Ahmet S. Yayla v. Refinitiv US LLC

United States District Court for the Central District of California

Ahmet S. Yayla v. Refinitiv US LLC

Trial Court Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 AHMET S. YAYLA, et al., ) Case No. 8:23-cv-00830-JWH-JDE ) 11 ) Plaintiffs, ) STIPULATED PROTECTIVE 12 ) ORDER ) 13 v. ) ) 14 ) REFINITIV US LLC, et al., ) 15 ) ) 16 Defendants. ) ) 17 18 Based on the parties’ Stipulation (Dkt. 43), and for good cause shown, 19 the Court finds and orders as follows. 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 disclosure and from use for any purpose other than pursuing this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the 25 Court to enter the following Stipulated Protective Order. The parties 26 acknowledge that this Order does not confer blanket protections on all 27 disclosures or responses to discovery and that the protection it affords from 28 1 public disclosure and use extends only to the limited information or items that 2 are entitled to confidential treatment under the applicable legal principles. 3 2. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, customer and pricing lists 5 and other valuable research, development, commercial, financial, technical 6 and/or proprietary information for which special protection from public 7 disclosure and from use for any purpose other than prosecution of this action is 8 warranted. Such confidential and proprietary materials and information 9 consist of, among other things, confidential business or financial information, 10 information regarding confidential business practices, or other confidential 11 research, development, or commercial information (including information 12 implicating privacy rights of third parties), information otherwise generally 13 unavailable to the public, or which may be privileged or otherwise protected 14 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 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to 18 ensure that the parties are permitted reasonable necessary uses of such material 19 in preparation for and in the conduct of trial, to address their handling at the 20 21 end of the litigation, and serve the ends of justice, a protective order for such 22 information is justified in this matter. It is the intent of the parties that 23 information will not be designated as confidential for tactical reasons and that 24 nothing be so designated without a good faith belief that it has been 25 maintained in a confidential, non-public manner, and there is good cause why 26 it should not be part of the public record of this case. 27 / / / 28 / / / 1 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 2 PROCEDURE 3 The parties further acknowledge, as set forth in Section 14.3, below, that 4 this Stipulated Protective Order does not entitle them to file confidential 5 information under seal; Local Civil Rule 79-5 sets forth the procedures that 6 must be followed and the standards that will be applied when a party seeks 7 permission from the court to file material under seal. There is a strong 8 presumption that the public has a right of access to judicial proceedings and 9 records in civil cases. In connection with non-dispositive motions, good cause 10 must be shown to support a filing under seal. See Kamakana v. City and 11 County of Honolulu,

447 F.3d 1172, 1176

(9th Cir. 2006), Phillips v. Gen. 12 Motors Corp.,

307 F.3d 1206

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Electrics, Inc.,

187 F.R.D. 576, 577

(E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of good 15 cause or compelling reasons with proper evidentiary support and legal 16 justification, must be made with respect to Protected Material that a party 17 seeks to file under seal. The parties’ mere designation of Disclosure or 18 Discovery Material as CONFIDENTIAL or HIGHLY CONFIDENTIAL — 19 ATTORNEY’S EYES ONLY does not—without the submission of competent 20 21 evidence by declaration, establishing that the material sought to be filed under 22 seal qualifies as confidential, privileged, or otherwise protectable—constitute 23 good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, 25 then compelling reasons, not only good cause, for the sealing must be shown, 26 and the relief sought shall be narrowly tailored to serve the specific interest to 27 be protected. See Pintos v. Pacific Creditors Ass’n.,

