including, among other things,
14 testimony, transcripts, and tangible things), that are produced or generated in disclosures or in
15 response to discovery in this Action.
16 2.7 Expert: A person with specialized knowledge or experience relevant to this
17 Action who has been retained by a Party or its Counsel to serve as an expert witness or as a
18 consultant in this Action.
19 2.8 “HIGHLY CONFIDENTIAL” Information or Items: Extremely sensitive
20 CONFIDENTIAL Information or Items, the disclosure of which to another Party or Non-Party
21 would create a substantial risk of serious harm that could not be avoided by less restrictive
22 means.
23 2.9 Final Disposition: The later of (1) dismissal of all claims and defenses in this
24 Action, with or without prejudice, or (2) final judgment herein after the completion and
25 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, including the
26 time limits for filing any motions or applications for extension of time pursuant to applicable
27 law.
1 are retained to represent or advise a Party in its prosecution or defense in this Action, including
2 their paralegal, investigative, technical, secretarial and clerical personnel who are engaged in
3 assisting them, who have signed the “Acknowledgment and Agreement to Be Bound”
4 (Exhibit A).
5 2.11 In-House Counsel: Attorneys who are employees of a Party to this Action. In-
6 House Counsel does not include Outside Counsel of Record or any other outside counsel.
7 2.12 Non-Party: Any natural person, partnership, corporation, association, or other
8 legal entity not named as a Party to this Action.
9 2.13 Outside Counsel of Record: Attorneys who are not employees of a party to this
10 Action, but are retained to represent or advise a Party to this Action and have appeared in this
11 Action on behalf of that Party (or are affiliated with a law firm that has appeared on behalf of
12 that Party, including firm support staff).
13 2.14 Party: Any Party to this Action, including all of its officers, directors, employees,
14 consultants, retained experts, and Outside Counsel of Record (and their support staff). Ebraz and
15 TerraFresh are referred to collectively herein as the “Parties.”
16 2.15 Producing Party: A Party or Non-Party that produces Disclosure or Discovery
17 Material in this Action.
18 2.16 Professional Vendors: Persons or entities that provide litigation support services
19 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
20 organizing, storing, or retrieving data in any form or medium) and their employees and
21 subcontractors.
22 2.17 Protected Material: Any Disclosure or Discovery Material that is designated
23 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” pursuant to this Order.
24 2.18 Receiving Party: A Party that receives Disclosure or Discovery Material from a
25 Producing Party.
26 3. SCOPE
27 The protections conferred by this Stipulation and Order cover not only Protected Material
1 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
2 conversations, or presentations by a Party or its Counsel that might reveal Protected Material.
3 4. TRIAL AND DURATION
4 This Stipulated Protective Order does not govern the use of Protected Material at trial.
5 Any use of Protected Material at trial shall be governed by the orders of the trial judge. But the
6 terms of this Order apply through Final Disposition of the Action. Even after Final Disposition
7 of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until
8 a Designating Party agrees otherwise in writing or a court order otherwise directs.
9 5. DESIGNATING PROTECTED MATERIAL
10 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party
11 or Non-Party that designates information or items for protection under this Order must take care
12 to limit any such designation to specific material that qualifies under the appropriate standards.
13 The Designating Party must designate for protection only those parts of material, documents,
14 items, or oral or written communications that qualify so that other portions of the material,
15 documents, items, or communications for which protection is not warranted are not swept
16 unjustifiably within the ambit of this protective order.
17 Mass, indiscriminate, or routine designations are prohibited. Designations that are shown
18 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
19 encumber the case development process or to impose unnecessary expenses and burdens on other
20 parties) may expose the Designating Party to sanctions.
