Natalie King v. Westlake Services, LLC ( 2020 )

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 NATALIE KING, Case No. 8:20-cv-00530-JVS(JDEx) 12 Plaintiff, STIPULATED PROTECTIVE 13 ORDER v. 14 15 WESTLAKE SERVICES, LLC; Complaint filed: March 15, 2020 EQUIFAX INFORMATION 16 SERVICES LLC; AND, EXPERIAN FAC filed: April 1, 2020 INFORMATION SOLUTIONS, INC., 17 Defendants. 18 19 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 24 disclosure and from use for any purpose other than pursuing this litigation may be 25 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 27 enter the following Stipulated Protective Order. The parties acknowledge that this 28 1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 5 under the applicable legal principles. 6 2. GOOD CAUSE STATEMENT 7 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 11 12 from use for any purpose other than prosecution of this action is warranted. Such 13 confidential and proprietary materials and information consist of, among other 14 15 things, confidential business or financial information, information regarding 16 confidential business practices, or other confidential research, development, or 17 commercial information (including information implicating privacy rights of third 18 19 parties), information otherwise generally unavailable to the public, or which may 20 be privileged or otherwise protected from disclosure under state or federal statutes, 21 court rules, case decisions, or common law. Accordingly, to expedite the flow of 22 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to 25 26 keep confidential, to ensure that the parties are permitted reasonable necessary uses 27 of such material in preparation for and in the conduct of trial, to address their 28 1 handling at the end of the litigation, and serve the ends of justice, a protective order 2 for such information is justified in this matter. It is the intent of the parties that 3 information will not be designated as confidential for tactical reasons and that 4 5 nothing be so designated without a good faith belief that it has been maintained in 6 a confidential, non-public manner, and there is good cause why it should not be 7 8 part of the public record of this case. 9 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 10 PROCEDURE 11 12 The parties further acknowledge, as set forth in Section 14.3, below, that this 13 Stipulated Protective Order does not entitle them to file confidential information 14 15 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 16 and the standards that will be applied when a party seeks permission from the court 17 to file material under seal. There is a strong presumption that the public has a right 18 19 of access to judicial proceedings and records in civil cases. In connection with non- 20 dispositive motions, good cause must be shown to support a filing under seal. See 21 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), 22 23 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar- 24 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even 25 26 stipulated protective orders require good cause showing), and a specific showing of 27 good cause or compelling reasons with proper evidentiary support and legal 28 1 justification, must be made with respect to Protected Material that a party seeks to 2 file under seal. The parties’ mere designation of Disclosure or Discovery Material 3 as CONFIDENTIAL does not— without the submission of competent evidence by 4 5 declaration, establishing that the material sought to be filed under seal qualifies as 6 confidential, privileged, or otherwise protectable—constitute good cause. 7 8 Further, if a party requests sealing related to a dispositive motion or trial, 9 then compelling reasons, not only good cause, for the sealing must be shown, and 10 the relief sought shall be narrowly tailored to serve the specific interest to be 11 12 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 13 2010). For each item or type of information, document, or thing sought to be filed 14 15 or introduced under seal, the party seeking protection must articulate compelling 16 reasons, supported by specific facts and legal justification, for the requested sealing 17 order. Again, competent evidence supporting the application to file documents 18 19 under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable 21 in its entirety will not be filed under seal if the confidential portions can be 22 23 redacted. If documents can be redacted, then a redacted version for public viewing, 24 omitting only the confidential, privileged, or otherwise protectable portions of the 25 26 document, shall be filed. Any application that seeks to file documents under seal in 27 their entirety should include an explanation of why redaction is not feasible. 28 1 4. DEFINITIONS 2 4.1 Action: this pending federal lawsuit Case No. 8:20-cv-00530- 3 JVS(JDEx). 4 5 4.2 Challenging Party: a Party or Non-Party that challenges the 6 designation of information or items under this Order. 7 8 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 9 how it is generated, stored or maintained) or tangible things that qualify for 10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 12 the Good Cause Statement. 13 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 14 15 their support staff). 16 4.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 19 “CONFIDENTIAL.” 20 4.6 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 23 among other things, testimony, transcripts, and tangible things), that are produced 24 or generated in disclosures or responses to discovery. 25 26 4.7 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve 28 1 as an expert witness or as a consultant in this Action. 2 4.8 House Counsel: attorneys who are employees of a party to this 3 Action. House Counsel does not include Outside Counsel of Record or any other 4 5 outside counsel. 6 4.9 Non-Party: any natural person, partnership, corporation, association or 7 8 other legal entity not named as a Party to this action. 