The opinion
NOTE: CHANGES MADE
1 BY THE COURT
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3
4
5
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12
JOSUE SANCHEZ, No. 2:23-cv-03239-JFW (BFMx)
13 inti
yp aint, ORDER RE: STIPULATED
14 PROTECTIVE ORDER
CONTEMPORARY
15 INFORMATION CORPORATION,
et al.,
16
Defendants.
17
18 Having considered the papers and finding that good cause exists, the
19 || Parties’ Stipulated Protective Order is granted with the changes made by
20 || the Court as reflected in the Stipulated Protective Order attached
21 |) hereto and issued contemporaneously with this Order.
22
23 || ITIS SO ORDERED.
24
25 || DATED: August 21, 2023 TEN
26
27 BRIANNA FULLER MIRCHEFF
UNITED STATES MAGISTRATE JUDGE
28
1
2
3
4
5
6
7
8 IN THE UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
10
11 JOSUE SANCHEZ, Case No.: 2:23-cv-03239-JFW-BFMx
12 Plaintiff, STIPULATED PROTECTIVE
ORDER
13 v.
14 CONTEMPORARY INFORMATION
15 CORPORATION, ONE SOURCE
TECHNOLOGY, LLC d/b/a
16 ASURINT, and FIRST
17 ADVANTAGE BACKGROUND
SERVICES CORP.,
18
19 Defendants.
20
21 1. GENERAL
22 1.1 Purposes and Limitations. Discovery in this action is likely to involve
23 production of confidential, proprietary, or private information for which special
24 protection from public disclosure and from use for any purpose other than prosecuting
25 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
26 petition the Court to enter the following Stipulated Protective Order. The parties
27 acknowledge that this Order does not confer blanket protections on all disclosures or
28 responses to discovery and that the protection it affords from public disclosure and
1 use extends only to the limited information or items that are entitled to confidential
2 treatment under the applicable legal principles. The parties further acknowledge, as
3 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
4 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the
5 procedures that must be followed and the standards that will be applied when a party
6 seeks permission from the court to file material under seal.
7 1.2 Good Cause Statement.
8 This action is likely to involve trade secrets, customer and pricing lists and
9 other valuable research, development, commercial, financial, technical and/or
10 proprietary information for which special protection from public disclosure and from
11 use for any purpose other than prosecution of this action is warranted. Such
12 confidential and proprietary materials and information consist of, among other things,
13 confidential business or financial information, information regarding confidential
14 business practices, or other confidential research, development, or commercial
15 information (including information implicating privacy rights of third parties),
16 information otherwise generally unavailable to the public, or which may be privileged
17 or otherwise protected from disclosure under state or federal statutes, court rules, case
18 decisions, or common law. Accordingly, to expedite the flow of information, to
19 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
20 to adequately protect information the parties are entitled to keep confidential, to
21 ensure that the parties are permitted reasonable necessary uses of such material in
22 preparation for and in the conduct of trial, to address their handling at the end of the
23 litigation, and serve the ends of justice, a protective order for such information is
24 justified in this matter. It is the intent of the parties that information will not be
25 designated as confidential for tactical reasons and that nothing be so designated
26 without a good faith belief that it has been maintained in a confidential, non-public
27 manner, and there is good cause why it should not be part of the public record of this
28 case.
1 2. DEFINITIONS
2 2.1 Action: this pending federal lawsuit, including all appellate proceedings.
3 2.2 Challenging Party: a Party or Non-Party that challenges the designation
4 of information or items under this Order.
5 2.3 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information
6 (regardless of how it is generated, stored or maintained) or tangible things that qualify
7 for protection under Federal Rule of Civil Procedure 26(c) and as specified above in
8 the Good Cause Statement, and contain confidential information of a nature that
9 would place a defendant Designating Party at a competitive disadvantage if disclosed
10 to another defendant party, including but not limited to trade secret or other
11 confidential research, development, financial, or other commercial information.”
12 2.4 “CONFIDENTIAL” Information or Items: information (regardless of
13 how it is generated, stored or maintained) or tangible things that qualify for protection
14 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
15 Cause Statement.
16 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their
17 support staff).
18 2.6 Designating Party: a Party or Non-Party that designates information or
19 items that it produces in disclosures or in responses to discovery as
20 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
21 2.7 Disclosure or Discovery Material: all items or information, regardless
22 of the medium or manner in which it is generated, stored, or maintained (including,
23 among other things, testimony, transcripts, and tangible things), that are produced or
24 generated in disclosures or responses to discovery in this matter.
