Arconic Inc. v. Cal-Tron Plating, Inc.

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 1 of 17 Page ID #:920

1 LATHROP GPM LLP

Nancy Sher Cohen (State Bar No. 81706)

2

nancy.cohen@lathropgpm.com

3 Ronald A. Valenzuela (State Bar No. 210025)

ronald.valenzuela@lathropgpm.com

4

2049 Century Park East, Suite 3500S

5 Los Angeles, CA 90067

Telephone: 310.789.4600

6

Facsimile: 310.789.4601

7

Attorneys for Plaintiffs

8

BASF Corporation et al.

9

10

UNITED STATES DISTRICT COURT

11 CENTRAL DISTRICT OF CALIFORNIA

12

13 BASF CORPORATION, et al., Case No. 2:20-cv-2586-GW-(Ex)

14 Plaintiffs, STIPULATED PROTECTIVE

15 vs. ORDER

16 CAL-TRON PLATING INC., et al.,

17 Defendants.

18

19

20

21

22

23

24

25

26

27

28

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 2 of 17 Page ID #:921

1 1. 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.

11 2. GOOD CAUSE STATEMENT

12 This action is likely to involve valuable commercial, financial, technical,

13 settlement-related and/or proprietary information for which special protection from

14 public disclosure and from use for any purpose other than prosecution of this action

15 is warranted. Such confidential and proprietary materials and information consist

16 of, among other things, confidential business or financial information, information

17 regarding confidential business practices, or other confidential commercial

18 information (including information implicating privacy rights of third parties),

19 information otherwise generally unavailable to the public, or which may be

20 privileged or otherwise protected from disclosure under state or federal statutes,

21 court rules, case decisions, or common law. Accordingly, to expedite the flow of

22 information, to facilitate the prompt resolution of disputes over confidentiality of

23 discovery materials, to adequately protect information the parties are entitled to

24 keep confidential, to ensure that the parties are permitted reasonable necessary uses

25 of such material in preparation for and in the conduct of trial, to address their

26 handling at the end of the litigation, and serve the ends of justice, a protective order

27 for such information is justified in this action. It is the intent of the parties that

28

2

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 3 of 17 Page ID #:922

1 information will not be designated as confidential for tactical reasons and that

2 nothing be so designated without a good faith belief that it has been maintained in

3 a confidential, non-public manner, and there is good cause why it should not be part

4 of the public record of this case.

5 3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

6 The parties further acknowledge, as set forth in Section 14(c), below, that

7 this Stipulated Protective Order does not entitle them to file confidential

8 information under seal; Local Civil Rule 79-5 sets forth the procedures that must be

9 followed and the standards that will be applied when a party seeks permission from

10 the court to file material under seal. There is a strong presumption that the public

11 has a right of access to judicial proceedings and records in civil cases. In

12 connection with non-dispositive motions, good cause must be shown to support a

13 filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 1172,

14 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th

15 Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis.

16 1999) (even stipulated protective orders require good cause showing), and a

17 specific showing of good cause or compelling reasons with proper evidentiary

18 support and legal justification, must be made with respect to Protected Material that

19 a party seeks to file under seal. The parties’ mere designation of Disclosure or

20 Discovery Material as CONFIDENTIAL does not—without the submission of

21 competent evidence by declaration, establishing that the material sought to be filed

22 under seal qualifies as confidential, privileged, or otherwise protectable—constitute

23 good cause.

24 Further, competent evidence supporting the application to file documents

25 under seal must be provided by declaration. If a party requests sealing related to a

26 dispositive motion or trial, then compelling reasons, not only good cause, for the

27 sealing must be shown, and the relief sought shall be narrowly tailored to serve the

28

3

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 4 of 17 Page ID #:923

1 specific interest to be protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d

2 665, 677-79 (9th Cir. 2010). For each item or type of information, document, or

3 thing sought to be filed or introduced under seal in connection with a dispositive

4 motion or trial, the party seeking protection must articulate compelling reasons,

5 supported by specific facts and legal justification, for the requested sealing order.

6 Any document that is not confidential, privileged, or otherwise protectable in

7 its entirety will not be filed under seal if the confidential portions can be redacted.

8 If documents can be redacted, then a redacted version for public viewing, omitting

9 only the confidential, privileged, or otherwise protectable portions of the document,

10 shall be filed. Any application that seeks to file documents under seal in their

11 entirety should include an explanation of why redaction is not feasible.

