1 GARY R. CARLIN, CSBN: 44945 2 [email protected] BRENT S. BUCHSBAUM, CSBN: 194816 3 [email protected] LAUREL N. HAAG, CSBN: 211279 4 [email protected] CLAUDETTE H. VILLICAÑA, CSBN: 325669 5 [email protected] 301 East Ocean Boulevard, Suite 1550 6 Long Beach, California 90802 Telephone: (562) 432-8933; Fax: (562) 435-1656 7 Attorneys for Plaintiff, 8 STEVEN FECKLEY MICHAEL R. LINDSAY (SBN: 110845) 9 [email protected] 10 IRENE SCHOLL-TATEVOSYAN (SBN: 301568) [email protected] 11 ANDREA CHAVEZ (SBN: 318297) [email protected] 12 NIXONPEABODY LLP 300 S. Grand Avenue, Suite 4100 13 Los Angeles, CA 90071-3151 Tel: 213-629-6000 14 Fax: 213-629-6001 15 Attorneys for Defendants COVANCE LABORATORIES, INC.; LABORATORY 16 CORPORATION OF AMERICA and LABORATORY CORPORATION 17 OF AMERICA HOLDINGS 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 21 22 STEVEN FECKLEY individually, and Case No: 8:19-cv-00122-AG-ADSx on behalf of all others similarly (CLASS ACTION) 23 situated; [Assigned to Hon. Andrew J. Guilford, 24 Plaintiff, Courtroom 10D] 25 vs. STIPULATION AND PROTECTIVE 26 COVANCE, INC., a Delaware ORDER corporation; LABORATORY 27 CORPORATION OF AMERICA, a Delaware corporation; 28 LABORATORY CORPORATION OF AMERICA HOLDINGS, a Delaware 1 CORPORATION OF AMERICA, a Trial Date: October 6, 2020 California corporation; and DOES 1 2 through 50, inclusive, 3 Defendants. 4 5 6 IT IS HEREBY STIPULATED by and between the Parties to Steven Feckley 7 v. Covance, Inc., et al., by and through their respective counsel of record, that in order 8 to facilitate the exchange of information and documents which may be subject to 9 confidentiality limitations on disclosure due to federal laws, state laws, and privacy 10 rights, the Parties stipulate as follows: 11 1. A. PURPOSES AND LIMITATIONS 12 Discovery in this action is likely to involve production of trade secrets, customer and 13 pricing lists and other valuable research, development, commercial, financial, 14 technical, proprietary, and/or private information for which special protection from 15 public disclosure and from use for any purpose other than prosecuting this litigation 16 may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 17 enter the following Stipulated Protective Order. The parties acknowledge that this 18 Order does not confer blanket protections on all disclosures or responses to discovery 19 and that the protection it affords from public disclosure and use extends only to the 20 limited information or items that are entitled to confidential treatment under the 21 applicable legal principles. 22 B. GOOD CAUSE STATEMENT 23 This action is likely to involve private information for which special protection from 24 public disclosure and from use for any purpose other than prosecution of this action is 25 warranted. Such confidential and proprietary materials and information consist of, 26 among other things, medical information relating to 3rd Parties that are not parties to 27 the above-titled action, confidential business or financial information, information 28 regarding confidential business practices, or other confidential research, development, 1 or commercial information (including information implicating privacy rights of third 2 parties), information otherwise generally unavailable to the public, or which may be 3 privileged or otherwise protected from disclosure under state or federal statutes, court 4 rules, case decisions, or common law. Accordingly, to expedite the flow of 5 information, to facilitate the prompt resolution of disputes over confidentiality of 6 discovery materials, to adequately protect information the parties are entitled to keep 7 confidential, to ensure that the parties are permitted reasonable necessary uses of such 8 material in preparation for and in the conduct of trial, to address their handling at the 9 end of the litigation, and serve the ends of justice, a protective order for such 10 information is justified in this matter. It is the intent of the parties that information will 11 not be designated as confidential for tactical reasons and that nothing be so designated 12 without a good faith belief that it has been maintained in a confidential, non-public 13 manner, and there is good cause why it should not be part of the public record of this 14 case. 15 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 16 SEAL 17 The parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential information under 19 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 20 standards that will be applied when a party seeks permission from the court to file 21 material under seal. 22 There is a strong presumption that the public has a right of access to judicial 23 proceedings and records in civil cases. In connection with non-dispositive motions, 24 good cause must be shown to support a filing under seal. See Kamakana v. City and 25 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 26 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 27

(E.D. Wis. 1999) (even stipulated protective orders require good 28 cause showing), and a specific showing of good cause or compelling reasons with 1 proper evidentiary support and legal justification, must be made with respect to 2 Protected Material that a party seeks to file under seal. The parties’ mere designation 3 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 4 submission of competent evidence by declaration, establishing that the material sought 5 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 6 constitute good cause. 7 Further, if a party requests sealing related to a dispositive motion or trial, then 8 compelling reasons, not only good cause, for the sealing must be shown, and the relief 9 sought shall be narrowly tailored to serve the specific interest to be protected. See 10 Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item 11 or type of information, document, or thing sought to be filed or introduced under seal 12 in connection with a dispositive motion or trial, the party seeking protection must 13 articulate compelling reasons, supported by specific facts and legal justification, for the 14 requested sealing order. Again, competent evidence supporting the application to file 15 documents under seal must be provided by declaration. 