# Cynthia Romano v. Boston Scientific Corporation

> District Court, C.D. California · February 23, 2022

URL: https://www.frixlaw.com/law-library/cases/9979240

## Case

- **Court:** District Court, C.D. California
- **Decided:** February 23, 2022
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

Case 2:21-cv-09863-GW-AS Document 16 Filed 02/23/22 Page 1 of 15 Page ID #:163

1 MORGAN, LEWIS & BOCKIUS LLP
Barbara J. Miller, Bar No. 167223
2 Matthew M. Arnold, Bar No. 341862
600 Anton Boulevard, Suite 1800
3 Costa Mesa, CA 92626-7653
Tel: +1.714.830.0600
4 Fax: +1.714.830.0700
barbara.miller@morganlewis.com
5 sarah.allen@morganlewis.com
6 Attorneys for Defendants
BOSTON SCIENTIFIC CORPORATION and
7 BOSTON SCIENTIFIC
NEUROMODULATION CORPORATION,
8
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
12
CYNTHIA ROMANO, an individual, Case No. 2:21-cv-09863-GW(ASx)
13
Plaintiff,
14
vs. PROTECTIVE ORDER
15
BOSTON SCIENTIFIC
16 CORPORATION, a Delaware
corporation; BOSTON SCIENTIFIC
17 NEUROMODULATION
CORPORATION, a Delaware
18 corporation; and DOES 1 through 20, Complaint Filed: Oct. 28, 2021
inclusive,
19
Defendants.
20
21
22
23
24
25
26
27
28
MORGAN,LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
Case 2:21-cv-09863-GW-AS Document 16 Filed 02/23/22 Page 2 of 15 Page ID #:164

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
4 disclosure and from use for any purpose other than prosecuting this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 enter the following Stipulated Protective Order. The parties acknowledge that this
7 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
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles. The parties further acknowledge, as set forth
11 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
12 file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a
14 party seeks permission from the court to file material under seal.
15 B. GOOD CAUSE STATEMENT
16 Plaintiff worked as a Director of National Accounts for Defendant Boston
17 Scientific Neuromodulation Corporation and, based on the nature of her position
18 and duties, Plaintiff had access to and worked with documents and information that
19 are trade secrets and other valuable technical and/or proprietary information of
20 Defendants. This action is likely to involve trade secrets, customer and pricing lists
21 and other valuable research, development, commercial, financial, technical and/or
22 proprietary information for which special protection from public disclosure and
23 from use for any purpose other than prosecution of this action is warranted. Such
24 confidential and proprietary materials and information consist of, among other
25 things, confidential business or financial information, information regarding
26 confidential business practices, or other confidential research, development, or
27 commercial information (including information implicating privacy rights of third
28 parties), information otherwise generally unavailable to the public, or which may be
MORGAN,LEWIS &
BOCKIUS LLP 2
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
Case 2:21-cv-09863-GW-AS Document 16 Filed 02/23/22 Page 3 of 15 Page ID #:165

1 privileged or otherwise protected from disclosure under state or federal statutes,
2 court rules, case decisions, or common law. Accordingly, to expedite the flow of
3 information, to facilitate the prompt resolution of disputes over confidentiality of
4 discovery materials, to adequately protect information the parties are entitled to
5 keep confidential, to ensure that the parties are permitted reasonable necessary uses
6 of such material in preparation for and in the conduct of trial, to address their
7 handling at the end of the litigation, and serve the ends of justice, a protective order
8 for such information is justified in this matter. It is the intent of the parties that
9 information will not be designated as confidential for tactical reasons and that
10 nothing be so designated without a good faith belief that it has been maintained in a
11 confidential, non-public manner, and there is good cause why it should not be part
12 of the public record of this case.
13 2. DEFINITIONS
14 2.1 Action: Cynthia Romano v. Boston Scientific Corporation, et al., United
15 States District Court, Central District of California, Case No. 2:21-cv-09863 GW
16 (ASx).
17 2.2 Challenging Party: a Party or Non-Party that challenges the designation
18 of information or items under this Order.
19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
20 how it is generated, stored or maintained) or tangible things that qualify for
21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
22 the Good Cause Statement.
23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
24 support staff).
25 2.5 Designating Party: a Party or Non-Party that designates information or
26 items that it produces in disclosures or in responses to discovery as
27 “CONFIDENTIAL.”
28 2.6 Disclosure or Discovery Material: all items or information, regardless of
MORGAN,LEWIS &
BOCKIUS LLP 3
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 the medium or manner in which it is generated, stored, or maintained (including,
2 among other things, testimony, transcripts, and tangible things), that are produced
3 or generated in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as
6 an expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action.
8 House Counsel does not include Outside Counsel of Record or any other outside
9 counsel.
10 2.9 Non-Party: any natural person, partnership, corporation, association, or
11 other legal entity not named as a Party to this action.
12 2.10 Outside Counsel of Record: attorneys who are not employees of a party
13 to this Action but are retained to represent or advise a party to this Action and have
14 appeared in this Action on behalf of that party or are affiliated with a law firm
15 which has appeared on behalf of that party, and includes support staff.
16 2.11 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of Record (and their
18 support staffs).
19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
20 Discovery Material in this Action.
21 2.13 Professional Vendors: persons or entities that provide litigation support
22 services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 demonstrations, and organizing, storing, or retrieving data in any form or medium)
24 and their employees and subcontractors.
25 2.14 Protected Material: any Disclosure or Discovery Material that is
26 designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
28 from a Producing Party.
MORGAN,LEWIS &
BOCKIUS LLP 4
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
Case 2:21-cv-09863-GW-AS Document 16 Filed 02/23/22 Page 5 of 15 Page ID #:167

