Opinion

Court: District Court, E.D. California
Filed: Jan 14, 2026
Cited by: 0 cases
Authority: More cited than 40.6%

The opinion

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6 UNITED STATES DISTRICT COURT

7 FOR THE EASTERN DISTRICT OF CALIFORNIA

9 RYAN TAN, Case No. 25-cv-02944-DAD-CSK

10 Plaintiff, ORDER GRANTING MODIFIED

4 y STIPULATED PROTECTIVE ORDER

(ECF No. 12)

12 || NURSE-FAMILY PARTNERSHIP DBA

3 CHANGENT,

Defendant.

15 The Court has reviewed the parties’ stipulated protective order below (ECF No.

16 || 12), and finds it comports with the relevant authorities and the Court’s Local Rule. See

17 || L.R. 141.1. The Court APPROVES the protective order, subject to the following

18 || clarification.

19 The Court’s Local Rules indicate that once an action is closed, it “will not retain

20 || jurisdiction over enforcement of the terms of any protective order filed in that action.”

21 || L.R. 141.1(f); see Bylin Heating Sys., Inc. v. Thermal Techs., Inc., 2012 WL 13237584,

22 || at *2 (E.D. Cal. Oct. 29, 2012) (noting that courts in the district generally do not retain

23 || jurisdiction for disputes concerning protective orders after closure of the case). Thus, the

24 || Court will not retain jurisdiction over this protective order once the case is closed.

25 || Dated: January 14, 2026 OC iy $

26 CHI SOO KIM

27 |) 4 semsoaas UNITED STATES MAGISTRATE JUDGE

1 Carrie Francis, Bar No. 309280

CFrancis@taftlaw.com

2 Taft Stettinius & Hollister LLP

2555 East Camelback Road

3 Suite 1050

Phoenix, Arizona 85016

4 Telephone: (602) 240-3000

Facsimile: (602) 240-6600

5 Attorneys for Defendant Changent

9 UNITED STATES DISTRICT COURT

10 EASTERN DISTRICT OF CALIFORNIA

12 Ryan Tan, an individual, Case No. 25-cv-02944-DAD-CSK

13 Plaintiff, STIPULATION AND [PROPOSED]

PROTECTIVE ORDER

14 v.

Assigned to Hon. Dale A. Drozd and

15 Nurse-Family Partnership, a Colorado Magistrate Judge Chi Soo Kim

nonprofit corporation, dba Changent ,

Defendant.

19 STIPULATION

20 Plaintiff Ryan Tan and Defendant Nurse-Family Partnership (collectively, the

21 “Parties”), by and through their undersigned counsel, hereby stipulate and agree, subject to

22 approval by the Court, to the entry of the following Confidentiality and Protective Order

23 pursuant to Federal Rule of Civil Procedure 26(c) and Eastern District of California Local

24 Rule 141.1.

25 The Parties submit this stipulation jointly and represent that good cause exists for

26 entry of the proposed Order as set forth below.

2 Dated: January 12, 2026

TAFT STETTINIUS & HOLLISTER LLP

By:/s/ Carrie M. Francis

6 Carrie Francis

Attorneys for Defendant Changent

RYAN TAN

By:/s/ Ryan Tan

11 Ryan Tan, Plaintiff in Pro Per

1 [PROPOSED] ORDER

1. Purposes and Limitations

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

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

public disclosure and from use for any purpose other than prosecuting this litigation

may be warranted. Accordingly, the parties hereby stipulate to and petition the court

to enter the following Stipulated Protective Order. The parties acknowledge that this

Order does not confer blanket protections on all disclosures or responses to discovery

and that the protection it affords from public disclosure and use extends only to the

limited information or items that are entitled to confidential treatment under the

applicable legal principles. The parties further acknowledge that this Stipulated

Protective Order does not entitle them to file confidential information under seal;

Local Rule 141 sets forth the procedures that must be followed and the standards that

will be applied when a party seeks permission from the court to file material under

seal.

2. Definitions

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

designation of information or items under this Order.

2.2 “CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that qualify for

protection under Federal Rule of Civil Procedure 26(c).

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

Counsel (as well as their support staff).

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

or items that it produces in disclosures or in responses to discovery as

“CONFIDENTIAL.”

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

of the medium or manner in which it is generated, stored, or maintained (including,

1 among other things, testimony, transcripts, and tangible things), that are produced or

2 generated in disclosures or responses to discovery in this matter.

