distinguishing “good cause” 24 showing for sealing documents produced in discovery from “compelling reasons” 25 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 24 showing for sealing documents produced in discovery from “compelling reasons” 25 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 1 of 15 Page ID #:336
1 SCHEIN LAW GROUP LIANG LY LLP
Joshua D. Schein (SBN 264055) Jason Liang (SBN 251235)
2 E-mail: jschein@scheinlawgroup.com E-mail: jliang@lianglyllp.com
2029 Century Park East, Suite 400 601 South Figueroa Street, Suite 1950
3 Los Angeles, California 90067 Los Angeles, California 90017
Telephone: (424) 355-8555 Telephone: (213) 262-8000
4 Facsimile: (424) 355-8087 Facsimile: (213) 335-7776
5 Attorneys for Plaintiffs
6 JAMAL AL-MASHAT, et al.
7
SEYFARTH SHAW LLP DOWD BENNETT LLP
8 Diana Tabacopoulos (SBN 128238) James F. Bennett
E-mail: E-mail: jbennett@dowdbennett.com
9 dtabacopoulos@seyfarth.com John D. Comerford
Jessica C. Koenig (SBN 340974) E-mail:
10 E-mail: jkoenig@seyfarth.com jcomerford@dowdbennett.com
2029 Century Park East, Suite 3500 Carolina C. Beck
11 Los Angeles, California 90067-3021 E-Mail: cbeck@dowdbennett.com
Telephone: (310) 277-7200 7676 Forsyth Blvd., Suite 1900
12 Facsimile: (310) 201-5219 St. Louis, Missouri 63119
Telephone: (314) 889-7300
13 Facsimile: (314) 863-2111
14 Attorneys for Defendant STV
INCORPORATED
15
16 UNITED STATES DISTRICT COURT
17 CENTRAL DISTRICT OF CALIFORNIA
18
19 JAMAL AL MASHAT, an individual, Case No. 2:22-cv-06268 FMO
ALBERD GHARIBIAN, an individual, (MARx)
20 and MUNA AL MASHAT, an
individual, Hon. Fernando M. Olguin
21
Plaintiffs, Hon. Margo A. Rocconi
22
v. JOINT STIPULATION AND
23 [PROPOSED] PROTECTIVE
STV INCORPORATED, a California ORDER
24 Corporation; and DOES 1 through 10,
25 Defendants.
Complaint Filed: August 3, 2022
26 Removal Filed: September 1, 2022
Trial Date: None Set
27
28
STIPULATED PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 2 of 15 Page ID #:337
1 TO THE CLERK OF THE COURT AND TO ALL PARTIES AND
2
THEIR COUNSEL OF RECORD:
3
4 Plaintiffs Jamal Al-Mashat, Alberd Gharibian, and Muna Al-Mashat
5 (“Plaintiffs”) and Defendant STV Incorporated (“Defendant”), by and through their
6
counsel of record, hereby stipulate and agree to the following proposed protective
7
8 order:
9
1. INTRODUCTION
10
1.1. PURPOSES AND LIMITATIONS
11
Discovery in this action is likely to involve production of confidential,
12
proprietary, or private information for which special protection from public
13
disclosure and from use for any purpose other than prosecuting this litigation may
14
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
15
enter the following Stipulated Protective Order. The parties acknowledge that this
16
Order does not confer blanket protections on all disclosures or responses to
17
discovery and that the protection it affords from public disclosure and use extends
18
only to the limited information or items that are entitled to confidential treatment
19
under the applicable legal principles. The parties further acknowledge, as set forth
20
in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
21
file confidential information under seal; Civil Local Rule 79-5 sets forth the
22
procedures that must be followed and the standards that will be applied when a
23
party seeks permission from the court to file material under seal.
24
1.2. GOOD CAUSE STATEMENT
25
This action is likely to involve Defendant’s commercial, financial, technical
26
and/or proprietary information for which special protection from public disclosure
27
and from use for any purpose other than prosecution of this action is warranted.
