# IDC Logistics, Inc. v. Dile Solutions LLC

> District Court, C.D. California · August 16, 2023

URL: https://www.frixlaw.com/law-library/cases/9984118

## Case

- **Court:** District Court, C.D. California
- **Decided:** August 16, 2023
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9984118

## Opinion text

1 ROSS LLP
Peter W. Ross (CA Bar No. 109741)
2
pross@rossllp.la
3 Richard A. Schwartz (CA Bar No. 267469)
rschwartz@rossllp.la
4 1900 Avenue of the Stars, Suite 1225
Los Angeles, California 90067
5
Telephone: (424) 704-5600
6 Facsimile: (424) 724-5680
7
KREVOLIN & HORST, LLC
8 Jessica G. Cino (CA Bar No. 240455)
cino@khlawfirm.com
9 1201 West Peachtree St NW, Suite 3250
Atlanta, Georgia 30309
10
Telephone: (404) 888-9700
11 Facsimile: (404) 888-9577
12
Attorneys for Defendant
13 DILE Solutions LLC
14
UNITED STATES DISTRICT COURT
15
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
16
17
IDC LOGISTICS INC., a California Case No. 2:22-cv-08690-MWF(ASx)
18 Corporation, Hon. Michael W. Fitzgerald
19
Plaintiff, PROTECTIVE ORDER
20
vs. Complaint filed: December 2, 2022
21
Trial date: August 26, 2024
22 DILE SOLUTIONS LLC, a Georgia
Limited Liability Company,
23
24 Defendant.
25
26
27
1 1. A. PURPOSES AND LIMITATIONS
2 Disclosure and discovery activity in this action are likely to involve production
3 of confidential, proprietary, or private information for which special protection from
4 public disclosure and from use for any purpose other than prosecuting this litigation
5 may be warranted. Accordingly, the parties hereby stipulate to and petition the court
6 to enter the following Stipulated Protective Order. The parties acknowledge that this
7 Order does not confer blanket protections on all disclosures or responses to discovery
8 and that the protection it affords from public disclosure and use extends only to the
9 limited information or items that are entitled to confidential treatment under the
10 applicable legal principles. The parties further acknowledge, as set forth in Section
11 12.3, below, that this Stipulated Protective Order does not entitle them to file
12 confidential information under seal; L.R. 79-5 sets forth the procedures that must be
13 followed and the standards that will be applied when a party seeks permission from
14 the court to file material under seal.
15
16 B. GOOD CAUSE STATEMENT
17 This action is likely to involve confidential financial and proprietary
18 commercial information, for which special protection from public disclosure and
19 from use for any purpose other than prosecution of this action is warranted. Such
20 confidential and proprietary materials and information consist of, among other things,
21 the parties’ business or financial information; information regarding confidential and
22 proprietary business practices; information produced through confidential research
23 and development; proprietary commercial information such as financial statements,
24 invoices, and marketing and sales strategies; private client and pricing lists and
25 information; confidential contractual terms and other confidential information
26 relating to the commercial drayage business; information relating to proprietary
27 software and processes used by the parties in the drayage business; other information
1 related to the commercial drayage business; as well as information implicating
2 privacy rights of third parties, information otherwise generally unavailable to the
3 public, and information which may be privileged or otherwise protected from
4 disclosure under state or federal statutes, court rules, case decisions, or common law,
5 including but not limited to the California Uniform Trade Secrets Act and the Defend
6 Trade Secrets Act.
7 Disclosure of such information to third parties “would likely “provide
8 competitors insight into the parties' business operations, and courts generally “refuse[
9 ] to permit their files to serve as ... sources of business information that might harm a
10 litigant's competitive standing.” Capitol Specialty Ins. Corp. v. GEICO Gen. Ins. Co.,
