Opinion

Opinion

Court
District Court, E.D. California
Filed
May 19, 2026
Cited by
0 cases

The opinion

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

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11 | ROSENDIN ELECTRIC, INC., a California} Case No. 2:25-cv-03357-TLN-CKD

corporation,

12 Judge:

13 Plaintiff, JOINT STIPULATED PROTECTIVE

ORDER & ORDER

14 VS.

15 | AMERICAN WIRE GROUP, LLC, a

Florida Limited Liability Company;

16 | POLYCAB INDIA, LTD., a Public Limited

Company; and DOES 1-25, inclusive,

17

18 Defendants.

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25

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27 \///

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1 PURPOSES AND LIMITATIONS

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

3 | confidential, proprietary, or private information for which special protection from public

4 | disclosure and from use for any purpose other than prosecuting this litigation may be

5 | warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the

6 | following Stipulated Protective Order. The parties acknowledge that this Order does not

7 | confer blanket protections on all disclosures or responses to discovery and that the

8 | protection it affords from public disclosure and use extends only to the limited information

9 | or items that are entitled to confidential treatment under the applicable legal principles.

10 | The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated

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

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

13 | be applied when a party seeks permission from the court to file material under seal.

2. DEFINITIONS

15 2.1 Challenging Party: A Party or Non-Party that challenges the designation of

16 | information or items under this Order.

17 2.2 “CONFIDENTIAL” Information or Items: Information (regardless of how it

18 | 1s generated, stored or maintained) or tangible things that qualify for protection under

19 | Federal Rule of Civil Procedure 26€.

20 2.3. Counsel (without qualifier): Outside Counsel of Record and House Counsel

21 | (as well as their support staff).

22 2.4 Designating Party: A Party or Non-Party that designates information or

23 | items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or

24 | “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY.”

25 2.5 Disclosure or Discovery Material: All items or information, regardless of the

26 | medium or manner in which it is generated, stored, or maintained (including, among other

27 | things, testimony, transcripts, and tangible things), that are produced or generated in

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1 | disclosures or responses to discovery in this matter.

2 2.6 Expert: A person with specialized knowledge or experience in a matter

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

4 | expert witness or as a consultant in this action.

5 2.7 “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY” Information

6 | or Items: Extremely sensitive “Confidential Information or Items,” disclosure of which to

7 | another Party or Non-Party would create a substantial risk of serious harm that cannot be

8 | avoided by less restrictive means.

9 2.8 In-House Counsel: Attorneys who are employees of a party to this action.

10 | In-House Counsel does not include Outside Counsel of Record or any other outside

11 | counsel.

12 2.9 Non-Party: Any natural person, partnership, corporation, association, or

13 | other legal entity not named as a Party to this action.

14 2.10 Outside Counsel of Record: Attorneys who are not employees of a party to

15 | this action but are retained to represent or advise a party to this action and have appeared

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

17 | behalf of that party.

18 2.11 Party: Any party to this action, including all of its officers, directors,

19 | employees, consultants, retained experts, and Outside Counsel of Record (and their support

20 | staffs).

21 2.12 Producing Party: A Party or Non-Party that produces Disclosure or

22 | Discovery Material tn this action.

23 2.13 Professional Vendors: Persons or entities that provide litigation support

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

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

26 | their employees and subcontractors.

27 2.14 Protected Material: Any Disclosure or Discovery Material that is designated

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1 | as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY.”

2 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material

3 | from a Producing Party.

3. SCOPE

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

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

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

8 | Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel

9 | that might reveal Protected Material. However, the protections conferred by this

10 | Stipulation and Order do not cover the following information: (a) any information that is in

11 | the public domain at the time of disclosure to a Receiving Party or becomes part of the

12 | public domain after its disclosure to a Receiving Party as a result of publication not

13 | involving a violation of this Order, including becoming part of the public record through

14 | trial or otherwise; and (b) any information known to the Receiving Party prior to the

15 | disclosure or obtained by the Receiving Party after the disclosure from a source who

16 | obtained the information lawfully and under no obligation of confidentiality to the

17 | Designating Party. Any use of Protected Material at trial shall be governed by a separate

18 | agreement or order.

