distinguishing “good cause” showing 3 for sealing documents produced in discovery from “compelling reasons” standard 4 when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” showing 3 for sealing documents produced in discovery from “compelling reasons” standard 4 when merits-related documents are part of court record
- even stipulated protective orders 8 require good cause showing
Written by the judges who cited it.
The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 SOUTHERN DIVISION
11 JEFF BLOOM, an individual and DEVON Case No. 8:23-cv-00442-JWH-JDE
BLOOM, an individual,
12
Plaintiffs,
13 STIPULATED PROTECTIVE
v. ORDER
14
STATE FARM GENERAL INSURANCE
15 COMPANY, an Illinois corporation; and
DOES 1 TO 25, inclusive.
16
Defendants.
17
18 Based on the Stipulation (Dkt. 27) between Plaintiffs Jeff and Devon Bloom
19 (“Plaintiffs”) and Defendant State Farm General Insurance Company (“State Farm”)
20 (collectively referred to herein as “Parties”) and good cause appearing, the Court
21 finds and orders as follows.
22 1. PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 proprietary or private information for which special protection from public
25 disclosure and from use for any purpose other than pursuing this litigation may be
26 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
27 the following Stipulated Protective Order. The parties acknowledge that this Order
28 does not confer blanket protections on all disclosures or responses to discovery and
1 that the protection it affords from public disclosure and use extends only to the
2 limited information or items that are entitled to confidential treatment under the
3 applicable legal principles.
4 2. GOOD CAUSE STATEMENT
5 This action is likely to involve trade secrets customer and pricing lists and other
6 valuable research, development, commercial, financial, technical and/or proprietary
7 information for which special protection from public disclosure and from use for any
8 purpose other than prosecution of this action is warranted. Such confidential and
9 proprietary materials and information consist of, among other things, confidential
10 business or financial information, information regarding confidential business
11 practices, or other confidential research, development, or commercial information
12 (including information implicating privacy rights of third parties), information
13 otherwise generally unavailable to the public, or which may be privileged or otherwise
14 protected from disclosure under state or federal statutes, court rules, case decisions, or
15 common law. Accordingly, to expedite the flow of information, to facilitate the prompt
16 resolution of disputes over confidentiality of discovery materials, to adequately protect
17 information the parties are entitled to keep confidential, to ensure that the parties are
18 permitted reasonable necessary uses of such material in preparation for and in the
19 conduct of trial, to address their handling at the end of the litigation, and serve the ends
20 of justice, a protective order for such information is justified in this matter. It is the
21 intent of the parties that information will not be designated as confidential for tactical
22 reasons and that nothing be so designated without a good faith belief that it has been
23 maintained in a confidential, non-public manner, and there is good cause why it should
24 not be part of the public record of this case.
25 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
26 The parties further acknowledge, as set forth in Section 14.3, below, that this
27 Stipulated Protective Order does not entitle them to file confidential information under
28 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
1 standards that will be applied when a party seeks permission from the court to file
2 material under seal. There is a strong presumption that the public has a right of access
3 to judicial proceedings and records in civil cases. In connection with non-dispositive
4 motions, good cause must be shown to support a filing under seal. See Kamakana v.
5 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
6 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
7 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
8 require good cause showing), and a specific showing of good cause or compelling
9 reasons with proper evidentiary support and legal justification, must be made with
10 respect to Protected Material that a party seeks to file under seal. The parties’ mere
11 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
12 without the submission of competent evidence by declaration, establishing that the
13 material sought to be filed under seal qualifies as confidential, privileged, or otherwise
14 protectable—constitute good cause.
15 Further, if a party requests sealing related to a dispositive motion or trial, then
16 compelling reasons, not only good cause, for the sealing must be shown, and the relief
17 sought shall be narrowly tailored to serve the specific interest to be protected. See
18 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
19 or type of information, document, or thing sought to be filed or introduced under seal,
20 the party seeking protection must articulate compelling reasons, supported by specific
21 facts and legal justification, for the requested sealing order. Again, competent evidence
22 supporting the application to file documents under seal must be provided by
23 declaration.
24 Any document that is not confidential, privileged, or otherwise protectable in
25 its entirety will not be filed under seal if the confidential portions can be redacted. If
26 documents can be redacted, then a redacted version for public viewing, omitting only
27 the confidential, privileged, or otherwise protectable portions of the document, shall
28 be filed. Any application that seeks to file documents under seal in their entirety should
1 include an explanation of why redaction is not feasible.
2 4. DEFINITIONS
3 4.1 Action: This pending federal lawsuit.
4 4.2 Challenging Party: a Party or Non-Party that challenges the
5 designation of information or items under this Order.
