finding even stipulated protective orders require 24 a showing of good cause
How later courts described this case
- finding even stipulated protective orders require 24 a showing of good cause
Written by the judges who cited it.
The opinion
Case 2:22-cv-01488-SVW-JEM Document 30 Filed 06/01/22 Page 1 of 17 Page ID #:640
1 SARAH E. ROSS, Bar No. 252206
sross@littler.com
2 JAMAR D. DAVIS, Bar No. 340949
jddavis@littler.com
3 LITTLER MENDELSON, P.C.
2049 Century Park East
4 5th Floor
Los Angeles, California 90067.3107
5 Telephone: 310.553.0308
Fax No.: 310.553.5583
6
Attorneys for Defendants
7 CLAIRE’S STORES, INC.
CLAIRE’S BOUTIQUES, INC.
8
Mika Hilaire, Esq. (SBN: 212263)
9
EQUAL RIGHTS LAW GROUP
10 15233 Ventura Boulevard, Suite 420
Sherman Oaks, California 91403
11
Telephone and Fax: (818) 305-6297
12 mika@equalrightslawgroup.com
13
Attorneys for Plaintiff, JULIA RIMES
14
15 UNITED STATES DISTRICT COURT
16 CENTRAL DISTRICT OF CALIFORNIA
17
JULIA RIMES, an individual, Case No. 2:22-cv-01488-SVW-JEM
18
Plaintiff, [PxxRxOxxPxOxSxxExDx] PROTECTIVE
19 ORDER FOR PRODUCTION OF
v. CONFIDENTIAL INFORMATION
20
CLAIRE'S STORES, INC., a Delaware ASSIGNED TO HONORABLE JUDGE
21 Corporation, CLAIRE'S BOUTIQUES, JOHN E. MCDERMOTT FOR
INC., a Michigan Corporation, and DISCOVERY MATTERS
22 DOES 1 through 25, inclusive,
[DISCOVERY DOCUMENT:
23 Defendants. REFERRED TO MAGISTRATE
JUDGE JOHN E. MCDERMOTT]
24
Trial date: September 20, 2022
25 Pretrial Conference: September 12, 2022
Discovery Cutoff: None Set
26 Complaint Filed: February 1, 2022
27
28
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1 PROTECTIVE ORDER
2 Pursuant to Honorable Magistrate Judge John E. McDermott’s May 5, 2022
3 Order (Docket #24), Plaintiff Julia Rimes (“Plaintiff”) and Defendants Claire’s Stores,
4 Inc. and Claire’s Boutiques, Inc. (“Defendants”), by and though their counsel of record,
5 hereby AGREE and STIPULATE as follows:
6 1. PURPOSES AND LIMITATIONS
7 Discovery in this action is likely to involve production of confidential or private
8 information for which special protection from public disclosure and from use for any
9 purpose other than pursuing this litigation may be warranted. Accordingly, the parties
10 hereby stipulate to enter the following Stipulated Protective Order. The parties
11 acknowledge that this Order does not confer blanket protections on all disclosures or
12 responses to discovery and that the protection it affords from public disclosure and use
13 extends only to the limited information or items that are entitled to confidential
14 treatment under the applicable legal principles.
15 2. GOOD CAUSE STATEMENT
16 Plaintiff’s allegations may require disclosure of Defendants’ confidential,
17 proprietary, or private information and/or Plaintiff’s private and/or confidential medical
18 information, including but not limited to, prescription records and orders, medical
19 records and history, billing and accounting records, treatment plans, insurance
20 information, medial ailments, genetic information, recommendations for referral
21 medical providers, and other private and confidential information for which special
22 protection from public disclosure and from use for any purpose other than prosecution
23 of this action is warranted. Such confidential and private information is otherwise
24 generally unavailable to the public and/or is privileged or otherwise protected from
25 disclosure under state or federal statutes, court rules, case decisions, or common law.