19 4. DURATION

20 Even after final disposition of this litigation, the confidentiality obligations □□□□□□□

21 | by this Order shall remain in effect until a Designating Party agrees otherwise in writing or

22 |a court order otherwise directs. Final disposition shall be deemed to be the later of

23 | (1) dismissal of all claims and defenses in this action, with or without prejudice; and

24 (2) final judgment herein after the completion and exhaustion of all appeals, rehearings,

25 | remands, trials, or reviews of this action, including the time limits for filing any motions or

26 | applications for extension of time pursuant to applicable law.

2715. DESIGNATING PROTECTED MATERIAL

28 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

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1 | Party or Non-Party that designates information or items for protection under this Order

2 | must take care to limit any such designation to specific material that qualifies under the

3 | appropriate standards. The Designating Party must designate for protection only those

4 | parts of material, documents, items, or oral or written communications that qualify — so

5 | that other portions of the material, documents, items, or communications for which

6 || protection is not warranted are not swept unjustifiably within the ambit of this Order.

7 Mass, indiscriminate, or routinized designations are prohibited. Designations that

8 | are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

9 | to unnecessarily encumber or retard the case development process or to impose

10 | unnecessary expenses and burdens on other parties) expose the Designating Party to

11 sanctions.

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

13 | designated for protection do not qualify for protection, that Designating Party must

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

15 5.2 Manner and Timing of Designations. Except as otherwise provided in this

16 | Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

17 | ordered, Disclosure or Discovery Material that qualifies for protection under this Order

18 | must be clearly so designated before the material is disclosed or produced.

19 Designation in conformity with this Order requires:

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

21 | documents, but excluding transcripts of depositions or other pretrial or trial proceedings),

22 | that the Producing Party affix the legend “CONFIDENTIAL” or “HIGHLY

23 | CONFIDENTIAL — ATTORNEYS’ EYES ONLY” to each page that contains protected

24 | material. If only a portion or portions of the material on a page qualifies for protection, the

25 | Producing Party also must clearly identify the protected portion(s) (e.g., by making

26 | appropriate markings in the margins).

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

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

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

2 | before the designation, all of the material made available for inspection shall be deemed

3 | “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY.” After the inspecting Party

4 | has identified the documents it wants copied and produced, the Producing Party must

5 | determine which documents, or portions thereof, qualify for protection under this Order.

6 | Then, before producing the specified documents, the Producing Party must affix the

7 | “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY”

8 | legend, as appropriate, to each page that contains Protected Material. If only a portion or

9 | portions of the material on a page qualifies for protection, the Producing Party also must

10 | clearly identify the protected portion(s) (e.g., by making appropriate markings in the

11 | margins).

12 (b) testimony given in deposition or in other pretrial or trial

13 | proceedings, that the Designating Party identify on the record, before the close of the

14 | deposition, hearing, or other proceeding, all protected testimony.

15 (c) For information produced in some form other than documentary and

16 | for any other tangible items, that the Producing Party affix in a prominent place on the

17 | exterior of the container or containers in which the information or item is stored the legend

18 | “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY.” If

19 | only a portion or portions of the information or item warrant protection, the Producing

20 | Party, to the extent practicable, shall identify the protected portion(s).

21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

22 | to designate qualified information or items does not, standing alone, waive the Designating

23 | Party’s right to secure protection under this Order for such material. Upon timely

24 | correction of a designation, the Receiving Party must make reasonable efforts to assure

25 | that the material 1s treated in accordance with the provisions of this Order.

26 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation

28 | of confidentiality at any time. Unless a prompt challenge to a Designating Party’s

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1 | confidentiality designation is necessary to avoid foreseeable, substantial unfairness,

2 | unnecessary economic burdens, or a significant disruption or delay of the litigation, a Party

3 | does not waive its right to challenge a confidentiality designation by electing not to mount

4 | a challenge promptly after the original designation is disclosed.