16 Any document that is not confidential, privileged, or otherwise protectable in its 17 entirety will not be filed under seal if the confidential portions can be redacted. If 18 documents can be redacted, then a redacted version for public viewing, omitting only 19 the confidential, privileged, or otherwise protectable portions of the document, shall be 20 filed. Any application that seeks to file documents under seal in their entirety should 21 include an explanation of why redaction is not feasible. 22 2. DEFINITIONS 23 2.1 Action: Case No. 8:19-CV-00122-AG-ADSx 24 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 25 information or items under this Order. 26 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 27 generated, stored or maintained) or tangible things that qualify for protection under 28 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 1 Statement. 2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support 3 staff). 4 2.5 Designating Party: a Party or Non-Party that designates information or items that it 5 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 6 2.6 Disclosure or Discovery Material: all items or information, regardless of the 7 medium or manner in which it is generated, stored, or maintained (including, among 8 other things, testimony, transcripts, and tangible things), that are produced or generated 9 in disclosures or responses to discovery in this matter. 10 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to 11 the litigation who has been retained by a Party or its counsel to serve as an expert 12 witness or as a consultant in this Action. 13 2.8 House Counsel: attorneys who are employees of a party to this Action. House 14 Counsel does not include Outside Counsel of Record or any other outside counsel. 15 2.9 Non-Party: any natural person, partnership, corporation, association or other legal 16 entity not named as a Party to this action. 17 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 18 Action but are retained to represent or advise a party to this Action and have appeared 19 in this Action on behalf of that party or are affiliated with a law firm that has appeared 20 on behalf of that party, and includes support staff. 21 2.11 Party: any party to this Action, including all of its officers, directors, employees, 22 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure of Discovery 24 Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation support services 26 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 27 organizing, storing, or retrieving data in any form or medium) and their employees and 28 subcontractors. 1 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 2 “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 4 Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only Protected 7 Material (as defined above), but also (1) any information copied or extracted from 8 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 9 Material; and (3) any testimony, conversations, or presentations by Parties or their 10 Counsel that might reveal Protected Material. Any use of Protected Material at trial 11 shall be governed by the orders of the trial judge. This Order does not govern the use 12 of Protected Material at trial. 13 4. DURATION 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 16 an exhibit at trial becomes public and will be presumptively available to all members 17 of the public, including the press, unless compelling reasons supported by specific 18 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 19 See Kamakana,

(distinguishing “good cause” showing for sealing 20 documents produced in discovery from “compelling reasons” standard when merits- 21 related documents are part of court record). Accordingly, the terms of this protective 22 order do not extend beyond the commencement of the trial. 23 /// 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 26 Party or Non-Party that designates information or items for protection under this Order 27 must take care to limit any such designation to specific material that qualifies under the 28 appropriate standards. The Designating Party must designate for protection only those 1 parts of material, documents, items or oral or written communications that qualify so 2 that other portions of the material, documents, items or communications for which 3 protection is not warranted are not swept unjustifiably within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. Designations that 5 are shown to be clearly unjustified or that have been made for an improper purpose 6 (e.g., to unnecessarily encumber the case development process or to impose 7 unnecessary expenses and burdens on other parties) may expose the Designating Party 8 to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in this 13 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 14 or ordered, Disclosure or Discovery Material that qualifies for protection under this 15 Order must be clearly so designated before the material is disclosed or produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic documents, 18 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 19 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 20 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 21 portion of the material on a page qualifies for protection, the Producing Party also must 22 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 23 margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and before 27 the designation, all of the material made available for inspection shall be deemed 28 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 1 copied and produced, the Producing Party must determine which documents, or 2 portions thereof, qualify for protection under this Order. Then, before producing the 3 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 4 each page that contains Protected Material. If only a portion of the material on a page 5 qualifies for protection, the Producing Party also must clearly identify the protected 6 portion(s) (e.g., by making appropriate markings in the margins). 