Opinion

Kym Torrence v. Wells Fargo Bank, N.A.

Court: District Court, C.D. California
Filed: Aug 9, 2019
Authority: More cited than 16.3%

How later courts described this case

recognizing trade secrets and 9 confidential business information as legitimate categories of information subject to 10 protection

Written by the judges who cited it.

The opinion

1 SHEPPARD, MULLIN, RICHTER SCHERWIN LAW FIRM

& HAMPTON LLP

2 Thomas R. Kaufman, (SBN 177936) Jeremy D. Scherwin, Esq. (SBN 274632)

tkaufman@sheppardmullin.com jscherwin@scherwinlaw.com

3 Paul Berkowitz, (SBN 251077) 1055 West 7th St., PH 33

4 p 1b 9e 0r 1k Aow veit nz u@ e s oh fe tp hp ea Srd tam rsu ,l l Sin u. ic teo m 1600 Los Angeles, California 90017

Telephone: 213.297.8777

Los Angeles, California 90067

5 Telephone: 310.228.3700 Facsimile: 213.318.0512

Facsimile: 310.228.3701

7 Y.Douglas Yang, (SBN 307550) Attorneys for Plaintiff

dyang@sheppardmullin.com

333 South Hope Street, 43rd Floor KYM TORRENCE

Los Angeles, California 90071

9 Telephone: 213.620.1780

Facsimile: 213.620.1398

Attorneys for Defendant

11 WELLS FARGO BANK, N.A.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

KYM TORRENCE, an individual, Case No. 2:19-cv-03202-DMG (ASx)

18 Plaintiff,

PROTECTIVE ORDER

19 v.

20 WELLS FARGO BANK, N.A., a Complaint Filed: April 2, 2019

business entity, exact form unknown;

21 DOES 1-25, inclusive

22 Defendants.

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1 TO THE HONORABLE COURT, ALL PARTIES AND THEIR

2 ATTORNEYS OF RECORD:

3 In order to facilitate discovery in the above-caption matter, Plaintiff Kym

4 Torrence (“Plaintiff”) and Defendant Wells Fargo Bank, N.A. (“Defendant”)

5 (collectively, “the parties”) hereby agree to the following Jointly Stipulated

6 Protective Order concerning the CONFIDENTIAL treatment of certain documents

7 and information.

8 1. PURPOSES AND LIMITATIONS

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

10 production of confidential, proprietary, or private information for which special

11 protection from public disclosure and from use for any purpose other than

12 prosecuting this litigation may be warranted. Accordingly, the parties hereby

13 stipulate to and petition the court to enter the following Stipulated Protective Order.

14 The parties acknowledge that this Order does not confer blanket protections on all

15 disclosures or responses to discovery and that the protection it affords from public

16 disclosure and use extends only to the limited information or items that are entitled

17 to confidential treatment under the applicable legal principles. The parties further

18 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

19 Order does not entitle them to file confidential information under seal; Civil Local

20 Rule 79-5 sets forth the procedures that must be followed and the standards that will

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

22 It is the intent of the parties that information will not be designated as

23 confidential for tactical reasons and that nothing be so designated without a good

24 faith belief that it has been maintained in a confidential, non-public manner, and

25 there is good cause why it should not be part of the public record of this case.

26 1.1 Good Cause For a Protective Order

27 Good cause exists for a Protective Order because both Plaintiff and

28 Defendant’s document productions disclose information relating to (1) private bank

customer information, such as account numbers and photographs of bank

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1 customers; (2) Plaintiff’s Personally Identifiable Information (“PII”); (3) the PII of

2 non-party employees of Defendant; (4) the confidential business practices of

3 Defendant, which Defendant safeguards as a means to ensure competitiveness in

4 the financial industry; and (5) Defendant’s confidential investigation practices

5 relating to lost, misplaced, and stolen monies. See Harmon v. City of Santa Clara,

6 323 F.R.D. 617, 623 (N.D. Cal. 2018) (identifying privacy interests, among others

7 when considering existence of good cause); Nutratech, Inc. v. Syntech (SSPF) Int'l,

8 Inc., 242 F.R.D. 552, 554 (C.D. Cal. 2007) (recognizing trade secrets and

9 confidential business information as legitimate categories of information subject to

10 protection).