11 CV 20-672-RSWL-EX, 2021 WL 7708484, at *3 (C.D. Cal. Apr. 14, 2021) (quoting
12 Nixon v. Warner Commc'ns, Inc., 435 U.S. 589, 598 (1978)); see also In re
13 Photochromic Lens Antitrust Litig., 2173, 2013 WL 12156446, at *1 (M.D. Fla. Oct.
14 21, 2013) (finding protective order appropriate where “parties anticipated that
15 discovery would include extensive cost, forecasting, production, and pricing data that
16 may provide the parties' suppliers and customers a commercial advantage in
17 subsequent negotiations”); Green v. Nicholson Mfg. Co., CIV.A. 9:04CV227, 2005
18 WL 5959605, at *2 (E.D. Tex. Sept. 22, 2005) (“[C]lient information and sales
19 contacts represent business relationships developed over years whose value could be
20 needlessly compromised by public disclosure”).
21 Accordingly, to expedite the flow of information, to facilitate the prompt
22 resolution of disputes over confidentiality of discovery materials, to adequately
23 protect information the parties are entitled to keep confidential, to ensure that the
24 parties are permitted reasonably necessary uses of such material in preparation for
25 and in the conduct of trial, to address their handling at the end of the litigation, and
26 serve the ends of justice, a protective order for such information is justified in this
27 matter. It is the intent of the parties that information will not be designated as
1 faith belief that it has been maintained in a confidential, non-public manner, and there
2 is good cause why it should not be part of the public record of this case.
3

4 2. DEFINITIONS
5 2.1 Challenging Party: a Party or Non-Party that challenges the designation
6 of information or items under this Order.
7 2.2 “CONFIDENTIAL” Information or Items: information (regardless of
8 how it is generated, stored or maintained) or tangible things that qualify for protection
9 under Federal Rule of Civil Procedure 26(c).
10 2.3 Counsel: Outside Counsel of Record and House Counsel (as well as their
11 support staff).
12 2.4 Designating Party: a Party or Non-Party that designates information or
13 items that it produces in disclosures or in responses to discovery as
14 “CONFIDENTIAL.”
15 2.5 Disclosure or Discovery Material: all items or information, regardless of
16 the medium or manner in which it is generated, stored, or maintained (including,
17 among other things, testimony, transcripts, and tangible things), that are produced or
18 generated in disclosures or responses to discovery in this matter.
19 2.6 Expert: a person with specialized knowledge or experience in a matter
20 pertinent to the litigation who has been retained by a Party or its counsel to serve as
21 an expert witness or as a consultant in this action.
22 2.7 House Counsel: attorneys who are employees of a party to this action.
23 House Counsel does not include Outside Counsel of Record or any other outside
24 counsel.
25 2.8 Non-Party: any natural person, partnership, corporation, association, or
26 other legal entity not named as a Party to this action.
27 2.9 Outside Counsel of Record: attorneys who are not employees of a party
1 appeared in this action on behalf of that party or are affiliated with a law firm which
2 has appeared on behalf of that party.
3 2.10 Party: any party to this action, including all of its officers, directors,
4 employees, consultants, retained experts, and Outside Counsel of Record (and their
5 support staffs).
6 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this action.
8 2.12 Professional Vendors: persons or entities that provide litigation support
9 services (e.g., photocopying, videotaping, translating, preparing exhibits or
10 demonstrations, and organizing, storing, or retrieving data in any form or medium)
11 and their employees and subcontractors.
12 2.13 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
15 from a Producing Party.
16
17 3. SCOPE
18 The protections conferred by this Stipulation and Order cover not only
19 Protected Material (as defined above), but also (1) any information copied or
20 extracted from Protected Material; (2) all copies, excerpts, summaries, or
21 compilations of Protected Material; and (3) any testimony, conversations, or
22 presentations by Parties or their Counsel that might reveal Protected Material.