605 F.3d 665, 677-79

(9th 28 Cir. 2010). For each item or type of information, document, or thing sought to 1 be filed or introduced under seal, the party seeking protection must articulate 2 compelling reasons, supported by specific facts and legal justification, for the 3 requested sealing order. Again, competent evidence supporting the application 4 to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise 6 protectable in its entirety will not be filed under seal if the confidential portions 7 can be redacted. If documents can be redacted, then a redacted version for 8 public viewing, omitting only the confidential, privileged, or otherwise 9 protectable portions of the document, shall be filed. Any application that seeks 10 to file documents under seal in their entirety should include an explanation of 11 why redaction is not feasible. 12 4. DEFINITIONS 13 4.1 Action: Yayla, et al. v. Refinitiv US LLC, Case No. 8:23-cv-00830- 14 JWH-JDE. 15 4.2 Challenging Party: a Party or Non-Party that challenges the 16 designation of information or items under this Order. 17 4.3 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — 18 ATTORNEY’S EYES ONLY” Information or Items: information (regardless 19 of how it is generated, stored or maintained) or tangible things that qualify for 20 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above 22 in the Good Cause Statement. 23 4.4 Consultant: a non-testifying Expert. 24 4.5 Counsel: Outside Counsel of Record and House Counsel (as well 25 as their support staff). 26 4.6 Designating Party: a Party or Non-Party that designates 27 information or items that it produces in disclosures or in responses to discovery 28 1 as “CONFIDENTIAL” and “HIGHLY CONFIDENTIAL — 2 ATTORNEY’S EYES ONLY.” 3 4.7 Disclosure or Discovery Material: all items or information, 4 regardless of the medium or manner in which it is generated, stored, or 5 maintained (including, among other things, testimony, transcripts, and tangible 6 things), that are produced or generated in disclosures or responses to discovery. 7 4.8 Expert: a person with specialized knowledge or experience in a 8 matter pertinent to the litigation who has been retained by a Party or its 9 counsel to serve as a Testifying Expert witness or as a Consultant in this 10 Action. 11 4.9 House Counsel: attorneys who are employees of a party to this 12 Action. House Counsel does not include Outside Counsel of Record or any 13 other outside counsel. 14 410 Non-Party: any natural person, partnership, corporation, 15 association or other legal entity not named as a Party to this action. 16 4.11 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent a party to this Action and 18 have appeared in this Action on behalf of that party or are affiliated with a law 19 firm that has appeared on behalf of that party, and includes support staff. 20 21 4.12 Party: any party to this Action, including all of its officers, 22 directors, employees, consultants, retained Experts, and Outside Counsel of 23 Record (and their support staffs). 24 4.13 Producing Party: a Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 4.14 Professional Vendors: persons or entities that provide litigation 27 support services (e.g., photocopying, videotaping, translating, preparing 28 exhibits or demonstrations, and organizing, storing, or retrieving data in any 1 form or medium) and their employees and subcontractors. 2 4.15 Protected Material: any Disclosure or Discovery Material that is 3 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — 4 ATTORNEY’S EYES ONLY.” 5 4.16 Receiving Party: a Party that receives Disclosure or Discovery 6 Material from a Producing Party. 7 4.17 Testifying Expert: an Expert who may be testifying at trial. 8 5. SCOPE 9 The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 compilations of Protected Material; and (3) any testimony, conversations, or 13 presentations by Parties or their Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of 15 the trial judge and other applicable authorities. This Order does not govern the 16 use of Protected Material at trial. 17 6. DURATION 18 Once a case proceeds to trial, information that was designated as 19 CONFIDENTIAL or HIGHLY CONFIDENTIAL — ATTORNEY’S EYES 20 21 ONLY or maintained pursuant to this protective order used or introduced as 22 an exhibit at trial becomes public and will be presumptively available to all 23 members of the public, including the press, unless compelling reasons 24 supported by specific factual findings to proceed otherwise are made to the trial 25 judge in advance of the trial. See Kamakana,

