# Linda Matlow v. Hive Media Group, LLC

> District Court, C.D. California · May 18, 2022

URL: https://www.frixlaw.com/law-library/cases/9980011

## Case

- **Court:** District Court, C.D. California
- **Decided:** May 18, 2022
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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UNITED STATES DISTRICT COURT
7
CENTRAL DISTRICT OF CALIFORNIA
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9
LINDA MATLOW
Case No. 2:21-cv-08754-VAP-PD
10 Plaintiff,
11 v. STIPULATED PROTECTIVE
ORDER1
12
HIVE MEDIA GROUP, LLC, et al.,
13 Defendant.
14
15
1. A. PURPOSES AND LIMITATIONS
16
Discovery in this action is likely to involve production of confidential,
17
proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may be
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warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
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the following Stipulated Protective Order. The parties acknowledge that this Order
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does not confer blanket protections on all disclosures or responses to discovery and
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that the protection it affords from public disclosure and use extends only to the
23
limited information or items that are entitled to confidential treatment under the
24
applicable legal principles.
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1 This Stipulated Protective Order is substantially based on the model protective
28 order provided under Magistrate Judge Patricia Donahue’s Procedures.
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1 B. GOOD CAUSE STATEMENT
2 This action is likely to involve valuable research, development, commercial,
3 financial, technical and/or proprietary information for which special protection from
4 public disclosure and from use for any purpose other than prosecution of this action
5 is warranted. Such confidential and proprietary materials and information consist of,
6 among other things: confidential business or financial informationincluding revenue
7 statements, pricing, payments, and invoices; corporate organization documents;
8 information regarding confidential business practices including internal policies and
9 practices; drafts, notes, reports, instructions, disclosuresandother writings; contracts
10 with third parties; other confidential research, development, or commercial
11 information (including information implicating privacy rights of third parties);
12 information otherwise generally unavailable to the public; orinformationwhich may
13 be privileged or otherwise protected from disclosure under state or federal statutes,
14 court rules, case decisions, or common law.
15 Accordingly, to expedite the flow of information, to facilitate the prompt
16 resolution of disputes over confidentiality of discovery materials, to adequately
17 protect information the parties are entitled to keep confidential, to ensure that the
18 parties are permitted reasonable necessary uses of such material in preparation for
19 and in the conduct of trial, to address their handling at the end of the litigation, and
20 serve the ends of justice, a protective order for such information is justified in this
21 matter. It is the intent of the parties that information will not be designated as
22 confidential for tactical reasons and that nothing be so designated without a good
23 faith belief that it has been maintained in a confidential, non-public manner, and
24 there is good cause why it should not be part of the public record of this case. This
25 also includes (1) any information copied or extracted from the Confidential
26 information; (2) copies, excerpts, summaries or compilations of Confidential
27 information; and (3) any testimony, conversations, or presentations that are
28 reasonably likely to reveal Confidential information.
2
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1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
2 The parties further acknowledge, as set forth in Section 12.3, below, that this
3 Stipulated Protective Order does not entitle them to file confidential information
4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
5 the standards that will be applied when a party seeks permission from the court to
6 file material under seal.
7 There is a strong presumption that the public has a right of access to judicial
8 proceedings and records in civil cases. In connection with non-dispositive motions,
9 good cause must be shown to support a filing under seal. See Kamakana v. City and
10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
12 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
13 good cause showing), and a specific showing of good cause or compelling reasons
14 with proper evidentiary support and legal justification, must be made with respect to
15 Protected Material that a party seeks to file under seal. The parties’ mere designation
16 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the
17 submission of competent evidence by declaration, establishing that the material
18 sought to be filed under seal qualifies as confidential, privileged, or otherwise
19 protectable—constitute good cause.
20 Further, if a party requests sealing related to a dispositive motion or trial, then
21 compelling reasons, not only good cause, for the sealing must be shown, and the
22 relief sought shall be narrowly tailored to serve the specific interest to be protected.
23 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each
24 item or type of information, document, or thing sought to be filed or introduced under
25 seal in connection with a dispositive motion or trial, the party seeking protection
26 must articulate compelling reasons, supported by specific facts and legal
27 justification, for the requested sealing order. Again, competent evidence supporting
28 the application to file documents under seal must be provided by declaration.
3
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1 Any document that is not confidential, privileged, or otherwise protectable in
2 its entirety will not be filed under seal if the confidential portions can be redacted. If
3 documents can be redacted, then a redacted version for public viewing, omitting only
4 the confidential, privileged, or otherwise protectable portions of the document, shall
5 be filed. Any application that seeks to file documents under seal in their entirety
6 should include an explanation of why redaction is not feasible.
7 2. DEFINITIONS
8 2.1 Action: this pending federal law suit, Case No. 2:21-cv-08754-
9 VAP-PD
10 2.2 Challenging Party: a Party or Non-Party that challenges
11 the designation of information or items under this Order.
12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
13 how it is generated, stored or maintained) or tangible things that qualify for
14 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
15 Good Cause Statement. This also includes (1) any information copied or extracted
16 from the Confidential information; (2) copies, excerpts, summaries or compilations
17 of Confidential information; and (3) any testimony, conversations, or presentations
18 that are reasonably likely to reveal Confidential information. References to
19 “CONFIDENTIAL” information or items in this Protective Order shall also include
20 information or items designated “HIGHLY CONFIDENTIAL – ATTORNEYS’
21 EYES ONLY,” unless stated otherwise.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 their support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or
25 items that it produces in disclosures or in responses to discovery as
26 “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless
28 of the medium or manner in which it is generated, stored, or maintained (including,
4
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1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery in thismatter.
3 2.7 Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association, or