23 However, the protections conferred by this Stipulation and Order do not cover the
24 following information: (a) any information that is in the public domain at the time of
25 disclosure to a Receiving Party or becomes part of the public domain after its
26 disclosure to a Receiving Party as a result of publication not involving a violation of
27 this Order, including becoming part of the public record through trial or otherwise;
1 obtained by the Receiving Party after the disclosure from a source who obtained the
2 information lawfully and under no obligation of confidentiality to the Designating
3 Party. Any use of Protected Material at trial shall be governed by a separate
4 agreement or order.
5
6 4. DURATION
7 Even after final disposition of this litigation, the confidentiality obligations
8 imposed by this Order shall remain in effect until a Designating Party agrees
9 otherwise in writing or a court order otherwise directs. Final disposition shall be
10 deemed to be the later of (1) dismissal of all claims and defenses in this action, with
11 or without prejudice; and (2) final judgment herein after the completion and
12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
13 including the time limits for filing any motions or applications for extension of time
14 pursuant to applicable law.
15
16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under this
19 Order must take care to limit any such designation to specific material that qualifies
20 under the appropriate standards. The Designating Party must designate for protection
21 only those parts of material, documents, items, or oral or written communications that
22 qualify – so that other portions of the material, documents, items, or communications
23 for which protection is not warranted are not swept unjustifiably within the ambit of
24 this Order.
25 Mass, indiscriminate, or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber or retard the case development process or to
1 Party to sanctions.
2 If it comes to a Designating Party’s attention that information or items that it
3 designated for protection do not qualify for protection, that Designating Party must
4 promptly notify all other Parties that it is withdrawing the mistaken designation.
5 5.2 Manner and Timing of Designations. Except as otherwise provided in
6 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
8 under this Order must be clearly so designated before the material is disclosed or
9 produced.
10 Designation in conformity with this Order requires:
11 (a) For information in documentary form (e.g., paper or electronic documents,
12 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
13 Producing Party affix the legend “CONFIDENTIAL” to each page that contains
14 protected material. If only a portion or portions of the material on a page qualifies for
15 protection, the Producing Party also must clearly identify the protected portion(s)
16 (e.g., by making appropriate markings in the margins).
17 A Party or Non-Party that makes original documents or materials available for
18 inspection need not designate them for protection until after the inspecting Party has
19 indicated which material it would like copied and produced. During the inspection
20 and before the designation, all of the material made available for inspection shall be
21 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
22 it wants copied and produced, the Producing Party must determine which documents,
23 or portions thereof, qualify for protection under this Order. Then, before producing
24 the specified documents, the Producing Party must affix the “CONFIDENTIAL”
25 legend to each page that contains Protected Material. If only a portion or portions of
26 the material on a page qualifies for protection, the Producing Party also must clearly
27 identify the protected portion(s) (e.g., by making appropriate markings in the
1 (b) for testimony given in deposition or in other pretrial or trial proceedings,
2 that the Designating Party identify on the record, before the close of the deposition,
3 hearing, or other proceeding, all protected testimony.
4 (c) for information produced in some form other than documentary and for any
5 other tangible items, that the Producing Party affix in a prominent place on the
6 exterior of the container or containers in which the information or item is stored the
7 legend “CONFIDENTIAL.” If only a portion or portions of the information or item
8 warrant protection, the Producing Party, to the extent practicable, shall identify the
9 protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
11 failure to designate qualified information or items does not, standing alone, waive the
12 Designating Party’s right to secure protection under this Order for such material.
13 Upon timely correction of a designation, the Receiving Party must make reasonable
14 efforts to assure that the material is treated in accordance with the provisions of this
15 Order.
16
17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
19 designation of confidentiality at any time. Unless a prompt challenge to a Designating
20 Party’s confidentiality designation is necessary to avoid foreseeable, substantial
21 unfairness, unnecessary economic burdens, or a significant disruption or delay of the
22 litigation, a Party does not waive its right to challenge a confidentiality designation
23 by electing not to mount a challenge promptly after the original designation is
24 disclosed.