7 (b) for testimony given in depositions that the Designating Party identifies the 8 Disclosure or Discovery Material on the record, before the close of the deposition all 9 protected testimony. 10 (c) for information produced in some form other than documentary and for any 11 other tangible items, that the Producing Party affix in a prominent place on the exterior 12 of the container or containers in which the information is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information warrants 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 17 to designate qualified information or items does not, standing alone, waive the 18 Designating Party’s right to secure protection under this Order for such material. Upon 19 timely correction of a designation, the Receiving Party must make reasonable efforts to 20 assure that the material is treated in accordance with the provisions of this Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 23 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 25 process under Local Rule 37-1 et seq. 26 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 27 stipulation pursuant to Local Rule 37-2. 28 1 6.4 The burden of persuasion in any such challenge proceeding shall be on the 2 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 3 to harass or impose unnecessary expenses and burdens on other parties) may expose 4 the Challenging Party to sanctions. Unless the Designating Party has waived or 5 withdrawn the confidentiality designation, all parties shall continue to afford the 6 material in question the level of protection to which it is entitled under the Producing 7 Party’s designation until the Court rules on the challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a Receiving 14 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a location 16 and in a secure manner that ensures that access is limited to the persons authorized 17 under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 19 ordered by the court or permitted in writing by the Designating Party, a Receiving 20 Party may disclose any information or item designated “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 22 employees of said Outside Counsel of Record to whom it is reasonable necessary to 23 disclose the information for this Action; 24 (b) the officers, directors, and employees (including House Counsel) of the 25 Receiving Party to whom disclosure is reasonably necessary for this Action; 26 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 27 is reasonably necessary for this Action and who have signed the “Acknowledgment 28 and Agreement to Be Bound” (Exhibit A); 1 (d) the court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 4 to whom disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 9 to whom disclosure is reasonably necessary provided: (1) the deposing party requests 10 that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be 11 permitted to keep any confidential information unless they sign the “Acknowledgment 12 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 13 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 14 depositions that reveal Protected Material may be separately bound by the court 15 reporter and may not be disclosed to anyone except as permitted under this Stipulated 16 Protective Order; and 17 (i) any mediator or settlement officer, and their supporting personnel, mutually 18 agreed upon by any of the parties engaged in settlement discussions. 19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 20 OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation that 22 compels disclosure of any information or items designated in this Action as 23 “CONFIDENTIAL,” that Party must: 24 (a) promptly notify in writing the Designating Party. Such notification shall 25 include a copy of the subpoena or court order; 26 (b) promptly notify in writing the party who caused the subpoena or order to 27 issue in the other litigation that some or all of the material covered by the subpoena or 28 1 order is subject to this Protective Order. Such notification shall include a copy of this 2 Stipulated Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be pursued by 4 the Designating Party whose Protected Material may be affected. If the Designating 5 Party timely seeks a protective order, the Party served with the subpoena or court order 6 shall not produce any information designated in this action as “CONFIDENTIAL” 7 before a determination by the court from which the subpoena or order issued, unless 8 the Party has obtained the Designating Party’s permission. The Designating Party shall 9 bear the burden and expense of seeking protection in that court of its confidential 10 material and nothing in these provisions should be construed as authorizing or 11 encouraging a Receiving Party in this Action to disobey a lawful directive from 12 another court. 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 14 IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as “CONFIDENTIAL.” Such information 17 produced by Non-Parties in connection with this litigation is protected by the remedies 18 and relief provided by this Order. Nothing in these provisions should be construed as 19 prohibiting a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to produce 21 a Non-Party’s confidential information in its possession, and the Party is subject to an 22 agreement with the Non-Party not to produce the Non-Party’s confidential information, 23 then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party that some 25 or all of the information requested is subject to a confidentiality agreement with a Non- 26 Party; 27 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 28 Order in this Action, the relevant discovery request(s), and a reasonably specific 1 description of the information requested; and 2 (3) make the information requested available for inspection by the Non-Party, if 3 requested. 