28
- 2 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 3 of 15 Page ID #:338
1 Such confidential and proprietary materials and information consist of, among other
2 things, confidential business or financial information, information regarding
3 confidential business practices, or other confidential commercial information
4 (including information implicating privacy rights of third parties), information
5 otherwise generally unavailable to the public, or which may be privileged or
6 otherwise protected from disclosure under state or federal statutes, court rules, case
7 decisions, or common law.
8 In addition to maintaining Defendant’s own documents as confidential,
9 Defendant must maintain the confidentiality of certain third-party documents
10 pursuant to contractual agreement and otherwise such as proprietary information,
11 financial information, and technical information.
12 Accordingly, to expedite the flow of information, to facilitate the prompt
13 resolution of disputes over confidentiality of discovery materials, to adequately
14 protect information the parties are entitled to keep confidential, to ensure that the
15 parties are permitted reasonable necessary uses of such material in preparation for
16 and in the conduct of trial, to address their handling at the end of the litigation, and
17 serve the ends of justice, a protective order for such information is justified in this
18 matter. It is the intent of the parties that information will not be designated as
19 confidential for tactical reasons and that nothing be so designated without a good
20 faith belief that it has been maintained in a confidential, non-public manner, and
21 there is good cause why it should not be part of the public record of this case.
22 2. DEFINITIONS
23 2.1. Action: This pending federal lawsuit, Jamal Al- Mashat, et al. v. STV
24 Incorporated, et al., 2:22-cv-06268-FMO(MARx).
25 2.2. Challenging Party: a Party or Non-Party that challenges the
26 designation of information or items under this Order.
27 2.3. “CONFIDENTIAL” Information or Items: information (regardless of
28 how it is generated, stored or maintained) or tangible things that qualify for
- 3 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 4 of 15 Page ID #:339
1 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
2 the Good Cause Statement.
3 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as
4 their support staff).
5 2.5. Designating Party: a Party or Non-Party that designates information or
6 items that it produces in disclosures or in responses to discovery as
7 “CONFIDENTIAL.”
8 2.6. Disclosure or Discovery Material: all items or information, regardless
9 of the medium or manner in which it is generated, stored, or maintained (including,
10 among other things, testimony, transcripts, and tangible things), that are produced
11 or generated in disclosures or responses to discovery in this matter.
12 2.7. Expert: a person with specialized knowledge or experience in a matter
13 pertinent to the litigation who has been retained by a Party or its counsel to serve as
14 an expert witness or as a consultant in this Action.
15 2.8. 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 2.9. Non-Party: any natural person, partnership, corporation, association, or
19 other legal entity not named as a Party to this action.
20 2.10. Outside Counsel of Record: attorneys who are not employees of a
21 party to this Action but are retained to represent or advise a party to this Action and
22 have appeared in this Action on behalf of that party or are affiliated with a law firm
23 which has appeared on behalf of that party, and includes support staff.
24 2.11. 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 2.12. Producing Party: a Party or Non-Party that produces Disclosure or
28 Discovery Material in this Action.
- 4 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 5 of 15 Page ID #:340
1 2.13. Professional Vendors: persons or entities that provide litigation
2 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
3 demonstrations, and organizing, storing, or retrieving data in any form or medium)
4 and their employees and subcontractors.
5 2.14. Protected Material: any Disclosure or Discovery Material that is
6 designated as “CONFIDENTIAL.”
7 2.15. Receiving Party: a Party that receives Disclosure or Discovery
8 Material from a Producing Party.
9 3. SCOPE
10 The protections conferred by this Stipulation and Order cover not only
11 Protected Material (as defined above), but also (1) any information copied or
12 extracted from Protected Material; (2) all copies, excerpts, summaries, or
13 compilations of Protected Material; and (3) any testimony, conversations, or
14 presentations by Parties or their Counsel that might reveal Protected Material.
15 Any use of Protected Material at trial will be governed by the orders of the
16 trial judge. This Order does not govern the use of Protected Material at trial.
17 4. DURATION
18 Once a case proceeds to trial, all of the information that was designated as
19 confidential or maintained pursuant to this protective order becomes public and will
20 be presumptively available to all members of the public, including the press, unless
21 compelling reasons supported by specific factual findings to proceed otherwise are
22 made to the trial judge in advance of the trial. See Kamakana v. City and County of
23 Honolulu, 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause”
24 showing for sealing documents produced in discovery from “compelling reasons”
25 standard when merits-related documents are part of court record). Accordingly, the
26 terms of this protective order do not extend beyond the commencement of the trial.