3 2.6 Expert: a person with specialized knowledge or experience in a matter

4 pertinent to the litigation who has been retained by a Party or its counsel to serve as

5 an expert witness or as a consultant in this action.

6 2.7 House Counsel: attorneys who are employees of a party to this action.

7 House Counsel does not include Outside Counsel of Record or any other outside

8 counsel.

9 2.8 Non-Party: any natural person, partnership, corporation, association,

10 or other legal entity not named as a Party to this action.

11 2.9 Outside Counsel of Record: attorneys who are not employees of a party

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

13 appeared in this action on behalf of that party or are affiliated with a law firm which

14 has appeared on behalf of that party.

15 2.10 Party: any party to this action, including all of its officers, directors,

16 employees, consultants, retained experts, and Outside Counsel of Record (and

17 their support staffs).

18 2.11 Producing Party: a Party or Non-Party that produces Disclosure

19 or Discovery Material in this action.

20 2.12 Professional Vendors: persons or entities that provide litigation support

21 services (e.g., photocopying, videotaping, translating, preparing exhibits or

22 demonstrations, and organizing, storing, or retrieving data in any form or medium)

23 and their employees and subcontractors.

24 2.13 Protected Material: any Disclosure or Discovery Material that is

25 designated as “CONFIDENTIAL.”

26 2.14 Receiving Party: a Party that receives Disclosure or Discovery

27 Material from a Producing Party.

1 3. Categories of Information Eligible for Protection (LR 141.1(c)(1))

2 The parties seek protection only for limited categories of information

3 exchanged in discovery that are non-public, sensitive, and the disclosure of which

4 could result in harm. Specifically, the categories of information eligible for protection

5 under this Order include:

a. Confidential personnel and employment records, including performance

evaluations, disciplinary records, compensation information, and internal

human resources investigations;

b. Proprietary business information, including internal policies, procedures,

training materials, and non-public business practices related to hiring,

promotion, discipline, and termination;

c. Confidential financial information, including non-public financial data,

payroll records, bonus or incentive structures, and budgeting materials;

d. Personally identifiable information (“PII”) of current or former employees

or third parties, including Social Security numbers, home addresses, personal

telephone numbers, dates of birth, and similar identifying information;

e. Sensitive internal communications, including non-public emails,

memoranda, and internal correspondence concerning personnel decisions or

employment practices.

4. Particularized Need for Protection (LR 141.1(c)(2))

Good cause exists for protection of each category of information identified

above. Disclosure of confidential personnel and employment records could violate

employee privacy rights and subject the producing party to legal and reputational

harm. See, e.g., Sanchez v. City of Santa Ana, 936 F.2d 1027, 1033–34 (9th Cir.

1990).

Disclosure of proprietary business information and internal policies could

provide competitors or third parties with insight into non-public business operations,

1 resulting in competitive harm. The information is maintained as confidential in the

2 ordinary course of business and is not publicly available.

3 Disclosure of confidential financial information could expose sensitive

4 business data and compensation practices, potentially causing financial and

5 competitive injury.

6 Disclosure of personally identifiable information presents a substantial risk of

7 identity theft, harassment, or misuse, and implicates recognized privacy interests

8 under federal and California law.

9 Disclosure of sensitive internal communications regarding personnel matters

10 could chill candid internal discussions, undermine employer decision-making

11 processes, and unfairly prejudice the producing party outside the context of this

12 litigation.

13 For each of these categories, unrestricted public disclosure would result in

14 specific, identifiable harm that outweighs the public’s interest in access to this

15 information at the discovery stage.

16 5. Necessity of a Court-Entered Protective Order (LR 141.1(c)(3))

17 A court-entered protective order is necessary because discovery materials may

18 be disclosed to third parties, experts, or filed with the Court, and a private agreement

19 between the parties would be insufficient to ensure enforceability or compliance.

20 Absent a court order, the parties would lack an effective mechanism to prevent

21 misuse or unauthorized disclosure of confidential information or to obtain relief in

22 the event of a violation. Moreover, discovery disputes or third-party subpoenas could

23 require judicial enforcement of confidentiality obligations.

24 A court-entered protective order provides clear, enforceable standards

25 governing the handling, use, and disclosure of confidential information and promotes

26 the efficient exchange of discovery while safeguarding legitimate privacy and

27 proprietary interests.