10 other legal entity not named as a Party to thisaction.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm which
14 has appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
28
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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
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FINAL DISPOSITION of the action is defined as the conclusion of any
11
appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
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has run. Except as set forth below, the terms of this protective order apply through
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FINAL DISPOSITION of the action. The parties may stipulate that they will be
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contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
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but will have to file a separate action for enforcement of the agreement once all
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proceedings in this case are complete.
17
Once a case proceeds to trial, information that was designated as
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CONFIDENTIAL or maintained pursuant to this protective order used or introduced
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as an exhibit at trial becomes public and will be presumptively available to all
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members of the public, including the press, unless compelling reasons supported by
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specific factual findings to proceed otherwise are made to the trial judge in advance
22
of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
23
showing for sealing documents produced in discovery from “compelling reasons”
24
standard when merits-related documents are part of court record). Accordingly, for
25
such materials, the terms of this protective order do not extend beyond the
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commencement of the trial.
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1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection under
4 this Order must take care to limit any such designation to specific material that
5 qualifies under the appropriate standards. The Designating Party must designate for
6 protection only those parts of material, documents, items, or oral or written
7 communications that qualify so that other portions of the material, documents, items,
8 or communications for which protection is not warranted are not swept unjustifiably
9 within the ambit of this Order.
10 Mass, indiscriminate, or routinized designations are prohibited. Designations
11 that are shown to be clearly unjustified or that have been made for an improper
12 purpose (e.g., to unnecessarily encumber the case development process or to impose
13 unnecessary expenses and burdens on other parties) may expose the Designating
14 Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 5.2 Manner and Timing of Designations. Except as otherwise provided in
19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
21 under this Order must be clearly so designated before the material is disclosed or
22 produced.
23 Designation in conformity with this Order requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or trial
26 proceedings), that the Producing Party affix at a minimum, the legend
27 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
28 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains
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1 protected material. If only a portion of the material on a page qualifies for protection,
2 the Producing Party also must clearly identify the protected portion(s) (e.g., by
3 making appropriate markings in themargins).
4 A Party or Non-Party that makes original documents available for inspection
5 need not designate them for protection until after the inspecting Party has indicated
6 which documents it would like copied and produced. During the inspection and
7 before the designation, all of the material made available for inspection shall be
8 deemed “CONFIDENTIAL” (not “HIGHLY CONFIDENTIAL – ATTORNEYS’
9 EYES ONLY”). After the inspecting Party has identified the documents it wants
10 copied and produced, the Producing Party must determine which documents, or
11 portions thereof, qualify for protection under this Order. Then, before producing the
12 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
13 to each page that contains Protected Material. If only a portion of the material on a
14 page qualifies for protection, the Producing Party also must clearly identify the
15 protected portion(s) (e.g., by making appropriate markings in the margins).
16 (b) for testimony given in depositions that the Designating Party identifies
17 the Disclosure or Discovery Material on the record, before the close of the deposition
18 all protected testimony. Any Party also may designate information disclosed at a
19 deposition as “CONFIDENTIAL” (or “HIGHLY CONFIDENTIAL –
20 ATTORNEYS’ EYES ONLY”) by notifying all Parties in writing, not later than 30
21 days after receipt of the transcript, of the specific pages and lines of the transcript that
22 should be treated thereafter as “CONFIDENTIAL.” All deposition transcripts shall
23 be treated as “CONFIDENTIAL” (not “HIGHLY CONFIDENTIAL –
24 ATTORNEYS’ EYES ONLY”) for a period of 30 days after initial receipt of the
25 transcript.
26 (c) for information produced in some form other than documentary and for
27 any other tangible items, that the Producing Party affix in a prominent place on the
28 exterior of the container or containers in which the information is stored the
8
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1 “CONFIDENTIAL legend.” If only a portion or portions of the information warrants
2 protection, the Producing Party, to the extent practicable, shall identify the protected
3 portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
5 failure to designate qualified information or items does not, standing alone, waive
6 the Designating Party’s right to secure protection under this Order for such material.
7 Upon timely correction of a designation, the Receiving Party must make reasonable
8 efforts to assure that the material is treated in accordance with the provisions of this
9 Order.
10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
12 designation of confidentiality at any time that is consistent with the Court’s
13 Scheduling Order.
14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
15 resolution process under Local Rule 37.1 et seq.
16 6.3 The burden of persuasion in any such challenge proceeding shall be on
17 the Designating Party. Frivolous challenges, and those made for an improper purpose
18 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
19 expose the Challenging Party to sanctions. Unless the Designating Party has waived
20 or withdrawn the confidentiality designation, all parties shall continue to afford the
21 material in question the level of protection to which it is entitled under the Producing
22 Party’s designation until the Court rules on the challenge.
23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24
7.1 Basic Principles. A Receiving Party may use Protected Material that is
25
disclosed or produced by another Party or by a Non-Party in connection with this
26
Action only for prosecuting, defending, or attempting to settle this Action. Such
27
Protected Material may be disclosed only to the categories of persons and under the
28
9
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1 conditions described in this Order. When the Action has been terminated, a
2 Receiving Party must comply with the provisions of section 13 below (FINAL
3 DISPOSITION).
4 Protected Material must be stored and maintained by a Receiving Party at a
5 location and in a secure manner that ensures that access is limited to the persons
6 authorized under this Order.
7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