27
28
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PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 6 of 15 Page ID #:341
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,
8 items, or communications for which protection is not warranted are not swept
9 unjustifiably 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
13 impose unnecessary expenses and burdens on other parties) may expose the
14 Designating 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” (hereinafter “CONFIDENTIAL legend”), to each page that
28 contains protected material. If only a portion or portions of the material on a page
- 6 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 7 of 15 Page ID #:342
1 qualifies for protection, the Producing Party also must clearly identify the protected
2 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-
3 Party that makes original documents available for inspection need not designate
4 them for protection until after the inspecting Party has indicated which documents it
5 would like copied and produced. During the inspection and before the designation,
6 all of the material made available for inspection will be deemed
7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it
8 wants copied and produced, the Producing Party must determine which documents,
9 or portions thereof, qualify for protection under this Order. Then, before producing
10 the specified documents, the Producing Party must affix the “CONFIDENTIAL
11 legend” to each page that contains Protected Material. If only a portion or portions
12 of the material on a page qualifies for protection, the Producing Party also must
13 clearly identify the protected portion(s) (e.g., by making appropriate markings in
14 the margins).
15 (b) for testimony given in depositions that the Designating Party identify
16 the Disclosure or Discovery Material on the record, before the close of the
17 deposition all protected testimony.
18 (c) for information produced in some form other than documentary and
19 for any other tangible items, that the Producing Party affix in a prominent place on
20 the exterior of the container or containers in which the information is stored the
21 legend “CONFIDENTIAL.” If only a portion or portions of the information
22 warrants protection, the Producing Party, to the extent practicable, will identify the
23 protected portion(s).
24 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such material.
27 Upon timely correction of a designation, the Receiving Party must make reasonable
28
- 7 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 8 of 15 Page ID #:343
1 efforts to assure that the material is treated in accordance with the provisions of this
2 Order.
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
5 designation of confidentiality at any time that is consistent with the Court’s
6 Scheduling Order.
7 6.2. Meet and Confer. The Challenging Party will initiate the dispute
8 resolution process under Local Rule 37.1 et seq.
9 6.3. The burden of persuasion in any such challenge proceeding will be on
10 the Designating Party. Frivolous challenges, and those made for an improper
11 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
12 parties) may expose the Challenging Party to sanctions. Unless the Designating
13 Party has waived or withdrawn the confidentiality designation, all parties will
14 continue to afford the material in question the level of protection to which it is
15 entitled under the Producing Party’s designation until the Court rules on the
16 challenge.
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1. Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this
20 Action only for prosecuting, defending, or attempting to settle this Action. Such
21 Protected Material may be disclosed only to the categories of persons and under the
22 conditions described in this Order. When the Action has been terminated, a
23 Receiving Party must comply with the provisions of section 13 below (FINAL
24 DISPOSITION).
25 Protected Material must be stored and maintained by a Receiving Party at a
26 location and in a secure manner that ensures that access is limited to the persons
27 authorized under this Order.
28
- 8 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 9 of 15 Page ID #:344
1 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
2 otherwise ordered by the court or permitted in writing by the Designating Party, a
3 Receiving Party may disclose any information or item designated
4 “CONFIDENTIAL” only to:
5 (a) the Receiving Party’s Outside Counsel of Record in this Action,
6 as well as employees of said Outside Counsel of Record to whom it is reasonably
7 necessary to disclose the information for this Action;
8 (b) the officers, directors, and employees (including House
9 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this
10 Action;
11 (c) Experts (as defined in this Order) of the Receiving Party to
12 whom disclosure is reasonably necessary for this Action and who have signed the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (d) the Court and its personnel;
15 (e) court reporters and their staff;
16 (f) professional jury or trial consultants, mock jurors, and
17 Professional Vendors to whom disclosure is reasonably necessary for this Action
18 and who have signed the “Acknowledgment and Agreement to Be Bound”
19 (Exhibit A);
20 (g) during their depositions, witnesses, and attorneys for witnesses,
21 in the Action to whom disclosure is reasonably necessary provided: (1) the
22 deposing party requests that the witness sign the form attached as Exhibit A hereto;
23 and (2) they will not be permitted to keep any confidential information unless they
24 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
25 otherwise agreed by the Designating Party or ordered by the court. Pages of
26 transcribed deposition testimony or exhibits to depositions that reveal Protected
27 Material may be separately bound by the court reporter and may not be disclosed to
28 anyone except as permitted under this Stipulated Protective Order; and
- 9 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 10 of 15 Page ID #:345
1 (h) any mediator or settlement officer, and their supporting
2 personnel, mutually agreed upon by any of the parties engaged in settlement
3 discussions, who have signed the “Acknowledgment and Agreement to Be Bound”
4 (Exhibit A).