26 Disclosure of the foregoing confidential information to the public without proper
27 protection will result in a serious violation of Defendants’ and/or Plaintiff’s privacy
28 interests and may lead to the misuse of such information. Accordingly, to expedite the
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1 flow of information, to facilitate the prompt resolution of disputes over confidentiality
2 of discovery materials, to adequately protect information the parties are entitled to keep
3 confidential, to ensure that the parties are permitted reasonable and necessary uses of
4 such material in preparation for and in the conduct of trial, to address their handling at
5 the end of the litigation, and serve the ends of justice, a protective order for such
6 information is justified in this matter. It is the intent of the parties that information will
7 not be designated as confidential for tactical reasons and that nothing be so designated
8 without a good faith belief that it has been maintained in a confidential, non-public
9 manner, and there is good cause why it should not be part of the public record of this
10 case.
11 3. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE
12 The parties further acknowledge, as set forth in Section 13.3, below, that this
13 Stipulated Protective Order does not entitle them to file confidential information under
14 seal; Local Rule 79-5 sets forth the procedures that must be followed and the standards
15 that will be applied when a party seeks permission from the court to file material under
16 seal. There is a strong presumption that the public has a right of access to judicial
17 proceedings and records in civil cases. In connection with non-dispositive motions,
18 good cause must be shown to support a filing under seal, and a specific showing of good
19 cause with proper evidentiary support and legal justification, must be made with respect
20 to Protected Material that a party seeks to file under seal. See Kamakana v. City and
21 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
22 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,
23 187 F.R.D. 576, 577 (E.D. Wis. 1999) (finding even stipulated protective orders require
24 a showing of good cause). The parties’ mere designation of Disclosure or Discovery
25 Material as CONFIDENTIAL does not—without the submission of competent evidence
26 by declaration, establishing that the material sought to be filed under seal qualifies as
27 confidential, privileged, or otherwise protectable—constitute good cause.
28 Further, if a party requests sealing related to a dispositive motion or trial, then
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1 compelling reasons, not only good cause, for the sealing must be shown, and the relief
2 sought shall be narrowly tailored to serve the specific interest to be protected. See
3 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
4 or type of information, document, or thing sought to be filed or introduced under seal,
5 the party seeking protection must articulate compelling reasons, supported by specific
6 facts and legal justification, for the requested sealing order. Again, competent evidence
7 supporting the application to file documents under seal must be provided by declaration.
8 Any document that is not confidential, privileged, or otherwise protectable in its
9 entirety will not be filed under seal if the confidential portions can be redacted. If
10 documents can be redacted, then a redacted version for public viewing, omitting only
11 the confidential, privileged, or otherwise protectable portions of the document, shall be
12 filed. Any application that seeks to file documents under seal in their entirety should
13 include an explanation of why redaction is not feasible.
14 4. DEFINITIONS
15 4.1 Action: Julia Rimes v. Claire’s Stores Inc. et al., Case No. 2:22-cv-01488-
16 SVW-JEM.
17 4.2 Challenging Party: a Party or Non-Party that challenges the designation
18 of information or items under this Order.
19 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
20 how it is generated, stored, or maintained) or tangible things that qualify for protection
21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
22 Statement.
23 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
24 support staff).
25 4.5 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
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1 4.6 Disclosure or Discovery Material: all items or information, regardless
2 of the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced or
4 generated in disclosures or responses to discovery.
5 4.7 Expert: a person with specialized knowledge or experience in a matter
6 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
7 expert witness or as a consultant in this Action.
8 4.8 Plaintiff’s Medical Information: all information that is provided from a
9 health care provider that contains, including without limitation, prescription records and
10 orders, medical records and history, billing and accounting records, treatment plans,
11 insurance information, medial ailments, genetic information, and recommendations for
12 referral medical providers. Unless otherwise designated as “Confidential,” Plaintiff’s
13 Medical Information does not include information provided by Defendants regarding
14 Plaintiff Julia Rimes.
15 4.9 House Counsel: attorneys who are employees of a party to this Action.
16 House Counsel does not include Outside Counsel of Record or any other outside
17 counsel.
18 4.10 Non-Party: any natural person, partnership, corporation, association, or
19 other legal entity not named as a Party to this action.
20 4.11 Outside Counsel of Record: attorneys who are not employees of a party
21 to this Action but are retained to represent a party to this Action and have appeared in
22 this Action on behalf of that party or are affiliated with a law firm that has appeared on
23 behalf of that party, and includes support staff.
24 4.12 Party: any party to this Action, including all of its officers, directors,
25 employees, consultants, retained experts, and Outside Counsel of Record (and their
26 support staffs).