9 4.10 Outside Counsel of Record: attorneys who are not employees of a 10 party to this Action but are retained to represent a party to this Action and have 11 12 appeared in this Action on behalf of that party or are affiliated with a law firm that 13 has appeared on behalf of that party, and includes support staff. 14 15 4.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 19 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 4.13 Professional Vendors: persons or entities that provide litigation 22 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 26 and their employees and subcontractors. 27 4.14 Protected Material: any Disclosure or Discovery Material that is 28 1 designated as “CONFIDENTIAL.” 2 4.15 Receiving Party: a Party that receives Disclosure or Discovery 3 Material from a Producing Party. 4 5 5. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 12 presentations by Parties or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 15 trial judge and other applicable authorities. This Order does not govern the use of 16 Protected Material at trial. 17 6. DURATION 18 19 Once a case proceeds to trial, information that was designated as 20 CONFIDENTIAL or maintained pursuant to this protective order used or 21 introduced as an exhibit at trial becomes public and will be presumptively 22 23 available to all members of the public, including the press, unless compelling 24 reasons supported by specific factual findings to proceed otherwise are made to the 25 26 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 27 (distinguishing “good cause” showing for sealing documents produced in 28 1 discovery from “compelling reasons” standard when merits-related documents are 2 part of court record). Accordingly, the terms of this protective order do not extend 3 beyond the commencement of the trial. 4 5 7. DESIGNATING PROTECTED MATERIAL 6 7.1 Exercise of Restraint and Care in Designating Material for 7 8 Protection. Each Party or Non-Party that designates information or 9 items for protection under this Order must take care to limit any such designation 10 to specific material that qualifies under the appropriate standards. The Designating 11 12 Party must designate for protection only those parts of material, documents, items 13 or oral or written communications that qualify so that other portions of the 14 15 material, documents, items or communications for which protection is not 16 warranted are not swept unjustifiably within the ambit of this Order. 17 Mass, indiscriminate or routinized designations are prohibited. Designations 18 19 that are shown to be clearly unjustified or that have been made for an improper 20 purpose (e.g., to unnecessarily encumber the case development process or to 21 impose unnecessary expenses and burdens on other parties) may expose the 22 23 Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 1 7.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 3 that qualifies for protection under this Order must be clearly so designated before 4 5 the material is disclosed or produced. 6 Designation in conformity with this Order requires: 7 8 (a) for information in documentary form (e.g., paper or electronic 9 documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 12 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 13 contains protected material. If only a portion of the material on a page qualifies for 14 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 available for inspection 18 19 need not designate them for protection until after the inspecting Party has indicated 20 which documents it would like copied and produced. During the inspection and 21 before the designation, all of the material made available for inspection shall be 22 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine 25 26 which documents, or portions thereof, qualify for protection under this Order. 27 Then, before producing the specified documents, the Producing Party must affix 28 1 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 2 only a portion of the material on a page qualifies for protection, the Producing 3 Party also must clearly identify the protected portion(s) (e.g., by making 4 5 appropriate markings in the margins). 6 (b) for testimony given in depositions that the Designating Party 7 8 identifies the Disclosure or Discovery Material on the record, before the close of 9 the deposition all protected testimony. 10 (c) for information produced in some form other than documentary 11 12 and for any other tangible items, that the Producing Party affix in a prominent 13 place on the exterior of the container or containers in which the information is 14 15 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 16 information warrants protection, the Producing Party, to the extent practicable, 17 shall identify the protected portion(s). 18 19 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 failure to designate qualified information or items does not, standing alone, waive 21 the Designating Party’s right to secure protection under this Order for such 22 23 material. Upon timely correction of a designation, the Receiving Party must make 24 reasonable efforts to assure that the material is treated in accordance with the 25 26 provisions of this Order. 27 28 1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 5 Scheduling Order. 6 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 7 8 resolution process under Local Rule 37-1 et seq. 9 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 10 joint stipulation pursuant to Local Rule 37-2. 11 12 8.4 The burden of persuasion in any such challenge proceeding shall be 13 on the Designating Party. Frivolous challenges, and those made for an improper 14 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 parties) may expose the Challenging Party to sanctions. Unless the Designating 17 Party has waived or withdrawn the confidentiality designation, all parties shall 18 19 continue to afford the material in question the level of protection to which it is 20 entitled under the Producing Party’s designation until the Court rules on the 21 challenge. 