21 If it comes to a Designating Party’s attention that information or items that it designated
22 for protection do not qualify for protection, that Designating Party must promptly notify all other
23 Parties that it is withdrawing the inapplicable designation.
24 5.2 Manner and Timing of Designations. Except as otherwise provided in this
25 Stipulated Protective Order, or as otherwise stipulated or ordered, Disclosure or Discovery
26 Material that qualifies for protection under this Order must be clearly designated before the
27 material is disclosed or produced. Designation in conformity with this Order requires:
1 but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
2 Party affix, at a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” to
3 each page that contains Protected Material. If only a portion or portions of the material on a
4 page qualifies for protection, the Producing Party also must clearly identify the protected
5 portion(s) (e.g., by making appropriate markings in the margins) and must specify, for each
6 portion, the level of protection being asserted.
7 A Party or Non-Party that makes original documents available for inspection need not
8 designate them for protection until after the inspecting Party has indicated which documents it
9 would like copied and produced. During the inspection and before the designation, all of the
10 material made available for inspection shall be deemed “HIGHLY CONFIDENTIAL.” After the
11 inspecting Party has identified the documents it wants copied and produced, the Producing Party
12 must determine which documents, or portions thereof, qualify for protection under this Stipulated
13 Protective Order. Then, before producing the specified documents, the Producing Party must
14 affix the “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” legend to each page that contains
15 Protected Material. If only a portion or portions of the material on a page qualifies for
16 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by
17 making appropriate markings in the margins).
18 (b) for testimony given in depositions, that the Designating Party identify the
19 Disclosure or Discovery Material on the record, before the close of the deposition all protected
20 testimony, or within 21 days following receipt of the deposition transcript, all protected
21 testimony.
22 (c) for information produced in some form other than documentary and for
23 any other tangible items, that the Producing Party affix in a prominent place on the exterior of
24 the container or containers in which the information is stored the “CONFIDENTIAL” or
25 “HIGHLY CONFIDENTIAL” legend. If only a portion or portions of the information warrants
26 protection, the Producing Party, to the extent practicable, shall identify the protected portion(s),
27 and must specify, for each portion, the level of protection being asserted.
1 that is subject to a “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” designation is
2 inadvertently produced without such designation, the Party that inadvertently produced the
3 document or material shall give written notice to the other Party of such inadvertent production
4 within three (3) business days of the discovery of the inadvertent production, together with a
5 further copy of the document or material properly designated as “CONFIDENTIAL” or
6 “HIGHLY CONFIDENTIAL” (the “Inadvertent Production Notice”). Upon receipt of such
7 Inadvertent Production Notice, the Party that received the inadvertently produced document or
8 material shall promptly destroy the inadvertently produced document or material and all copies
9 thereof and shall retain only the properly designated “CONFIDENTIAL” or “HIGHLY
10 CONFIDENTIAL” document or material. The receiving Party shall notify the producing Party
11 in writing of its compliance with the procedure in this provision within three (3) business days of
12 receiving the Inadvertent Production Notice.
13 This provision does not apply to the inadvertent production of any document or material
14 protected by the attorney-client privilege or any other legal privilege or protection. In the event
15 that this provision conflicts with any applicable law regarding the waiver of privilege or
16 confidentiality through the inadvertent production of documents or other materials, such law
17 shall govern.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 Any Party or Non-Party may challenge a confidentiality designation pursuant to this
20 Stipulated Protective Order at any time that is consistent with the Court’s Scheduling Order. All
21 such challenges shall be made according to Magistrate Judge Stanley A. Boone’s then-current
22 “Informal Discovery Dispute Procedures,” which are available on the Court’s website.1 For the
23 avoidance of doubt, the burden of persuasion in any such challenge proceeding shall be on the
24 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass
25 or impose unnecessary expenses and burdens on other parties), may subject the Challenging
26 Party to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality
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1 designation, all parties shall continue to afford the material in question the level of protection to
2 which it is entitled under the Producing Party’s designation until the Court rules on the
3 challenge.
4 7. ACCESS TO AND USE OF PROTECTED MATERIAL
5 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed
6 or produced by another Party or by a Non-Party in connection with this Action only for
7 prosecuting, defending, or attempting to settle this Action. Such Protected Material may be
8 disclosed only to the categories of persons and under the conditions described in this Order.
