1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 ERIC HUMPHREY, Case No. 8:23-cv-02116 HDV (JDEx) 11 Plaintiff, STIPULATED PROTECTIVE ORDER 12 v.

13 EXPERIAN INFORMATION SOLUTIONS, INC., 14 Defendant. 15 16 17 Based on the parties’ Stipulation (Dkt. 23) and for good cause shown, the 18 Court finds and orders as follows. 19 1. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public 22 disclosure and from use for any purpose other than pursuing this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 24 to enter the following Stipulated Protective Order. The parties acknowledge that 25 this Order does not confer blanket protections on all disclosures or responses to 26 discovery and that the protection it affords from public disclosure and use 27 extends only to the limited information or items that are entitled to confidential 28 treatment under the applicable legal principles. 11 22 2. GOOD CAUSE STATEMENT 33 This action is likely to involve trade secrets, customer and pricing lists and 44 other valuable research, development, commercial, financial, technical and/or 55 proprietary information for which special protection from public disclosure and 66 from use for any purpose other than prosecution of this action is warranted. 77 Such confidential and proprietary materials and information consist of, among 88 other things, confidential business or financial information, information 99 regarding confidential business practices, or other confidential research, 1100 development, or commercial information (including information implicating 1111 privacy rights of third parties), information otherwise generally unavailable to 1122 the public, or which may be privileged or otherwise protected from disclosure 1133 under state or federal statutes, court rules, case decisions, or common law. 1144 Accordingly, to expedite the flow of information, to facilitate the prompt 1155 resolution of disputes over confidentiality of discovery materials, to adequately 1166 protect information the parties are entitled to keep confidential, to ensure that 1177 the parties are permitted reasonable necessary uses of such material in 1188 preparation for and in the conduct of trial, to address their handling at the end 1199 of the litigation, and serve the ends of justice, a protective order for such 2200 information is justified in this matter. It is the intent of the parties that 2211 information will not be designated as confidential for tactical reasons and that 2222 nothing be so designated without a good faith belief that it has been maintained 2233 in a confidential, non-public manner, and there is good cause why it should not 2244 be part of the public record of this case. 2255 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 2266 PROCEDURE 2277 The parties further acknowledge, as set forth in Section 14.3, below, that 2288 this Stipulated Protective Order does not entitle them to file confidential 11 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 22 be followed and the standards that will be applied when a party seeks 33 permission from the court to file material under seal. There is a strong 44 presumption that the public has a right of access to judicial proceedings and 55 records in civil cases. In connection with non-dispositive motions, good cause 66 must be shown to support a filing under seal. See Kamakana v. City and County 77 of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 88 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 99 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 1100 require good cause showing), and a specific showing of good cause or 1111 compelling reasons with proper evidentiary support and legal justification, must 1122 be made with respect to Protected Material that a party seeks to file under seal. 1133 The parties’ mere designation of Disclosure or Discovery Material as 1144 CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS’ EYES ONLY does 1155 not— without the submission of competent evidence by declaration, establishing 1166 that the material sought to be filed under seal qualifies as confidential, 1177 privileged, or otherwise protectable—constitute good cause. 1188 Further, if a party requests sealing related to a dispositive motion or trial, 1199 then compelling reasons, not only good cause, for the sealing must be shown, 2200 and the relief sought shall be narrowly tailored to serve the specific interest to be 2211 protected. See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2222 2010). For each item or type of information, document, or thing sought to be 2233 filed or introduced under seal, the party seeking protection must articulate 2244 compelling reasons, supported by specific facts and legal justification, for the 2255 requested sealing order. Again, competent evidence supporting the application 2266 to file documents under seal must be provided by declaration. 2277 Any document that is not confidential, privileged, or otherwise 2288 protectable in its entirety will not be filed under seal if the confidential portions 11 can be redacted. If documents can be redacted, then a redacted version for 22 public viewing, omitting only the confidential, privileged, or otherwise 33 protectable portions of the document, shall be filed. Any application that seeks 44 to file documents under seal in their entirety should include an explanation of 55 why redaction is not feasible. 66 4. DEFINITIONS 77 4.1 Action: Eric Humphrey v. Experian Information Solutions, Inc., United 88 States District Court, Central District of California, Case No. 8:23-cv-02116- 99 CJC-JDE. 1100 4.2 Challenging Party: a Party or Non-Party that challenges the 1111 designation of information or items under this Order. 