The opinion
1 FERRUZZO & FERRUZZO, LLP
A Limited Liability Partnership,
2 including Professional Corporations
3737 Birch Street, Suite 400
3 Newport Beach, California 92660
Telephone: (949) 608-6900
4 Facsimile: (949) 608-6994
5 VASKO R. MITZEV, Bar No. 213973
vmitzev@ferruzzo.com
6 TYLER J. PORTO, Bar No. 339075
tporto@ferruzzo.com
7
Daniel E. Beederman (Pro Hac Vice)
8 daniel.beederman@sfbbg.com
9 Andrew S. Johnson (Pro Hac Vice)
andrew.johnson@sfbbg.com
10 SCHOENBERG FINKEL BEEDERMAN
11 BELL GLAZER LLC
300 S. Wacker Drive, Suite 1500
12 Chicago, Illinois 60606
13 Telephone: (312) 648-2300
Facsimile: (312) 648-1212
14
Attorneys for Plaintiff
15 DALE GLENN
16 [Additional parties and counsel on next page]
17 UNITED STATES DISTRICT COURT
18 CENTRAL DISTRICT OF CALIFORNIA
19
20 DALE GLENN Case No. 8:26-CV-01555-JVS-RAO
21 Plaintiff, Assigned for All Purposes To:
Judge: James V. Selna
22 vs.
STIPULATED PROTECTIVE
23 FREUDENBERG MEDICAL, LLC, et ORDER1
al
24
Defendants. State Action Filed: April 2, 2026
25 Removal Date: June 16, 2026
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1 This Stipulated Protective Order is substantially based on the model protective order
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1 Josh Rodine, Esq.
jrodine@seyfarth.com
2 Aaron Belzer, Esq.
abelzer@seyfarth.com
3 JT Theonugraha, Esq.
jtheonugraha@seyfarth.com
4 SEYFARTH SHAW LLP
2029 Century Park East, Suite 3500
5 Los Angeles, California 90067-3021
6 Attorneys for Defendants
FREUDENBERG MEDICAL, LLC
7 FREUDENBERG MEDICAL IRELAND LTD, f/k/a VISTAMED, LTD.
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1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that the
8 protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets, customer and pricing lists and other
13 valuable research, development, commercial, financial, technical and/or proprietary
14 information for which special protection from public disclosure and from use for any
15 purpose other than prosecution of this action is warranted. Such confidential and
16 proprietary materials and information consist of, among other things, confidential
17 business or financial information, information regarding confidential business
18 practices, or other confidential research, development, or commercial information
19 (including information implicating privacy rights of third parties), information
20 otherwise generally unavailable to the public, or which may be privileged or otherwise
21 protected from disclosure under state or federal statutes, court rules, case decisions, or
22 common law. Accordingly, to expedite the flow of information, to facilitate the
23 prompt resolution of disputes over confidentiality of discovery materials, to adequately
24 protect information the parties are entitled to keep confidential, to ensure that the
25 parties are permitted reasonable necessary uses of such material in preparation for and
26 in the conduct of trial, to address their handling at the end of the litigation, and serve
27 the ends of justice, a protective order for such information is justified in this matter. It
28 is the intent of the parties that information will not be designated as confidential for
1 tactical reasons and that nothing be so designated without a good faith belief that it has
2 been maintained in a confidential, non-public manner, and there is good cause why it
3 should not be part of the public record of this case.
4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
5 The parties further acknowledge, as set forth in Section 12.3, below, that this
6 Stipulated Protective Order does not entitle them to file confidential information under
7 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
8 standards that will be applied when a party seeks permission from the court to file
9 material under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,
15 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
16 cause showing), and a specific showing of good cause or compelling reasons with
17 proper evidentiary support and legal justification, must be made with respect to
18 Protected Material that a party seeks to file under seal. The parties’ mere designation
19 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
20 submission of competent evidence by declaration, establishing that the material sought
21 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
22 constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion or trial, then
24 compelling reasons, not only good cause, for the sealing must be shown, and the relief
25 sought shall be narrowly tailored to serve the specific interest to be protected. See
26 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
27 or type of information, document, or thing sought to be filed or introduced under seal
28 in connection with a dispositive motion or trial, the party seeking protection must
1 articulate compelling reasons, supported by specific facts and legal justification, for
2 the requested sealing order. Again, competent evidence supporting the application to
3 file documents under seal must be provided by declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in its
5 entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting only
7 the confidential, privileged, or otherwise protectable portions of the document shall be
8 filed. Any application that seeks to file documents under seal in their entirety should
9 include an explanation of why redaction is not feasible.