9 When the Action reaches a Final Disposition, a Receiving Party must comply with the provisions
10 of section 13 below. Protected Material must be stored and maintained by a Receiving Party at a
11 location and in a secure manner that ensures that access is limited to the persons authorized
12 under this Order.
13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
14 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may
15 disclose any information or item designated “CONFIDENTIAL” only:
16 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well
17 as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose
18 the information for this Action;
19 (b) to the officers, directors, and employees (including In-House Counsel) of
20 the Receiving Party to whom disclosure is reasonably necessary for this Action;
21 (c) to the Receiving Party’s Foreign Counsel to whom it is reasonably
22 necessary to disclose the information for this Action and who have signed the “Acknowledgment
23 and Agreement to Be Bound” (Exhibit A);
24 (d) to Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment
26 and Agreement to Be Bound” (Exhibit A);
27 (e) to the Court and its personnel;
1 (g) to professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (h) to the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information in the document;
6 (i) during depositions, to witnesses and attorneys for witnesses in the Action
7 to whom disclosure is reasonably necessary, provided: (1) the witnesses and their attorneys first
8 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A) or otherwise agree to be
9 bound by its terms; and (2) the witnesses and their attorneys will not be permitted to keep any
10 CONFIDENTIAL information unless agreed by the Designating Party or ordered by the Court.
11 Pages of transcribed deposition testimony or exhibits to depositions that reveal
12 CONFIDENTIAL Protected Material shall be separately bound by the court reporter and may
13 not be disclosed to anyone except as permitted under this Stipulated Protective Order; and
14 (j) to any mediator or settlement officer, and their supporting personnel, that
15 the Parties engage for settlement purposes; provided they first sign the “Acknowledgment and
16 Agreement to Be Bound” (Exhibit A) or otherwise agrees to be bound by its terms.
17 7.3 Disclosure of “HIGHLY CONFIDENTIAL” Information or Items. Unless
18 otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving
19 Party may disclose any information or item designated “HIGHLY CONFIDENTIAL” only:
20 (a) to the Receiving Party’s Outside Counsel of Record in this action, as well
21 as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose
22 the information for this litigation;
23 (b) to the Receiving Party’s Foreign Counsel to whom it is reasonably
24 necessary to disclose the information for this Action and who have signed the “Acknowledgment
25 and Agreement to Be Bound” (Exhibit A);
26 (c) to Experts (as defined in this Order) of the Receiving Party to whom
27 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment
1 (d) to the Court and its personnel;
2 (e) to court reporters and their staff;
3 (f) to Professional Vendors to whom disclosure is reasonably necessary for
4 this litigation who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (g) to the author or recipient of a document containing the information or a
6 custodian or other person who otherwise possessed or knew the information in the document;
7 (h) during depositions, to witnesses and attorneys for witnesses in the Action
8 to whom disclosure is reasonably necessary, provided: (1) the witnesses and their attorneys first
9 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A) or otherwise agree to be
10 bound by its terms; and (2) the witnesses and their attorneys will not be permitted to keep any
11 HIGHLY CONFIDENTIAL information unless agreed by the Designating Party or ordered by
12 the Court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
13 HIGHLY CONFIDENTIAL Protected Material shall be separately bound by the court reporter
14 and may not be disclosed to anyone except as permitted under this Stipulated Protective Order;
15 and
16 (i) to any mediator or settlement officer, and their supporting personnel, that
17 the Parties engage for settlement purposes; provided they first sign the “Acknowledgment and