25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
26 resolution process by providing written notice of each designation it is challenging
27 and describing the basis for each challenge. To avoid ambiguity as to whether a
1 confidentiality is being made in accordance with this specific paragraph of the
2 Protective Order. The parties shall attempt to resolve each challenge in good faith and
3 must begin the process by conferring directly (in voice to voice dialogue; other forms
4 of communication are not sufficient) within 14 days of the date of service of notice.
5 In conferring, the Challenging Party must explain the basis for its belief that the
6 confidentiality designation was not proper and must give the Designating Party an
7 opportunity to review the designated material, to reconsider the circumstances, and, if
8 no change in designation is offered, to explain the basis for the chosen designation. A
9 Challenging Party may proceed to the next stage of the challenge process only if it
10 has engaged in this meet and confer process first or establishes that the Designating
11 Party is unwilling to participate in the meet and confer process in a timely manner.
12 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without
13 court intervention, the Designating Party shall file and serve a motion to retain
14 confidentiality pursuant to L.R. 7-4 (and in compliance with L.R. 79-5, if applicable)
15 within 21 days of the initial notice of challenge or within 14 days of the parties
16 agreeing that the meet and confer process will not resolve their dispute, whichever is
17 earlier. Each such motion must be accompanied by a competent declaration affirming
18 that the movant has complied with the meet and confer requirements imposed in the
19 preceding paragraph. Failure by the Designating Party to make such a motion
20 including the required declaration within 21 days (or 14 days, if applicable) shall
21 automatically waive the confidentiality designation for each challenged designation.
22 In addition, the Challenging Party may file a motion challenging a confidentiality
23 designation at any time if there is good cause for doing so, including a challenge to
24 the designation of a deposition transcript or any portions thereof. Any motion brought
25 pursuant to this provision must be accompanied by a competent declaration affirming
26 that the movant has complied with the meet and confer requirements imposed by the
27 preceding paragraph.
1 Designating Party. Frivolous challenges, and those made for an improper purpose
2 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
3 expose the Challenging Party to sanctions. Unless the Designating Party has waived
4 the confidentiality designation by failing to file a motion to retain confidentiality as
5 described above, all parties shall continue to afford the material in question the level
6 of protection to which it is entitled under the Producing Party’s designation until the
7 court rules on the challenge.
8
9 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1 Basic Principles. A Receiving Party may use Protected Material that is
11 disclosed or produced by another Party or by a Non-Party in connection with this case
12 only for prosecuting, defending, or attempting to settle this litigation. Such Protected
13 Material may be disclosed only to the categories of persons and under the conditions
14 described in this Order. When the litigation has been terminated, a Receiving Party
15 must comply with the provisions of section 13 below (FINAL DISPOSITION).
16 Protected Material must be stored and maintained by a Receiving Party at a
17 location and in a secure manner that ensures that access is limited to the persons
18 authorized under this Order.
19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
20 otherwise ordered by the court or permitted in writing by the Designating Party, a
21 Receiving Party may disclose any information or item designated
22 “CONFIDENTIAL” only to:
23 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
24 employees of said Outside Counsel of Record to whom it is reasonably necessary to
25 disclose the information for this litigation and who have signed the
26 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A;
27 (b) the officers, directors, and employees (including House Counsel) of the
1 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (c) Experts (as defined in this Order) of the Receiving Party to whom
3 disclosure is reasonably necessary for this litigation and who have signed the
4 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (d) the court and its personnel;
6 (e) court reporters and their staff
7 (f) professional jury or trial consultants, mock jurors, and Professional
8 Vendors to whom disclosure is reasonably necessary for this litigation and who have
9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
10 (g) the author or recipient of a document containing the information or a
11 custodian or other person who otherwise possessed or knew the information.