28 6. Scope

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

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

3 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

4 Material; and (3) any testimony, conversations, or presentations by Parties or their

5 Counsel that might reveal Protected Material. However, the protections conferred by

6 this Stipulation and Order do not cover the following information: (a) any

7 information that is in the public domain at the time of disclosure to a Receiving Party

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

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

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

11 Receiving Party prior to the disclosure or obtained by the Receiving Party after the

12 disclosure from a source who obtained the information lawfully and under no

13 obligation of confidentiality to the Designating Party. Any use of Protected Material

14 at trial shall be governed by a separate agreement or order.

15 7. Duration

16 Even after final disposition of this litigation, the confidentiality obligations

17 imposed by this Order shall remain in effect until a Designating Party agrees

18 otherwise in writing or a court order otherwise directs. Final disposition shall be

19 deemed to be the later of (1) dismissal of all claims and defenses in this action, with

20 or without prejudice; and (2) final judgment herein after the completion and

21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,

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

23 pursuant to applicable law.

24 8. Designating Protected Material

25 8.1 Exercise of Restraint and Care in Designating Material for Protection.

26 Each Party or Non-Party that designates information or items for protection under

27 this Order must take care to limit any such designation to specific material that

28 qualifies under the appropriate standards. The Designating Party must designate for

1 protection only those parts of material, documents, items, or oral or written

2 communications that qualify – so that other portions of the material, documents,

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

4 unjustifiably within the ambit of this Order.

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

6 that are shown to be clearly unjustified or that have been made for an improper

7 purpose (e.g., to unnecessarily encumber or retard the case development process or

8 to impose unnecessary expenses and burdens on other parties) expose the

9 Designating Party to sanctions.

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

11 designated for protection do not qualify for protection, that Designating Party must

12 promptly notify all other Parties that it is withdrawing the mistaken designation.

13 8.2 Manner and Timing of Designations. Except as otherwise provided in this

14 Order, or as otherwise stipulated or ordered, Disclosure or Discovery

15 Material that qualifies for protection under this Order must be clearly so

16 designated before the material is disclosed or produced.

Designation in conformity with this Order requires:

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

documents, but excluding transcripts of depositions or other pretrial or trial

proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each

page that contains protected material. If only a portion or portions of the material on

a page qualifies for protection, the Producing Party also must clearly identify the

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

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

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

indicated which material it would like copied and produced. During the inspection

and before the designation, all of the material made available for inspection shall be

1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

2 documents it wants copied and produced, the Producing Party must determine which

3 documents, or portions thereof, qualify for protection under this Order. Then, before

4 producing the specified documents, the Producing Party must affix the

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

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

7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

8 markings in the margins).

9 (b) For testimony given in deposition or in other pretrial or trial

10 proceedings, that the Designating Party identify on the record, before the close

11 of the deposition, hearing, or other proceeding, all protected testimony.

12 (c) for information produced in some form other than documentary and for

13 any other tangible items, that the Producing Party affix in a prominent place on the

14 exterior of the container or containers in which the information or item is stored the

15 legend “CONFIDENTIAL.” If only a portion or portions of the information or item

16 warrant protection, the Producing Party, to the extent practicable, shall identify the

17 protected portion(s).

18 8.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

19 failure to designate qualified information or items does not, standing alone, waive

20 the Designating Party’s right to secure protection under this Order for such material.

21 Upon timely correction of a designation, the Receiving Party must make reasonable

22 efforts to assure that the material is treated in accordance with the provisions of this

23 Order.

24 9. Challenging Confidentiality Designations

25 9.1 Timing of Challenges. Any Party or Non-Party may challenge a

26 designation of confidentiality at any time. Unless a prompt challenge to a Designating

27 Party’s confidentiality designation is necessary to avoid foreseeable, substantial

28 unfairness, unnecessary economic burdens, or a significant disruption or delay of the

1 litigation, a Party does not waive its right to challenge a confidentiality designation

2 by electing not to mount a challenge promptly after the original designation is

3 disclosed.