1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9 4. DURATION
10 Once a case proceeds to trial, all of the information that was designated as
11 confidential or maintained pursuant to this protective order becomes public and will
12 be presumptively available to all members of the public, including the press, unless
13 compelling reasons supported by specific factual findings to proceed otherwise are
14 made to the trial judge in advance of the trial. See Kamakana v. City and County of
15 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
16 showing for sealing documents produced in discovery from “compelling reasons”
17 standard when merits-related documents are part of court record). Accordingly, the
18 terms of this protective order do not extend beyond the commencement of the trial.
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. Mass, indiscriminate, or routinized
28 designations are prohibited. Designations that are shown to be clearly unjustified or
MORGAN,LEWIS &
BOCKIUS LLP 5
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 that have been made for an improper purpose (e.g., to unnecessarily encumber
2 the case development process or to impose unnecessary expenses and burdens on
3 other parties) may expose the Designating Party to sanctions. If it comes to a
4 Designating Party’s attention that information or items that it designated for
5 protection do not qualify for protection, that Designating Party must promptly
6 notify all other Parties that it is withdrawing the inapplicable 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 documents,
14 but excluding transcripts of depositions or other pretrial or trial proceedings), that
15 the Producing Party affix at a minimum, the legend “CONFIDENTIAL”
16 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
17 material. If only a portion or portions of the material on a page qualifies for
18 protection, the Producing Party also must clearly identify the protected portion(s)
19 (e.g., by making appropriate markings in the margins).
20 A Party or Non-Party that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine
26 which documents, or portions thereof, qualify for protection under this Order. Then,
27 before producing the specified documents, the Producing Party must affix the
28 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
MORGAN,LEWIS &
BOCKIUS LLP 6
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 portion or portions of the material on a page qualifies for protection, the
2 Producing Party also must clearly identify the protected portion(s) (e.g., by making
3 appropriate markings in the margins).
4 (b) for testimony given in depositions that the Designating Party identify the
5 Disclosure or Discovery Material on the record, before the close of the deposition
6 all protected testimony.
7 (c) for information produced in some form other than documentary and for
8 any other tangible items, that the Producing Party affix in a prominent place on the
9 exterior of the container or containers in which the information is stored the legend
10 “CONFIDENTIAL.” If only a portion or portions of the information warrants
11 protection, the Producing Party, to the extent practicable, shall identify the
12 protected portion(s).
13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
14 failure to designate qualified information or items does not, standing alone, waive
15 the Designating Party’s right to secure protection under this Order for such
16 material. Upon timely correction of a designation, the Receiving Party must make
17 reasonable efforts to assure that the material is treated in accordance with the
18 provisions of this Order.
19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
21 designation of confidentiality at any time that is consistent with the Court’s
22 Scheduling Order.
23 6.2 Meet and Confer. The Challenging Party shall initiate the informal
24 dispute resolution process set forth in the Court's Procedures and Schedules. see
25 http://www.cacd.uscourts.gov/honorable-alka-sagar
26 6.3 The burden of persuasion in any such challenge proceeding shall be on
27 the Designating Party. Frivolous challenges, and those made for an improper
28 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
MORGAN,LEWIS &
BOCKIUS LLP 7
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 parties) may expose the Challenging Party to sanctions. Unless the Designating
2 Party has waived or withdrawn the confidentiality designation, all parties shall
3 continue to afford the material in question the level of protection to which it is
4 entitled under the Producing Party’s designation until the Court rules on the
5 challenge.
6 7. ACCESS TO AND USE OF PROTECTED MATERIAL
7 7.1 Basic Principles. A Receiving Party may use Protected Material that is
8 disclosed or produced by another Party or by a Non-Party in connection with this
9 Action only for prosecuting, defending, or attempting to settle this Action. Such
10 Protected Material may be disclosed only to the categories of persons and under the
11 conditions described in this Order. When the Action has been terminated, a
12 Receiving Party must comply with the provisions of section 13 below (FINAL
13 DISPOSITION). Protected Material must be stored and maintained by a Receiving
14 Party at a location and in a secure manner that ensures that access is limited to the
15 persons authorized under this Order.
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
17 otherwise ordered by the court or permitted in writing by the Designating Party, a
18 Receiving Party may disclose any information or item designated
19 “CONFIDENTIAL” only to:
20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
21 as employees of said Outside Counsel of Record to whom it is reasonably necessary
22 to disclose the information for this Action;
23 (b) the officers, directors, and employees (including House Counsel) of the
24 Receiving Party to whom disclosure is reasonably necessary for this Action;
25 (c) Experts (as defined in this Order) of the Receiving Party to whom
26 disclosure is reasonably necessary for this Action and who have signed the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
28 (d) the court and its personnel;
MORGAN,LEWIS &
BOCKIUS LLP 8
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 (e) court reporters and their staff;
2 (f) professional jury or trial consultants, mock jurors, and Professional
3 Vendors to whom disclosure is reasonably necessary for this Action and who have
4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (g) the author or recipient of a document containing the information or a
6 custodian or other person who otherwise possessed or knew the information;
7 (h) during their depositions, witnesses, and attorneys for witnesses, in the
8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
9 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
10 will not be permitted to keep any confidential information unless they sign the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