5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

6 || process by providing written notice of each designation it is challenging and describing the

7 | basis for each challenge. To avoid ambiguity as to whether a challenge has been made, the

8 | written notice must recite that the challenge to confidentiality is being made in accordance

9 | with this specific paragraph of the Protective Order. The parties shall attempt to resolve

10 | each challenge in good faith and must begin the process by conferring directly (in voice to

11 | voice dialogue; other forms of communication are not sufficient) within 14 days of the date

12 | of service of notice. In conferring, the Challenging Party must explain the basis for its

13 | belief that the confidentiality designation was not proper and must give the Designating

14 | Party an opportunity to review the designated material, to reconsider the circumstances,

15 | and, 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 has

17 | engaged in this meet and confer process first or establishes that the Designating Party is

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

19 6.3. Judicial Intervention. If the Parties cannot resolve a challenge without court

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

21 | under Civil Local Rule 230 within 21 days of the initial notice of challenge or within 14

22 | days of the parties agreeing that the meet and confer process will not resolve their dispute,

23 | whichever is earlier. Each such motion must be accompanied by a competent declaration

24 | affirming that the movant has complied with the meet and confer requirements imposed in

25 | the preceding paragraph. Failure by the Designating Party to make such a motion including

26 | the required declaration within 21 days (or 14 days, if applicable) shall automatically

27 | waive the confidentiality designation for each challenged designation. In addition, the

28 | Challenging Party may file a motion challenging a confidentiality designation at any time

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1 1f there 1s good cause for doing so, including a challenge to the designation of a deposition

2 | transcript or any portions thereof. Any motion brought pursuant to this provision must be

3 | accompanied by a competent declaration affirming that the movant has complied with the

4 | meet and confer requirements imposed by the preceding paragraph.

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

6 | Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to

7 | harass or impose unnecessary expenses and burdens on other parties) may expose the

8 | Challenging Party to sanctions. Unless the Designating Party has waived the

9 | confidentiality designation by failing to file a motion to retain confidentiality as described

10 | above, all parties shall continue to afford the material in question the level of protection to

11 | which it is entitled under the Producing Party’s designation until the court rules on the

12 | challenge.

13 |7. ACCESS TO AND USE OF PROTECTED MATERIAL

14 7.1. Basic Principles. A Receiving Party may use Protected Material that is

15 | disclosed or produced by another Party or by a Non-Party in connection with this case only

16 | for prosecuting, defending, or attempting to settle this litigation. Such Protected Material

17 | may be disclosed only to the categories of persons and under the conditions described in

18 | this Order. When the litigation has been terminated, a Receiving Party must comply with

19 | the provisions of section 13 below (FINAL DISPOSITION).

20 Protected Material must be stored and maintained by a Receiving Party at a location

21 | and in a secure manner that ensures that access is limited to the persons authorized under

22 | this Order.

23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

25 | may disclose any information or item designated “CONFIDENTIAL” only to:

26 (a) The Receiving Party’s Outside Counsel of Record in this action, as

27 | well as employees of said Outside Counsel of Record to whom it is reasonably necessary

28 | to disclose the information for this litigation and who have signed the “Acknowledgment

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1 | and Agreement to Be Bound” that is attached hereto as Exhibit A;

2 (b) The officers, directors, and employees (including House Counsel) of

3 | the Receiving Party to whom disclosure is reasonably necessary for this litigation and who

4 | have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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

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

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

8 (d) The court and its personnel;

9 (e) Court reporters and their staff, professional jury or trial consultants,

10 | mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this

11 | litigation and who have signed the “Acknowledgment and Agreement to Be Bound”

12 | (Exhibit A);

13 (f) During their depositions, witnesses in the action to whom disclosure is

14 | reasonably necessary and who have signed the “Acknowledgment and Agreement to Be

15 | Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the

16 | court. Pages of transcribed deposition testimony or exhibits to depositions that reveal

17 | Protected Material must be separately bound by the court reporter and may not be disclosed

18 | to anyone except as permitted under this Stipulated Protective Order.