18 Agreement to Be Bound” (Exhibit A) or otherwise agree to be bound by its terms.
19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
20 OTHER LITIGATION
21 If a Party is served with a valid subpoena or court order issued in other litigation that
22 compels the disclosure of any CONFIDENTIAL or HIGHLY CONFIDENTIAL documents or
23 information in this Action, the Party receiving the subpoena or court order must:
24 (a) promptly notify the Designating Party in writing of the subpoena or court
25 order. Such notification shall include a copy of the subpoena or court order;
26 (b) promptly notify the party who served the subpoena or court order in
27 writing that some or all of the material covered by the subpoena or order is subject to this
1 (c) cooperate with the Designating Party whose Protected Material may be
2 affected in reasonable, lawful efforts to oppose/object to the subpoena or court order. If the
3 Designating Party timely seeks a protective order, the Party served with the subpoena or court
4 order shall not produce any information designated in this action as “CONFIDENTIAL” or
5 “HIGHLY CONFIDENTIAL” before a determination by the court from which the subpoena or
6 order issued, unless the Party has obtained the Designating Party’s permission to do so. The
7 Designating Party shall bear the burden and expense of seeking such protection in that court and
8 nothing in this provision should be construed as authorizing or encouraging a Receiving Party in
9 this Action to disobey a lawful directive from another court.
10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
11 THIS LITIGATION
12 9.1 Application. The terms of this Stipulated Protective Order are applicable to
13 information produced by a Non-Party in this Action that is designated “CONFIDENTIAL” or
14 “HIGHLY CONFIDENTIAL.” Such information produced by a Non-Party in connection with
15 this Action is protected by the remedies and relief provided by this Order. Nothing in this
16 section 9 should be construed as prohibiting a Non-Party from seeking additional protections
17 beyond the scope of this Order.
18 9.2 Notification. In the event a Party is required by a valid discovery request to
19 produce a Non-Party’s confidential information in its possession, and the Party is subject to an
20 agreement with the Non-Party not to produce the that confidential information, the Party shall:
21 (a) promptly notify the Requesting Party and the Non-Party in writing that
22 some or all of the information requested is subject to a confidentiality agreement with the Non-
23 Party;
24 (b) make the information requested available for inspection by the Non-Party,
25 if requested.
26 9.3 Conditions of Production. If the Non-Party fails to seek a protective order from
27 this Court within 14 days of receiving the aforementioned notice and accompanying information,
1 valid discovery request. If the Non-Party timely seeks a protective order, the Receiving Party
2 shall not produce any information in its possession or control that is subject to the confidentiality
3 agreement with the Non-Party before the Court rules on the request for a protective order.
4 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking
5 protection of its Protected Material.
6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
8 Material to any person or in any circumstance not authorized under this Stipulated Protective
9 Order, the Receiving Party must immediately (a) notify the Designating Party of the
10 unauthorized disclosures in writing, (b) use its best efforts to retrieve all unauthorized copies of
11 the Protected Material, (c) inform the person or persons to whom unauthorized disclosures were
12 made of all the terms of this Order, and (d) request such person or persons execute the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A). The Designating Party may
14 pursue whatever lawful remedy or remedies it so chooses in response to the disclosure, including
15 a motion for sanctions against the Receiving Party.
16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
17 PROTECTED MATERIAL
18 When a Party gives notice to the other Party that certain inadvertently produced material
19 is subject to a claim of privilege or other protection, the obligations of the receiving Party are
20 those set forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not
21 intended to modify whatever procedure may be established in an e-discovery order that provides
22 for production without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
23 Rules of Evidence, insofar as the Parties reach agreement on the effect of the disclosure of a
24 communication or information covered by the attorney-client privilege or protection, the Parties
25 may incorporate their agreement into a court order.
26 12. MISCELLANEOUS
27 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order abridges the
1 12.2 Right to Assert Other Objections. By stipulating to the entry of this Stipulated
2 Protective Order, no Party waives any right it otherwise would have to object to disclosing or
3 producing any information or item on any ground not addressed in this Order. Similarly, no
4 Party waives any right to object on any ground to the use of any of the material covered by this
5 Order in this Action.
6 12.3 Filing Protected Material. A Party that seeks to file under seal, or redact any
7 Protected Material must comply with Local Rules 140 and 141, as applicable. Protected Material
8 may only be filed under seal or redacted pursuant to a court order authorizing the sealing or
9 redaction of the specific Protected Material at issue. If a Party’s request to file Protected
10 Material under seal or redacted is denied by the Court, then the Receiving Party may file the
11 information in the public record unless otherwise instructed by the Court.