10 2. DEFINITIONS
11 2.1 Action: this pending federal lawsuit.
12 2.2 Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
17 Statement.
18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
19 support staff).
20 2.5 Designating Party: a Party or Non-Party that designates information or
21 items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23 2.6 Disclosure or Discovery Material: all items or information, regardless of
24 the medium or manner in which it is generated, stored, or maintained (including,
25 among other things, testimony, transcripts, and tangible things) that are produced or
26 generated in disclosures or responses to discovery in this matter.
27 2.7 Expert: a person with specialized knowledge or experience in a matter
28 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
1 expert witness or as a consultant in this Action.
2 2.8 House Counsel: attorneys who are employees of a party to this Action.
3 House Counsel does not include Outside Counsel of Record or any other outside
4 counsel.
5 2.9 Non-Party: any natural person, partnership, corporation, association or
6 other legal entity not named as a Party to this action.
7 2.10 Outside Counsel of Record: attorneys who are not employees of a party
8 to this Action but are retained to represent or advise a party to this Action and have
9 appeared in this Action on behalf of that party or are affiliated with a law firm that has
10 appeared on behalf of that party, and includes support staff.
11 2.11 Party: any party to this Action, including all of its officers, directors,
12 employees, consultants, retained experts, and Outside Counsel of Record (and their
13 support staffs).
14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
15 Discovery Material in this Action.
16 2.13 Professional Vendors: persons or entities that provide litigation support
17 services (e.g., photocopying, videotaping, translating, preparing exhibits or
18 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
19 their employees and subcontractors.
20 2.14 Protected Material: any Disclosure or Discovery Material that is
21 designated as “CONFIDENTIAL.”
22 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
23 from a Producing Party.
24 3. SCOPE
25 The protections conferred by this Stipulation and Order cover not only Protected
26 Material (as defined above), but also (1) any information copied or extracted from
27 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
28 Material; and (3) any testimony, conversations, or presentations by Parties or their
1 Counsel that might reveal Protected Material.
2 Any use of Protected Material at trial shall be governed by the orders of the trial
3 judge. This Order does not govern the use of Protected Material at trial.
4 4. DURATION
5 Once a case proceeds to trial, information that was designated as
6 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
7 as an exhibit at trial becomes public and will be presumptively available to all members
8 of the public, including the press, unless compelling reasons supported by specific
9 factual findings to proceed otherwise are made to the trial judge in advance of the trial.
10 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
11 documents produced in discovery from “compelling reasons” standard when merits-
12 related documents are part of court record). Accordingly, the terms of this protective
13 order do not extend beyond the commencement of the trial.
14 5. DESIGNATING PROTECTED MATERIAL
15 5.1 Exercise of Restraint and Care in Designating Material for Protection.
16 Each Party or Non-Party that designates information or items for protection under this
17 Order must take care to limit any such designation to specific material that qualifies
18 under the appropriate standards. The Designating Party must designate for protection
19 only those parts of material, documents, items or oral or written communications that
20 qualify so that other portions of the material, documents, items or communications for
21 which protection is not warranted are not swept unjustifiably within the ambit of this
22 Order.
23 Mass, indiscriminate or routinized designations are prohibited. Designations
24 that are shown to be clearly unjustified or that have been made for an improper purpose
25 (e.g., to unnecessarily encumber the case development process or to impose
26 unnecessary expenses and burdens on other parties) may expose the Designating Party
27 to sanctions.
28 If it comes to a Designating Party’s attention that information or items that it
1 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
3 5.2 Manner and Timing of Designations. Except as otherwise provided in
4 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
5 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
6 under this Order must be clearly so designated before the material is disclosed or
7 produced.
8 Designation in conformity with this Order requires:
9 (a) for information in documentary form (e.g., paper or electronic documents,
10 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
11 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
12 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
13 portion of the material on a page qualifies for protection, the Producing Party also must
14 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
15 margins).
16 A Party or Non-Party that makes original documents available for
17 inspection need not designate them for protection until after the inspecting Party has
18 indicated which documents it would like copied and produced. During the inspection
19 and before the designation, all of the material made available for inspection shall be
20 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
21 it wants copied and produced, the Producing Party must determine which documents,
22 or portions thereof, qualify for protection under this Order. Then, before producing
23 the specified documents, the Producing Party must affix the “CONFIDENTIAL
24 legend” to each page that contains Protected Material. If only a portion of the material
25 on a page qualifies for protection, the Producing Party also must clearly identify the
26 protected portion(s) (e.g., by making appropriate markings in the margins).
