even 10 stipulated protective orders require good cause showing
How later courts described this case
- even 10 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 1 of 15 Page ID #:220
1
2
3
4
5
6
7
8 UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA
10
) Case No. 8:22-cv-00372-CJC-JDEx
)
11 IRVING CARLOS ZUNIGA, on behalf )
12 of himself and all others similarly ) ) STIPULATED PROTECTIVE ORDER
situated, )
13 Plaintiff, )
)
14 )
v. )
15 )
)
16 HOUSE FOODS AMERICA )
CORPORATION, a California )
17 )
corporation; HOUSE FOODS
)
18 HOLDING USA, INC., a California )
corporation; and DOES 1 through 100, )
19 )
inclusive, )
20 Defendants. )
21 Based on the parties’ Stipulation (Dkt. 30) and for good cause shown, the
22 Court finds and orders as follows.
23 1. PURPOSES AND LIMITATIONS
24 Discovery in this action is likely to involve production of confidential,
25 proprietary or private information for which special protection from public
26 disclosure and from use for any purpose other than pursuing this litigation may be
27 warranted. Accordingly, the parties hereby stipulate to and petition the Court to
28 enter the following Stipulated Protective Order. The parties acknowledge that this
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 2 of 15 Page ID #:221
1 Order does not confer blanket protections on all disclosures or responses to
2 discovery and that the protection it affords from public disclosure and use extends
3 only to the limited information or items that are entitled to confidential treatment
4 under the applicable legal principles.
5 2. GOOD CAUSE STATEMENT
6 This action is likely to involve trade secrets, employment practices, personal
7
identifying information of third-parties, and proprietary information for which
8
special protection from public disclosure and from use for any purpose other than
9
prosecution of this action is warranted. Such confidential and proprietary materials
10
and information consist of, among other things, confidential business or financial
11
information, information regarding confidential business practices, highly sensitive
12
personal identifying information, information otherwise generally unavailable to
13
the public, or which may be privileged or otherwise protected from disclosure
14
under state or federal statutes, court rules, case decisions, or common law.
15
Accordingly, to expedite the flow of information, to facilitate the prompt resolution
16
of disputes over confidentiality of discovery materials, to adequately protect
17
information the parties are entitled to keep confidential, to ensure that the parties
18
are permitted reasonable necessary uses of such material in preparation for and in
19
the conduct of trial, to address their handling at the end of the litigation, and serve
20
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
23 confidential for tactical reasons and that nothing be so designated without a good
24 faith belief that it has been maintained in a confidential, non-public manner, and
25 there is good cause why it should not be part of the public record of this case.
26 3. ACKNOWLEDGMENT OF UNDER SEAL FILING
27 PROCEDURE
28 The parties further acknowledge, as set forth in Section 14.3, below, that this
2
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 3 of 15 Page ID #:222
1 Stipulated Protective Order does not entitle them to file confidential information
2 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
3 and the standards that will be applied when a party seeks permission from the court
4 to file material under seal. There is a strong presumption that the public has a right
5 of access to judicial proceedings and records in civil cases. In connection with non-
6 dispositive motions, good cause must be shown to support a filing under seal. See
7
Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
8
Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
9
Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
10
stipulated protective orders require good cause showing), and a specific showing of
11
good cause or compelling reasons with proper evidentiary support and legal
12
justification, must be made with respect to Protected Material that a party seeks to
13
file under seal. The parties’ mere designation of Disclosure or Discovery Material
14
as CONFIDENTIAL does not— without the submission of competent evidence by
15
declaration, establishing that the material sought to be filed under seal qualifies as
16
confidential, privileged, or otherwise protectable—constitute good cause.
17
Further, if a party requests sealing related to a dispositive motion or trial,
18
then compelling reasons, not only good cause, for the sealing must be shown, and
19
the relief sought shall be narrowly tailored to serve the specific interest to be
20
protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
21
2010). For each item or type of information, document, or thing sought to be filed
22
23 or introduced under seal, the party seeking protection must articulate compelling
24 reasons, supported by specific facts and legal justification, for the requested sealing
25 order. Again, competent evidence supporting the application to file documents
26 under seal must be provided by declaration.
