The opinion
1 WINSTON P. HSIAO (SBN 273638)
winston.hsiao@skadden.com
2 ALYSSA MUSANTE (SBN 320821)
alyssa.musante@skadden.com
3 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
2000 Avenue of the Stars, Suite 200N
4 Los Angeles, California 90067
Telephone: (213) 687-5000
5 Facsimile: (213) 687-5600
6 Attorneys for Defendants Acrisure, LLC
and Benefits MatchMaking, LLC
7
8
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
WESTERN DIVISION
12
)
JOHN GREGORY, CASE NO: 2:24-cv-08661-HDV-E
)
13
Plaintiff, )
)
14 v.
)
[PROPOSED] STIPULATED
ACRISURE, LLC, BENEFITS )
15 PROTECTIVE ORDER
MATCHMAKING, LLC and ADAM )
DEVONE, and DOES 1 through 10, )
16
inclusive, )
Defendants. )
17 Hon. Hernán D. Vera
)
)
18 Magistrate Judge Charles F. Eick
)
)
19 Complaint Filed: July 15, 2024
)
)
20
)
21
22
23
24
25
26
27
28
1 1. GENERAL
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than prosecuting
5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition
6 the Court to enter the following Stipulated Protective Order. The parties acknowledge
7 that this Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends only to
9 the limited information or items that are entitled to confidential treatment under the
10 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,
11 below, that this Stipulated Protective Order does not entitle them to file confidential
12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
13 followed and the standards that will be applied when a party seeks permission from the
14 court to file material under seal.
15 1.2 Good Cause Statement. This action is likely to involve trade secrets,
16 customer and financial information and other valuable technical or proprietary
17 information, as well as individuals’ private information, such as tax returns, personally
18 identifiable information, and finances, for which special protection from public disclosure
19 and from use for any purpose other than prosecution of this action is warranted. Such
20 confidential and proprietary materials and information consist of, among other things,
21 confidential business or financial information, information regarding confidential
22 business practices, or other confidential research, development, or commercial
23 information (including information implicating privacy rights of third parties),
24 information otherwise generally unavailable to the public, or which may be privileged or
25 otherwise protected from disclosure under state or federal statutes, court rules, case
26 decisions, or common law.
27 In addition, a disclosing party may designate as Confidential any information that
28 it reasonably and in good faith believes constitutes, contains, reveals or evidences non-
1 public personal information, other sensitive personally identifiable information (such as
2 Social Security numbers, taxpayer-identification numbers, dates of birth, home addresses,
3 phone numbers, email addresses, names of minor children, financial accounting
4 information (which may be redacted to the last four digits), passport numbers and driver
5 license numbers).
6 A disclosing party may also designate as confidential other information for which
7 applicable law requires confidential treatment.
8 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
9 of disputes over confidentiality of discovery materials, to adequately protect information
10 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,
12 to address their handling at the end of the litigation, and serve the ends of justice, a
13 protective order for such information is justified in this matter. It is the intent of the
14 parties that information will not be designated as confidential for tactical reasons and that
15 nothing 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
17 public record of this case.
18 2. DEFINITIONS1
19 2.1 Action: this pending federal lawsuit, namely Gregory v. Acrisure, LLC, et
20 al., No. 2:24-cv-08661-HDV-E (C.D. Cal.).
21 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
22 information or items under this Order.
23 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it
24 is generated, stored or maintained) or tangible things that qualify for protection under
25
26
27 1 The Parties do not currently anticipate the need for an elevated Attorneys’ Eyes Only designation but
all parties reserve the right to raise if and when the need arises. The Parties further agree to discuss the
28
1 Federal Rule of Civil Procedure 26(c), any applicable case law interpreting Federal Rule
2 of Civil Procedure 26(c), and as specified above in the Good Cause Statement.
3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
4 support staff).