27 (b) for testimony given in depositions that the Designating Party identifies the
28 Disclosure or Discovery Material on the record, before the close of the deposition all
1 protected testimony.
2 (c) for information produced in some form other than documentary and for any
3 other tangible items, that the Producing Party affix in a prominent place on the exterior
4 of the container or containers in which the information is stored the legend
5 “CONFIDENTIAL.” If only a portion or portions of the information warrants
6 protection, the Producing Party, to the extent practicable, shall identify the protected
7 portion(s).
8 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
9 failure to designate qualified information or items does not, standing alone, waive the
10 Designating Party’s right to secure protection under this Order for such material. Upon
11 timely correction of a designation, the Receiving Party must make reasonable efforts
12 to assure that the material is treated in accordance with the provisions of this Order.
13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
15 designation of confidentiality at any time that is consistent with the Court’s Scheduling
16 Order.
17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
18 resolution process under Local Rule 37.1 et seq.
19 6.3 The burden of persuasion in any such challenge proceeding shall be on
20 the Designating Party. Frivolous challenges, and those made for an improper purpose
21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
22 expose the Challenging Party to sanctions. Unless the Designating Party has waived
23 or withdrawn the confidentiality designation, all parties shall continue to afford the
24 material in question the level of protection to which it is entitled under the Producing
25 Party’s designation until the Court rules on the challenge.
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that is
28 disclosed or produced by another Party or by a Non-Party in connection with this
1 Action only for prosecuting, defending or attempting to settle this Action. Such
2 Protected Material may be disclosed only to the categories of persons and under the
3 conditions described in this Order. When the Action has been terminated, a Receiving
4 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
5 Protected Material must be stored and maintained by a Receiving Party at a
6 location and in a secure manner that ensures that access is limited to the persons
7 authorized under this Order.
8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
9 otherwise ordered by the court or permitted in writing by the Designating Party, a
10 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
11 only to:
12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
13 employees of said Outside Counsel of Record to whom it is reasonably necessary to
14 disclose the information for this Action;
15 (b) the officers, directors, and employees (including House Counsel) of the
16 Receiving Party to whom disclosure is reasonably necessary for this Action;
17 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure
18 is reasonably necessary for this Action and who have signed the “Acknowledgment
19 and Agreement to Be Bound” (Exhibit A);
20 (d) the court and its personnel;
21 (e) court reporters and their staff;
22 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
23 to whom disclosure is reasonably necessary for this Action and who have signed the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) the author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, witnesses, and attorneys for witnesses, in the
28 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
1 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
2 not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
4 by the Designating Party or ordered by the court. Pages of transcribed deposition
5 testimony or exhibits to depositions that reveal Protected Material may be separately
6 bound by the court reporter and may not be disclosed to anyone except as permitted
7 under this Stipulated Protective Order; and
8 (i) any mediator or settlement officer, and their supporting personnel, mutually
9 agreed upon by any of the parties engaged in settlement discussions.
10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
11 OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL,” that Party must:
15 (a) promptly notify in writing the Designating Party. Such notification shall
16 include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or order to
18 issue in the other litigation that some or all of the material covered by the subpoena or
19 order is subject to this Protective Order. Such notification shall include a copy of this
20 Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be pursued by
22 the Designating Party whose Protected Material may be affected.
23 If the Designating Party timely seeks a protective order, the Party served with
24 the subpoena or court order shall not produce any information designated in this action
25 as “CONFIDENTIAL” before a determination by the court from which the subpoena
26 or order issued, unless the Party has obtained the Designating Party’s permission. The
27 Designating Party shall bear the burden and expense of seeking protection in that court
28 of its confidential material and nothing in these provisions should be construed as
1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
2 directive from another court.
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by a Non-
6 Party in this Action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the remedies
8 and relief provided by this Order. Nothing in these provisions should be construed as
9 prohibiting a Non-Party from seeking additional protections.
10 (b) In the event that a Party is required, by a valid discovery request, to produce
11 a Non-Party’s confidential information in its possession, and the Party is subject to an
12 agreement with the Non-Party not to produce the Non-Party’s confidential
13 information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the Non-Party that some
15 or all of the information requested is subject to a confidentiality agreement with a Non-
16 Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
18 Order in this Action, the relevant discovery request(s), and a reasonably specific
19 description of the information requested; and
20 (3) make the information requested available for inspection by the Non-Party,
21 if requested.