11 2. DEFINITIONS

12 2.1 Challenging Party: a Party or Non-Party that challenges the

13 designation of information or items under this Order.

14 2.2 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

17 2.3 Counsel (without qualifier): Outside Counsel of Record and House

18 Counsel (as well as their support staff).

19 2.4 Designating Party: a Party or Non-Party that designates information or

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

21 “CONFIDENTIAL.”

22 2.5 Disclosure or Discovery Material: all items or information, regardless

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

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

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

26 2.6 Expert: a person with specialized knowledge or experience in a matter

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

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

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1 2.7 House Counsel: attorneys who are employees of a party to this action.

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

3 counsel.

4 2.8 Non-Party: any natural person, partnership, corporation, association,

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

6 2.9 Outside Counsel of Record: attorneys who are not employees of a party

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

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

9 has appeared on behalf of that party.

10 2.10 Party: any party to this action, including all of its officers, directors,

11 employees, consultants, retained experts, and Outside Counsel of Record (and their

12 support staffs).

13 2.11 Producing Party: a Party or Non-Party that produces Disclosure or

14 Discovery Material in this action.

15 2.12 Professional Vendors: persons or entities that provide litigation

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

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

18 and their employees and subcontractors.

19 2.13 Protected Material: any Disclosure or Discovery Material that is

20 designated as “CONFIDENTIAL.”

21 2.14 Receiving Party: a Party that receives Disclosure or Discovery

22 Material from a Producing Party.

23 3. SCOPE

24 The protections conferred by this Stipulation and Order cover not only

25 Protected Material (as defined above), but also (1) any information copied or

26 extracted from Protected Material; (2) all copies, excerpts, summaries, or

27 compilations of Protected Material; and (3) any testimony, conversations, or

28 presentations by Parties or their Counsel that might reveal Protected Material.

However, the protections conferred by this Stipulation and Order do not cover the

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1 following information: (a) any information that is in the public domain at the time

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

3 disclosure to a Receiving Party as a result of publication not involving a violation

4 of this Order, including becoming part of the public record through trial or

5 otherwise; and (b) any information known to the Receiving Party prior to the

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

7 obtained the information lawfully and under no obligation of confidentiality to the

8 Designating Party. Any use of Protected Material at trial shall be governed by a

9 separate agreement or order.

10 4. DURATION

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

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

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

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

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

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

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

18 pursuant to applicable law.

19 5. DESIGNATING PROTECTED MATERIAL

20 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

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

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

27 unjustifiably within the ambit of this Order.

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

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

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

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

3 Designating Party to sanctions.

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

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

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

7 5.2 Manner and Timing of Designations. Except as otherwise provided in this

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

9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

10 under this Order must be clearly so designated before the material is disclosed or

11 produced.

12 Designation in conformity with this Order requires:

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

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

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

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

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

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

19 A Party or Non-Party that makes original documents or materials

20 available for inspection need not designate them for protection until after the

21 inspecting Party has indicated which material it would like copied and produced.

22 During the inspection and before the designation, all of the material made available

23 for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has

24 identified the documents it wants copied and produced, the Producing Party must

25 determine which documents, or portions thereof, qualify for protection under this

26 Order. Then, before producing the specified documents, the Producing Party must

27 affix the “CONFIDENTIAL” legend to each page that contains Protected Material.

28 If only a portion or portions of the material on a page qualifies for protection, the

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

2 appropriate markings in the margins).

3 (b) for testimony given in deposition or in other pretrial or trial

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

5 the deposition, hearing, or other proceeding, all protected testimony.

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

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

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

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

10 item warrant protection, the Producing Party, to the extent practicable, shall identify

11 the protected portion(s).

12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

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

17 Order.

18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

20 designation of confidentiality at any time that is consistent with the Court’s

21 Scheduling Order. Unless a prompt challenge to a Designating Party’s

22 confidentiality designation is necessary to avoid foreseeable, substantial unfairness,

23 unnecessary economic burdens, or a significant disruption or delay of the litigation,

24 a Party does not waive its right to challenge a confidentiality designation by electing

25 not to mount a challenge promptly after the original designation is disclosed.