4 9.2 Meet and Confer. The Challenging Party shall initiate the dispute

5 resolution process by providing written notice of each designation it is challenging

6 and describing the basis for each challenge. To avoid ambiguity as to whether a

7 challenge has been made, the written notice must recite that the challenge to

8 confidentiality is being made in accordance with this specific paragraph of the

9 Protective Order. The parties shall attempt to resolve each challenge in good faith and

10 must begin the process by conferring directly (in voice to voice dialogue; other forms

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

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

13 confidentiality designation was not proper and must give the Designating Party an

14 opportunity to review the designated material, to reconsider the circumstances, and,

15 if no change in designation is offered, to explain the basis for the chosen designation.

16 A Challenging Party may proceed to the next stage of the challenge process only if it

17 has engaged in this meet and confer process first or establishes that the Designating

18 Party is unwilling to participate in the meet and confer process in a timely manner.

19 9.3 Judicial Intervention. If the Parties cannot resolve a challenge without

20 court intervention, the Designating Party shall file and serve a motion to retain

21 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule

22 79-5, if applicable) within 21 days of the initial notice of challenge or within 14 days

23 of the parties agreeing that the meet and confer process will not resolve their dispute,

24 whichever is earlier. Each such motion must be accompanied by a competent

25 declaration affirming that the movant has complied with the meet and confer

26 requirements imposed in the preceding paragraph. Failure by the Designating Party

27 to make such a motion including the required declaration within 21 days (or 14 days,

28 if applicable) shall automatically waive the confidentiality designation for each

1 challenged designation. In addition, the Challenging Party may file a motion

2 challenging a confidentiality designation at any time if there is good cause for doing

3 so, including a challenge to the designation of a deposition transcript or any portions

4 thereof. Any motion brought pursuant to this provision must be accompanied by a

5 competent declaration affirming that the movant has complied with the meet and

6 confer requirements imposed by the preceding paragraph.

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

8 Designating Party. Frivolous challenges, and those made for an improper purpose

9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

10 expose the Challenging Party to sanctions. Unless the Designating Party has waived

11 the confidentiality designation by failing to file a motion to retain confidentiality as

12 described above, all parties shall continue to afford the material in question the level

13 of protection to which it is entitled under the Producing Party’s designation until the

14 court rules on the challenge.

15 10. Access to and Use of Protected Material

16 10.1 Basic Principles. A Receiving Party may use Protected Material that is

17 disclosed or produced by another Party or by a Non-Party in connection with this

18 case only for prosecuting, defending, or attempting to settle this litigation. Such

19 Protected Material may be disclosed only to the categories of persons and under the

20 conditions described in this Order. When the litigation has been terminated, a

21 Receiving Party must comply with the provisions of section 16 below (FINAL

22 DISPOSITION). Protected Material must be stored and maintained by a Receiving

23 Party at a location and in a secure manner that ensures that access is limited to the

24 persons authorized under this Order.

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

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

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

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

2 as employees of said Outside Counsel of Record to whom it is reasonably necessary

3 to disclose the information for this litigation and who have signed the

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

5 A;

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

7 the Receiving Party to whom disclosure is reasonably necessary for this litigation

8 and who have signed the “Acknowledgment and Agreement to Be Bound”

9 (Exhibit A);

10 (c) Experts (as defined in this Order) of the Receiving Party to whom

11 disclosure is reasonably necessary for this litigation and who have signed the

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

13 (d) the court and its personnel;

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

15 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary

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

17 Bound” (Exhibit A);

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

19 is reasonably necessary and who have signed the “Acknowledgment and

20 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the

21 Designating Party or ordered by the court. Pages of transcribed deposition

22 testimony or exhibits to depositions that reveal Protected Material must be

23 separately bound by the court reporter and may not be disclosed to anyone

24 except as permitted under this Stipulated Protective Order.

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

26 or a custodian or other person who otherwise possessed or knew the

27 information.

1 11. Protected Material and Subpoenaed or Ordered Produced in Other

2 Litigation

3 If a Party is served with a subpoena or a court order issued in other litigation

4 that compels disclosure of any information or items designated in this action as

5 “CONFIDENTIAL,” that Party must:

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

7 shall include a copy of the subpoena or court order;

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

9 to issue in the other litigation that some or all of the material covered by the subpoena

10 or order is subject to this Protective Order. Such notification shall include a copy of

11 this Stipulated Protective Order; and

12 (c) cooperate with respect to all reasonable procedures sought to be

13 pursued by the Designating Party whose Protected Material may be affected.