8 otherwise ordered by the court or permitted in writing by the Designating Party, a
9 Receiving Party may disclose any information or item designated
10 “CONFIDENTIAL” only to:
11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
12 as employees of said Outside Counsel of Record to whom it is reasonably necessary
13 to disclose the information for thisAction;
14 (b) the officers, directors, and employees (including House Counsel) of the
15 Receiving Party to whom disclosure is reasonably necessary for thisAction;
16 (c) Experts (as defined in this Order) of the Receiving Party to whom
17 disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (d) the court and its personnel;
20 (e) court reporters and their staff;
21 (f) professional jury or trial consultants and mock jurors to whom
22 disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (ExhibitA);
24 (g) Professional Vendors to whom disclosure is reasonably necessary for
25 this Action;
26 (h) the author or recipient of a document containing the information or a
27 custodian or other person who otherwise possessed or knew theinformation;
28
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1 (i) during their depositions, witnesses, and attorneys for witnesses, in the
2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
3 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
4 not be permitted to keep any confidential information unless they sign the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
6 agreed by the Designating Party or ordered by the court. Pages of transcribed
7 deposition testimony or exhibits to depositions that reveal Protected Material may
8 be separately bound by the court reporter and may not be disclosed to anyone except
9 as permitted under this Stipulated Protective Order; and
10 (j) any mediator or settlement officer, and their supporting personnel,
11 mutually agreed upon by any of the parties engaged in settlementdiscussions.
12 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
13 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
14 writing by the Designating Party, a Receiving Party may disclose any information or
15 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
16 to the persons listed in Paragraphs 7.2(a), (c), (d), (e), (f), (g), (h), and (j) above and
17 House Counsel of the Receiving Party.
18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
19 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 courtorder;
25 (b) promptly notify in writing the party who caused the subpoena or order
26 to 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
11
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1 (c) cooperate with respect to all reasonable procedures sought to be pursued
2 by the Designating Party whose Protected Material may beaffected.
3 If the Designating Party timely seeks a protective order, the Party served
4 with 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
12 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 additionalprotections.
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
23 that 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
26 Protective Order in this Action, the relevant discovery request(s), and a reasonably
27 specific description of the information requested; and
28
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1 (3) make the information requested available for inspection by the
2 Non-Party, if requested.
3 (c) If the Non-Party fails to seek a protective order from this court within
4 14 days of receiving the notice and accompanying information, the Receiving Party
5 may produce the Non-Party’s confidential information responsive to the discovery
6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
7 not produce any information in its possession or control that is subject to the
8 confidentiality agreement with the Non-Party before a determination by the court.
9 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
10 of seeking protection in this court of its ProtectedMaterial.
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of this Order,
18 and (d) request such person or persons to execute the “Acknowledgment and
19 Agreement to Be Bound” that is attached hereto as Exhibit A.
20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
21 PROTECTED MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain
23 inadvertently produced material is subject to a claim of privilege or other protection,
24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
26 may be established in an e-discovery order that provides for production without prior
27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), the disclosure
28 or production of documents protected by the attorney-client privilege or work-
13
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1 product protection, whether inadvertent or not, will not constitute a waiver of the
2 privilege or protection by the disclosing Party in either the litigation pending before
3 the Court, or any other federal or state proceeding.
4 12. MISCELLANEOUS
5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
6 person to seek its modification by the Court in thefuture.
7 12.2 Right to Assert Other Objections. By stipulating to the entry of this
8 Protective Order, no Party waives any right it otherwise would have to object to
9 disclosing or producing any information or item on any ground not addressed in this
10 Stipulated Protective Order. Similarly, no Party waives any right to object on any
11 ground to use in evidence of any of the material covered by this ProtectiveOrder.
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 may
14 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 thecourt.
18 12.4 Prior or Public Knowledge. This Protective Order shall not apply to
19 information that, prior to disclosure, is public knowledge, and the restrictions
20 contained in this Protective Order shall not apply to information that is, or after
21 disclosure becomes, public; was in the possession of the Party to whom disclosure is
22 made prior to disclosure; or is public knowledge other than by an act or omission of
23 the party to whom such disclosure is made; or that is legitimately and independently
24 acquired from a source not subject to this Protective Order.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60
27 days of a written request by the Designating Party, each Receiving Party must return
28 all Protected Material to the Producing Party or destroy such material. As used in
14
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1 || this subdivision, “all Protected Material’ includes all copies, abstracts, compilations,
2 || summaries, and any other format reproducing or capturing any of the Protected
3 || Material. Whether the Protected Material is returned or destroyed, the Receiving
4 || Party must submit a written certification to the Producing Party (and, if not the same
5 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
6 || (by category, where appropriate) all the Protected Material that was returned or
7 || destroyed and (2) affirms that the Receiving Party has not retained any copies,
g || abstracts, compilations, summaries or any other format reproducing or capturing any
9 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to
10 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
11 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
12 || reports, attorney work product, and consultant and expert work product, even if such
13 || materials contain Protected Material. Any such archival copies that contain or
14 || constitute Protected Material remain subject to this Protective Order as set forth in
15 || Section 4 (DURATION).
16 || 14. Any violation of this Order may be punished by appropriate measures
17 || including, without limitation, contempt proceedings and/or monetary sanctions.
18
19 || □□ □□ SO STIPULATED, THROUGH COUNSEL OF RECORD.
20
21 || DATED:__ May 16, 2022
22
23 /s/Scott Alan Burroughs
54 Scott Alan Burroughs
Trevor W. Barrett
25 || Frank R. Trechsel
06 DONIGER / BURROUGHS
Attorneys for Plaintiff
27
28
15
14220525.2