6 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
7 how it is generated, stored or maintained) or tangible things that qualify for protection
8 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
9 Statement.
10 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
11 support staff).
12 4.5 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 4.6 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.
19 4.7 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 4.8 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 4.9 Non-Party: any natural person, partnership, corporation, association or
26 other legal entity not named as a Party to this action.
27 4.10 Outside Counsel of Record: attorneys who are not employees of a party
28 to this Action but are retained to represent a party to this Action and have appeared in
1 this Action on behalf of that party or are affiliated with a law firm that has appeared
2 on behalf of that party, and includes support staff.
3 4.11 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 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this Action.
8 4.13 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) and
11 their employees and subcontractors.
12 4.14 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 4.15 Receiving Party: a Party that receives Disclosure or Discovery
15 Material from a Producing Party.
16 5. SCOPE
17 The protections conferred by this Stipulation and Order cover not only Protected
18 Material (as defined above), but also (1) any information copied or extracted from
19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
20 Material; and (3) any testimony, conversations, or presentations by Parties or their
21 Counsel that might reveal Protected Material.
22 Any use of Protected Material at trial shall be governed by the orders of the trial
23 judge. This Order does not govern the use of Protected Material at trial.
24 6. DURATION
25 Once a case proceeds to trial, information that was designated as
26 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
27 as an exhibit at trial becomes public and will be presumptively available to all
28 members of the public, including the press, unless compelling reasons supported by
1 specific factual findings to proceed otherwise are made to the trial judge in advance of
2 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing
3 for sealing documents produced in discovery from “compelling reasons” standard
4 when merits-related documents are part of court record). Accordingly, the terms of
5 this protective order do not extend beyond the commencement of the trial.
6 7. DESIGNATING PROTECTED MATERIAL
7 7.1 Exercise of Restraint and Care in Designating Material for
8 Protection. Each Party or Non-Party that designates information or items
9 for protection under this Order must take care to limit any such designation to specific
10 material that qualifies under the appropriate standards. The Designating Party must
11 designate for protection only those parts of material, documents, items or oral or
12 written communications that qualify so that other portions of the material, documents,
13 items or communications for which protection is not warranted are not swept
14 unjustifiably within the ambit of this Order.
15 Mass, indiscriminate or routinized designations are prohibited. Designations
16 that are shown to be clearly unjustified or that have been made for an improper purpose
17 (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating Party
19 to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 7.2 Manner and Timing of Designations. Except as otherwise provided in this
24 Order, (see e.g., second paragraph of 7.2(a) below) or as otherwise stipulated or
25 ordered, Disclosure of Discovery Material that qualifies for protection under this Order
26 must be clearly so designated before the material is disclosed or produced.
27 Designation in conformity with this Order requires:
28 (a) for information in documentary form (e.g., paper or electronic
1 documents, but excluding transcripts of depositions or other pretrial or trial
2 proceedings), that the Producing Party affix at a minimum, the legend
3 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
4 contains protected material. If only a portion of the material on a page qualifies for
5 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
6 by making appropriate markings in the margins).
7 A Party or Non-Party that makes original documents available for inspection
8 need not designate them for protection until after the inspecting Party has indicated
9 which documents it would like copied and produced. During the inspection and before
10 the designation, all of the material made available for inspection shall be deemed
11 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
12 copied and produced, the Producing Party must determine which documents, or
13 portions thereof, qualify for protection under this Order. Then, before producing the
14 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
15 to each page that contains Protected Material. If only a portion of the material on a
16 page qualifies for protection, the Producing Party also must clearly identify the
17 protected portion(s) (e.g., by making appropriate markings in the margins).
18 (b) for testimony given in depositions that the Designating Party
19 identifies the Disclosure or Discovery Material on the record, before the close of the
20 deposition all protected testimony.
21 (c) for information produced in some form other than documentary and
22 for any other tangible items, that the Producing Party affix in a prominent place on the
23 exterior of the container or containers in which the information is stored the legend
24 “CONFIDENTIAL.” If only a portion or portions of the information warrants
25 protection, the Producing Party, to the extent practicable, shall identify the protected
26 portion(s).
27 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
28 failure to designate qualified information or items does not, standing alone, waive the
1 Designating Party’s right to secure protection under this Order for such material. Upon
2 timely correction of a designation, the Receiving Party must make reasonable efforts
3 to assure that the material is treated in accordance with the provisions of this Order.
4 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
6 designation of confidentiality at any time that is consistent with the Court’s Scheduling
7 Order.
8 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
9 resolution process under Local Rule 37-1 et seq.
10 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
11 stipulation pursuant to Local Rule 37-2.