5 2.5 Designating Party: a Party or Non-Party that designates information or items
6 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
7 2.6 Disclosure or Discovery Material: all items or information, regardless of the
8 medium or manner in which it is generated, stored, or maintained (including, among
9 other things, testimony, transcripts, and tangible things), that are produced or generated in
10 disclosures or responses to discovery in this matter.
11 2.7 Expert: a person with specialized knowledge or experience in a matter
12 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
13 expert witness or as a consultant in this Action.
14 2.8 House Counsel: attorneys who are employees of a party to this Action.
15 House Counsel does not include Outside Counsel of Record or any other outside counsel.
16 2.9 Non-Party: any natural person, partnership, corporation, association, or other
17 legal entity not named as a Party to this action.
18 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
19 this Action but are retained to represent or advise a party to this Action and have
20 appeared in this Action on behalf of that party or are affiliated with a law firm that has
21 appeared on behalf of that party, including support staff.
22 2.11 Party: any party to this Action, including all of its officers, directors,
23 employees, consultants, retained experts, and Outside Counsel of Record (and their
24 support staffs).
25 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
26 Discovery Material in this Action.
27 2.13 Professional Vendors: persons or entities that provide litigation support
28 services (e.g., photocopying, videotaping, translating, preparing exhibits or
1 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
2 their employees and subcontractors.
3 2.14 Protected Material: any Disclosure or Discovery Material that is designated
4 as “CONFIDENTIAL.”
5 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
6 a Producing Party.
7 3. SCOPE
8 The protections conferred by this Stipulation and Order cover not only Protected
9 Material (as defined above), but also (1) any information copied or extracted from
10 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
11 Material; and (3) any testimony, conversations, or presentations by Parties or their
12 Counsel that might reveal Protected Material.
13 Any use of Protected Material at trial shall be governed by the orders of the trial
14 judge. This Order does not govern the use of Protected Material at trial.
15 4. DURATION
16 Once a case proceeds to trial, all of the court-filed information to be introduced
17 that was previously designated as confidential or maintained pursuant to this protective
18 order becomes public and will be presumptively available to all members of the public,
19 including the press, unless compelling reasons supported by specific factual findings to
20 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
21 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good
22 cause” showing for sealing documents produced in discovery from “compelling reasons”
23 standard when merits-related documents are part of court record).
24 For non-court-filed information, the confidentiality obligations imposed by this
25 Order shall remain in effect even after final disposition of this litigation and unless a
26 Designating Party agrees otherwise in writing or a court order otherwise directs.
27
28
1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
3 Party or Non-Party that designates information or items for protection under this Order
4 must take care to limit any such designation to specific material that qualifies under the
5 appropriate standards. The Designating Party must designate for protection only those
6 parts of material, documents, items, or oral or written communications that qualify so that
7 other portions of the material, documents, items, or communications for which protection
8 is not warranted are not swept unjustifiably within the ambit of this Order.
9 Mass, indiscriminate, or routinized designations are prohibited. Designations that
10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
11 to unnecessarily encumber the case development process or to impose unnecessary
12 expenses and burdens on other parties) may expose the Designating Party to sanctions.
13 If it comes to a Designating Party’s attention that information or items that it
14 designated for protection do not qualify for protection that Designating Party must
15 promptly notify all other Parties that it is withdrawing the inapplicable designation.
16 5.2 Manner and Timing of Designations. Except as otherwise provided in this
17 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
18 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
19 must be clearly so designated before the material is disclosed or produced.
20 Designation in conformity with this Order requires:
21 (a) for information in documentary form (e.g., paper or electronic
22 documents, but excluding transcripts of depositions or other pretrial or trial proceedings),
23 that the Producing Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter
24 “CONFIDENTIAL legend”), to each page that contains protected material.
25 If needed, a Receiving Party may request that a Producing Party identify where on
26 a particular page Protected Material appears. Such requests must be reasonable and made
27 in good faith. The Producing Party shall respond to such a request within 48 hours of
28 receiving it. If a Party believes that a Producing Party is abusing the right to make
1 designations on a page-by-page, instead of on a portion-by-portion basis, the Parties shall
2 meet and confer and exercise best efforts to resolve disputes without Court intervention.