25 2.8 Expert: a person with specialized knowledge or experience in a matter
26 pertinent to the litigation who has been retained by a Party or its counsel to serve as
27 an expert witness or as a consultant in this Action.
28
1 2.9 House Counsel: attorneys who are employees of a party to this Action.
2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4 2.10 Non-Party: any natural person, partnership, corporation, association, or
5 other legal entity not named as a Party to this action.
6 2.11 Outside Counsel of Record: attorneys who are not employees of a party
7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm that
9 has appeared on behalf of that party, including support staff.
10 2.12 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.14 Professional Vendors: persons or entities that provide litigation support
16 services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.15 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES
21 ONLY.”
22 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
23 from a Producing Party.
24
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or extracted
28 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
1 Protected Material; and (3) any testimony, conversations, or presentations by Parties
2 or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
4 trial judge. This Order does not govern the use of Protected Material at trial.
5
6 4. DURATION
7 Once a case proceeds to trial, all of the court-filed information to be introduced
8 that was previously designated as confidential or maintained pursuant to this
9 protective order becomes public and will be presumptively available to all members
10 of the public, including the press, unless compelling reasons supported by specific
11 factual findings to proceed otherwise are made to the trial judge in advance of the
12 trial. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
13 2006) (distinguishing “good cause” showing for sealing documents produced in
14 discovery from “compelling reasons” standard when merits-related documents are
15 part of court record). Accordingly, the terms of this protective order do not extend
16 beyond the commencement of the trial.
17
18 5. DESIGNATING PROTECTED MATERIAL
19 5.1 Exercise of Restraint and Care in Designating Material for Protection.
20 Each Party or Non-Party that designates information or items for protection under this
21 Order must take care to limit any such designation to specific material that qualifies
22 under the appropriate standards. The Designating Party must designate for protection
23 only those parts of material, documents, items, or oral or written communications that
24 qualify so that other portions of the material, documents, items, or communications
25 for which protection is not warranted are not swept unjustifiably within the ambit of
26 this Order.
27 Mass, indiscriminate, or routinized designations are prohibited. Designations
28 that are shown to be clearly unjustified or that have been made for an improper
1 purpose (e.g., to unnecessarily encumber the case development process or to impose
2 unnecessary expenses and burdens on other parties) may expose the Designating Party
3 to sanctions.
4 If it comes to a Designating Party’s attention that information or items that it
5 designated for protection do not qualify for protection, that Designating Party must
6 promptly notify all other Parties that it is withdrawing the inapplicable designation.
7 5.2 Manner and Timing of Designations. Except as otherwise provided in
8 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
10 under this Order must be clearly so designated before the material is disclosed or
11 produced.
12 Designation in conformity with this Order requires:
13 (a) for information in documentary form (e.g., paper or electronic
14 documents, but excluding transcripts of depositions or other pretrial or trial
15 proceedings), that the Producing Party affix, at a minimum, the legend
16 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
17 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
18 material. If only a portion or portions of the material on a page qualifies for protection,
19 the Producing Party also must clearly identify the protected portion(s) (e.g., by
20 making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and before
24 the designation, all of the material made available for inspection shall be deemed
25 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After
26 the inspecting Party has identified the documents it wants copied and produced, the
27 Producing Party must determine which documents, or portions thereof, qualify for
28 protection under this Order. Then, before producing the specified documents, the
1 Producing Party must affix the “CONFIDENTIAL legend” to each page that contains
2 Protected Material. If only a portion or portions of the material on a page qualifies for
3 protection, the Producing Party also must clearly identify the protected portion(s)
4 (e.g., by making appropriate markings in the margins).
5 (b) Deposition testimony may be designated as Protected Material by any
6 party by indicating on the record at the deposition that the testimony is confidential
7 and subject to the provisions of this Protective Order, or alternatively, within fourteen
8 (14) days after receiving the deposition transcript, by notifying in writing the parties
9 and those who were present at the deposition of the designations by circulating a copy
10 of the transcript wherein the designating party identifies line by line the portions of
11 the testimony that it contends should be designated confidential, unless otherwise
12 agreed. The entire deposition transcript (including any exhibits not previously
13 produced in discovery in the Action) shall be treated as Protected Material under this
14 Protective Order until the expiration of the above-referenced 14-day period for
15 designation, except that, if the deponent is a non-party, the deponent (and his or her
16 counsel, if any) may review the transcript of his or her own deposition during the 14-
17 day period subject to this Protective Order upon executing the required
18 Acknowledgement and Agreement to Comply with Protective Order in the form
19 attached hereto as Exhibit A. After a party designates portions of a deposition
20 transcript as Protected Material, the front of the original and each copy of the
21 deposition transcript shall be marked “This deposition transcript includes
22 CONFIDENTIAL INFORMATION SUBJECT TO PROTECTIVE ORDER.” If the
23 deposition was filmed, both the recording storage medium (i.e., CD or DVD) and its
24 container shall also be labeled: “This deposition transcript includes CONFIDENTIAL
25 INFORMATION SUBJECT TO PROTECTIVE ORDER.” If an AEO designation is
26 made on the record, and participants are asked to leave the deposition, Plaintiff shall
27 be permitted to stay under all circumstances.