12 8.4 The burden of persuasion in any such challenge proceeding shall be on
13 the Designating Party. Frivolous challenges, and those made for an improper purpose
14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
15 expose the Challenging Party to sanctions. Unless the Designating Party has waived
16 or withdrawn the confidentiality designation, all parties shall continue to afford the
17 material in question the level of protection to which it is entitled under the Producing
18 Party’s designation until the Court rules on the challenge.
19 9. ACCESS TO AND USE OF PROTECTED MATERIAL
20 9.1 Basic Principles. A Receiving Party may use Protected Material that is
21 disclosed or produced by another Party or by a Non-Party in connection with this
22 Action only for prosecuting, defending or attempting to settle this Action. Such
23 Protected Material may be disclosed only to the categories of persons and under the
24 conditions described in this Order. When the Action has been terminated, a Receiving
25 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
28 authorized under this Order.
1 9.2 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, as
6 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 Counsel) of
9 the Receiving Party to whom disclosure is reasonably necessary for this Action;
10 (c) Experts (as defined in this Order) of the Receiving Party to whom
11 disclosure is reasonably necessary for this Action and who have signed the
12 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (d) the court and its personnel;
14 (e) court reporters and their staff;
15 (f) professional jury or trial consultants, mock jurors, and Professional
16 Vendors to whom disclosure is reasonably necessary for this Action and who have
17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
18 (g) the author or recipient of a document containing the information or a
19 custodian or other person who otherwise possessed or knew the information;
20 (h) during their depositions, witnesses, and attorneys for witnesses, in the
21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
23 not be permitted to keep any confidential information unless they sign the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
25 by the Designating Party or ordered by the court. Pages of transcribed deposition
26 testimony or exhibits to depositions that reveal Protected Material may be separately
27 bound by the court reporter and may not be disclosed to anyone except as permitted
28 under this Stipulated Protective Order; and
1 (i) any mediators or settlement officers and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
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5 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification
9 shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the subpoena
12 or order is subject to this Protective Order. Such notification shall include a copy of
13 this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 pursued by the Designating Party whose Protected Material may be affected. If the
16 Designating Party timely seeks a protective order, the Party served with the subpoena
17 or court order shall not produce any information designated in this action as
18 “CONFIDENTIAL” before a determination by the court from which the subpoena or
19 order issued, unless the Party has obtained the Designating Party’s permission. The
20 Designating Party shall bear the burden and expense of seeking protection in that court
21 of its confidential material and nothing in these provisions should be construed as
22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
23 directive from another court.
24 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
BE PRODUCED IN THIS LITIGATION
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26 (a) The terms of this Order are applicable to information produced by a
27 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
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1 produced by Non-Parties in connection with this litigation is protected by the remedies
2 and relief provided by this Order. Nothing in these provisions should be construed as
3 prohibiting a Non-Party from seeking additional protections.
4 (b) In the event that a Party is required, by a valid discovery request, to
5 produce a Non-Party’s confidential information in its possession, and the Party is
6 subject to an agreement with the Non-Party not to produce the Non-Party’s
7 confidential information, then the Party shall:
8 (1) promptly notify in writing the Requesting Party and the Non-Party
9 that some or all of the information requested is subject to a confidentiality agreement
10 with a Non-Party;
11 (2) promptly provide the Non-Party with a copy of the Stipulated
12 Protective Order in this Action, the relevant discovery request(s), and a reasonably
13 specific description of the information requested; and
14 (3) make the information requested available for inspection by the Non-
15 Party, if requested.
16 (c) If the Non-Party fails to seek a protective order from this court within
17 14 days of receiving the notice and accompanying information, the Receiving Party
18 may produce the Non-Party’s confidential information responsive to the discovery
19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not
20 produce any information in its possession or control that is subject to the
21 confidentiality agreement with the Non-Party before a determination by the court.
22 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
23 of seeking protection in this court of its Protected Material.
24 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
MATERIAL
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26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27 Protected Material to any person or in any circumstance not authorized under this
28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
3 persons to whom unauthorized disclosures were made of all the terms of this Order,
4 and (d) request such person or persons to execute the “Acknowledgment an Agreement
5 to Be Bound” attached hereto as Exhibit A.
6 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
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8 When a Producing Party gives notice to Receiving Parties that certain inadvertently
9 produced material is subject to a claim of privilege or other protection, the
10 obligations of the Receiving Parties are those set forth in Federal Rule of Civil\
11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
12 may be established in an e-discovery order that provides for production without prior
13 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
14 parties reach an agreement on the effect of disclosure of a communication or
15 information covered by the attorney-client privilege or work product protection, the
16 parties may incorporate their agreement in the stipulated protective order submitted
17 to the court.