22 (c) If the Non-Party fails to seek a protective order from this court within 14
23 days of receiving the notice and accompanying information, the Receiving Party may
24 produce the Non-Party’s confidential information responsive to the discovery request.
25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
26 any information in its possession or control that is subject to the confidentiality
27 agreement with the Non-Party before a determination by the court. Absent a court
28 order to the contrary, the Non-Party shall bear the burden and expense of seeking
1 protection in this court of its Protected Material.
2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 Protected Material to any person or in any circumstance not authorized under this
5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
6 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
7 all unauthorized copies of the Protected Material, (c) inform the person or persons to
8 whom unauthorized disclosures were made of all the terms of this Order, and (d)
9 request such person or persons to execute the “Acknowledgment and Agreement to Be
10 Bound” that is attached hereto as Exhibit A.
11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted to
22 the court.
23 12. MISCELLANEOUS
24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
25 person to seek its modification by the Court in the future.
26 12.2 Right to Assert Other Objections. By stipulating to the entry of this
27 Protective Order, no Party waives any right it otherwise would have to object to
28 disclosing or producing any information or item on any ground not addressed in this
1 Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 ground to use in evidence of any of the material covered by this Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
5 only be filed under seal pursuant to a court order authorizing the sealing of the specific
6 Protected Material at issue. If a Party’s request to file Protected Material under seal is
7 denied by the court, then the Receiving Party may file the information in the public
8 record unless otherwise instructed by the court.
9 13. FINAL DISPOSITION
10 After the final disposition of this Action, as defined in paragraph 4, within 60
11 days of a written request by the Designating Party, each Receiving Party must return
12 all Protected Material to the Producing Party or destroy such material. As used in this
13 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
14 summaries, and any other format reproducing or capturing any of the Protected
15 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
16 must submit a written certification to the Producing Party (and, if not the same person
17 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
18 category, where appropriate) all the Protected Material that was returned or destroyed
19 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
20 compilations, summaries or any other format reproducing or capturing any of the
21 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
22 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
23 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
24 attorney work product, and consultant and expert work product, even if such materials
25 contain Protected Material. Any such archival copies that contain or constitute
26 Protected Material remain subject to this Protective Order as set forth in Section 4
27 (DURATION).
28 ///
1 14. VIOLATION
2 Any violation of this Order may be punished by appropriate measures including,
3 without limitation, contempt proceedings and/or monetary sanctions.
4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6 Dated: August 26, 2026 SCHOENBERG FINKEL BEEDERMAN
BELL GLAZER LLC,
7 TRIAL ATTORNEYS
8
9 By: /s/ Tyler J. Porto
DANIEL E. BEEDERMAN
10 ANDREW S. JOHNSON
11 FERRUZZO & FERRUZZO,
LLP
12 VASKO R. MITZEV
TYLER J. PORTO
13
Attorneys for Plaintiff
14 DALE GLENN
15
Dated: August 26, 2026 SEYFARTH SHAW LLP
16
17
By: /s/ Aaron Belzer
18 JOSH RODINE
AARON BELZER
19 JT THEONUGRAHA
Attorneys for Defendants
20 FREUDENBERG MEDICAL, LLC
FREUDENBERG MEDICAL
21 IRELAND LTD, f/k/a VISTAMED,
LTD.
22
ATTESTATION
23
Pursuant to L.R. 5-4.3.4(a)(2)(i), the undersigned hereby attests that all other
24
signatories listed, and on whose behalf this filing is submitted, concur in this filing’s
25
content and have authorized this filing.
26
/s/ Tyler J. Porto
27
Tyler J. Porto
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1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 ATED: _ 08/26/2026
° ON. OZELLA A. OLIVER
nited States Magistrate Judge
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GH
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury that
6 I have read in its entirety and understand the Stipulated Protective Order that was
7 issued by the United States District Court for the Central District of California on
8 [date] in the case of Dale Glenn v. Freudenberg Medical,
9 LLC, Case No. 8:26-CV-011555-JVS-RAO. I agree to comply with and to be bound
10 by all the terms of this Stipulated Protective Order and I understand and acknowledge
11 that failure to so comply could expose me to sanctions and punishment in the nature
12 of contempt. I solemnly promise that I will not disclose in any manner any information
13 or item that is subject to this Stipulated Protective Order to any person or entity except
14 in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action. I hereby appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25 Printed name: _______________________________
26
27 Signature: __________________________________
28