12 4. DEFINITIONS

13 (a) Action: the above-captioned lawsuit.

14 (b) Challenging Party: a Party or Non-Party that challenges

15 the designation of information or items under this Order.

16 (c) “CONFIDENTIAL” Information or Items: information (regardless of

17 how it is generated, stored or maintained) or tangible things that

18 qualify for protection under Federal Rule of Civil Procedure 26(c),

19 and as specified above in the Good Cause Statement.

20 (d) Counsel: Outside Counsel of Record and House Counsel (as well as

21 their support staff).

22 (e) Designating Party: a Party or Non-Party that designates Disclosure or

23 Discovery Material (as defined below) as “CONFIDENTIAL.”

24 (f) Disclosure or Discovery Material: all items or information, regardless

25 of the medium or manner in which it is generated, stored, or

26 maintained (including, among other things, testimony, transcripts, and

27 tangible things), that are produced or generated in disclosures or

28 responses to discovery in this Action.

4

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 5 of 17 Page ID #:924

1 (g) Expert: a person with specialized knowledge or experience in a matter

2 pertinent to the litigation who has been retained by a Party or its

3 Counsel to serve as an expert witness or as a consultant in this Action.

4 (h) Final Disposition: the conclusion of any appellate proceedings, or, if

5 no appeal is taken, when the time for filing of an appeal has run.

6 (i) House Counsel: attorneys who are employees of a party to this Action.

7 House Counsel does not include Outside Counsel of Record or any

8 other outside counsel.

9 (j) Non-Party: any natural person, partnership, corporation, association,

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

11 (k) Outside Counsel of Record: attorneys who are not employees of a

12 party to this Action but are retained to represent or advise a party to

13 this Action and have appeared in this Action on behalf of that party or

14 are affiliated with a law firm which has appeared on behalf of that

15 party, and includes support staff.

16 (l) Party: any party to this Action, including all of its officers, directors,

17 employees, Experts, House Counsel, and Outside Counsel of Record

18 (and their support staffs).

19 (m) Producing Party: a Party or Non-Party that produces Disclosure or

20 Discovery Material in this Action.

21 (n) Professional Vendors: persons or entities that provide litigation

22 support services (e.g., photocopying, videotaping, translating,

23 preparing exhibits or demonstrations, and organizing, storing, or

24 retrieving data in any form or medium) and their employees and

25 subcontractors.

26 (o) Protected Material: any Disclosure or Discovery Material that is

27 designated as “CONFIDENTIAL.”

28 (p) Receiving Party: a Party that receives Disclosure or Discovery

5

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 6 of 17 Page ID #:925

1 Material from a Producing Party.

2 (q) Third Party: a person or entity that is not a party to the Stipulation.

3 5. SCOPE

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

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

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

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

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

9 Any use of Protected Material at trial shall be governed by the orders of the

10 trial judge. This Order does not govern the use of Protected Material at trial.

11 6. DURATION

12 Except as set forth below, the terms of this protective order apply through

13 Final Disposition of the Action. The parties may stipulate that they will be

14 contractually bound by the terms of this agreement beyond Final Disposition, but

15 will have to file a separate action for enforcement of the agreement once all

16 proceedings in this case are complete.

17 Once a case proceeds to trial, information that was designated as

18 CONFIDENTIAL or maintained pursuant to this protective order used or

19 introduced as an exhibit at trial becomes public and will be presumptively available

20 to all members of the public, including the press, unless compelling reasons

21 supported by specific factual findings to proceed otherwise are made to the trial

22 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing

23 “good cause” showing for sealing documents produced in discovery from

24 “compelling reasons” standard when merits-related documents are part of court

25 record). Accordingly, for such materials, the terms of this protective order do not

26 extend beyond the commencement of the trial.

27 7. DESIGNATING PROTECTED MATERIAL

28

6

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 7 of 17 Page ID #:926

1 (a) Exercise of Restraint and Care in Designating Material for Protection.

2 Each Party or Non-Party that designates information or items for protection

3 under this Order must take care to limit any such designation to specific material

4 that qualifies under the appropriate standards. The Designating Party must

5 designate for protection only those parts of material, documents, items, or oral or

6 written communications that qualify so that other portions of the material,

7 documents, items, or communications for which protection is not warranted are not

8 swept unjustifiably within the ambit of this Order.

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

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

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

12 impose unnecessary expenses and burdens on other parties) may expose the

13 Designating Party to sanctions.

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

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

16 promptly notify all other Parties that it is withdrawing the inapplicable designation.