12 13. FINAL DISPOSITION
13 Within 60 days of the Final Disposition of this Action, each Party must permanently
14 destroy all Protected Material of the other Party and any Non-Party that is in its possession,
15 custody, or control. The phrase “all Protected Material” includes all copies, abstracts,
16 compilations, summaries, and any other format reproducing or capturing any of the Protected
17 Material. Each Party must submit to the other Party (and, if not the same person or entity, to the
18 Designating Party) a written certification of its compliance with this provision by the 60-day
19 deadline. Notwithstanding the requirements of this provision, Counsel for each Party is entitled
20 to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports,
22 attorney work product, and consultant and expert work product, even if such items are Protected
23 Material. Any such archival copies that contain or constitute Protected Material remain subject
24 to this Stipulated Protective Order.
25 14. VIOLATION
26 Any violation of this Stipulated Protective Order may be punished by any and all
27 appropriate measures including, without limitation, contempt proceedings and/or monetary and
1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: January 13, 2026 /s/ Steven L. Penaro (as authorized on January 12, 2026)
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ALSTON & BIRD LLP
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Steven L. Penaro
5 Jenna Jones
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Attorneys for Plaintiff Ebraz Exportadora Ltda.
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8 DATED: January 13, 2026 /s/ James J. Ward
9 BAKER & MCKENZIE LLP
10 James J. Ward
Michael T. Boardman
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William Devaney
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Attorneys for Defendant TerraFresh Organics, LLC
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, ___________________________________ [insert full name], residing at
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_________________________________________________ [insert full address], declare
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under penalty of perjury that I have read in its entirety and understand the Stipulated Protective
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Order issued by the United States District Court for the Eastern District of California in the
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case of Ebraz Exportadora Ltda. v. TerraFresh Organics, LLC, Case No. 1:25-cv-00473-KES-
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SAB . I agree to comply with and to be bound by all the terms of that Stipulated Protective
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Order and I understand and acknowledge that failure to so comply could expose me to sanctions
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and punishment in the nature of contempt. I solemnly promise that I will not disclose in any
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manner any information or item that is subject to that Stipulated Protective Order to any person
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or entity except in strict compliance with the provisions of that Order.
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I further agree to submit to the jurisdiction of the United States District Court for the
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Eastern District of California for the purpose of enforcing the terms of that Stipulated Protective
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Order, even if such enforcement proceedings occur after termination of the action. I hereby
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appoint ________________________ [insert full name], located at
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____________________________________________________ [insert full address and
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telephone number] as my California agent for service of process in connection with this action
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or any proceedings related to enforcement of the Stipulated Protective Order.
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Date: ___________________________
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City and State where sworn and signed: ___________________________
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Printed name: ___________________________
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Signature: ___________________________
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1 COURT ORDER ENTERING STIPULATED PROTECTIVE ORDER
2 Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY
3 | ORDERED that:
4 1. The above stipulated protective order is ENTERED;
5 2. The provisions of the parties’ stipulation and this protective order shall remain in
6 effect until further order of the Court;
7 3. The parties are advised that pursuant to the Local Rules of the United States
8 District Court, Eastern District of California, any documents which are to be filed
9 under seal will require a written request which complies with Local Rule 141;
10 4. The party making a request to file documents under seal shall be required to show
11 either good cause or compelling reasons to seal the documents, depending on the
12 type of filing, Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir.
13 2009); Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1101 (9th Cir.
14 2016);
15 5. If a party’s request to file Protected Material under seal is denied by the Court,
16 then the previously filed material shall be immediately accepted by the Court and
17 become information in the public record and the information will be deemed filed
18 as of the date that the request to file the Protected Information under seal was
19 made; and
20 6. Additionally, the parties shall consider resolving any dispute arising under this
21 protective order according to the Court’s informal discovery dispute procedure.
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73 IT IS SO ORDERED. OF. nf Se
24 | Dated: _January 14, 2026 _ OO
STANLEY A. BOONE
25 United States Magistrate Judge
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