1122 4.3 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES 1133 ONLY” Information or Items: information (regardless of how it is generated, 1144 stored or maintained) or tangible things that qualify for protection under Federal 1155 Rule of Civil Procedure 26(c), and as specified above in the Good Cause 1166 Statement. 1177 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 1188 their support staff). 1199 4.5 Designating Party: a Party or Non-Party that designates information 2200 or items that it produces in disclosures or in responses to discovery as 2211 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” 2222 4.6 Disclosure or Discovery Material: all items or information, 2233 regardless of the medium or manner in which it is generated, stored, or 2244 maintained (including, among other things, testimony, transcripts, and tangible 2255 things), that are produced or generated in disclosures or responses to discovery. 2266 4.7 Expert: a person with specialized knowledge or experience in a 2277 matter pertinent to the litigation who has been retained by a Party or its counsel 2288 to serve as an expert witness or as a consultant in this Action. 11 4.8 House Counsel: attorneys who are employees of a party to this 22 Action. House Counsel does not include Outside Counsel of Record or any 33 other outside counsel. 44 4.9 Non-Party: any natural person, partnership, corporation, 55 association or other legal entity not named as a Party to this action. 66 4.10 Outside Counsel of Record: attorneys who are not employees of a 77 party to this Action but are retained to represent a party to this Action and have 88 appeared in this Action on behalf of that party or are affiliated with a law firm 99 that has appeared on behalf of that party, and includes support staff. 1100 4.11 Party: any party to this Action, including all of its officers, directors, 1111 employees, consultants, retained experts, and Outside Counsel of Record (and 1122 their support staffs). 1133 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 1144 Discovery Material in this Action. 1155 4.13 Professional Vendors: persons or entities that provide litigation 1166 support services (e.g., photocopying, videotaping, translating, preparing exhibits 1177 or demonstrations, and organizing, storing, or retrieving data in any form or 1188 medium) and their employees and subcontractors. 1199 4.14 Protected Material: any Disclosure or Discovery Material that is 2200 designated as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ 2211 EYES ONLY.” 2222 4.15 Receiving Party: a Party that receives Disclosure or Discovery 2233 Material from a Producing Party. 2244 5. SCOPE 2255 The protections conferred by this Stipulation and Order cover not only 2266 Protected Material (as defined above), but also (1) any information copied or 2277 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2288 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of 33 the trial judge and other applicable authorities. This Order does not govern the 44 use of Protected Material at trial. 55 6. DURATION 66 Once a case proceeds to trial, information that was designated as 77 CONFIDENTIAL or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or 88 maintained pursuant to this protective order used or introduced as an exhibit at 99 trial becomes public and will be presumptively available to all members of the 1100 public, including the press, unless compelling reasons supported by specific 1111 factual findings to proceed otherwise are made to the trial judge in advance of 1122 the trial. See Kamakana,

(distinguishing “good cause” 1133 showing for sealing documents produced in discovery from “compelling 1144 reasons” standard when merits-related documents are part of court record). 1155 Accordingly, the terms of this protective order do not extend beyond the 1166 commencement of the trial. 1177 7. DESIGNATING PROTECTED MATERIAL 1188 7.1 Exercise of Restraint and Care in Designating Material for 1199 Protection. Each Party or Non-Party that designates information or 2200 items for protection under this Order must take care to limit any such 2211 designation to specific material that qualifies under the appropriate standards. 2222 The Designating Party must designate for protection only those parts of 2233 material, documents, items or oral or written communications that qualify so 2244 that other portions of the material, documents, items or communications for 2255 which protection is not warranted are not swept unjustifiably within the ambit 2266 of this Order. 2277 Mass, indiscriminate or routinized designations are prohibited. 2288 Designations that are shown to be clearly unjustified or that have been made for 11 an improper purpose (e.g., to unnecessarily encumber the case development 22 process or to impose unnecessary expenses and burdens on other parties) may 33 expose the Designating Party to sanctions. 44 If it comes to a Designating Party’s attention that information or items 55 that it designated for protection do not qualify for protection, that Designating 66 Party must promptly notify all other Parties that it is withdrawing the 77 inapplicable designation. 88 7.2 Manner and Timing of Designations. Except as otherwise provided 99 in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery 1100 Material that qualifies for protection under this Order must be clearly so 1111 designated before the material is disclosed or produced. 