17 (b) Manner and Timing of Designations.

18 Except as otherwise provided in this Order, or as otherwise stipulated or

19 ordered, Disclosure or Discovery Material that qualifies for protection under this

20 Order must be clearly so designated before the material is disclosed or produced.

21 For information in documentary form (e.g., paper or electronic documents,

22 but excluding transcripts of depositions or other pretrial or trial proceedings),

23 designation in conformity with this Order requires the Producing Party affix at a

24 minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL

25 legend”), to each page that contains protected material. If only a portion or portions

26 of the material on a page qualifies for protection, the Producing Party also must

27 clearly identify the protected portion(s) (e.g., by making appropriate markings in

28

7

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 8 of 17 Page ID #:927

1 the margins).

2 A Party or Non-Party that makes original documents available for inspection

3 need not designate them for protection until after the inspecting Party has indicated

4 which documents it would like copied and produced. During the inspection and

5 before the designation, all of the material made available for inspection shall be

6 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

7 documents it wants copied and produced, the Producing Party must determine

8 which documents, or portions thereof, qualify for protection under this Order. Then,

9 before producing the specified documents, the Producing Party must affix the

10 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

11 portion or portions of the material on a page qualifies for protection, the Producing

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

13 appropriate markings in the margins).

14 For testimony given in depositions, designation in conformity with this Order

15 requires the Designating Party to identify the Disclosure or Discovery Material on

16 the record, before the close of the deposition, all protected testimony.

17 For information produced in some form other than documentary and for any

18 other tangible items, designation in conformity with this Order requires that the

19 Producing Party affix in a prominent place on the exterior of the container or

20 containers in which the information is stored the legend “CONFIDENTIAL.” If

21 only a portion or portions of the information warrants protection, the Producing

22 Party, to the extent practicable, shall identify the protected portion(s).

23 (c) Inadvertent Failures to Designate.

24 If timely corrected, an inadvertent failure to designate qualified information

25 or items does not, standing alone, waive the Designating Party’s right to secure

26 protection under this Order for such material. Upon timely correction of a

27 designation, the Receiving Party must make reasonable efforts to assure that the

28

8

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 9 of 17 Page ID #:928

1 material is treated in accordance with the provisions of this Order.

2 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

3 (a) Timing of Challenges.

4 Any Party or Non-Party may challenge a designation of confidentiality at any

5 time that is consistent with the Court’s Scheduling Order.

6 (b) Meet and Confer.

7 The Challenging Party shall initiate the dispute resolution process under

8 Local Rule 37.1 et seq., with the exception that the Designating Party must provide

9 its portion of the Joint Stipulation under Local Rule 37-2.2 first, followed by the

10 Challenging Party adding its portion second. The burden of persuasion in any such

11 challenge proceeding shall be on the Designating Party. Frivolous challenges, and

12 those made for an improper purpose (e.g., to harass or impose unnecessary

13 expenses and burdens on other parties) may expose the Challenging Party to

14 sanctions. Unless the Designating Party has waived or withdrawn the

15 confidentiality designation, all parties shall continue to afford the material in

16 question the level of protection to which it is entitled under the Producing Party’s

17 designation until the Court rules on the challenge.

18 9. ACCESS TO AND USE OF PROTECTED MATERIAL

19 (a) Basic Principles.

20 A Receiving Party may use Protected Material that is disclosed or produced

21 by another Party or by a Non-Party in connection with this Action only for

22 prosecuting, defending, or attempting to settle this Action. Such Protected Material

23 may be disclosed only to the categories of persons and under the conditions

24 described in this Order. Protected Material must be stored and maintained by a

25 Receiving Party at a location and in a secure manner that ensures that access is

26 limited to the persons authorized under this Order.

27 (b) Disclosure of “CONFIDENTIAL” Information or Items.