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

20 | custodian or other person who otherwise possessed or knew the information.

2118. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

22 OTHER LITIGATION

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

24 | compels disclosure of any information or items designated in this action as

25 | “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY,”

26 | that Party must:

27 (a) Promptly notify in writing the Designating Party. Such notification

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1 | shall include a copy of the subpoena or court order;

2 (b) Promptly notify in writing the party who caused the subpoena or order

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

4 | order is subject to this Protective Order. Such notification shall include a copy of this

5 | Stipulated Protective Order; and

6 (c) | Cooperate with respect to all reasonable procedures sought to be

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

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

9 | subpoena or court order shall not produce any information designated in this action as

10 | “CONFIDENTIAL” or HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY”

11 | before a determination by the court from which the subpoena or order issued, unless the

12 | Party has obtained the Designating Party’s permission. The Designating Party shall bear

13 | the burden and expense of seeking protect€on in that court of its confidential material —

14 | and nothing in these provisions should be construed as authorizing or encouraging a

15 | Receiving Party in this action to disobey a lawful directive from another court.

16 }9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN

17 THIS LITIGATION

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

19 | Non-Party in this action and designated as “CONFIDENTIAL” or “HIGHLY

20 | CONFIDENTIAL — ATTORNEYS’ EYES ONLY.” Such information produced by Non-

21 | Parties in connection with this litigation is protected by the remedies and relief provided by

22 | this Order. Nothing in these provisions should be construed as prohibiting a Non-Party

23 | from seeking additional protections.

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

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

26 | to an agreement with the Non-Party not to produce the Non-Party’s confidential

27 | information, then the Party shall:

28 (1) Promptly notify in writing the Requesting Party and the Non-

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

2 | with a Non-Party;

3 (2) Promptly provide the Non-Party with a copy of the Stipulated

4 | Protective Order in this litigation, the relevant discovery request(s), and a reasonably

5 | specific description of the information requested; and

6 (3) | Make the information requested available for inspection by the

7 | Non-Party.

8 (c) Ifthe Non-Party fails to object or seek a protective order from this

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

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

11 | request. If the Non-Party timely seeks a protective order, the Receiving Party shall not

12 | produce any information in its possession or control that is subject to the confidentiality

13 | agreement with the Non-Party before a determination by the court. Absent a court order to

14 | the contrary, the Non-Party shall bear the burden and expense of seeking protection in this

15 | court of its Protected Material.

16]10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

19 | Sttpulated Protective Order, the Receiving Party must immediately (a) notify in writing the

20 | Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

21 | unauthorized copies of the Protected Material, (c) inform the person or persons to whom

22 | unauthorized disclosures were made of all the terms of this Order, and (d) request such

23 | person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is

24 | attached hereto as Exhibit A.

25]}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

26 PROTECTED MATERIAL

27 When a Producing Party gives notice to Receiving Parties that certain inadvertently

28 | produced material is subject to a claim of privilege or other protection, the obligations of

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] | the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).

2 | This provision is not intended to modify whatever procedure may be established in an e-

3 | discovery order that provides for production without prior privilege review. Pursuant to

4 | Federal Rule of Evidence 502(d) and €, insofar as the parties reach an agreement on the

5 | effect of disclosure of a communication or information covered by the attorney-client

6 | privilege or work product protection, the parties may incorporate their agreement in the

7 | stipulated protective order submitted to the court.

MISCELLANEOUS

9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any persor

10 | to seek its modification by the court in the future.

1] 12.2 Right to Assert Other Objections. By stipulating to the entry of this

12 | Protective Order no Party waives any right it otherwise would have to object to disclosing

13 | or producing any information or item on any ground not addressed in this Stipulated

14 | Protective Order. Similarly, no Party waives any right to object on any ground to use in

15 evidence of any of the material covered by this Protective Order.