27 Any document that is not confidential, privileged, or otherwise protectable
28 in its entirety will not be filed under seal if the confidential portions can be
3
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 4 of 15 Page ID #:223
1 redacted. If documents can be redacted, then a redacted version for public viewing,
2 omitting only the confidential, privileged, or otherwise protectable portions of the
3 document, shall be filed. Any application that seeks to file documents under seal in
4 their entirety should include an explanation of why redaction is not feasible.
5 4. DEFINITIONS
6 4.1 Action: this pending federal lawsuit.
7
4.2 Challenging Party: a Party or Non-Party that challenges the
8
designation of information or items under this Order.
9
4.3 “CONFIDENTIAL” Information or Items: information (regardless of
10
how it is generated, stored or maintained) or tangible things that qualify for
11
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
12
the Good Cause Statement.
13
4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
14
their support staff).
15
4.5 Designating Party: a Party or Non-Party that designates information or
16
items that it produces in disclosures or in responses to discovery as
17
“CONFIDENTIAL.”
18
4.6 Disclosure or Discovery Material: all items or information, regardless
19
of the medium or manner in which it is generated, stored, or maintained (including,
20
among other things, testimony, transcripts, and tangible things), that are produced
21
or generated in disclosures or responses to discovery.
22
23 4.7 Expert: a person with specialized knowledge or experience in a matter
24 pertinent to the litigation who has been retained by a Party or its counsel to serve
25 as an expert witness or as a consultant in this Action.
26 4.8 House Counsel: attorneys who are employees of a party to this
27 Action. House Counsel does not include Outside Counsel of Record or any other
28 outside counsel.
4
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 5 of 15 Page ID #:224
1 4.9 Non-Party: any natural person, partnership, corporation, association or
2 other legal entity not named as a Party to this action.
3 4.10 Outside Counsel of Record: attorneys who are not employees of a
4 party to this Action but are retained to represent a party to this Action and have
5 appeared in this Action on behalf of that party or are affiliated with a law firm that
6 has appeared on behalf of that party, and includes support staff.
7
4.11 Party: any party to this Action, including all of its officers, directors,
8
employees, consultants, retained experts, and Outside Counsel of Record (and their
9
support staffs).
10
4.12 Producing Party: a Party or Non-Party that produces Disclosure or
11
Discovery Material in this Action.
12
4.13 Professional Vendors: persons or entities that provide litigation
13
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
14
demonstrations, and organizing, storing, or retrieving data in any form or medium)
15
and their employees and subcontractors.
16
4.14 Protected Material: any Disclosure or Discovery Material that is
17
designated as “CONFIDENTIAL.”
18
4.15 Receiving Party: a Party that receives Disclosure or Discovery
19
Material from a Producing Party.
20
5. SCOPE
21
The protections conferred by this Stipulation and Order cover not only
22
23 Protected Material (as defined above), but also (1) any information copied or
24 extracted from Protected Material; (2) all copies, excerpts, summaries, or
25 compilations of Protected Material; and (3) any testimony, conversations, or
26 presentations by Parties or their Counsel that might reveal Protected Material.
27 Any use of Protected Material at trial shall be governed by the orders of the
28 trial judge and other applicable authorities. This Order does not govern the use of
5
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 6 of 15 Page ID #:225
1 Protected Material at trial.
2 6. DURATION
3 Once a case proceeds to trial, information that was designated as
4 CONFIDENTIAL or maintained pursuant to this protective order used or
5 introduced as an exhibit at trial becomes public and will be presumptively
6 available to all members of the public, including the press, unless compelling
7
reasons supported by specific factual findings to proceed otherwise are made to the
8
trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
9
(distinguishing “good cause” showing for sealing documents produced in
10
discovery from “compelling reasons” standard when merits-related documents are
11
part of court record). Accordingly, the terms of this protective order do not extend
12
beyond the commencement of the trial.
13
7. DESIGNATING PROTECTED MATERIAL
14
7.1 Exercise of Restraint and Care in Designating Material for
15
Protection. Each Party or Non-Party that designates information or
16
items for protection under this Order must take care to limit any such designation
17
to specific material that qualifies under the appropriate standards. The Designating
18
Party must designate for protection only those parts of material, documents, items
19
or oral or written communications that qualify so that other portions of the
20
material, documents, items or communications for which protection is not
21
warranted are not swept unjustifiably within the ambit of this Order.