28

9

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 10 of 17 Page ID #:929

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

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

3 designated “CONFIDENTIAL” only to:

4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

5 as employees of said Outside Counsel of Record to whom it is reasonably necessary

6 to disclose the information for this Action;

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

8 Receiving Party to whom disclosure is reasonably necessary for this Action;

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

10 disclosure is reasonably necessary for this Action and who have signed the

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

12 (d) the court and its personnel;

13 (e) court reporters and their staff;

14 (f) professional jury or trial consultants, mock jurors, and Professional

15 Vendors to whom disclosure is reasonably necessary for this Action and who have

16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

17 (g) the author or recipient of a document containing the information or a

18 custodian or other person who otherwise possessed or knew the information;

19 (h) during their depositions, witnesses, and attorneys for witnesses, in the

20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

21 requests that the witness sign the “Acknowledgement and Agreement to Be Bound”

22 (Exhibit A); and (2) they will not be permitted to keep any confidential information

23 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),

24 unless otherwise agreed by the Designating Party or ordered by the court. Pages of

25 transcribed deposition testimony or exhibits to depositions that reveal Protected

26 Material may be separately bound by the court reporter and may not be disclosed to

27 anyone except as permitted under this Stipulated Protective Order; and

28

10

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 11 of 17 Page ID #:930

1 (i) any mediator or settlement officer, and their supporting personnel,

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

3 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

4 IN OTHER LITIGATION

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

6 that compels disclosure of any information or items designated in this Action as

7 “CONFIDENTIAL,” that Party must:

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

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

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

11 to issue in the other litigation that some or all of the material covered

12 by the subpoena or order is subject to this Protective Order. Such

13 notification shall include a copy of this Stipulated Protective Order; and

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

15 pursued by the Designating Party whose Protected Material may be

16 affected.

17 If the Designating Party timely seeks a protective order, the Party served

18 with the subpoena or court order shall not produce any information designated in

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

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

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

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

23 should be construed as authorizing or encouraging a Receiving Party in this Action

24 to disobey a lawful directive from another court.

25 11. NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

26 IN THIS ACTION

27 The terms of this Order are applicable to information produced by a Non-

28

11

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 12 of 17 Page ID #:931

1 Party in this Action and designated as “CONFIDENTIAL.” Such information

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

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

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

5 In the event that a Party is required, by a valid discovery request, to produce

6 a Non-Party’s confidential information in its possession, and the Party is subject to

7 an agreement with the Non-Party not to produce the Non-Party’s confidential

8 information, then the Party shall (a) promptly notify in writing the Requesting Party

9 and the Non-Party that some or all of the information requested is subject to a

10 confidentiality agreement with a Non-Party; (b) promptly provide the Non-Party

11 with a copy of the Stipulated Protective Order in this Action, the relevant discovery

12 request(s), and a reasonably specific description of the information requested; and

13 (c) make the information requested available for inspection by the Non-Party, if

14 requested.

15 If the Non-Party fails to seek a protective order from this court within 14

16 days of receiving the notice and accompanying information, the Receiving Party

17 may produce the Non-Party’s confidential information responsive to the discovery

18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

19 not produce any information in its possession or control that is subject to the

20 confidentiality agreement with the Non-Party before a determination by the court.

21 Absent a court order to the contrary, the Non-Party shall bear the burden and

22 expense of seeking protection in this court of its Protected Material.

23 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

25 disclosed Protected Material to any person or in any circumstance not authorized

26 under this Stipulated Protective Order, the Receiving Party must immediately (i)

27 notify in writing the Designating Party of the unauthorized disclosures, (ii) use its

28

12

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 13 of 17 Page ID #:932

1 best efforts to retrieve all unauthorized copies of the Protected Material, (iii) inform

2 the person or persons to whom unauthorized disclosures were made of all the terms

3 of this Order, and (iv) request such person or persons to execute the

4 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A.

5 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

6 PROTECTED MATERIAL

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

8 inadvertently produced material is subject to a claim of privilege or other

9 protection, the obligations of the Receiving Parties are those set forth in Federal

10 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

11 whatever procedure may be established in an e-discovery order that provides for

12 production without prior privilege review. Pursuant to Federal Rule of Evidence

13 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

14 of a communication or information covered by the attorney-client privilege or work

15 product protection, the parties may incorporate their agreement in the stipulated

16 protective order submitted to the court.

17 14. MISCELLANEOUS

18 (a) Right to Further Relief.

19 Nothing in this Order abridges the right of any person to seek its

20 modification by the Court in the future.

21 (b) Right to Assert Other Objections.

22 By stipulating to the entry of this Protective Order no Party waives any right

23 it otherwise would have to object to disclosing or producing any information or

24 item on any ground not addressed in this Stipulated Protective Order. Similarly, no

25 Party waives any right to object on any ground to use in evidence of any of the

26 material covered by this Protective Order.

27 (c) Filing Protected Material.

28

13

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 14 of 17 Page ID #:933

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

2 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to

3 a court order authorizing the sealing of the specific Protected Material at issue. If a

4 Party's request to file Protected Material under seal is denied by the court, then the

5 Receiving Party may file the information in the public record unless otherwise

6 instructed by the court.