28
1 (c) for information produced in some form other than documentary and
2 for any other tangible items, that the Producing Party affix in a prominent place on
3 the exterior of the container or containers in which the information is stored the legend
4 “CONFIDENTIAL or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” If only
5 a portion or portions of the information warrants protection, the Producing Party, to
6 the extent practicable, shall identify the protected portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
8 failure to designate qualified information or items does not, standing alone, waive the
9 Designating Party’s right to secure protection under this Order for such material.
10 Upon timely correction of a designation, the Receiving Party must make reasonable
11 efforts to assure that the material is treated in accordance with the provisions of this
12 Order.
13
14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 6.1 Timing of Challenges. Timing of Challenges. Any Party or Non-Party
16 may challenge a designation of Protected Material at any time that is consistent with
17 the Court’s Scheduling Order.
18 6.2 Meet and Confer. In the event that any party to this litigation disagrees
19 with the designation of any information as Protected Material, the parties shall first
20 try to resolve the dispute in good faith on an informal basis, such as by production of
21 redacted copies. If the dispute cannot be resolved, the objecting party shall initiate the
22 dispute resolution process under Local Rule 37-1, et seq. Any discovery motion must
23 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
24 6.3 Burden. The burden of persuasion in any such challenge proceeding shall
25 be on 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 parties)
27 may expose the Challenging Party to sanctions. Unless the Designating Party has
28 waived or withdrawn the confidentiality designation, all parties shall continue to
1 afford the material in question the level of protection to which it is entitled under the
2 Producing Party’s designation until the Court rules on the challenge.
3
4 7. ACCESS TO AND USE OF PROTECTED MATERIAL
5 7.1 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 the
9 conditions described in this Order. When the Action has been terminated, a Receiving
10 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
11 Protected Material must be stored and maintained by a Receiving Party at a
12 location and in a secure manner that ensures that access is limited to the persons
13 authorized under this Order.
14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
15 otherwise ordered by the Court or permitted in writing by the Designating Party, a
16 Receiving Party may disclose any information or item designated
17 “CONFIDENTIAL” only to:
18 (a) the parties in this Action;
19 (b) the Receiving Party’s Outside Counsel of Record in this Action,
20 as well as employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (c) the officers, directors, and employees (including House Counsel)
23 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (d) Experts (as defined in this Order) of the Receiving Party to whom
25 disclosure is reasonably necessary for this Action and who have signed the
26 “Acknowledgment and Agreement to Comply with Protective Order” (Exhibit A);
27 (e) the Court and its personnel;
28 (f) court reporters and their staff;
1 (g) professional jury or trial consultants, mock jurors, and
2 Professional Vendors to whom disclosure is reasonably necessary for this Action and
3 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (h) the author or recipient of a document containing the information
5 or a custodian or other person who otherwise possessed or knew the information;
6 (i) during their depositions, witnesses, and attorneys for witnesses, in
7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
8 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
9 will not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 agreed by the Designating Party or ordered by the Court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may be
13 separately bound by the court reporter and may not be disclosed to anyone except as
14 permitted under this Stipulated Protective Order; and
15 (j) any mediator, settlement officer, or other third-party neutral in
16 connection with alternative dispute resolution proceedings, and their supporting
17 personnel, mutually agreed upon by any of the parties engaged in settlement
18 discussions.
19 7.3 Disclosure of Defendants’ “CONFIDENTIAL – ATTORNEYS’ EYES
20 ONLY” Information or Items. Information designated as “CONFIDENTIAL –
21 ATTORNEYS’ EYES ONLY” may only be disclosed the persons listed above in
22 7.2(b), (d), (e), (f), (g), (h), (i), (j) and Plaintiff.