22
23 Mass, indiscriminate or routinized designations are prohibited. Designations
24 that are shown to be clearly unjustified or that have been made for an improper
25 purpose (e.g., to unnecessarily encumber the case development process or to
26 impose unnecessary expenses and burdens on other parties) may expose the
27 Designating Party to sanctions.
28 If it comes to a Designating Party’s attention that information or items that it
6
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 7 of 15 Page ID #:226
1 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
3 7.2 Manner and Timing of Designations. Except as otherwise provided in
4 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
5 that qualifies for protection under this Order must be clearly so designated before
6 the material is disclosed or produced.
7
Designation in conformity with this Order requires:
8
(a) for information in documentary form (e.g., paper or electronic
9
documents, but excluding transcripts of depositions or other pretrial or trial
10
proceedings), that the Producing Party affix at a minimum, the legend
11
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
12
contains protected material. If only a portion of the material on a page qualifies for
13
protection, the Producing Party also must clearly identify the protected portion(s)
14
(e.g., by making appropriate markings in the margins).
15
A Party or Non-Party that makes original documents available for inspection
16
need not designate them for protection until after the inspecting Party has indicated
17
which documents it would like copied and produced. During the inspection and
18
before the designation, all of the material made available for inspection shall be
19
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
20
documents it wants copied and produced, the Producing Party must determine
21
which documents, or portions thereof, qualify for protection under this Order.
22
23 Then, before producing the specified documents, the Producing Party must affix
24 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
25 only a portion of the material on a page qualifies for protection, the Producing
26 Party also must clearly identify the protected portion(s) (e.g., by making
27 appropriate markings in the margins).
28 (b) for testimony given in depositions that the Designating Party
7
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 8 of 15 Page ID #:227
1 identifies the Disclosure or Discovery Material on the record, before the close of
2 the deposition all protected testimony.
3 (c) for information produced in some form other than documentary
4 and for any other tangible items, that the Producing Party affix in a prominent
5 place on the exterior of the container or containers in which the information is
6 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
7
information warrants protection, the Producing Party, to the extent practicable,
8
shall identify the protected portion(s).
9
7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
10
failure to designate qualified information or items does not, standing alone, waive
11
the Designating Party’s right to secure protection under this Order for such
12
material. Upon timely correction of a designation, the Receiving Party must make
13
reasonable efforts to assure that the material is treated in accordance with the
14
provisions of this Order.
15
8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
16
8.1. Timing of Challenges. Any Party or Non-Party may challenge a
17
designation of confidentiality at any time that is consistent with the Court’s
18
Scheduling Order.
19
8.2 Meet and Confer. The Challenging Party shall initiate the dispute
20
resolution process under Local Rule 37-1 et seq.
21
8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
22
23 joint stipulation pursuant to Local Rule 37-2.
24 8.4 The burden of persuasion in any such challenge proceeding shall be on
25 the Designating Party. Frivolous challenges, and those made for an improper
26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
27 parties) may expose the Challenging Party to sanctions. Unless the Designating
28 Party has waived or withdrawn the confidentiality designation, all parties shall
8
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 9 of 15 Page ID #:228
1 continue to afford the material in question the level of protection to which it is
2 entitled under the Producing Party’s designation until the Court rules on the
3 challenge.
4
9. ACCESS TO AND USE OF PROTECTED MATERIAL
5
9.1 Basic Principles. A Receiving Party may use Protected Material that is
6
disclosed or produced by another Party or by a Non-Party in connection with this
7
Action only for prosecuting, defending or attempting to settle this Action. Such
8
Protected Material may be disclosed only to the categories of persons and under
9
the conditions described in this Order. When the Action has been terminated, a
10
Receiving Party must comply with the provisions of section 15 below (FINAL
11
12 DISPOSITION).
13 Protected Material must be stored and maintained by a Receiving Party at a
14 location and in a secure manner that ensures that access is limited to the persons
15 authorized under this Order.