18 14. MISCELLANEOUS
19 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 14.2 Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order, no Party waives any right it otherwise would have to object to
23 disclosing or producing any information or item on any ground not addressed in this
24 Stipulated Protective Order. Similarly, no Party waives any right to object on any
25 ground to use in evidence of any of the material covered by this Protective Order.
26 14.3 Filing Protected Material. A Party that seeks to file under seal any
27 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
28
1 specific Protected Material. If a Party’s request to file Protected Material under seal
2 is denied by the court, then the Receiving Party may file the information in the
3 public record unless otherwise instructed by the court.
4 15. FINAL DISPOSITION
5 A. After the final disposition of this Action, as defined in paragraph 6,
6 within 60 days of a written request by the Designating Party, each Receiving Party
7 must return all Protected Material to the Producing Party or destroy such material.
8 As used in this subdivision, “all Protected Material” includes all copies, abstracts,
9 compilations, summaries, and any other format reproducing or capturing any of the
10 Protected Material. Whether the Protected Material is returned or destroyed, the
11 Receiving Party must submit a written certification to the Producing Party (and, if
12 not the same person or entity, to the Designating Party) by the 60-day deadline that
13 (1) identifies (by category, where appropriate) all the Protected Material that was
14 returned or destroyed and (2) affirms that the Receiving Party has not retained any
15 copies, abstracts, compilations, summaries or any other format reproducing or
16 capturing any of the Protected Material. Notwithstanding this provision, Counsel are
17 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
18 and hearing transcripts, legal memoranda, correspondence, deposition and trial
19 exhibits, expert reports, attorney work product, and consultant and expert work
20 product, even if such materials contain Protected Material. Any such archival copies
21 that contain or constitute Protected Material remain subject to this Protective Order
22 as set forth in Section 6 (DURATION).
23 B. Nothing in this Order disallows State Farm from:
24 a. complying with any state or federal law or regulation, including
25 reporting of information to a regulatory or government entity as permitted and/or
26 required by applicable state and federal law;
27 b. adding information discovered that is relevant to a claim to the
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1 c. disclosing evidence of a crime or fraud; retaining information
2|| necessary to meet mandated retention requirements; or,
3 d. retaining copies of Protected Material that may exist on back-up
media or other computer or archive storage not regularly accessed by business users
5|| in the ordinary course provided that should a copy of the Confidential Information be
6|| accessed it will not be used for a purpose inconsistent with this Order.
7 16. VIOLATION
8 Any violation of this Order may be punished by appropriate measures
9|| including, without limitation, contempt proceedings and/or monetary sanctions.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
12
|| DATED: September 07, 2023
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/
'6 JOHN D. EARLY
17 nited States Magistrate Judge
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_ TA.
1 EXHIBIT A
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Acknowledgment and Agreement to Be Bound
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4 I, (PRINT OR TYPE FULL NAME), of
[print or type full address] declare under penalty of
5
perjury that I have read in its entirety, understand and am fully familiar with the
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terms of the Stipulated Protective Order entered on September 7, 2923,, United
7
States District Court, Central District of California, Case No. 8:23-cv-00442-
8
JWH-JDE, and agree to comply with and be bound by the terms and conditions
9
of said Order unless and until modified by further Order of this Court.
10
11 I understand that Confidential Information, as defined in the Stipulated
12 Protective Order, including any notes or other records that may be made
13 regarding any such materials, shall not be disclosed to anyone except as expressly
14 permitted by this Stipulated Protective Order. I understand and acknowledge that
15 failure to so comply could expose me to sanctions and punishment in the nature
16 of contempt. I solemnly promise that I will not disclose in any manner any
17 information or item that is subject to this Order to any person or entity except in
18 strict compliance with the provisions of this Order. I will not copy or use, except
19 solely for the purposes of this Proceeding, any Confidential Information obtained
20 pursuant to this Stipulated Protective Order, except as provided therein or
21 otherwise ordered by the Court in the proceeding.
22
I further understand that I am to retain all copies of all Confidential
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Information and/or Trade Secret Information provided to me in the proceeding
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in a secure manner, and that all copies of such Confidential Information and/or
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Trade Secret Information are to remain in my personal custody until termination
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of my participation in this proceeding, whereupon the copies of such Confidential
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Information and/or Trade Secret Information will be returned to counsel who
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1 provided me with such Confidential Information and/or Trade Secret
2 Information.
3
I further consent to the jurisdiction of this Court for purposes of enforcing
4
this Order, even if such enforcement proceedings occur after termination of this
5
action. I hereby appoint [print or type full name] of
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[print or type full address and
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telephone number] as my California agent for service of process in connection
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with this action or any proceedings related to enforcement of this Order.
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Executed this day of _________, 20__, at ,
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.
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12 Dated: By:
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Signature:
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Title:
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16 Address:
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City, State, Zip
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