1122 Designation in conformity with this Order requires: 1133 (a) for information in documentary form (e.g., paper or electronic 1144 documents, but excluding transcripts of depositions or other pretrial or trial 1155 proceedings), that the Producing Party affix at a minimum, the legend 1166 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” 1177 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 1188 material. If only a portion of the material on a page qualifies for protection, the 1199 Producing Party also must clearly identify the protected portion(s) (e.g., by 2200 making appropriate markings in the margins). 2211 A Party or Non-Party that makes original documents available for 2222 inspection need not designate them for protection until after the inspecting Party 2233 has indicated which documents it would like copied and produced. During the 2244 inspection and before the designation, all of the material made available for 2255 inspection shall be deemed “CONFIDENTIAL” or “CONFIDENTIAL- 2266 ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the 2277 documents it wants copied and produced, the Producing Party must determine 2288 which documents, or portions thereof, qualify for protection under this Order. 11 Then, before producing the specified documents, the Producing Party must affix 22 the “CONFIDENTIAL legend” to each page that contains Protected Material. 33 If only a portion of the material on a page qualifies for protection, the Producing 44 Party also must clearly identify the protected portion(s) (e.g., by making 55 appropriate markings in the margins). 66 (b) for testimony given in depositions that the Designating Party 77 identifies the Disclosure or Discovery Material on the record, before the close of 88 the deposition all protected testimony. 99 (c) for information produced in some form other than documentary 1100 and for any other tangible items, that the Producing Party affix in a prominent 1111 place on the exterior of the container or containers in which the information is 1122 stored the legend “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ 1133 EYES ONLY.” If only a portion or portions of the information warrants 1144 protection, the Producing Party, to the extent practicable, shall identify the 1155 protected portion(s). 1166 7.3 Inadvertent Failures to Designate. If timely corrected, an 1177 inadvertent failure to designate qualified information or items does not, standing 1188 alone, waive the Designating Party’s right to secure protection under this Order 1199 for such material. Upon timely correction of a designation, the Receiving Party 2200 must make reasonable efforts to assure that the material is treated in accordance 2211 with the provisions of this Order. 2222 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2233 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 2244 designation of confidentiality at any time that is consistent with the Court’s 2255 Scheduling Order. 2266 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 2277 resolution process under Local Rule 37-1 et seq. 2288 / / / 11 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 22 joint stipulation pursuant to Local Rule 37-2. 33 8.4 The burden of persuasion in any such challenge proceeding shall be on 44 the Designating Party. Frivolous challenges, and those made for an improper 55 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 66 parties) may expose the Challenging Party to sanctions. Unless the Designating 77 Party has waived or withdrawn the confidentiality designation, all parties shall 88 continue to afford the material in question the level of protection to which it is 99 entitled under the Producing Party’s designation until the Court rules on the 1100 challenge. 1111 9. ACCESS TO AND USE OF PROTECTED MATERIAL 1122 9.1 Basic Principles. A Receiving Party may use Protected Material that is 1133 disclosed or produced by another Party or by a Non-Party in connection with 1144 this Action only for prosecuting, defending or attempting to settle this Action. 1155 Protected Material shall not be used, directly or indirectly, by any person, for 1166 any business, commercial or competitive purposes or for any purpose 1177 whatsoever other than solely for the preparation for and trial of this action in 1188 accordance with the provisions of this Order. Such Protected Material may be 1199 disclosed only to the categories of persons and under the conditions described in 2200 this Order. When the Action has been terminated, a Receiving Party must 2211 comply with the provisions of section 15 below (FINAL DISPOSITION). 2222 Protected Material must be stored and maintained by a Receiving Party at 2233 a location and in a secure manner that ensures that access is limited to the 2244 persons authorized under this Order. 2255 9.2 Disclosure of “CONFIDENTIAL” or “CONFIDENTIAL - 2266 ATTORNEYS’ EYES ONLY” Information or Items. Unless 2277 otherwise ordered by the court or permitted in writing by the Designating Party, 2288 a Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES ONLY” 22 only to: 33 (a) the Receiving Party’s Outside Counsel of Record in this Action, 44 as well as employees of said Outside Counsel of Record to whom it is 55 reasonably necessary to disclose the information for this Action; 66 (b) the officers, directors, and employees (including House Counsel) 77 of the Receiving Party to whom disclosure is reasonably necessary for this 88 Action; 99 (c) Experts (as defined in this Order) of the Receiving Party to 1100 whom disclosure is reasonably necessary for this Action and who have signed 1111 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1122 (d) the court and its