16 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
17 otherwise ordered by the court or permitted in writing by the Designating Party, a
18 Receiving Party may disclose any information or item designated
19 “CONFIDENTIAL” only to:
20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
21 well as employees of said Outside Counsel of Record to whom it is reasonably
22 necessary to disclose the information for this Action;
23
(b) the officers, directors, and employees (including House Counsel)
24
of the Receiving Party to whom disclosure is reasonably necessary for this Action;
25
(c) Experts (as defined in this Order) of the Receiving Party to whom
26
disclosure is reasonably necessary for this Action and who have signed the
27
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
28
9
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 10 of 15 Page ID #:229
1 (d) the court and its personnel;
2 (e) court reporters and their staff;
3 (f) professional jury or trial consultants, mock jurors, and Professional
4 Vendors to whom disclosure is reasonably necessary for this Action and who have
5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (g) the author or recipient of a document containing the information or
7
a custodian or other person who otherwise possessed or knew the information;
8
(h) during their depositions, witnesses, and attorneys for witnesses, in
9
the Action to whom disclosure is reasonably necessary provided: (1) the deposing
10
party requests that the witness sign the form attached as Exhibit A hereto; and (2)
11
they will not be permitted to keep any confidential information unless they sign the
12
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
13
agreed by the Designating Party or ordered by the court. Pages of transcribed
14
deposition testimony or exhibits to depositions that reveal Protected Material may
15
be separately bound by the court reporter and may not be disclosed to anyone
16
except as permitted under this Stipulated Protective Order; and
17
(i) any mediators or settlement officers and their supporting personnel,
18
mutually agreed upon by any of the parties engaged in settlement discussions.
19
10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
20
PRODUCED IN OTHER LITIGATION
21
If a Party is served with a subpoena or a court order issued in other litigation
22
23 that compels disclosure of any information or items designated in this Action as
24 “CONFIDENTIAL,” that Party must:
25 (a) promptly notify in writing the Designating Party. Such notification
26 shall include a copy of the subpoena or court order;
27 (b) promptly notify in writing the party who caused the subpoena or
28 order to issue in the other litigation that some or all of the material covered by the
10
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 11 of 15 Page ID #:230
1 subpoena or order is subject to this Protective Order. Such notification shall
2 include a copy of this Stipulated Protective Order; and
3 (c) cooperate with respect to all reasonable procedures sought to be
4 pursued by the Designating Party whose Protected Material may be affected. If the
5 Designating Party timely seeks a protective order, the Party served with the
6 subpoena or court order shall not produce any information designated in this action
7
as “CONFIDENTIAL” before a determination by the court from which the
8
subpoena or order issued, unless the Party has obtained the Designating Party’s
9
permission. The Designating Party shall bear the burden and expense of seeking
10
protection in that court of its confidential material and nothing in these provisions
11
should be construed as authorizing or encouraging a Receiving Party in this Action
12
to disobey a lawful directive from another court.
13
14 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
BE PRODUCED IN THIS LITIGATION
15
16 (a) The terms of this Order are applicable to information produced by a
17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
18 produced by Non-Parties in connection with this litigation is protected by the
19 remedies and relief provided by this Order. Nothing in these provisions should be
20 construed as prohibiting a Non-Party from seeking additional protections.
21 (b) In the event that a Party is required, by a valid discovery request,
22 to produce a Non-Party’s confidential information in its possession, and the Party
23
is subject to an agreement with the Non-Party not to produce the Non-Party’s
24
confidential information, then the Party shall:
25
(1) promptly notify in writing the Requesting Party and the Non-Party
26
that some or all of the information requested is subject to a confidentiality
27
agreement with a Non-Party;
28
11
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 12 of 15 Page ID #:231
1 (2) promptly provide the Non-Party with a copy of the Stipulated
2 Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 specific description of the information requested; and
4 (3) make the information requested available for inspection by the
5 Non-Party, if requested.
6 (c) If the Non-Party fails to seek a protective order from this court
7
within 14 days of receiving the notice and accompanying information, the
8
Receiving Party may produce the Non-Party’s confidential information responsive
9
to the discovery request. If the Non-Party timely seeks a protective order, the
10
Receiving Party shall not produce any information in its possession or control that
11
is subject to the confidentiality agreement with the Non-Party before a
12
determination by the court. Absent a court order to the contrary, the Non-Party
13
shall bear the burden and expense of seeking protection in this court of its
14
Protected Material.
15
12. UNAUTHORIZED DISCLOSURE OF PROTECTED
16
MATERIAL
17 If a Receiving Party learns that, by inadvertence or otherwise, it has
18 disclosed Protected Material to any person or in any circumstance not authorized
19 under this Stipulated Protective Order, the Receiving Party must immediately (a)
20 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
21 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
22 the person or persons to whom unauthorized disclosures were made of all the terms
23 of this Order, and (d) request such person or persons to execute the
24 “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A.