12 agreed by the Designating Party or ordered by the court. Pages of transcribed
13 deposition testimony or exhibits to depositions that reveal Protected Material may
14 be separately bound by the court reporter and may not be disclosed to anyone
15 except as permitted under this Stipulated Protective Order; and
16 (i) any mediator or settlement officer, and their supporting personnel,
17 mutually agreed upon by any of the parties engaged in settlement discussions.
18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
19 PRODUCED IN OTHER LITIGATION
20 If a Party is served with a subpoena or a court order issued in other litigation
21 that compels disclosure of any information or items designated in this Action as
22 “CONFIDENTIAL,” that Party must:
23 (a) promptly notify in writing the Designating Party. Such notification shall
24 include a copy of the subpoena or court order;
25 (b) promptly notify in writing the party who caused the subpoena or order to
26 issue in the other litigation that some or all of the material covered by the subpoena
27 or order is subject to this Protective Order. Such notification shall include a copy of
28 this Stipulated Protective Order; and
MORGAN,LEWIS &
BOCKIUS LLP 9
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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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. If the
3 Designating Party timely seeks a protective order, the Party served with the
4 subpoena or court order shall not produce any information designated in this action
5 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
12 PRODUCED IN THIS LITIGATION
13 (a) The terms of this Order are applicable to information produced by a Non-
14 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-Party that
23 some or all of the information requested is subject to a confidentiality agreement
24 with a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
26 Order in this Action, the relevant discovery request(s), and a reasonably specific
27 description of the information requested; and
28 (3) make the information requested available for inspection by the Non-
MORGAN,LEWIS &
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ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 Party, if requested.
2 (c) If the Non-Party fails to seek a protective order from this court within 14
3 days of receiving the notice and accompanying information, the Receiving Party
4 may produce the Non-Party’s confidential information responsive to the discovery
5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
6 not produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the court.
8 Absent a court order to the contrary, the Non-Party shall bear the burden and
9 expense of seeking protection in this court of its Protected 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
15 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
16 person or persons to whom unauthorized disclosures were made of all the terms of
17 this Order, and (d) request such person or persons to execute the “Acknowledgment
18 and Agreement to Be Bound” that is attached hereto as Exhibit A.
19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20 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
23 protection, the obligations of the Receiving Parties are those set forth in Federal
24 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
25 whatever procedure may be established in an e-discovery order that provides for
26 production without prior privilege review. Pursuant to Federal Rule of Evidence
27 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
28 of a communication or information covered by the attorney-client privilege or work
MORGAN,LEWIS &
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ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
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1 product protection, the parties may incorporate their agreement in the stipulated
2 protective order submitted to the court.
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
9 this Stipulated Protective Order. Similarly, no Party waives any right to object on
10 any ground to use in evidence of any of the material covered by this Protective
11 Order.
12 12.3 Filing Protected Material. A Party that seeks to file under seal any
13 Protected Material must comply with Civil Local Rule 79-5. Protected Material
14 may only be filed under seal pursuant to a court order authorizing the sealing of the
15 specific Protected Material at issue. If a Party's request to file Protected Material
16 under seal is denied by the court, then the Receiving Party may file the information
17 in the public record unless otherwise instructed by the court.
18 13. FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 4, within 60
20 days of a written request by the Designating Party, each Receiving Party must
21 return all Protected Material to the Producing Party or destroy such material. As
22 used in this subdivision, “all Protected Material” includes all copies, abstracts,
23 compilations, summaries, and any other format reproducing or capturing any of the
24 Protected Material. Whether the Protected Material is returned or destroyed, the
25 Receiving Party must submit a written certification to the Producing Party (and, if
26 not the same person or entity, to the Designating Party) by the 60 day deadline that
27 (1) identifies (by category, where appropriate) all the Protected Material that was
28 returned or destroyed and (2)affirms that the Receiving Party has not retained any
MORGAN,LEWIS &
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ATTORNEYS AT LAW
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1 copies, abstracts, compilations, summaries or any other format reproducing or
2 capturing any of the Protected Material. Notwithstanding this provision, Counsel
3 are entitled to retain an archival copy of all pleadings, motion papers, trial,
4 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
5 and trial exhibits, expert reports, attorney work product, and consultant and expert
6 work product, even if such materials contain Protected Material. Any such archival
7 copies that contain or constitute Protected Material remain subject to this Protective
8 Order as set forth in Section 4 (DURATION).
9 14. Any violation of this Order may be punished by any and all appropriate
10 measures including, without limitation, contempt proceedings and/or monetary
11 sanctions.
12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
13 DATED ___F_e_b_r_u_ar_y_ _2_2_, _2_0_2_2_______
14 ___/s_/ _D_a_w__n_ K__n_ep__p_er_______________
15 KNEPPER LAW PC
16 Dawn Knepper
17 Attorneys for Plaintiff
18
19 DATED: __F_e_b_r_u_a_ry_ _2_2_, _2_0_2_2________
20 __/_s_/ _B_a_r_b_a_ra_ _J_. _M__il_le_r______________
21 MORGAN, LEWIS & BOCKIUS LLP
22 Barbara J. Miller
23 Attorneys for Defendant
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ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER
Case 2:21-cv-09863-GW-AS Document16 Filed 02/23/22 Page 14o0f15 Page ID #:176