3 If the Parties are unable to agree, a Party may move the Court to require that Producing
4 Party to comply with the following language: “If only a portion or portions of the
5 material on a page qualifies for protection, the Producing Party also must clearly identify
6 the protected portion(s) (e.g., by making appropriate markings in the margins).”
7 A Party or Non-Party that makes original documents available for inspection
8 need not designate them for protection until after the inspecting Party has indicated which
9 documents it would like copied and produced. During the inspection and before the
10 designation, all of the material made available for inspection shall be deemed
11 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
12 copied and produced, the Producing Party must determine which documents, or portions
13 thereof, qualify for protection under this Order. Then, before producing the specified
14 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
15 that contains Protected Material.
16 (b) for deposition testimony, at any time during the deposition and at the
17 request of any party, the deposition transcript or a portion thereof shall be provisionally
18 marked by the reporter with “CONFIDENTIAL.” Any portions so designated shall
19 thereafter be separated and treated in accordance with the terms of this Order. Any party
20 may designate a deposition transcript or portion thereof with CONFIDENTIAL as
21 appropriate within 30 days after first receiving a formal copy of the same transcript from
22 the deposition service by informing all other parties in writing.
23 (c) for information produced in some form other than documentary and
24 for any other tangible items, that the Producing Party affix in a prominent place on the
25 exterior of the container or containers in which the information is stored the legend
26 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
27 the Producing Party, to the extent practicable, shall identify the protected portion(s).
28
1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
2 to designate qualified information or items does not, standing alone, waive the
3 Designating Party’s right to secure protection under this Order for such material. Upon
4 timely correction of a designation, the Receiving Party must make reasonable efforts to
5 assure that the material is treated in accordance with the provisions of this Order.
6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
8 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
10 process under Local Rule 37-1, et seq. Any discovery motion must strictly comply with
11 the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
12 6.3 Burden. The burden of persuasion in any such challenge proceeding shall be
13 on the Designating Party. Frivolous challenges, and those made for an improper purpose
14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose
15 the Challenging Party to sanctions. Unless the Designating Party has waived or
16 withdrawn the confidentiality designation, all parties shall continue to afford the material
17 in question the level of protection to which it is entitled under the Producing Party’s
18 designation until the Court rules on the challenge.
19 7. ACCESS TO AND USE OF PROTECTED MATERIAL
20 7.1 Basic Principles. A Receiving Party may use Protected Material that is
21 disclosed or produced by another Party or by a Non-Party in connection with this Action
22 only for prosecuting, defending, or attempting to settle this Action. Such Protected
23 Material may be disclosed only to the categories of persons and under the conditions
24 described in this Order. When the Action has been terminated, a Receiving Party must
25 comply with the provisions of section 13 below (FINAL DISPOSITION).
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
28 authorized under this Order.
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
2 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party
3 may disclose any information or item designated “CONFIDENTIAL” only to:
4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
5 well as employees of said Outside Counsel of Record to whom it is reasonably necessary
6 to disclose the information for this Action;
7 (b) the officers, directors, and employees (including House Counsel) of
8 the Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this Action and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the Court and its personnel;
13 (e) court reporters and their staff;
14 (f) professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and who have signed
16 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) the author or recipient of a document containing the information or a
18 custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, witnesses, and attorneys for witnesses, in the
20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
21 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
22 (Exhibit A); and (2) they will not be permitted to keep any confidential information
23 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
24 otherwise agreed by the Designating Party or ordered by the Court. Pages of transcribed
25 deposition testimony or exhibits to depositions that reveal Protected Material may be
26 separately bound by the court reporter and may not be disclosed to anyone except as
27 permitted under this Stipulated Protective Order; and
28
1 (i) any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
OTHER LITIGATION
4
5 If a Party is served with a subpoena or a court order issued in other litigation that
6 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 or
12 order is subject to this Protective Order. Such notification shall include a copy of this
13 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.