26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

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

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

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

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

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

3 and must begin the process by conferring directly (in voice to voice dialogue; other

4 forms of communication are not sufficient) within 14 days of the date of service of

5 notice. In conferring, the Challenging Party must explain the basis for its belief that

6 the confidentiality designation was not proper and must give the Designating Party

7 an opportunity to review the designated material, to reconsider the circumstances,

8 and, if no change in designation is offered, to explain the basis for the chosen

9 designation. A Challenging Party may proceed to the next stage of the challenge

10 process only if it has engaged in this meet and confer process first or establishes

11 that the Designating Party is unwilling to participate in the meet and confer process

12 in a timely manner.

13 6.3 Judicial Intervention. If the Parties cannot resolve a challenge

14 without court intervention, the Designating Party shall file and serve a motion to

15 retain confidentiality under Civil Local Rules 7-4 through 7-8 (and in compliance

16 with Civil Local Rule 79-5, if applicable) within 21 days of the initial notice of

17 challenge or within 14 days of the parties agreeing that the meet and confer process

18 will not resolve their dispute, whichever is earlier. Each such motion must be

19 accompanied by a competent declaration affirming that the movant has complied

20 with the meet and confer requirements imposed in the preceding paragraph. Failure

21 by the Designating Party to make such a motion including the required declaration

22 within 21 days (or 14 days, if applicable) shall automatically waive the

23 confidentiality designation for each challenged designation. In addition, the

24 Challenging Party may file a motion challenging a confidentiality designation at

25 any time if there is good cause for doing so, including a challenge to the designation

26 of a deposition transcript or any portions thereof. Any motion brought pursuant to

27 this provision must be accompanied by a competent declaration affirming that the

28 movant has complied with the meet and confer requirements imposed by the

preceding paragraph.

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

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

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

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

5 or withdrawn the confidentiality designation, all parties shall continue to afford the

6 material in question the level of protection to which it is entitled under the

7 Producing Party’s designation until the Court rules on the challenge.

8 7. ACCESS TO AND USE OF PROTECTED MATERIAL

9 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

14 Receiving Party must comply with the provisions of section 13 below (FINAL

15 DISPOSITION).

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

17 location and in a secure manner that ensures that access is limited to the persons

18 authorized under this Order.

19 7.2 Disclosure of “CONFIDENTIAL” Information or Items.

20 Unless otherwise ordered by the court or permitted in writing by the

21 Designating Party, a Receiving Party may disclose any information or item

22 designated “CONFIDENTIAL” only to:

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

24 well as employees of said Outside Counsel of Record to whom it is reasonably

25 necessary to disclose the information for this litigation;

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

27 the Receiving Party;

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

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

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

4 (d) the court and its personnel;

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

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

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

8 Bound” (Exhibit A); during their depositions, witnesses in the action to whom

9 disclosure is reasonably necessary and who have signed the “Acknowledgment and

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

11 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to

12 depositions that reveal Protected Material must be separately bound by the court

13 reporter and may not be disclosed to anyone except as permitted under this

14 Stipulated Protective Order.

15 (f) the author or recipient of a document containing the information or

16 a custodian or other person who otherwise possessed or knew the information.

17 (g) any mediator or settlement officer, and their supporting personnel,

18 mutually agreed upon by any of the parties engaged in settlement discussions.

19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

IN OTHER LITIGATION

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

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

23 “CONFIDENTIAL,” that Party must:

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

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

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

27 order to issue in the other litigation that some or all of the material covered by the

28 subpoena or order is subject to this Protective Order. Such notification shall include

a copy of this Stipulated Protective Order; and

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

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

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

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

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

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

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

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

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

10 to disobey a lawful directive from another court.

11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

21 confidential information, then the Party shall:

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

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

24 agreement with a Non-Party;

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

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

27 reasonably specific description of the information requested; and

28 (3) make the information requested available for inspection by the

Non-Party.

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1 (c) If the Non-Party fails to object or seek a protective order from this

2 court within 14 days of receiving the notice and accompanying information, the

3 Receiving Party may produce the Non-Party’s confidential information responsive

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

5 Receiving Party shall not produce any information in its possession or control that

6 is subject to the confidentiality agreement with the Non-Party before a

7 determination by the court. Absent a court order to the contrary, the Non-Party shall

8 bear the burden and expense of seeking protection in this court of its Protected

9 Material.

10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

16 or persons to whom unauthorized disclosures were made of all the terms of this

17 Order, and (d) request such person or persons to execute the “Acknowledgment and

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

19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

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

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

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

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

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

26 privilege review. Pursuant to Federal Rule of Evidence502(d) and (e), insofar as the

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

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

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

2 to the court.