27 4.13 Producing Party: a Party or Non-Party that produces Disclosure or
28 Discovery Material in this Action.
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1 4.14 Professional Vendors: persons or entities that provide litigation support
2 services (e.g., photocopying, videotaping, translating, preparing exhibits or
3 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
4 their employees and subcontractors.
5 4.15 Protected Material: any Disclosure or Discovery Material that is
6 designated as “CONFIDENTIAL.”
7 4.16 Receiving Party: a Party that receives Disclosure or Discovery Material
8 from a Producing Party.
9 5. SCOPE
10 The protections conferred by this Stipulation and Order cover not only Protected
11 Material (as defined above), but also (1) any information copied or extracted from
12 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
13 Material; and (3) any testimony, conversations, or presentations by Parties or their
14 Counsel that might reveal Protected Material.
15 Any use of Protected Material at trial shall be governed by the orders of the trial
16 judge and other applicable authorities. This Order does not govern the use of Protected
17 Material at trial.
18 6. DESIGNATING PROTECTED MATERIAL
19 6.1 Manner and Timing of Designations. Except as otherwise provided in this
20 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that
21 qualifies for protection under this Order must be clearly so designated before the
22 material is disclosed or 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” (hereinafter “CONFIDENTIAL legend”), to each page that
28 contains protected material. If only a portion of the material on a page qualifies for
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1 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
2 by making appropriate markings in the margins).
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and before
6 the designation, all of the material made available for inspection shall be deemed
7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
8 copied and produced, the Producing Party must determine which documents, or portions
9 thereof, qualify for protection under this Order. Then, before producing the specified
10 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
11 that contains Protected Material. If only a portion of the material on a page qualifies
12 for protection, the Producing Party also must clearly identify the protected portion(s)
13 (e.g., by making appropriate markings in the margins).
14 (b) for testimony given in depositions that the Designating Party identifies
15 the Disclosure or Discovery Material on the record, before the close of the deposition
16 all protected testimony.
17 (c) for information produced in some form other than documentary and for
18 any other tangible items, that the Producing Party affix in a prominent place on the
19 exterior of the container or containers in which the information is stored the legend
20 “CONFIDENTIAL.” If only a portion or portions of the information warrants
21 protection, the Producing Party, to the extent practicable, shall identify the protected
22 portion(s).
23 6.2 Inadvertent Failures to Designate. If timely corrected, an inadvertent
24 failure to designate qualified information or items does not, standing alone, waive the
25 Designating Party’s right to secure protection under this Order for such material. Upon
26 timely correction of a designation, the Receiving Party must make reasonable efforts to
27 assure that the material is treated in accordance with the provisions of this Order.
28
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1 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 7.1 Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time that is consistent with the Court’s Scheduling
4 Order.
5 7.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37-1 et seq.
7 7.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
8 stipulation pursuant to Local Rule 37-2.
9 7.4 The burden of persuasion in any such challenge proceeding shall be on the
10 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
11 to harass or impose unnecessary expenses and burdens on other parties) may expose the
12 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
13 the confidentiality designation, all parties shall continue to afford the material in
14 question the level of protection to which it is entitled under the Producing Party’s
15 designation until the Court rules on the challenge.
16 8. ACCESS TO AND USE OF PROTECTED MATERIAL
17 8.1 Basic Principles. A Receiving Party may use Protected Material that is
18 disclosed or produced by another Party or by a Non-Party in connection with this Action
19 only for prosecuting, defending, or attempting to settle this Action. Such Protected
20 Material may be disclosed only to the categories of persons and under the conditions
21 described in this Order. When the Action has been terminated, a Receiving Party must
22 comply with the provisions of Section 14 below (FINAL DISPOSITION).
23 Protected Material must be stored and maintained by a Receiving Party at a
24 location and in a secure manner that ensures that access is limited to the persons
25 authorized under this Order.