25
13. INADVERTENT PRODUCTION OF PRIVILEGED OR
26 OTHERWISE PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain
27
inadvertently produced material is subject to a claim of privilege or other
28
12
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 13 of 15 Page ID #:232
1 protection, the obligations of the Receiving Parties are those set forth in Federal
2 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify
3 whatever procedure may be established in an e-discovery order that provides for
4 production without prior privilege review. Pursuant to Federal Rule of Evidence
5 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
6 of a communication or information covered by the attorney-client privilege or
7
work product protection, the parties may incorporate their agreement in the
8
stipulated protective order submitted to the court.
9
14. MISCELLANEOUS
10
14.1 Right to Further Relief. Nothing in this Order abridges the right of any
11
person to seek its modification by the Court in the future.
12
14.2 Right to Assert Other Objections. By stipulating to the entry of this
13
Protective Order, no Party waives any right it otherwise would have to object to
14
disclosing or producing any information or item on any ground not addressed in
15
this Stipulated Protective Order. Similarly, no Party waives any right to object on
16
any ground to use in evidence of any of the material covered by this Protective
17
Order.
18
14.3 Filing Protected Material. A Party that seeks to file under seal any
19
Protected Material must comply with Local Civil Rule 79-5. Protected Material
20
may only be filed under seal pursuant to a court order authorizing the sealing of the
21
specific Protected Material. If a Party’s request to file Protected Material under
22
23 seal is denied by the court, then the Receiving Party may file the information in the
24 public record unless otherwise instructed by the court.
25 15. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 6, within
27 60 days of a written request by the Designating Party, each Receiving Party must
28 return all Protected Material to the Producing Party or destroy such material. As
13
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page14o0f15 Page ID #:233
I |} used in this subdivision, “all Protected Material” includes all copies, abstracts,
2 || compilations, summaries, and any other format reproducing or capturing any of the
3 || Protected Material. Whether the Protected Material is returned or destroyed, the
4 || Receiving Party must submit a written certification to the Producing Party (and, if
> |! not the same person or entity, to the Designating Party) by the 60-day deadline that
6 (1) identifies (by category, where appropriate) all the Protected Material that was
7 I returned or destroyed and (2) affirms that the Receiving Party has not retained any
8 copies, abstracts, compilations, summaries or any other format reproducing or
7 capturing any of the Protected Material. Notwithstanding this provision, Counsel
'0 are entitled to retain an archival copy of all pleadings, motion papers, trial,
0 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
and trial exhibits, expert reports, attorney work product, and consultant and expert
work product, even if such materials contain Protected Material. Any such archival
Is copies that contain or constitute Protected Material remain subject to this
16 Protective Order as set forth in Section 6 (DURATION).
7 16. VIOLATION
13 Any violation of this Order may be punished by appropriate measures
19 including, without limitation, contempt proceedings and/or monetary sanctions.
20
21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22 xe dL
93 || DATED: October 12, 2022 Liew OG
D. EARLY
24 nited States Magistrate Judge
25
26
27
28
14
Case 8:22-cv-00372-CJC-JDE Document 31 Filed 10/12/22 Page 15 of 15 Page ID #:234
1 EXHIBIT A
2
ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND BY TERMS OF
3 THE PROTECTIVE ORDER
4
5
I, ____________________, have received a copy of the Stipulation for Protective
6
Order and Protective Order entered in the action entitled:
7
Zuniga v. House Foods America Corporation et. al. (U.S.D.C., Central
8
District of California, Case No. 8:22-cv-00372-CJC-JDEx).
9
I have carefully read and understand the provisions of the Protective Order. I
10
agree that I will comply with all provision of the Protective Order and will use any
11
“CONFIDENTIAL” information only for purposes of this action. At the end of this
12
litigation or my involvement in this litigation, whichever occurs first, I will either
13
destroy or return to counsel for the party by whom I am employed or retained all
14
such “CONFIDENTIAL” documents or information that comes into my
15
possession.
16
17
18
19 DATED: _______________ ______________________________
Name
20
21
22
23
24
25
26
27
28
15