5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
6 IN OTHER LITIGATION
7 If a Party is served with a subpoena or a court order issued in other litigation
8 that compels disclosure of any information or items designated in this Action as
9 “CONFIDENTIAL,” that Party must:
10 (a) promptly notify in writing the Designating Party. Such notification
11 will include a copy of the subpoena or court order;
12 (b) promptly notify in writing the party who caused the subpoena or order
13 to issue in the other litigation that some or all of the material covered by the
14 subpoena or order is subject to this Protective Order. Such notification will include
15 a copy of this Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served with
19 the subpoena or court order will not produce any information designated in this
20 action as “CONFIDENTIAL” before a determination by the court from which the
21 subpoena or order issued, unless the Party has obtained the Designating Party’s
22 permission. The Designating Party will bear the burden and expense of seeking
23 protection in that court of its confidential material and nothing in these provisions
24 should be construed as authorizing or encouraging a Receiving Party in this Action
25 to disobey a lawful directive from another court.
26
27
28
- 10 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 11 of 15 Page ID #:346
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a
4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
5 produced by Non-Parties in connection with this litigation is protected by the
6 remedies and relief provided by this Order. Nothing in these provisions should be
7 construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 produce a Non-Party’s confidential information in its possession, and the Party is
10 subject to an agreement with the Non-Party not to produce the Non-Party’s
11 confidential information, then the Party will:
12 (1) promptly notify in writing the Requesting Party and the
13 Non-Party that some or all of the information requested is subject to a
14 confidentiality agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated
16 Protective Order in this Action, the relevant discovery request(s), and a reasonably
17 specific description of the information requested; and
18 (c) If the Non-Party fails to seek a protective order from this court within
19 14 days of receiving the notice and accompanying information, the Receiving Party
20 may produce the Non-Party’s confidential information responsive to the discovery
21 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
22 not produce any information in its possession or control that is subject to the
23 confidentiality agreement with the Non-Party before a determination by the court.
24 Non-Parties may also delegate to a Party such methods of production on its behalf
25 such that the Non-Party need not bear the burden and expense of seeking protection
26 in this court of its Protected Material.
27
28
- 11 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 12 of 15 Page ID #:347
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of this Order,
8 and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” that is attached hereto as Exhibit A.
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other
14 protection, the obligations of the Receiving Parties are those set forth in Federal
15 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
16 whatever procedure may be established in an e-discovery order that provides for
17 production without prior privilege review. Pursuant to Federal Rule of Evidence
18 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
19 of a communication or information covered by the attorney-client privilege or work
20 product protection, the parties may incorporate their agreement in the stipulated
21 protective order submitted to the court.
22 12. MISCELLANEOUS
23 12.1. Right to Further Relief. Nothing in this Order abridges the right of any
24 person to seek its modification by the Court in the future.
25 12.2. Right to Assert Other Objections. By stipulating to the entry of this
26 Protective Order no Party waives any right it otherwise would have to object to
27 disclosing or producing any information or item on any ground not addressed in
28 this Stipulated Protective Order. Similarly, no Party waives any right to object on
- 12 -
PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 13 of 15 Page ID #:348
1 any ground to use in evidence of any of the material covered by this Protective
2 Order.
3 12.3. Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Civil Local Rule 79-5. Protected Material
5 may only be filed under seal pursuant to a court order authorizing the sealing of the
6 specific Protected Material at issue. If a Party’s request to file Protected Material
7 under seal is denied by the court, then the Receiving Party may file the information
8 in the public record unless otherwise instructed by the court.