23
24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
25 PRODUCED IN OTHER LITIGATION
26 If a Party is served with a subpoena or a court order issued in other litigation
27 that compels disclosure of any information or items designated in this Action as
28 “CONFIDENTIAL,” or CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” that
1 Party will immediately notify the other parties and agree to cooperate in the protection
2 of the materials. Under no circumstances shall the Party be expected to incur legal
3 fees to protect the document.
4 (a) promptly notify in writing the Designating Party. Such notification shall
5 include a copy of the subpoena or court order;
6 (b) promptly notify in writing the party who caused the subpoena or order to
7 issue in the other litigation that some or all of the material covered by the subpoena
8 or order is subject to this Protective Order. Such notification shall include a copy of
9 this Stipulated Protective Order; and
10 (c) cooperate with respect to all reasonable procedures sought to be pursued
11 by the Designating Party whose Protected Material may be affected.
12 If the Designating Party timely seeks a protective order, the Party served with
13 the subpoena or court order shall not produce any information designated in this action
14 as “CONFIDENTIAL or CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before
15 a determination by the court from which the subpoena or order issued, unless the Party
16 has obtained the Designating Party’s permission. The Designating Party shall bear the
17 burden and expense of seeking protection in that court of its confidential material and
18 nothing in these provisions should be construed as authorizing or encouraging a
19 Receiving Party in this Action to disobey a lawful directive from another court.
20
21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
22 PRODUCED IN THIS LITIGATION
23 (a) The terms of this Order are applicable to information produced by a Non-
24 Party in this Action and designated as “CONFIDENTIAL or CONFIDENTIAL –
25 ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties in
26 connection with this litigation is protected by the remedies and relief provided by this
27 Order. Nothing in these provisions should be construed as prohibiting a Non-Party
28 from seeking additional protections.
1 (b) In the event that a Party is required, by a valid discovery request, to produce
2 a Non-Party’s confidential information in its possession, and the Party is subject to an
3 agreement with the Non-Party not to produce the Non-Party’s confidential
4 information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the Non-Party
6 that some or all of the information requested is subject to a confidentiality agreement
7 with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the Stipulated
9 Protective Order in this Action, the relevant discovery request(s), and a reasonably
10 specific description of the information requested; and
11 (3) make the information requested available for inspection by the Non-
12 Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this Court within 14
14 days of receiving the notice and accompanying information, the Receiving Party may
15 produce the Non-Party’s confidential information responsive to the discovery request.
16 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
17 any information in its possession or control that is subject to the confidentiality
18 agreement with the Non-Party before a determination by the Court. Absent a court
19 order to the contrary, the Non-Party shall bear the burden and expense of seeking
20 protection in this Court of its Protected Material.
21
22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
24 Protected Material to any person or in any circumstance not authorized under this
25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
28 persons to whom unauthorized disclosures were made of all the terms of this Order,
1 and (d) request such person or persons to execute the “Acknowledgment and
2 Agreement to Comply with Protective Order” that is attached hereto as Exhibit A.
3
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection,
8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without prior
11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12 parties reach an agreement on the effect of disclosure of a communication or
13 information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement in the stipulated protective order submitted
15 to the Court.
16
17 12. DOCUMENTS OR INFORMATION OBTAINED FROM THIRD
18 PARTIES
19 Documents or information produced by a non-party may be designated as
20 Protected Material by the non-party in the manner set forth above. Further, the
21 documents or information produced by a non-party shall be treated as Protected
22 Material, whether or not they are designated as such, for fourteen (14) days after
23 receipt of the documents and information to allow a party to review the material for
24 confidentiality.
25 A copy of this Protective Order must be provided to any third parties served
26 with subpoenas in this Action.
27
28
1 13. MISCELLANEOUS
2 13.1 Right to Further Relief. Nothing in this Order abridges the right of any
3 person to seek its modification by the Court in the future.
4 13.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order, no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9 13.3 Filing Protected Material. A Party that seeks to file under seal any
10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
11 only be filed under seal pursuant to a court order authorizing the sealing of the specific
12 Protected Material at issue; good cause must be shown in the request to file under
13 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
14 then the Receiving Party may file the information in the public record unless
15 otherwise instructed by the Court.