4 (c) If the Non-Party fails to seek a protective order from this court within 14 5 days of receiving the notice and accompanying information, the Receiving Party may 6 produce the Non-Party’s confidential information responsive to the discovery request. 7 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 8 any information in its possession or control that is subject to the confidentiality 9 agreement with the Non-Party before a determination by the court. Absent a court 10 order to the contrary, the Non-Party shall bear the burden and expense of seeking 11 protection in this court of its Protected Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 16 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 17 all unauthorized copies of the Protected Material, (c) inform the person or persons to 18 whom unauthorized disclosures were made of all the terms of this Order, and (d) 19 request such person or persons to execute the “Acknowledgment and Agreement to Be 20 Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other protection, 25 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 26 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 27 may be established in an e-discovery order that provides for production without prior 28 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 1 parties reach an agreement on the effect of disclosure of a communication or 2 information covered by the attorney-client privilege or work product protection, the 3 parties may incorporate their agreement in the stipulated protective order submitted to 4 the court. 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order, no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 ground to use in evidence of any of the material covered by this Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 15 only be filed under seal pursuant to a court order authorizing the sealing of the specific 16 Protected Material at issue. If a Party’s request to file Protected Material under seal is 17 denied by the court, then the Receiving Party may file the information in the public 18 record unless otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 21 days of a written request by the Designating Party, each Receiving Party must return 22 all Protected Material to the Producing Party or destroy such material. As used in this 23 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected 25 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 26 must submit a written certification to the Producing Party (and, if not the same person 27 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 28 category, where appropriate) all the Protected Material that was returned or destroyed 1 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 2 compilations, summaries or any other format reproducing or capturing any of the 3 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 4 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 5 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 6 attorney work product, and consultant and expert work product, even if such materials 7 contain Protected Material. Any such archival copies that contain or constitute 8 Protected Material remain subject to this Protective Order as set forth in Section 4 9 (DURATION). 10 14. VIOLATION 11 Any violation of this Order may be punished by appropriate measures including, 12 without limitation, contempt proceedings and/or monetary sanctions. 13 /// 14 /// 15 /// Dated: November 4, 2019 THE LAW OFFICES OF CARLIN & 16 BUCHSBAUM 17 A Limited Liability Partnership 18 19 By: /s/ Claudette Villicaña Gary R. Carlin, 20 Claudette Villicaña, 21 Attorneys for Plaintiff, Steven Feckley 22 23 Dated: November 4, 2019_ NIXON PEABODY LLP 24 25 By: _/s/ Irene Scholl-Tatevosyan Michael R. Lindsay 26 Irene Scholl-Tatevosyan 27 Andrea Chavez Attorneys for Defendants 28 1 CLAOBVOARNACTEO LRAYB OCORARPTOORRAIETSI,O INN CO.F; 2 AMERICA and LABORATORY CORPORATION OF AMERICA 3 HOLDINGS 4 I, Irene Scholl-Tatevosyan, attest that all other signatories listed, and on whose behalf 5 this filing is also being submitted, concur to the filing’s content and have authorized 6 this filing. /s/ Irene Scholl-Tatevosyan 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 Dated: ____N_o_v_e_m__b_er_ _5_, _2_0_1_9_____ 10 _______/_s_/ _A_u_t_u_m_n_ _D_._ S_p_a_e_t_h__________ 11 Honorable Autumn D. Spaeth 12 United States Magistrate Judge 13 14 15 16 EXHIBIT A 17 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 18 I, _____________________________ [print or type full name], of 19 _________________ [print or type full address], declare under penalty of perjury that I 20 have read in its entirety and understand the Stipulated Protective Order that was issued 21 by the United States District Court for the Central District of California on [date] in the 22 case of STEVEN FECKLEY vs. COVANCE, INC., LABORATORY 23 CORPORATION OF AMERICA, LABORATORY CORPORATION OF AMERICA 24 HOLDINGS, and LC LABORATORY CORPORATION OF AMERICA; Case No. 25 8:19-CV-00122-AG-ADSx. I agree to comply with and to be bound by all the terms of 26 this Stipulated Protective Order and I understand and acknowledge that failure to so 27 comply could expose me to sanctions and punishment in the nature of contempt. I 28 solemnly promise that I will not disclose in any manner any information or item that is 1 subject to this Stipulated Protective Order to any person or entity except in strict 2 compliance with the provisions of this Order. I further agree to submit to the 3 jurisdiction of the United States District Court for the Central District of California for 4 enforcing the terms of this Stipulated Protective Order, even if such enforcement 5 proceedings occur after termination of this action. 6 I hereby appoint __________________________ [print or type full name] of 7 _______________________________________ [print or type full address and 8 telephone number] as my California agent for service of process in connection with 9 this action or any proceedings related to enforcement of this Stipulated Protective 10 Order. 11 /// 12 /// 13 /// 14 /// 15 Date: 16 City and State where sworn and signed: 17 18 Printed name: 19 Signature: 20 21 22 23 24 25 26 27 28