personnel; 1133 (e) court reporters and their staff; 1144 (f) professional jury or trial consultants, mock jurors, and 1155 Professional Vendors to whom disclosure is reasonably necessary for this Action 1166 and who have signed the “Acknowledgment and Agreement to Be Bound” 1177 (Exhibit A); 1188 (g) the author or recipient of a document containing the information 1199 or a custodian or other person who otherwise possessed or knew the 2200 information; 2211 (h) during their depositions, witnesses, and attorneys for witnesses, 2222 in the Action to whom disclosure is reasonably necessary provided: (1) the 2233 deposing party requests that the witness sign the form attached as Exhibit A 2244 hereto; and (2) they will not be permitted to keep any confidential information 2255 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 2266 A), unless otherwise agreed by the Designating Party or ordered by the court. 2277 Pages of transcribed deposition testimony or exhibits to depositions that reveal 2288 Protected Material may be separately bound by the court reporter and may not 11 be disclosed to anyone except as permitted under this Stipulated Protective 22 Order; and 33 (i) any mediators or settlement officers and their supporting 44 personnel, mutually agreed upon by any of the parties engaged in settlement 55 discussions. 66 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 77 PRODUCED IN OTHER LITIGATION 88 If a Party is served with a subpoena or a court order issued in other 99 litigation that compels disclosure of any information or items designated in this 1100 Action as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES 1111 ONLY” that Party must: 1122 (a) promptly notify in writing the Designating Party. Such 1133 notification shall include a copy of the subpoena or court order; 1144 (b) promptly notify in writing the party who caused the subpoena or 1155 order to issue in the other litigation that some or all of the material covered by 1166 the subpoena or order is subject to this Protective Order. Such notification shall 1177 include a copy of this Stipulated Protective Order; and 1188 (c) cooperate with respect to all reasonable procedures sought to be 1199 pursued by the Designating Party whose Protected Material may be affected. If 2200 the Designating Party timely seeks a protective order, the Party served with the 2211 subpoena or court order shall not produce any information designated in this 2222 action as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS’ EYES 2233 ONLY” before a determination by the court from which the subpoena or order 2244 issued, unless the Party has obtained the Designating Party’s permission. The 2255 Designating Party shall bear the burden and expense of seeking protection in 2266 that court of its confidential material and nothing in these provisions should be 2277 construed as authorizing or encouraging a Receiving Party in this Action to 2288 disobey a lawful directive from another court. 11 22 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 33 BE PRODUCED IN THIS LITIGATION 44 (a) The terms of this Order are applicable to information produced 55 by a Non-Party in this Action and designated as “CONFIDENTIAL” or 66 “CONFIDENTIAL - ATTORNEYS’ EYES ONLY.” Such information 77 produced by Non-Parties in connection with this litigation is protected by the 88 remedies and relief provided by this Order. Nothing in these provisions should 99 be construed as prohibiting a Non-Party from seeking additional protections. 1100 (b) In the event that a Party is required, by a valid discovery request, 1111 to produce a Non-Party’s confidential information in its possession, and the 1122 Party is subject to an agreement with the Non-Party not to produce the Non- 1133 Party’s confidential information, then the Party shall: 1144 (1) promptly notify in writing the Requesting Party and the Non- 1155 Party that some or all of the information requested is subject to a confidentiality 1166 agreement with a Non-Party; 1177 (2) promptly provide the Non-Party with a copy of the Stipulated 1188 Protective Order in this Action, the relevant discovery request(s), and a 1199 reasonably specific description of the information requested; and 2200 (3) make the information requested available for inspection by the 2211 Non-Party, if requested. 2222 (c) If the Non-Party fails to seek a protective order from this court 2233 within 14 days of receiving the notice and accompanying information, the 2244 Receiving Party may produce the Non-Party’s confidential information 2255 responsive to the discovery request. If the Non-Party timely seeks a protective 2266 order, the Receiving Party shall not produce any information in its possession or 2277 control that is subject to the confidentiality agreement with the Non-Party 2288 before a determination by the court. Absent a court order to the contrary, the 11 Non-Party shall bear the burden and expense of seeking protection in this court 22 of its Protected Material. 