22 23 9. ACCESS TO AND USE OF PROTECTED MATERIAL 24 9.1 Basic Principles. A Receiving Party may use Protected Material that is 25 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending or attempting to settle this Action. Such 28 1 Protected Material may be disclosed only to the categories of persons and under 2 the conditions described in this Order. When the Action has been terminated, a 3 Receiving Party must comply with the provisions of section 15 below (FINAL 4 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 8 location and in a secure manner that ensures that access is limited to the persons 9 authorized under this Order. 10 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 11 12 otherwise ordered by the court or permitted in writing by the Designating Party, a 13 Receiving Party may disclose any information or item designated 14 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 well as employees of said Outside Counsel of Record to whom it is reasonably 18 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) 21 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 22 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or 7 8 a custodian or other person who otherwise possessed or knew the information; 9 (h) during their depositions, witnesses, and attorneys for witnesses, in 10 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 11 12 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 13 they will not be permitted to keep any confidential information unless they sign the 14 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 19 be separately bound by the court reporter and may not be disclosed to anyone 20 except as permitted under this Stipulated Protective Order; and 21 (i) any mediators or settlement officers and their supporting personnel, 22 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 26 27 28 1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 5 that compels disclosure of any information or items designated in this Action as 6 “CONFIDENTIAL,” that Party must: 7 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 11 12 order to issue in the other litigation that some or all of the material covered by the 13 subpoena or order is subject to this Protective Order. Such notification shall 14 15 include a copy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. If the 18 19 Designating Party timely seeks a protective order, the Party served with the 20 subpoena or court order shall not produce any information designated in this action 21 as “CONFIDENTIAL” before a determination by the court from which the 22 23 subpoena or order issued, unless the Party has obtained the Designating Party’s 24 permission. The Designating Party shall bear the burden and expense of seeking 25 26 protection in that court of its confidential material and nothing in these provisions 27 28 1 should be construed as authorizing or encouraging a Receiving Party in this Action 2 to disobey a lawful directive from another court. 3 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 4 5 BE PRODUCED IN THIS LITIGATION 6 (a) The terms of this Order are applicable to information produced by 7 8 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 9 information produced by Non-Parties in connection with this litigation is protected 10 by the remedies and relief provided by this Order. Nothing in these provisions 11 12 should be construed as prohibiting a Non-Party from seeking additional 13 protections. 14 15 (b) In the event that a Party is required, by a valid discovery request, 16 to produce a Non-Party’s confidential information in its possession, and the Party 17 is subject to an agreement with the Non-Party not to produce the Non-Party’s 18 19 confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality 22 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 26 Protective Order in this Action, the relevant discovery request(s), and a reasonably 27 specific description of the information requested; and 28 1 (3) make the information requested available for inspection by the 2 Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court 4 5 within 14 days of receiving the notice and accompanying information, the 6 Receiving Party may produce the Non-Party’s confidential information responsive 7 8 to the discovery request. If the Non-Party timely seeks a protective order, the 9 Receiving Party shall not produce any information in its possession or control that 10 is subject to the confidentiality agreement with the Non-Party before a 11 12 determination by the court. Absent a court order to the contrary, the Non-Party 13 shall bear the burden and expense of seeking protection in this court of its 14 15 Protected Material. 16 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 17 MATERIAL 18 19 If a Receiving Party learns that, by inadvertence or otherwise, it has 20 disclosed Protected Material to any person or in any circumstance not authorized 21 under this Stipulated Protective Order, the Receiving Party must immediately (a) 22 23 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 24 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 25 26 the person or persons to whom unauthorized disclosures were made of all the terms 27 28 1 of this Order, and (d) request such person or persons to execute the 2 “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A. 3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 4 5 OTHERWISE PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain inadvertently 7 8 produced material is subject to a claim of privilege or other protection, the 9 obligations of the Receiving Parties are those set forth in Federal Rule of Civil\ 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 11 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 14 15 (e), insofar as the parties reach an agreement on the effect of disclosure of a 16 communication or information covered by the attorney-client privilege or work 17 product protection, the parties may incorporate their agreement in the stipulated 18 19 protective order submitted to the court. 