16 12.3 Filing Protected Material. Without written permission from the Designating

17 | Party or a court order secured after appropriate notice to all interested persons, a Party may

18 | not file in the public record in this action any Protected Material. A Party that seeks to file

19 under seal any Protected Material must comply with Civil Local Rule 141. Protected

20 | Material may only be filed under seal pursuant to a court order authorizing the sealing of

21 || the specific Protected Material at issue. Pursuant to Civil Local Rule 141, a sealing order

22 | will issue only upon a request establishing that the Protected Material at issue 1s privileged,

23 | protectable as a trade secret, or otherwise entitled to protection under the law. Ifa

24 | Receiving Party’s request to file Protected Material under seal pursuant to Civil Local Rule

25 | 141 is denied by the court, then the Receiving Party may file the information in the public

26 | record unless otherwise instructed by the court.

13. FINAL DISPOSITION

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

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1 | each Receiving Party must return all Protected Material to the Producing Party or destroy

2 | such material. As used in this subdivision, “all Protected Material” includes all copies,

3 | abstracts, compilations, summaries, and any other format reproducing or capturing any of

4 | the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

5 | archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

6 | legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

7 | work product, and consultant and expert work product, even if such materials contain

8 | Protected Material. Any such archival copies that contain or constitute Protected Material

9 | remain subject to this Protective Order indefinitely as set forth in Section 4.

10

11 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

12

13

DATED:

14 RUTAN & TUCKER, LLP

William T. Eliopoulos

15 Mary Christine Brady

16 ROSENDIN ELECTRIC, INC.

17

18 DATED:

FOX SWIBEL LEVIN & CARROLL LLP

19 Edward Keidan

AMERICAN WIRE GROUP, LLC

20

21

DATED:

22 RALLS GRUBER & NIECE

3 John Foust

POLYCAB INDIA, LTD.

24

95

96 |l!/

07 Hil

/II/

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1 ORDER

3 The Court has reviewed the parties’ stipulated protective order. The stipulation

comports with the relevant authorities and the court’s applicable local rule. See L.R. 141.1.

‘ The Court APPROVES the protective order, subject to the following clarifications. The

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

6 over enforcement of the terms of any protective order filed in that action.” L.R. □□□□□□□

7 see also, e.g., MD Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 (E.D. Cal., Feb.

8 03, 2017) (noting that courts in the district generally do not retain jurisdiction for disputes

9 | concerning protective orders after closure of the case). Thus, the Court will not retain

10 | jurisdiction over this protective order once the case is closed.

11 Further, this Stipulated Protective Order does not entitle a party to file

12 | confidential information under seal. Local Rule 141 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. I f a party’s request to file confidential material under seal

15 is denied by the Court, then the party may file the information in the public record unless

16 otherwise instructed by the Court. ee

7 Dated: May 19, 2026 Card p- it a ip f a

18 CAROLYN K. DELANEY

UNITED STATES MAGISTRATE JUDGE

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3/1, [print or type full name], of

4 | [print or type full address], declare under penalty of perjury that I have read in its entirety

5 | and understand the Stipulated Protective Order that was issued by the United States

6 | District Court for the Eastern District of California on [date] in the case of

7 | [insert formal name of the case and the number and initials assigned to it by the

8 | court]. I agree to comply with and to be bound by all the terms of this Stipulated

9 | Protective Order and I understand and acknowledge that failure to so comply could expose

10 | me to sanctions and punishment in the nature of contempt. I solemnly promise that I will

11 | not disclose in any manner any information or item that is subject to this Stipulated

12 | Protective Order to any person or entity except in strict compliance with the provisions of

13 | this Order.

14 | I further agree to submit to the jurisdiction of the United States District Court for the

15 | Eastern District of California for the purpose of enforcing the terms of this Stipulated

16 | Protective Order, even if such enforcement proceedings occur after termination of this

17 | action.

18 | I hereby appoint [print or type full name] of

19 [print or type full address and telephone

20 | number] as my California agent for service of process in connection with this action or any

21 | proceedings related to enforcement of this Stipulated Protective Order.

22

Date:

23

City and State where sworn and signed:

25 | Printed name:

26

27 Signature:

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