3 12. MISCELLANEOUS

4 12.1 Right to Further Relief. Nothing in this Order abridges the right of

5 any 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

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

11 12.3 Filing Protected Material. Without written permission from the

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

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

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

15 Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court

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

17 Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that

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

19 entitled to protection under the law. If a Receiving Party's request to file Protected

20 Material under seal pursuant to Civil Local Rule 79-5.2.2 is denied by the court, then

21 the Receiving Party may file the information in the public record pursuant to Civil

22 Local Rule 79-5.2.2(b)(ii) unless otherwise instructed by the Court.

23 13. FINAL DISPOSITION

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

25 paragraph 4, each Receiving Party must return all Protected Material to the

26 Producing Party or destroy such material. As used in this subdivision, “all Protected

27 Material” includes all copies, abstracts, compilations, summaries, and any other

28 format reproducing or capturing any of the Protected Material. Whether the

Protected Material is returned or destroyed, the Receiving Party must submit a

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1 written certification to the Producing Party (and, if not the same person or entity, to

2 the Designating Party) by the 60 day deadline that (1) identifies (by category, where

3 appropriate) all the Protected Material that was returned or destroyed and (2)

4 affirms that the Receiving Party has not retained any copies, abstracts, compilations,

5 summaries or any other format reproducing or capturing any of the Protected

6 Material. Notwithstanding this provision, Counsel are entitled to retain an archival

7 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

8 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

9 work product, and consultant and expert work product, even if such materials

10 contain Protected Material. Any such archival copies that contain or constitute

11 Protected Material remain subject to this Protective Order as set forth in Section 4

12 (DURATION).

14. SANCTIONS FOR VIOLATION OF ORDER: Any violation of this Order

may be punished by all appropriate measures, including, without limitation,

contempt proceedings and/or monetary sanctions. (See Judge Sagar’s Procedures,

available on the Court’s website: www.cacd.uscourts.gov; “Stipulated Protective

Orders.”)

19 //

20 //

23 //

27 //

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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: August 7, 2019 SHEPPARD, MULLIN, RICHTER & HAMPTON

LLP

By /s/

6 THOMAS R. KAUFMAN

PAUL BERKOWITZ

7 Y. DOUGLAS YANG

Attorneys for Defendant

8 WELLS FARGO BANK, N.A.

Dated: August 7, 2019 SCHERWIN LAW FIRM

By /s/

11 JEREMY SCHERWIN

Attorneys for Plaintiff

12 KYM TORRENCE

15 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

17 Dated: August 9, 2019 ______________/_ s_ _/ _________________

18 THE HONORABLE ALKA SAGAR

UNITED STATES MAGISTRATE JUDGE

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1 EXHIBIT A

2 CONFIDENTIALITY AGREEMENT

3 I, ______________________, hereby declare:

5 1. My address is

_____________________________________________. My telephone number is

(_____) ______-____________.

2. I have read in its entirety and understand the Stipulation and

Protective Order that was issued by the United States District Court for the Central

District of California in the case of Kym Torrence v. Wells Fargo Bank, N.A., et

al., United States District Court, Central District of California, Case No. 2:19-cv-

03202-DMG-AS. I hereby agree to comply with and to be bound by all the terms of

this Stipulation and Protective Order.

3. I understand that the Stipulation and Protective Order requires that I

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

17 Stipulation and Protective Order to any person or entity except in strict compliance

18 with the provisions of this Stipulation and Protective Order.

19 4. I consent to the jurisdiction of the United States District Court for the

20 Central District of California for the purpose of enforcing the terms of this

21 Stipulation and Protective Order, even if such enforcement proceedings occur after

22 termination of this action.

23 I declare under penalty of perjury that the foregoing is true and correct.

Executed on _____________, 2019 at _____________________________ .

_________________________________

27 Signature

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SMRH:4832-7101-3279.1 -17-

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.