447 F.3d at 1180

-81 26 (distinguishing “good cause” showing for sealing documents produced in 27 discovery from “compelling reasons” standard when merits-related documents 28 1 are part of court record). Accordingly, the terms of this protective order do not 2 extend beyond the commencement of the trial. 3 7. DESIGNATING PROTECTED MATERIAL 4 7.1 Exercise of Restraint and Care in Designating Material for 5 Protection. Each Party or Non-Party that designates information 6 or items for protection under this Order must take care to limit any such 7 designation to specific material that qualifies under the appropriate standards. 8 The Designating Party must designate for protection only those parts of 9 material, documents, items or oral or written communications that qualify so 10 that other portions of the material, documents, items or communications for 11 which protection is not warranted are not swept unjustifiably within the ambit 12 of this Order. 13 Mass, indiscriminate or routinized designations are prohibited. 14 Designations that are shown to be clearly unjustified or that have been made 15 for an improper purpose (e.g., to unnecessarily encumber the case development 16 process or to impose unnecessary expenses and burdens on other parties) may 17 expose the Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items 19 that it designated for protection do not qualify for protection, that Designating 20 21 Party must promptly notify all other Parties that it is withdrawing the 22 inapplicable designation. 23 7.2 Manner and Timing of Designations. Except as otherwise 24 provided in this Order, or as otherwise stipulated or ordered, Disclosure of 25 Discovery Material that qualifies for protection under this Order must be 26 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” or “HIGHLY CONFIDENTIAL — ATTORNEY’S 4 EYES ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the 7 protected portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for 9 inspection need not designate them for protection until after the inspecting 10 Party has indicated which documents it would like copied and produced. 11 During the inspection and before the designation, all of the material made 12 available for inspection shall be deemed “HIGHLY CONFIDENTIAL — 13 ATTORNEY’S EYES ONLY.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must determine 15 which documents, or portions thereof, qualify for protection under this Order. 16 Then, before producing the specified documents, the Producing Party must 17 affix the appropriate “CONFIDENTIAL legend” to each page that contains 18 Protected Material. If only a portion of the material on a page qualifies for 19 protection, the Producing Party also must clearly identify the protected 20 21 portion(s) (e.g., by making appropriate markings in the margins). 22 (b) for testimony given in depositions that the Designating Party 23 identifies the Disclosure or Discovery Material on the record, before the close 24 of the deposition all protected testimony. 25 (c) for information produced in some form other than 26 documentary and for any other tangible items, that the Producing Party affix 27 in a prominent place on the exterior of the container or containers in which the 28 information is stored the legend “CONFIDENTIAL” or “HIGHLY 1 CONFIDENTIAL — ATTORNEY’S EYES ONLY.” If only a portion or 2 portions of the information warrants protection, the Producing Party, to the 3 extent practicable, shall identify the protected portion(s). 4 7.3 Inadvertent Failures to Designate. If timely corrected, an 5 inadvertent failure to designate qualified information or items does not, 6 standing alone, waive the Designating Party’s right to secure protection under 7 this Order for such material. Upon timely correction of a designation, the 8 Receiving Party must make reasonable efforts to assure that the material is 9 treated in accordance with the provisions of this Order. 10 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 12 designation of confidentiality at any time that is consistent with the Court’s 13 Scheduling Order. 14 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 15 resolution process under Local Rule 37-1 et seq. 16 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 17 joint stipulation pursuant to Local Rule 37-2. 18 8.4 The burden of persuasion in any such challenge proceeding shall be 19 on the Designating Party. Frivolous challenges, and those made for an 20 21 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 22 on other parties) may expose the Challenging Party to sanctions. Unless the 23 Designating Party has waived or withdrawn the confidentiality designation, all 24 parties shall continue to afford the material in question the level of protection 25 to which it is entitled under the Producing Party’s designation until the Court 26 rules on the challenge. 