26 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
27 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
28 may disclose any information or item designated “CONFIDENTIAL” only to:
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1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
3 disclose the information for this Action;
4 (b) the officers, directors, and employees (including House Counsel) of the
5 Receiving Party to whom disclosure is reasonably necessary for this Action;
6 (c) Experts (as defined in this Order) of the Receiving Party to whom
7 disclosure is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (d) the court and its personnel;
10 (e) court reporters and their staff;
11 (f) professional jury or trial consultants, mock jurors, and Professional
12 Vendors to whom disclosure is reasonably necessary for this Action and who have
13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (g) the author or recipient of a document containing the information or a
15 custodian or other person who otherwise possessed or knew the information;
16 (h) during their depositions, witnesses, and attorneys for witnesses, in the
17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
19 not be permitted to keep any confidential information unless they sign the
20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
21 by the Designating Party or ordered by the court. Pages of transcribed deposition
22 testimony or exhibits to depositions that reveal Protected Material may be separately
23 bound by the court reporter and may not be disclosed to anyone except as permitted
24 under this Stipulated Protective Order; and
25 (i) any mediators or settlement officers and their supporting personnel,
26 mutually agreed upon by any of the parties engaged in settlement discussions.
27
28
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1 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2 OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification
7 shall include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order
9 to issue in the other litigation that some or all of the material covered by the subpoena
10 or order is subject to this Protective Order. Such notification shall include a copy of
11 this Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be
13 pursued by the Designating Party whose Protected Material may be affected. If the
14 Designating Party timely seeks a protective order, the Party served with the subpoena
15 or court order shall not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court
19 of its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
21 from another court.
22 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
23 IN THIS LITIGATION
24 (a) The terms of this Order are applicable to information produced by a
25 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
26 produced by Non-Parties in connection with this litigation is protected by the remedies
27 and relief provided by this Order. Nothing in these provisions should be construed as
28 prohibiting a Non-Party from seeking additional protections.
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1 (b) In the event that a Party is required, by a valid discovery request, to
2 produce a Non-Party’s confidential information in its possession, and the Party is
3 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
4 information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the Non-
6 Party that some or all of the information requested is subject to a confidentiality
7 agreement with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the Stipulated
9 Protective Order in this Action, the relevant discovery request(s), and a reasonably
10 specific description of the information requested; and
11 (3) make the information requested available for inspection by the
12 Non-Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this court within
14 14 days of receiving the notice and accompanying information, the Receiving Party may
15 produce the Non-Party’s confidential information responsive to the discovery request.
16 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
17 any information in its possession or control that is subject to the confidentiality
18 agreement with the Non-Party before a determination by the court. Absent a court order
19 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
20 in this court of its Protected Material.
21 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
26 all unauthorized copies of the Protected Material, (c) inform the person or persons to
27 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
28 such person or persons to execute the “Acknowledgment an Agreement to Be Bound”
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1 attached hereto as Exhibit A.
2 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
3 PROTECTED MATERIAL
4 When a Producing Party gives notice to Receiving Parties that certain
5 inadvertently produced material is subject to a claim of privilege or other protection,
6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
8 may be established in an e-discovery order that provides for production without prior
9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
10 parties reach an agreement on the effect of disclosure of a communication or
11 information covered by the attorney-client privilege or work product protection, the
12 parties may incorporate their agreement in the stipulated protective order submitted to
13 the court.
14 13. MISCELLANEOUS
15 13.1 Right to Further Relief. Nothing in this Order abridges the right of any
16 person to seek its modification by the Court in the future.
17 13.2 Right to Assert Other Objections. By stipulating to the entry of this
18 Protective Order, no Party waives any right it otherwise would have to object to
19 disclosing or producing any information or item on any ground not addressed in this
20 Stipulated Protective Order. Similarly, no Party waives any right to object on any
21 ground to use in evidence of any of the material covered by this Protective Order.
22 13.3 Filing Protected Material. A Party that seeks to file under seal any
23 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
24 only be filed under seal pursuant to a court order authorizing the sealing of the specific
25 Protected Material. If a Party’s request to file Protected Material under seal is denied
26 by the court, then the Receiving Party may file the information in the public record
27 unless otherwise instructed by the court.