Case :21-cv-08754-VAP-PD Document 24 Filed 05/18/22 Page 160f17 Page ID#:122
2 || DATED: May 16, 2022
4 /s/Emily F. Evitt
Emily F. Evitt
> || Gabriella N. Ismaj
6 || MITCHELL, SILBERBERG & KNUPP LLP
; Attorneys for Defendant

g Attestation Regarding Signatures
I, Emily F. Evitt, attest that all signatories listed, and on whose behalf the filing
9 || is submitted, concur in this filing’s content and have authorized the filing.
10 /s/Emily F. Evitt
Emily F. Evitt
11
12
13
14 || FOR GOOD CAUSE SHOWN, IT IS SO
is ORDERED.
16
7 DATED: May 18, 2022

18
Piaticcca Donati
9 Patricia Donahue
20 || United States Magistrate Judge
21
22
23
24
25
26
27
28
16
14220525.2

CCaassee 22::2211--ccvv--0088775544--VVAAPP--PPDD DDooccuummeenntt 2234 FFiilleedd 0055//1178//2222 PPaaggee 1177 ooff 1177 PPaaggee IIDD ##::110263

1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I, ___________________________________ [print or type full name], of
4
____________________________________ [print or type full address], declare
5
under penalty of perjury that I have read in its entirety and understand the Stipulated
6
Protective Order that was issued by the United States District Court for the Central
7
District of California in the case of Matlow v. Hive Media Group, LLC, Case No.
8
2:21-cv-08754 VAP-PDx. I agree to comply with and to be bound by all the terms
9
of this Stipulated Protective Order and I understand and acknowledge that failure
10
to so comply could expose me to sanctions and punishment in the nature of
11
contempt. I solemnly promise that I will not disclose in any manner any information
12
or item that is subject to this Stipulated Protective Order to any person or entity
13
except in strict compliance with the provisions of this Order.
14
I further agree to submit to the jurisdiction of the United States District Court for
15
the Central District of California for enforcing the terms of this Stipulated
16
Protective Order, even if such enforcement proceedings occur after termination of
17
this action. I hereby appoint ________________________ [print or type full
18
name] of _________ [print or type full address and telephone number] as my
19
California agent for service of process in connection with this action or any
20
proceedings related to enforcement of this Stipulated Protective Order.
21
22 Date: __________________________
23
City and State where sworn and signed: _____________________________
24
25
Printedname: ____________________________________
26
27 Signature: ________________________________
28
17
14220525.2

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9980011. Public record. Not legal advice.