16 If the Designating Party timely seeks a protective order, the Party served with the
17 subpoena 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. The
20 Designating Party shall bear the burden and expense of seeking protection in that court of
21 its confidential material and nothing in these provisions should be construed as
22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
23 from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
25
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 remedies
1 and relief provided by this Order. Nothing in these provisions should be construed as
2 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 subject
5 to an agreement with the Non-Party not to produce the Non-Party’s confidential
6 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 from this Court within
16 14 days of receiving the notice and accompanying information, the Receiving Party may
17 produce the Non-Party’s confidential information responsive to the discovery request. If
18 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
19 information in its possession or control that is subject to the confidentiality agreement
20 with the Non-Party before a determination by the Court. Absent a court order to the
21 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
22 Court of its Protected Material.
23 10. 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 writing
27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
28 all unauthorized copies of the Protected Material, (c) inform the person or persons to
1 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
2 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
3 that is attached hereto as Exhibit A.
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain inadvertently
7 produced material is subject to a claim of privilege or other protection, the obligations of
8 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
9 The obligations in Federal Rule of Civil Procedure 26(b)(5)(B) also apply when a
10 Producing Party gives notice of the inadvertent disclosure of any non-public personal
11 information, other sensitive personally identifiable information (such as Social Security
12 numbers, taxpayer-identification numbers, dates of birth, home addresses, phone
13 numbers, email addresses, names of minor children, financial accounting information,
14 passport numbers and driver license numbers), or other information for which applicable
15 federal or state law requires confidential treatment. This provision is not intended to
16 modify whatever procedure may be established in an e-discovery order that provides for
17 production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d)
18 and (e), the inadvertent disclosure of attorney-client privileged or work product protected
19 material does not constitute a waiver of privilege or protection in this litigation, or in any
20 other federal or state proceeding—unless the Court makes a final determination that the
21 inadvertent disclosure constitutes a waiver. If a Party uses any material that a Party has
22 not claimed as attorney-client privileged or work product protected, and a Party thereafter
23 claims the material is privileged or protected as such, the Party using that material should
24 comply with their obligations in Federal Rule of Civil Procedure 26(b)(5)(B). In addition,
25 the material shall be treated as privileged or protected until such time as the Court finally
26 determines that the material is not attorney-client privileged or work product protected, or
27 that a waiver has occurred. Any Party claiming a waiver has occurred may bring the
28
1 matter to the Court for decision, after following the Local Rule’s requirements for
2 resolving discovery disputes.
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
5 person to seek its modification by the Court in the future.
6 12.2 Right to Assert Other Objections. By stipulating to the entry of this
7 Protective Order, no Party waives any right it otherwise would have to object to
8 disclosing or producing any information or item on any ground not addressed in this
9 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground
10 to use in evidence of any of the material covered by this Protective Order.
11 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
12 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
13 under seal pursuant to a court order authorizing the sealing of the specific Protected
14 Material at issue; good cause must be shown in the request to file under seal. If a Party’s
15 request to file Protected Material under seal is denied by the Court, then the Receiving
16 Party may file the information in the public record unless otherwise instructed by the
17 Court.
18 13. FINAL DISPOSITION
19 After the final disposition of this Action, within 60 days of a written request by the
20 Designating Party, each Receiving Party must return all Protected Material to the
21 Producing Party or destroy such material. As used in this subdivision, “all Protected
22 Material” includes all copies, abstracts, compilations, summaries, and any other format
23 reproducing or capturing any of the Protected Material. Whether the Protected Material is
24 returned or destroyed, the Receiving Party must submit a written certification to the
25 Producing Party (and, if not the same person or entity, to the Designating Party) by the
26 60-day deadline that (1) identifies (by category, where appropriate) all the Protected
27 Material that was returned or destroyed, and (2) affirms that the Receiving Party has not
28 retained any copies, abstracts, compilations, summaries or any other format reproducing
1 or capturing any of the Protected Material. Notwithstanding this provision, counsel are
2 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
3 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
4 expert reports, attorney work product, and consultant and expert work product, even if
5 such materials contain Protected Material. Any such archival copies that contain or
6 constitute Protected Material remain subject to this Protective Order as set forth in