20 14. MISCELLANEOUS 21 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 23 person to seek its modification by the Court in the future. 24 14.2 Right to Assert Other Objections. By stipulating to the entry of this 25 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in 28 1 this Stipulated Protective Order. Similarly, no Party waives any right to object on 2 any ground to use in evidence of any of the material covered by this Protective 3 Order. 4 5 14.3 Filing Protected Material. A Party that seeks to file under seal any 6 Protected Material must comply with Local Civil Rule 79-5. Protected Material 7 8 may only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material. If a Party’s request to file Protected Material under 10 seal is denied by the court, then the Receiving Party may file the information in the 11 12 public record unless otherwise instructed by the court. 13 15. FINAL DISPOSITION 14 15 After the final disposition of this Action, as defined in paragraph 6, within 16 60 days of a written request by the Designating Party, each Receiving Party must 17 return all Protected Material to the Producing Party or destroy such material. As 18 19 used in this subdivision, “all Protected Material” includes all copies, abstracts, 20 compilations, summaries, and any other format reproducing or capturing any of the 21 Protected Material. Whether the Protected Material is returned or destroyed, the 22 23 Receiving Party must submit a written certification to the Producing Party (and, if 24 not the same person or entity, to the Designating Party) by the 60-day deadline that 25 26 (1) identifies (by category, where appropriate) all the Protected Material that was 27 returned or destroyed and (2) affirms that the Receiving Party has not retained any 28 1 copies, abstracts, compilations, summaries or any other format reproducing or 2 capturing any of the Protected Material. Notwithstanding this provision, Counsel 3 are entitled to retain an archival copy of all pleadings, motion papers, trial, 4 5 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 6 and trial exhibits, expert reports, attorney work product, and consultant and expert 7 8 work product, even if such materials contain Protected Material. Any such archival 9 copies that contain or constitute Protected Material remain subject to this 10 Protective Order as set forth in Section 6 (DURATION). 11 12 16. VIOLATION 13 Any violation of this Order may be punished by appropriate measures 14 15 including, without limitation, contempt proceedings and/or monetary sanctions. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 Dated: August 18, 2020 Respectfully submitted, 18 19 /s/ Matthew M. Loker Matthew M. Loker, Esq. 20 LOKER LAW, APC 21 1303 East Grand Avenue, Suite 101 Arroyo Grande, CA 93420 22 Telephone: (805)-994-0177 23 Fax: (805)-994-0197 Email: matt@loker.law 24 25 Attorney for Plaintiff 26 27 28 1 Dated: August 18, 2020 /s/ Daniel Lopez Daniel Lopez 2 JONES DAY 3 3161 Michelson Drive, Suite 800 4 Irvine CA 92612 Telephone: (949) 851-3939 5 Facsimile: (949) 553-7539 6 Email: daniellopez@jonesday.com 7 Attorneys for Defendant 8 Experian Information Solutions, Inc. 9 /s/ Benjamin J. Carter Dated: August 18, 2020 10 Benjamin J. Carter, Esq. MOLINO & BERARDINO 11 4751 Wilshire Boulevard, Suite 207 12 Los Angeles, California 90010-3838 Telephone: (323)-692-4010 13 Fax: (323)-692-4015 14 Email: bcarter@molinolawfirm.com 15 Attorneys for Westlake Services, LLC 16 17 /s/ Eric M. Lloyd Dated: August 18, 2020 Eric M. Lloyd 18 SEYFARTH SHAW LLP 19 560 Mission Street Suite 3100 San Francisco, CA 94105 20 Telephone: (415)-397-2823 21 Fax: (415)-397-8549 22 Email: elloyd@seyfarth.com 23 Attorney for Equifax Information 24 Services LLC 25 26 27 28 1 2 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 DATED: August 19, 2020 Mg ba 7 JOHND. EARLY □ 8 ed States Magistrate Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 QTTDTITT ATLRIY DDFYVTICIA'TIV CTC “O\DInLlp 1 EXHIBIT A – DECLARATION OF COMPLIANCE 2 I, _____________________________________, declare as follows: 3 1. My address is ___________________________________________________. 4 2. My present employer is ____________________________________________. 5 3. My present occupation or job description is ____________________________. 6 4. I have received a copy of the Stipulated Protective Order entered in United 7 States District Court, Central District of California, Case No. 8:20-cv-00530- 8 JVS(JDEx) captioned Natalie King vs. Westlake Services, LLC et al. action on 9 _______________, 20___. 10 5. I have carefully read and understand the provisions of this Stipulated Protective 11 Order. I will comply with all provisions of this Stipulated Protective Order. 12 6. I will hold in confidence, and will not disclose to anyone not qualified under the 13 Stipulated Protective Order, any information, documents or other materials 14 produced subject to this Stipulated Protective Order. 15 7. I will use such information, documents or other materials produced subject to 16 this Stipulated Protective Order only for purposes of this present action. 17 8. Upon termination of this action, or upon request, I will return and deliver all 18 19 information, documents or other materials produced subject to this Stipulated 20 Protective Order, and all documents or things which I have prepared relating to 21 the information, documents or other materials that are subject to the Stipulated 22 Protective Order, to my counsel in this action, or to counsel for the party by 23 whom I am employed or retained or from whom I received the documents. 24 9. I hereby submit to the jurisdiction of this Court for the purposes of enforcing 25 the Stipulated Protective Order in this action. 26 /// 27 28 1 I declare under penalty of perjury under the laws of the United States that 2 the foregoing is true and correct. 3 4 Executed this ____ day of _____________, 20__, at __________________. 5 6 7 ________________________________ 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28