9 13. FINAL DISPOSITION
10 After the final disposition of this Action, as defined in paragraph 4, within 60
11 days of a written request by the Designating Party, each Receiving Party must
12 return all Protected Material to the Producing Party or destroy such material. As
13 used in this subdivision, “all Protected Material” includes all copies, abstracts,
14 compilations, summaries, and any other format reproducing or capturing any of the
15 Protected Material. Whether the Protected Material is returned or destroyed, the
16 Receiving Party must submit a written certification to the Producing Party (and, if
17 not the same person or entity, to the Designating Party) by the 60 day deadline that
18 (1) identifies (by category, where appropriate) all the Protected Material that was
19 returned or destroyed and (2) affirms that the Receiving Party has not retained any
20 copies, abstracts, compilations, summaries or any other format reproducing or
21 capturing any of the Protected Material. Notwithstanding this provision, Counsel
22 are entitled to retain an archival copy of all pleadings, motion papers, trial,
23 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
24 and trial exhibits, expert reports, attorney work product, and consultant and expert
25 work product, even if such materials contain Protected Material. Any such archival
26 copies that contain or constitute Protected Material remain subject to this Protective
27 Order as set forth in Section 4 (DURATION).
28
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PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 14o0f15 Page ID #:349
1 14. Any willful violation of this Order may be punished by civil or
2 || criminal contempt proceedings, financial or evidentiary sanctions, reference to
3 || disciplinary authorities, or other appropriate action at the discretion of the Court.
4 Pursuant to Central District Local Rule 5-4.3.4(2)(1), I, Diana Tabacopoulos,
5 || hereby attest that all other signatories listed, and on whose behalf this filing is
6 || submitted, concur in the filing’s content and have authorized the filing.
g || DATED: February 24, 2023 Respectfully submitted,
9 SEYFARTH SHAW LLP
10
By: /s/ Diana Tabacopoulos
11 Diana Tabacopoulos
12 Jessica C. Koenig
Attorneys for Defendant
13 STV INCORPORATED
14
15 || DATED: February 24, 2023 SCHEIN LAW GROUP
16 LIANG LY LLP
17 By: /s/ Joshua D. Schein
18 Joshua D. Schein
Jason Liang
19 Attorneys for Plaintiffs
40 JAMAL AL-MASHAT, et al.
21
22 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
4 DATED: March 7, 2023
25
26 LER co — IN. MARGO A. R NI
17 United States Magistrate Judge
28
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PROTECTIVE ORDER
Case 2:22-cv-06268-FMO-MAR Document 29 Filed 03/07/23 Page 15 of 15 Page ID #:350
1 EXHIBIT A
2
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I, [print or type full name], of [print or type full address], declare under
4
penalty of perjury that I have read in its entirety and understand the Stipulated
5
Protective Order that was issued by the United States District Court for the Central
6
District of California on [date] in the case of Jamal Al- Mashat, et al. v. STV
7
Incorporated, et al., 2:22-cv-06268-FMO(MARx). I agree to comply with and to be
8
bound by all the terms of this Stipulated Protective Order and I understand and
9
acknowledge that failure to so comply could expose me to sanctions and punishment
10
in the nature of contempt. I solemnly promise that I will not disclose in any manner
11
any information or item that is subject to this Stipulated Protective Order to any
12
person or entity except in strict compliance with the provisions of this Order.
13
I further agree to submit to the jurisdiction of the United States District Court
14
for the Central District of California for the purpose of enforcing the terms of this
15
Stipulated Protective Order, even if such enforcement proceedings occur after
16
termination of this action. I hereby appoint [print or type full name] of [print or type
17
full address and telephone number] as my California agent for service of process in
18
connection with this action or any proceedings related to enforcement of this
19
Stipulated Protective Order.
20
21
Date: ___________________
22
Printed Name: ______________________
23
Signature: _______________________
24
25
26
27
28
- 15 -
PROTECTIVE ORDER