28
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1 14. FINAL DISPOSITION
2 After the final disposition of this Action, within 60 days of a written request by
3 the Designating Party, each Receiving Party must return all Protected Material to the
4 Producing Party or destroy such material. As used in this subdivision, “all Protected
5 Material” includes all copies, abstracts, compilations, summaries, and any other format
6 reproducing or capturing any of the Protected Material. Whether the Protected Material
7 is returned or destroyed, the Receiving Party must submit a written certification to the
8 Producing Party (and, if not the same person or entity, to the Designating Party) by the
9 60-day deadline that (1) identifies (by category, where appropriate) all the Protected
10 Material that was returned or destroyed and (2) affirms that the Receiving Party has not
11 retained any copies, abstracts, compilations, summaries or any other format reproducing
12 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are
13 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
14 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
15 expert reports, attorney work product, and consultant and expert work product, even if
16 such materials contain Protected Material. Any such archival copies that contain or
17 constitute Protected Material remain subject to this Protective Order.
18 15. VIOLATION
19 Any violation of this Order may be punished by appropriate measures including,
20 without limitation, contempt proceedings and/or monetary sanctions.
21
22 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
23
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1 Dated: June 1, 2022 LITTLER MENDELSON, P.C.
2
3 /s/ Sarah E. Ross
SARAH E. ROSS
4 JAMAR D. DAVIS
5 Attorneys for Defendant
CLAIRE’S STORES, INC.
6
7 Dated: June 1, 2022 EQUAL RIGHTS LAW GROUP
8
9 /s/ Mika Hilaire
MIKA HILAIRE
10
Attorneys for Plaintiff
11 JULIA RIMES
12
13 ATTESTATION
14
Pursuant to Civil Local Rule 5-4.3.4(a)(2)(i), the filer of this document attests
15
that all other signatories listed, and on whose behalf the filing is submitted, concur in
16
the filings’ content and have authorized the filing.
17
18
19 Dated: June 1, 2022 LITTLER MENDELSON, P.C.
20
21 /s/ Sarah E. Ross
SARAH E. ROSS
22 JAMAR D. DAVIS
23 Attorneys for Defendant
CLAIRE’S STORES, INC.
24
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1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: 6/2/22
5 UNITED STATES MAGISTRATE JUDGE
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15 PROTECTIVE ORDER
Case 2:22-cv-01488-SVW-JEM Document 30 Filed 06/01/22 Page 16 of 17 Page ID #:655
1 EXHIBIT A
2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
3 I hereby acknowledge that I, ________________________________ [NAME],
4 _________________________________________ [POSITION AND EMPLOYER],
5 am about to receive Protected Material supplied in connection with the Action: Julia
6 Rimes v. Claire’s Stores Inc. et al., Case No. 2:22-cv-01488-SVW-JEM. I understand
7 that said Protected Material is provided to me subject to the terms and restrictions of
8 the Stipulated Protective Order filed in this Action. I have been given a copy of the
9 Stipulated Protective Order; I have read it; and, I agree to be bound by its terms. I
10 understand that Protected Material as defined in the Stipulated Protective Order,
11 including any notes or other records that may be made regarding any such materials,
12 shall not be disclosed to anyone, except as expressly permitted by the Stipulated
13 Protective Order. I will not copy or use, except solely for the purposes of this Action,
14 any Protected Material obtained pursuant to the Stipulated Protective Order, except as
15 provided therein or otherwise ordered by the Court in the Action. I further understand
16 that I am to retain all copies of all Protected Material provided to me in a secure manner,
17 and that all copies of such Protected Material are to remain in my personal custody and
18 control until termination of my participation in this Action, whereupon the copies of
19 such Materials will be returned to counsel who provided me with such Material.
20 Dated: ______________
________________________________
21 Signature
________________________________
22 Print Name
________________________________
23 Title
________________________________
24
Address
25 ________________________________
City, State, Zip
26 ________________________________
Telephone Number
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LITTLER MENDELSON, P.C.
Los2 0 A4 n9 g 3eC 1lee5 0snt .h,5t u 5CFr 3y Al .o 0Po 39ar 00 r 8k 0 6E 7a .3st 1 07 16 PROTECTIVE ORDER
Case 2:22-cv-01488-SVW-JEM Document 30 Filed 06/01/22 Page 17 of 17 Page ID #:656
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4889-8261-2002.5 / 112144-1001
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LITTLER MENDELSON, P.C.
Los2 0 A4 n9 g 3eC 1lee5 0snt .h,5t u 5CFr 3y Al .o 0Po 39ar 00 r 8k 0 6E 7a .3st 1 07 17 PROTECTIVE ORDER