7 Section 4 (DURATION).
8 14. VIOLATION OF ORDER
9 Any violation of this Order may be punished by any and all appropriate measures
10 including, without limitation, contempt proceedings and/or monetary sanctions.
11
12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
13 Dated: June 4, 2026 SALVATORE PRESCOTT PORTER & PORTER, PLLC
14
By: /s/ Hideaki Sano
15 Hideaki Sano
Attorney for Plaintiff John Gregory
16
17 Dated: June 4, 2026 REIF LAW GROUP, P.C.
18
By: /s/ Brandon S. Reif
19 Brandon S. Reif
Attorney for Defendant Adam DeVone
20
21 Dated: June 4, 2026 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
22
By: /s/ Winston P. Hsiao
23 Winston P. Hsiao
Attorneys for Defendants Acrisure, LLC
24 and Benefits MatchMaking, LLC
25
26
27
28
1 ATTESTATION
2 I, Winston P. Hsiao, attest that the signatories listed above, and on whose behalf
3 the filing is submitted, concur in the filing’s content and have authorized the filing.
4 /s/ Winston P. Hsiao
Winston P. Hsiao
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1 PROPOSED! ORDER
2 Having considered the papers, and finding that good cause exists, the Parties’
Stipulated Protective Order is granted.
4 IT IS SO ORDERED.
5
6] DATED: June 5 , 2026 LP
7 UNITED STATES MAGISTRATE JUDGE
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
VG
1 EXHIBIT A
2
3
4
5
6
7
8
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
WESTERN DIVISION
12
JOHN GREGORY, ) CASE NO: 2:24-cv-08661-HDV-E
)
13 Plaintiff, )
)
14 v. ) ACKNOWLEDGMENT AND
) AGREEMENT TO BE BOUND TO
15 ACRISURE, LLC, BENEFITS ) THE STIPULATED PROTECTIVE
MATCHMAKING, LLC and ADAM ) ORDER
16 DEVONE, and DOES 1 through 10, )
inclusive, )
17
Defendants. )
) Hon. Hernán D. Vera
18
)
) Magistrate Judge Charles F. Eick
19
)
) Complaint Filed: July 15, 2024
20
)
)
21
22 I, ______________________ [print or type full name], of
23 ________________________________ [print or type full address], declare under penalty
24 of perjury that I have read in its entirety and understand the Stipulated Protective Order
25 that was ordered by the United States District Court for the Central District of California
26 in Gregory v. Acrisure, LLC, et al., Case No. 2:24-cv-08661-HDV-E (C.D. Cal.). I agree
27 to comply with and to be bound by all the terms of the Stipulated Protective Order,
28 including any court-ordered amendments thereto, and I understand and acknowledge that
1 failure to so comply could expose me to sanctions and punishment in the nature of
2 contempt. I solemnly promise that I will not disclose in any manner any information or
3 item that is subject to this Stipulated Protective Order to any person or entity except in
4 strict compliance with the provisions of this Order.
5 I further agree to submit to the jurisdiction of the United States District Court for
6 the Central District of California for the purpose of enforcing the terms of this Stipulated
7 Protective Order, even if such enforcement proceedings occur after termination of this
8 action.
9 I declare under penalty of perjury under the laws of the United States of America
10 that the foregoing is true and correct.
11
12 Executed on _________.
13
14 City and State where signed: _____________________________
15
16 Printed Name: _____________________________
17
18 Signature: ____________________________
19
20
21
22
23
24
25
26
27
28