1 FILER’S ATTESTATION
2 Pursuant to Local Rule 5-4.3.4 regarding signatures, I attest that concurrence
3 || in the filing of the document has been obtained from the other signatory listed above.
5 Dated: February 22, 2022 MORGAN, LEWIS & BOCKIUS LLP
By _ /s/ Barbara J. Miller
7 Barbara J. Miller
10
i FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
'? | DATED: February 23, 2022
13 /s / Sagar
Honorable Alka Sagar
1S United States Magistrate Judge
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MGOCKUSLLP
Aron ara 14
STIPULATED PROTECTIVE ORDER

Case 2:21-cv-09863-GW-AS Document 16 Filed 02/23/22 Page 15 of 15 Page ID #:177

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of Cynthia Romano v. Boston Scientific Corporation et al.,
8 Case No. 2:21-cv-09863-GW(ASx). I agree to comply with and to be bound by all
9 the terms of this Stipulated Protective Order and I understand and acknowledge
10 that failure to so comply could expose me to sanctions and punishment in the
11 nature of contempt. I solemnly promise that I will not disclose in any manner any
12 information or item that is subject to this Stipulated Protective Order to any person
13 or entity except in strict compliance with the provisions of this Order. I further
14 agree to submit to the jurisdiction of the United States District Court for the
15 Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint __________________________ [print
18 or type full name] of _______________________________________ [print or
19 type full address and telephone number] as my California agent for service of
20 process in connection with this action or any proceedings related to enforcement of
21 this Stipulated Protective Order. Date:
22 ______________________________________
23 City and State where sworn and signed: ________________________________
24 Printed name: _______________________________
25 Signature: __________________________________
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MORGAN,LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA STIPULATED PROTECTIVE ORDER

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9979240. Public record. Not legal advice.