7 15. FINAL DISPOSITION

8 After the final disposition of this Action, as defined in paragraph 4, within 60

9 days of a written request by the Designating Party, each Receiving Party must

10 return all Protected Material to the Producing Party or destroy such material. As

11 used in this subdivision, “all Protected Material” includes all copies, abstracts,

12 compilations, summaries, and any other format reproducing or capturing any of the

13 Protected Material. Whether the Protected Material is returned or destroyed, the

14 Receiving Party must submit a written certification to the Producing Party (and, if

15 not the same person or entity, to the Designating Party) by the 60 day deadline that

16 identifies (by category, where appropriate) all the Protected Material that was

17 returned or destroyed, and affirms that the Receiving Party has not retained any

18 copies, abstracts, compilations, summaries or any other format reproducing or

19 capturing any of the Protected Material.

20 Notwithstanding this provision, Counsel are entitled to retain an archival

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

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

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

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

25 Protected Material remain subject to this Protective Order as set forth in Section 6

26 (DURATION).

27 16. VIOLATIONS

28

14

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 15 of 17 Page ID #:934

1 Any violation of this Order may be punished by any and all appropriate

2 measures including, without limitation, contempt proceedings and/or monetary

3 sanctions in the Court’s discretion.

4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5 We hereby attest that concurrence in the filing of this stipulation was

6 obtained by each of the below identified signatories.

7 Dated: June 7, 2022 LATHROP GPM LLP

8 By: /s/ Ronald A. Valenzuela

9 Nancy Sher Cohen

Ronald A. Valenzuela

10

Attorneys for Plaintiffs

11

12 Dated: June 7, 2022 VAN NESS FELDMAN LLP

13 By: /s/ Justin Panitchpakdi

14 Brian L. Zagon

Justin Panitchpakdi

15

Attorneys for Defendant Cal-Tron

16 Plating, Inc.

17

18 Dated: June 7, 2022 HAMRICK & EVANS, LLP

19 By: /s/ Jeff Poole

David L. Evans

20

Ilana Lohr-Schmidt

21 Jeff Poole

22

THE LAW OFFICES OF THOMAS P.

23 SCHMIDT

Thomas P. Schmidt

24

Attorneys for Defendant Electronic

25 Chrome & Grinding Co., Inc.

26

27

28

15

Case|2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 16of17 Page ID #:935

1 Dated: June 7. 2022 THE CRONIN LAW GROUP

2 By: /s/ Dennis J. Byrne

3 Timothy C. Cronin

4 Alan R. Johnston

Dennis J. Byrne

5 Attorneys for Defendant Mid-West

‘ Fabricating Co.

; Dated: June 7, 2022 VAN RIPER LAW

By: /s/ David A. Van Riper

7 David A. Van Riper

10 Attorneys for Defendant Santa Fe

Rubber Products, Inc.

12

3 Dated: June 7, 2022 WEISS & ZAMAN

4 By: /s/ Thomas J. Weiss

Thomas J. Weiss

15 Shawn Zaman

16 Attorneys for Defendant Vanowen

Holdings, LLC

17

|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

19

20 || DATED: 6/15/22 By: /S/ CHARLES F. EICK

21 Hon. Charles F. Eick

> United States Magistrate Judge

Central District of California

23

24

25

26

27

28

16

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 17 of 17 Page ID #:936

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 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

7

California on [date] in the case of __________ [insert formal name of the

8

case and the number and initials assigned to it by the court]. I agree to

9

comply with and to be bound by all the terms of this Stipulated Protective Order

10

and I understand and acknowledge that failure to so comply could expose me to

11

sanctions and punishment in the nature of contempt. I solemnly promise that I

12

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

13

Stipulated Protective Order to any person or entity except in strict compliance

14

with the provisions of this Order.

15

I further agree to submit to the jurisdiction of the United States District Court for

16

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

17

Stipulated Protective Order, even if such enforcement proceedings occur after

18

termination of this action. I hereby appoint ________________________ [print

19

or type full name] of _________ [print or type full address and telephone

20

number] as my California agent for service of process in connection with this

21

action or any proceedings related to enforcement of this Stipulated Protective

22

Order.

23

Date: __________________________

24

City and State where sworn and signed: _____________________________

25

Printed name: ____________________________________

26

27

Signature: ________________________________

28

17