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

15 the subpoena or court order shall not produce any information designated in this

16 action as “CONFIDENTIAL” before a determination by the court from which the

17 subpoena or order issued, unless the Party has obtained the Designating Party’s

18 permission. The Designating Party shall bear the burden and expense of seeking

19 protection in that court of its confidential material – and nothing in these provisions

20 should be construed as authorizing or encouraging a Receiving Party in this action

21 to disobey a lawful directive from another court.

22 12. A Non-Party’s Protected Material Sought to be Produced in this

23 Litigation

24 (a) The terms of this Order are applicable to information produced by a

25 Non-Party in this action and designated as “CONFIDENTIAL.” Such information

26 produced by Non-Parties in connection with this litigation is protected by the

27 remedies and relief provided by this Order. Nothing in these provisions should be

28 construed as prohibiting a Non-Party from seeking additional protections.

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

2 produce a Non-Party’s confidential information in its possession, and the Party is

3 subject to an agreement with the Non-Party not to produce the Non-Party’s

4 confidential information, then the Party shall:

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

6 that some or all of the information requested is subject to a confidentiality agreement

7 with a Non-Party;

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

9 Protective Order in this litigation, the relevant discovery request(s), and a

10 reasonably specific description of the information requested; and

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

Party.

within 14 days of receiving the notice and accompanying information, the Receiving

Party may produce the Non-Party’s confidential information responsive to the

discovery request. If the Non-Party timely seeks a protective order, the Receiving

Party shall not produce any information in its possession or control that is subject to

the confidentiality agreement with the Non-Party before a determination by the court.

Absent a court order to the contrary, the Non-Party shall bear the burden and expense

of seeking protection in this court of its Protected Material.

13. Unauthorized Disclosure of Protected Material

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

Protected Material to any person or in any circumstance not authorized under this

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

persons to whom unauthorized disclosures were made of all the terms of this Order,

1 and (d) request such person or persons to execute the “Acknowledgment and

2 Agreement to Be Bound” that is attached hereto as Exhibit A.

3 14. Inadvertent Production of Privileged or Otherwise Protected Material

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

5 inadvertently produced material is subject to a claim of privilege or other protection,

6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

8 may be established in an e-discovery order that provides for production without prior

9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

10 parties reach an agreement on the effect of disclosure of a communication or

11 information covered by the attorney-client privilege or work product protection, the

12 parties may incorporate their agreement in the stipulated protective order submitted

13 to the court.

14 15. Miscellaneous

15 15.1 Right to Further Relief. Nothing in this Order abridges the right of any

16 person to seek its modification by the court in the future.

17 15.2 Right to Assert Other Objections. By stipulating to the entry of this

18 Protective Order no Party waives any right it otherwise would have to object to

19 disclosing or producing any information or item on any ground not addressed in this

20 Stipulated Protective Order. Similarly, no Party waives any right to object on any

21 ground to use in evidence of any of the material covered by this Protective Order.

22 15.3 Filing Protected Material. Without written permission from the

23 Designating Party or a court order secured after appropriate notice to all interested

24 persons, a Party may not file in the public record in this action any Protected Material.

25 A Party that seeks to file under seal any Protected Material must comply with Civil

26 Local Rule 141. Protected Material may only be filed under seal pursuant to a court

27 order authorizing the sealing of the specific Protected Material at issue. Pursuant to

28 Civil Local Rule 141, a sealing order will issue only upon a request establishing that

1 the Protected Material at issue is privileged, protectable as a trade secret, or otherwise

2 entitled to protection under the law.

3 16. Final Disposition

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

5 7, each Receiving Party must return all Protected Material to the Producing Party or

6 destroy such material. As used in this subdivision, “all Protected Material” includes

7 all copies, abstracts, compilations, summaries, and any other format reproducing or

8 capturing any of the Protected Material. Whether the Protected Material is returned

9 or destroyed, the Receiving Party must submit a written certification to the

10 Producing Party (and, if not the same person or entity, to the Designating Party) by

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

12 Protected Material that was returned or destroyed and (2) affirms that the Receiving

13 Party has not retained any copies, abstracts, compilations, summaries or any other

14 format reproducing or capturing any of the Protected Material. Notwithstanding this

15 provision, Counsel are entitled to retain an archival copy of all pleadings, motion

16 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

17 deposition and trial exhibits, expert reports, attorney work product, and consultant

18 and expert work product, even if such materials contain Protected Material. Any

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

20 this Protective Order as set forth in Section 7 (DURATION).

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.