12 (h) during their depositions, witnesses in the action to whom disclosure is
13 reasonably necessary and who have signed the “Acknowledgment and Agreement to
14 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
15 by the court. Pages of transcribed deposition testimony or exhibits to depositions that
16 reveal Protected Material must be separately bound by the court reporter and may not
17 be disclosed to anyone except as permitted under this Stipulated Protective Order;
18 and
19 (i) any mediator or settlement officer, and their supporting personnel, mutually
20 agreed upon by any of the parties engaged in settlement discussions.
21
22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
23 OTHER LITIGATION
24 If a Party is served with a subpoena or a court order issued in other litigation
25 that compels disclosure of any information or items designated in this action as
26 “CONFIDENTIAL,” that Party must:
27 (a) promptly notify in writing the Designating Party. Such notification shall
1 (b) promptly notify in writing the party who caused the subpoena or order to
2 issue in the other litigation that some or all of the material covered by the subpoena or
3 order is subject to this Protective Order. Such notification shall include a copy of this
4 Stipulated Protective Order; and
5 (c) cooperate with respect to all reasonable procedures sought to be pursued by
6 the Designating Party whose Protected Material may be affected.
7 If the Designating Party timely seeks a protective order, the Party served with
8 the subpoena or court order shall not produce any information designated in this
9 action as “CONFIDENTIAL” before a determination by the court from which the
10 subpoena or order issued, unless the Party has obtained the Designating Party’s
11 permission. The Designating Party shall bear the burden and expense of seeking
12 protection in that court of its confidential material – and nothing in these provisions
13 should be construed as authorizing or encouraging a Receiving Party in this action to
14 disobey a lawful directive from another court.
15
16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
17 PRODUCED IN THIS LITIGATION
18 (a) The terms of this Order are applicable to information produced by a Non-
19 Party in this action and designated as “CONFIDENTIAL.” Such information
20 produced by Non-Parties in connection with this litigation is protected by the
21 remedies and relief provided by this Order. Nothing in these provisions should be
22 construed as prohibiting a Non-Party from seeking additional protections.
23 (b) In the event that a Party is required, by a valid discovery request, to
24 produce a Non-Party’s confidential information in its possession, and the Party is
25 subject to an agreement with the Non-Party not to produce the Non-Party’s
26 confidential information, then the Party shall:
27 (1) promptly notify in writing the Requesting Party and the Non-Party
1 agreement with a Non-Party;
2 (2) promptly provide the Non-Party with a copy of the Stipulated
3 Protective Order in this litigation, the relevant discovery request(s), and a
4 reasonably specific description of the information requested; and
5 (3) make the information requested available for inspection by the Non-
6 Party.
7 (c) If the Non-Party fails to object or seek a protective order from this court
8 within 14 days of receiving the notice and accompanying information, the Receiving
9 Party may produce the Non-Party’s confidential information responsive to the
10 discovery request. If the Non-Party timely seeks a protective order, the Receiving
11 Party shall not produce any information in its possession or control that is subject to
12 the confidentiality agreement with the Non-Party before a determination by the court.
13 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
14 of seeking protection in this court of its Protected Material.
15
16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
18 Protected Material to any person or in any circumstance not authorized under this
19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
20 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
21 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
22 persons to whom unauthorized disclosures were made of all the terms of this Order,
23 and (d) request such person or persons to execute the “Acknowledgment and
24 Agreement to Be Bound” that is attached hereto as Exhibit A.
25
26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
27 PROTECTED MATERIAL
1 inadvertently produced material is subject to a claim of privilege or other protection,
2 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
3 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
4 may be established in an e-discovery order that provides for production without prior
5 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
6 parties reach an agreement on the effect of disclosure of a communication or
7 information covered by the attorney-client privilege or work product protection, the
8 parties may incorporate their agreement in the stipulated protective order submitted to
9 the court.
10
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13 person to seek its modification by the court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in this
17 Stipulated Protective Order. Similarly, no Party waives any right to object on any
18 ground to use in evidence of any of the material covered by this Protective Order.