27 / / / 28 / / / 1 9. ACCESS TO AND USE OF PROTECTED MATERIAL 2 9.1 Basic Principles. A Receiving Party may use Protected Material that 3 is disclosed or produced by another Party or by a Non-Party in connection 4 with this Action only for prosecuting, defending or attempting to settle this 5 Action. Such Protected Material may be disclosed only to the categories of 6 persons and under the conditions described in this Order. When the Action has 7 been terminated, a Receiving Party must comply with the provisions of section 8 15 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party 10 at a location and in a secure manner that ensures that access is limited to the 11 persons authorized under this Order. 12 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating 14 Party, a Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this 17 Action, as well as employees of said Outside Counsel of Record to whom it is 18 reasonably necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House 20 21 Counsel) of the Receiving Party to whom disclosure is reasonably necessary 22 for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to 24 whom disclosure is reasonably necessary for this Action and who have signed 25 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the court and its personnel; 27 (e) court reporters and their staff; 28 (f) professional jury or trial consultants, mock jurors, and 1 Professional Vendors to whom disclosure is reasonably necessary for this 2 Action and who have signed the “Acknowledgment and Agreement to Be 3 Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the 5 information or a custodian or other person who otherwise possessed or knew 6 the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, 8 in the Action to whom disclosure is reasonably necessary provided: (1) the 9 deposing party requests that the witness sign the “Acknowledgment and 10 Agreement to Be Bound (Exhibit A); and (2) they will not be permitted to keep 11 any confidential information unless they sign the “Acknowledgment and 12 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 13 Designating Party or ordered by the court. Pages of transcribed deposition 14 testimony or exhibits to depositions that reveal Protected Material may be 15 separately bound by the court reporter and may not be disclosed to anyone 16 except as permitted under this Stipulated Protective Order; and 17 (i) any mediators or settlement officers and their supporting 18 personnel, mutually agreed upon by any of the parties engaged in settlement 19 discussions. 20 21 9.3 Disclosure of “HIGHLY CONFIDENTIAL — ATTORNEY’S 22 EYES ONLY” Information or Items. The “HIGHLY CONFIDENTIAL — 23 ATTORNEY’S EYES ONLY” designation may only be applied to 24 information or items pertaining to an individual or corporation’s finances, 25 trade secrets, or other proprietary information that the Designating Party has 26 good cause to believe the disclosure of which to another Party or Non-Party 27 would create a substantial risk of serious harm that could not be avoided by 28 less restrictive means. Unless otherwise ordered by the court or permitted in 1 writing by the Designating Party, only the Receiving Party’s Counsel may 2 receive, access, or view any information or item designated “HIGHLY 3 CONFIDENTIAL — ATTORNEY’S EYES ONLY,” and such Counsel may 4 disclose information or items designated “HIGHLY CONFIDENTIAL — 5 ATTORNEY’S EYES ONLY” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this 7 Action, as well as employees of said Outside Counsel of Record to whom it is 8 reasonably necessary to disclose the information for this Action; 9 (b) Experts (as defined in this Order) of the Receiving Party to 10 whom disclosure is reasonably necessary for this Action and who have signed 11 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (c) the court and its personnel; 13 (d) court reporters and their staff; 14 (e) professional jury or trial consultants, mock jurors, and 15 Professional Vendors to whom disclosure is reasonably necessary for this 16 Action and who have signed the “Acknowledgment and Agreement to Be 17 Bound” (Exhibit A); 18 (f) the author or recipient of a document containing the 19 information or a custodian or other person who otherwise possessed or knew 20 21 the information; 22 (g) any mediators or settlement officers and their supporting 23 personnel, mutually agreed upon by any of the parties engaged in settlement 24 discussions. 25 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 26