16 13.4 Use of Party’s Own Confidential Information. Nothing in this Protective
17 Order shall restrict the right of any party to use its own confidential information or
18 Protected Material for any purpose whatsoever, but if any such use results in a
19 disclosure that causes the confidential information or Protected Material to lose such
20 designation, then it shall no longer be subject to any protection under this Protective
21 Order.
22
23 14. FINAL DISPOSITION
24 After the final disposition of this Action, within 60 days of a written request by
25 the Designating Party, each Receiving Party must return all Protected Material to the
26 Producing Party or destroy such material. As used in this subdivision, “all Protected
27 Material” includes all copies, abstracts, compilations, summaries, and any other
28 format reproducing or capturing any of the Protected Material. Whether the Protected
1 Material is returned or destroyed, the Receiving Party must submit a written
2 certification to the Producing Party (and, if not the same person or entity, to the
3 Designating Party) by the 60 day deadline that (1) identifies (by category, where
4 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms
5 that the Receiving Party has not retained any copies, abstracts, compilations,
6 summaries or any other format reproducing or capturing any of the Protected Material.
7 Notwithstanding this provision, counsel are entitled to retain an archival copy of all
8 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
9 correspondence, deposition and trial exhibits, expert reports, attorney work product,
10 and consultant and expert work product, even if such materials contain Protected
11 Material. Any such archival copies that contain or constitute Protected Material
12 remain subject to this Protective Order as set forth in Section 4.
13 Upon final termination of this Action, whether by settlement, dismissal, or
14 other disposition, the provisions of this Protective Order shall continue to be binding
15 upon all persons or entities who are subject to the terms hereof (including former
16 employees of any party who received Protected Material. The Court shall retain
17 continuing jurisdiction as permitted by law in order to enforce the terms of this Order.
18
19
20
21
22
23
24
25
26
27
28
1 15. VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate
3 || measures including, without limitation, contempt proceedings and/or monetary
4 || sanctions.
5
6
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 [sf Natalie L. Cascario [sf Jenna Dakroub
ARNALL GOLDEN GREGORY LLP Jenna Dakroub, CA # 350170
9 Henry R. Chalmers CONSUMER ATTORNEYS
10 || Admitted Pro Hac Vice 8245 N. 85th Way
henry.chalmers@agg.com Scottsdale, AZ 85258
Natalie L. Cascario T: (602) 807-1525
12 || Admitted Pro Hac Vice F: (718) 715-1750
3 natalie.cascario@agg.com E: jdakroub@consumerattorneys.com
171 17th Street NW, Suite 2100
14 Atlanta. GA 30363 Youssef Hammoud, CA #321934
15 T: (404) 873-8646 E: yh@lawhammoud.com
Counsel for Defendant First Advantage HAMMOUD LAW, P.C.
16 . 3744 E. Chapman Ave., #F12269
Background Services Corp.
17 Orange, CA 92859
ig || WARREN TERZIAN LLP T: (949) 301-9692
Dan Terzian (SBN 283835) F: (949) vo Pin .
19 dan.terzian@warrenterzian.com Attorney Jer Plaintiff
20 222 N. Pacific Coast Highway, Suite Josue Sanchez
2000
[s/
21 | Los Angeles, CA 90245 sLJohn J. Atallah
9 T: (213) 410-2620 John J. Atallah, CA Bar No. 294116
Counsel for Defendant First Advantage Foley & Lardner LLP .
23 Backaround Services Cor 555 South Flower Street, Suite 3300
9 P Los Angeles, CA 90071-2418
Telephone: 213.972.4500
25 Facsimile: 213.486.0065
26 jatallah@foley.com
Attorneys for Defendant Contemporary
Information Corporation
28
1
2
3
4
IN THE UNITED STATES DISTRICT COURT
5
FOR THE CENTRAL DISTRICT OF CALIFORNIA
6 WESTERN DIVISION
7
JOSUE SANCHEZ, Case No.: 2:23-cv-03239-JFW-BFMx
8
Plaintiff,
9
EXHIBIT A
10 v.
11
CONTEMPORARY INFORMATION
12 CORPORATION, et al.,
13
Defendants.
14
15
16 ACKNOWLEDGMENT AND AGREEMENT TO COMPLY.
17 I, _____________ [print or type full name], of ________________ [print
or type full address], declare that I have read in its entirety and understand the
18
Protective Order that was issued in the above-captioned Litigation. I agree to comply
19 with all the terms of this Protective Order, and I understand and acknowledge that
failure to so comply could expose me to sanctions and punishment in the nature of
20 contempt. I agree that I will not disclose in any manner any information or item that
is subject to this Protective Order to any person or entity except in strict compliance
21 with the provisions of the Protective Order. As soon as my work in connection with
that action has ended, but not later than 30 days after the termination of that action
22
(including any appeals), I will return or destroy any confidential document that I
23 received, any copy of or excerpt from a confidential document, and any notes or other
document that contains information from a confidential document.
24
25
Date: _______________________________
26 Printed Name:
_________________________
27
Signature:
28