19 12.3 Filing Protected Material. Without written permission from the
20 Designating Party or a court order secured after appropriate notice to all interested
21 persons, a Party may not file in the public record in this action any Protected
22 Material. A Party that seeks to file under seal any Protected Material must comply
23 with L.R. 79-5. Protected Material may only be filed under seal pursuant to a court
24 order authorizing the sealing of the specific Protected Material at issue. Pursuant to
25 L.R. 79-5, a sealing order will issue only upon a request establishing that the
26 Protected Material at issue is privileged, protectable as a trade secret, or otherwise
27 entitled to protection under the law. If a Receiving Party's request to file Protected
1 Party may file the information in the public record pursuant to L.R. 79-5 unless
2 otherwise instructed by the court.
3
4 13. FINAL DISPOSITION
5 Within 60 days after the final disposition of this action, as defined in paragraph
6 4, each Receiving Party must return all Protected Material to the Producing Party or
7 destroy such material. As used in this subdivision, “all Protected Material” includes
8 all copies, abstracts, compilations, summaries, and any other format reproducing or
9 capturing any of the Protected Material. Whether the Protected Material is returned or
10 destroyed, the Receiving Party must submit a written certification to the Producing
11 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
12 deadline that (1) identifies (by category, where appropriate) all the Protected Material
13 that was returned or destroyed and (2) affirms that the Receiving Party has not
14 retained any copies, abstracts, compilations, summaries or any other format
15 reproducing or capturing any of the Protected Material. Notwithstanding this
16 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
17 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
18 deposition and trial exhibits, expert reports, attorney work product, and consultant
19 and expert work product, even if such materials contain Protected Material. Any such
20 archival copies that contain or constitute Protected Material remain subject to this
21 Protective Order as set forth in Section 4 (DURATION).
22
23 14. Any violation of this Order may be punished by any and all appropriate
24 measures including, without limitation, contempt proceedings and/or monetary
25 sanctions.
26
27 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
1 DATED: August 10, 2023 KREVOLIN & HORST, LLC
JESSICA G. CINO
2
ROSS LLP
3 RICHARD A. SCHWARTZ
4
5
6
By: /s/ Jessica G. Cino
7 JESSICA G. CINO
8 Attorneys for Defendant DILE
SOLUTIONS LLC
9
10
11
DATED: August 10, 2023 FRANDZEL ROBINS BLOOM & CSATO, L.C.
12 LAWRENCE S. GROSBERG
BRETT L. McCLURE
13
GERRICK M. WARRINGTON
14
15
16 By: /s/ Gerrick M. Warrington*
GERRICK M. WARRINGTON
17
Attorneys for Plaintiff IDC LOGISTICS
18 INC
*signed with express permission
19
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22
23
DATED: __A_u_g_u_s_t _1_6_, _2_0_2_3___
24
25
26
________/_ s_ _/ _S_a_g_ar_____________________
Honorable Alka Sagar
27
United States Magistrate Judge
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury that
5 I have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Central District of California on
7 ______ [date] in the case of IDC Logistics Inc. v. DILE Solutions, LLC, No. 2:22-
8 cv-08690-MWF(ASx). I agree to comply with and to be bound by all the terms of
9 this Stipulated Protective Order and I understand and acknowledge that failure to so
10 comply could expose me to sanctions and punishment in the nature of contempt. I
11 solemnly promise that I will not disclose in any manner any information or item that
12 is subject to this Stipulated Protective Order to any person or entity except in strict
13 compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action.
18 I hereby appoint ____________________ [print or type full name] of
19 ___________________________________ [print or type full address and telephone
20 number] as my California agent for service of process in connection with this action
21 or any proceedings related to enforcement of this Stipulated Protective Order.
22 Date: ________________________________
23
24 City and State where sworn and signed: _______________________________
25
26 Printed name: _______________________________
27

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9984118. Public record. Not legal advice.