33 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 44 MATERIAL 55 If a Receiving Party learns that, by inadvertence or otherwise, it has 66 disclosed Protected Material to any person or in any circumstance not 77 authorized under this Stipulated Protective Order, the Receiving Party must 88 immediately (a) notify in writing the Designating Party of the unauthorized 99 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 1100 Protected Material, (c) inform the person or persons to whom unauthorized 1111 disclosures were made of all the terms of this Order, and (d) request such person 1122 or persons to execute the “Acknowledgment an Agreement to Be Bound” 1133 attached hereto as Exhibit A. 1144 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 1155 OTHERWISE PROTECTED MATERIAL 1166 When a Producing Party gives notice to Receiving Parties that certain 1177 inadvertently produced material is subject to a claim of privilege or other 1188 protection, the obligations of the Receiving Parties are those set forth in Federal 1199 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify 2200 whatever procedure may be established in an e-discovery order that provides for 2211 production without prior privilege review. Pursuant to Federal Rule of Evidence 2222 502(d) and (e), insofar as the parties reach an agreement on the effect of 2233 disclosure of a communication or information covered by the attorney-client 2244 privilege or work product protection, the parties may incorporate their 2255 agreement in the stipulated protective order submitted to the court. 2266 14. MISCELLANEOUS 2277 14.1 Right to Further Relief. Nothing in this Order abridges the right of 2288 any person to seek its modification by the Court in the future. 11 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 33 disclosing or producing any information or item on any ground not addressed in 44 this Stipulated Protective Order. Similarly, no Party waives any right to object 55 on any ground to use in evidence of any of the material covered by this 66 Protective Order. 77 14.3 Filing Protected Material. A Party that seeks to file under seal any 88 Protected Material must comply with Local Civil Rule 79-5. Protected Material 99 may only be filed under seal pursuant to a court order authorizing the sealing of 1100 the specific Protected Material. If a Party’s request to file Protected Material 1111 under seal is denied by the court, then the Receiving Party may file the 1122 information in the public record unless otherwise instructed by the court. 1133 15. FINAL DISPOSITION 1144 After the final disposition of this Action, as defined in paragraph 6, within 1155 60 days, each Receiving Party must return all Protected Material to the 1166 Producing Party. As used in this subdivision, “all Protected Material” includes 1177 all copies, abstracts, compilations, summaries, and any other format 1188 reproducing or capturing any of the Protected Material. The Receiving Party 1199 must submit a written certification to the Producing Party (and, if not the same 2200 person or entity, to the Designating Party) by the 60-day deadline that (1) 2211 identifies (by category, where appropriate) all the Protected Material that was 2222 returned and (2) affirms that the Receiving Party has not retained any copies, 2233 abstracts, compilations, summaries or any other format reproducing or 2244 capturing any of the Protected Material. Notwithstanding this provision, 2255 Counsel are entitled to retain an archival copy of all pleadings, motion papers, 2266 trial, deposition, and hearing transcripts, legal memoranda, correspondence, 2277 deposition and trial exhibits, expert reports, attorney work product, and 2288 consultant and expert work product, even if such materials contain Protected 1 || Material. Any such archival copies that contain or constitute Protected Material 2 || remain subject to 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 5 || including, without limitation, contempt proceedings and/or monetary 6 || sanctions. 7 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 || DATED: June 26, 2024 10 gf 11 Lis Ke 8 JO . EARLY Untted States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 is. __ STIPULATED PROTECTIVE ORDER

11 EXHIBIT A 22 ACKNOWLEDGMENT AN AGREEMENT TO BE BOUND 33 44 I, _____________________________________, declare as follows: 55 1. My address is ________________________________________________. 66 2. My present employer is ________________________________________. 77 3. My present occupation or job description is _________________________. 88 4. I have received a copy of the Stipulated Protective Order entered in this action 99 on _______________, 20___. 1100 5. I have carefully read and understand the provisions of this Stipulated 1111 Protective Order. 1122 6. I will comply with all provisions of this Stipulated Protective Order. 1133 7. I will hold in confidence, and will not disclose to anyone not qualified under 1144 the Stipulated Protective Order, any information, documents or other 1155 materials produced subject to this Stipulated Protective Order. 1166 8. I will use such information, documents or other materials produced subject to 1177 this Stipulated Protective Order only for purposes of this present action. 1188 9. Upon termination of this action, or upon request, I will return and deliver all 1199 information, documents or other materials produced subject to this Stipulated 2200 Protective Order, and all documents or things which I have prepared relating 2211 to the information, documents or other materials that are subject to the 2222 Stipulated Protective Order, to my counsel in this action, or to counsel for the 2233 party by whom I am employed or retained or from whom I received the 2244 documents. 2255 10. I hereby submit to the jurisdiction of this Court for the purposes of enforcing 2266 the Stipulated Protective Order in this action. 2277 /// 2288 /// 11 I declare under penalty of perjury under the laws of the United States that the 22 foregoing is true and correct. 33 44 Executed this ____ day of _____________, 20__, at __________________. 55 66

77 QUALIFIED PERSON 88 99 1100 1111 1122 1133 1144 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277 2288