27 If a Party is served with a subpoena or a court order issued in other 28 litigation that compels disclosure of any information or items designated in this 1 Action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — 2 ATTORNEY’S EYES ONLY” that Party must: 3 (a) promptly notify in writing the Designating Party. Such 4 notification shall include a copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the subpoena 6 or order to issue in the other litigation that some or all of the material covered 7 by the subpoena or order is subject to this Protective Order. Such notification 8 shall include a copy of this Stipulated Protective Order; and 9 (c) cooperate with respect to all reasonable procedures sought to be 10 pursued by the Designating Party whose Protected Material may be affected. If 11 the Designating Party timely seeks a protective order, the Party served with the 12 subpoena or court order shall not produce any information designated in this 13 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — 14 ATTORNEY’S EYES ONLY” before a determination by the court from which 15 the subpoena or order issued, unless the Party has obtained the Designating 16 Party’s permission. The Designating Party shall bear the burden and expense of 17 seeking protection in that court of its confidential material and nothing in these 18 provisions should be construed as authorizing or encouraging a Receiving Party 19 in this Action to disobey a lawful directive from another court. 20 21 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 22 BE PRODUCED IN THIS LITIGATION

23 (a) The terms of this Order are applicable to information produced 24 by a Non-Party in this Action and designated as “CONFIDENTIAL” or 25 “HIGHLY CONFIDENTIAL — ATTORNEY’S EYES ONLY.” Such 26 information produced by Non-Parties in connection with this litigation is 27 protected by the remedies and relief provided by this Order. Nothing in these 28 1 provisions should be construed as prohibiting a Non-Party from seeking 2 additional protections. 3 (b) In the event that a Party is required, by a valid discovery 4 request, to produce a Non-Party’s confidential information in its possession, 5 and the Party is subject to an agreement with the Non-Party not to produce the 6 Non-Party’s confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non- 8 Party that some or all of the information requested is subject to a 9 confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a 12 reasonably specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court 16 within 14 days of receiving the notice and accompanying information, the 17 Receiving Party may produce the Non-Party’s confidential information 18 responsive to the discovery request. If the Non-Party timely seeks a protective 19 order, the Receiving Party shall not produce any information in its possession 20 21 or control that is subject to the confidentiality agreement with the Non-Party 22 before a determination by the court. Absent a court order to the contrary, the 23 Non-Party shall bear the burden and expense of seeking protection in this court 24 of its Protected Material. 25 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26

27 If a Receiving Party learns that, by inadvertence or otherwise, it has 28 disclosed Protected Material to any person or in any circumstance not 1 authorized under this Stipulated Protective Order, the Receiving Party must 2 immediately (a) notify in writing the Designating Party of the unauthorized 3 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 4 Protected Material, (c) inform the person or persons to whom unauthorized 5 disclosures were made of all the terms of this Order, and (d) request such 6 person or persons to execute the “Acknowledgment and Agreement to Be 7 Bound” attached hereto as Exhibit A. 8 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 9 OTHERWISE PROTECTED MATERIAL

10 When a Producing Party gives notice to Receiving Parties that certain 11 inadvertently produced material is subject to a claim of privilege or other 12 protection, the obligations of the Receiving Parties are those set forth in 13 Federal Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to 14 modify whatever procedure may be established in an e-discovery order that 15 provides for production without prior privilege review. Pursuant to Federal 16 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on 17 the effect of disclosure of a communication or information covered by the 18 attorney-client privilege or work product protection, the parties may 19 incorporate their agreement in the stipulated protective order submitted to the 20 21 court. 22 14. MISCELLANEOUS 23 14.1 Right to Further Relief. Nothing in this Order abridges the right of 24 any person to seek its modification by the Court in the future. 25 14.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object 27 to disclosing or producing any information or item on any ground not 28 addressed in this Stipulated Protective Order. Similarly, no Party waives any 1 right to object on any ground to use in evidence of any of the material covered 2 by this Protective Order. 3 14.3 Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Local Civil Rule 79-5. Protected 5 Material may only be filed under seal pursuant to a court order authorizing the 6 sealing of the specific Protected Material. If a Party’s request to file Protected 7 Material under seal is denied by the court, then the Receiving Party may file 8 the information in the public record unless otherwise instructed by the court. 9 15. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 6, 11 within 60 days of a written request by the Designating Party, each Receiving 12 Party must return all Protected Material to the Producing Party or destroy such 13 material. As used in this subdivision, “all Protected Material” includes all 14 copies, abstracts, compilations, summaries, and any other format reproducing 15 or capturing any of the Protected Material. Whether the Protected Material is 16 returned or destroyed, the Receiving Party must submit a written certification 17 to the Producing Party (and, if not the same person or entity, to the 18 Designating Party) by the 60-day deadline that (1) identifies (by category, 19 where appropriate) all the Protected Material that was returned or destroyed 20 21 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 22 compilations, summaries or any other format reproducing or capturing any of 23 the Protected Material. Notwithstanding this provision, Counsel are entitled to 24 retain an archival copy of all pleadings, motion papers, trial, deposition, and 25 hearing transcripts, legal memoranda, correspondence, deposition and trial 26 exhibits, expert reports, attorney work product, and consultant and expert 27 work product, even if such materials contain Protected Material. Any such 28 I |) archival copies that contain or constitute Protected Material remain subject to 2 || this Protective Order as set forth in Section 6 (DURATION). 3 16. VIOLATION 4 Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary 6 sanctions. 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

10 ll DATED: November 22, 2023 12 13 iA OER D. EARLY é ited States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17

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