Halton et al v. Valspar Corp.
Filing
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JOINT STIPULATION and PROTECTIVE ORDER re CONFIDENTIAL DISCOVERY signed by Magistrate Judge Carolyn K. Delaney on 11/21/11. (Kaminski, H) Modified on 11/22/2011 (Krueger, M).
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JOAN B. TUCKER FIFE (SBN: 144572)
email: jfife@winston.com
WINSTON & STRAWN LLP
101 California Street, Suite 3900
San Francisco, CA 94111
Telephone: 415-591-1000
Facsimile:
415-591-1400
Attorneys for Defendant,
VALSPAR CORPORATION
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Los Angeles, CA 90071-1543
Winston & Strawn LLP
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SHAWN KHORRAMI (SBN: 180411)
skhorrami@kpalawyers.com
ROBERT J. DREXLER, JR. (SBN: 119119)
rdrexler@kpalawyers.com
LAUNA ADOLPH (SBN: 227743)
ladolph@kpalawyers.com
KHORRAMI POLLARD & ABIR LLP
444 S. Flower St., Thirty-Third Floor
Los Angeles, California 90071
Telephone: (213) 596-6000
Attorneys for Plaintiffs,
LUKE HALTON and DENNIS BIER
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ADDITIONAL COUNSEL LISTED ON SIGNATURE PAGE
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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LUKE HALTON and DENNIS BIER,
Individually and on behalf of All Other
Similarly Situated Current and Former
Employees,
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Plaintiffs,
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vs.
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VALSPAR CORPORATION &
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SUBSIDIARIES, a Delaware corporation, and )
DOES 1 through 10, inclusive,
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Defendants.
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Case No. 2:10-cv-02400-KJM-CKD
JOINT STIPULATION FOR PROTECTIVE
ORDER REGARDING CONFIDENTIAL
DISCOVERY AND ORDER
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STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY
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The Plaintiffs named in the First Amended Class Action Complaint and Defendant Valspar
Corporation (individually, a “Party”, and, collectively, the “Parties”), by and through their
undersigned counsel for the above captioned action (“Action”), stipulate and agree as follows:
1.
Purpose. Until further order of the Court or stipulation of the Parties, any and all (a)
documents and depositions which are produced, given, returned, or supplied by the Parties to this
Action or the Parties’ experts; (b) extracts and summaries prepared from such materials; (c)
information contained in or obtained from such materials; and/or (d) those portions of briefs,
affidavits, memoranda, depositions, or other writings, including exhibits thereto, which contain or
refer to such materials, shall be used solely for the prosecution, defense, or settlement of the Action
(including any appeals) and shall be subject to this Stipulated Protective Order (hereinafter
“Protective Order”).
2.
Types of Information Eligible For Protection. The following three types of
information are eligible for protection under this Protective Order.
a.
Confidential Information. Any Party or non-party subject to subpoena issued
in this matter (“Non-Party”) may, in good faith, designate as “Confidential,” in whole or in part,
information, documents, materials or testimony which contain or reveal confidential personal
information, or proprietary or other information treated as confidential by that Party in its business
operations. Confidential information and documents (“Confidential Information”) shall include
documents, portions of deposition transcripts, interrogatory answers, responses to requests for
admission, and any other discovery materials designated as Confidential as set forth below. Any
documents or information designated Confidential shall be treated as such, unless and until the
attorneys of record in this Action agree in writing that the documents or information may be
declassified or the Court rules to the contrary. This Paragraph shall be interpreted to be consistent
with the procedures set forth below governing objections to “Confidential” designations.
b.
Highly Confidential Information. The Parties acknowledge that discovery
may include information of an exceptionally sensitive nature, including proprietary business
information. Accordingly, any Party or Non-Party may, in good faith, designate such exceptionally
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sensitive information “Highly Confidential.” Highly Confidential information and documents
(“Highly Confidential Information”) shall include documents, portions of deposition transcripts,
interrogatory answers, responses to requests for admission, and any other discovery materials
designated as Highly Confidential as set forth below. Any documents or information designated
Highly Confidential shall be treated as such, unless and until the attorneys of record in this Action
agree in writing that the documents or information may be declassified or the Court rules to the
contrary. This Paragraph shall be interpreted to be consistent with the procedures set forth below
governing objections to “Highly Confidential” designations.
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c.
Confidential Personnel Information. Defendant Valspar Corporation
maintains information about its employees. Defendant maintains this information, such as personnel
files and payroll data, in confidence. This information shall be designated “Confidential Personnel”
and shall be treated as Highly Confidential information under the terms of this agreement. This
Paragraph shall be interpreted to be consistent with the procedures set forth below governing
objections to “Highly Confidential” designations.
3.
Particularized Need That Must Be Addressed By Court Order: The designation of
Confidential Information as defined in Paragraph 2(a), Highly Confidential Information as defined in
Paragraph 2(b) and Confidential Personnel Information as defined in Paragraph 2(c), is required in
order to protect the Parties from disclosure of information that may violate an individual’s right to
privacy, negatively impact a Party’s business and/or competitive position because it would reveal
confidential, trade secret, proprietary, financial or commercially sensitive information and/or breach
an obligation of a Party to maintain the confidentiality of information. A Court Order is required in
order to provide an enforcement mechanism between the Parties and with third parties allowed to
access the information who are identified in Paragraph 6.
4.
Method of Designating Documents Confidential or Highly Confidential. Any
documents intended to be Confidential, Highly Confidential or Confidential Personnel shall be so
designated by the producing Party by stamping “Confidential,” “Highly Confidential,” or
“Confidential Personnel” on the first page of the document.
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(a)
Documents produced prior to the entry of this Order may be designated
Confidential, Highly Confidential, or Confidential Personnel by the producing
Party within ten (10) business days of the date of the Order. Any such
designation shall be in writing delivered to the receiving Party.
(b)
If a portion of deposition testimony is designated Confidential, Highly
Confidential, or Confidential Personnel at the time given, the reporter shall
mark that portion of the transcript accordingly.
(c)
Employment records produced pursuant to authorizations shall automatically
be deemed Confidential Personnel.
(d)
The producing party may designate Electronically Stored Informed (ESI) as
Confidential, Highly Confidential, or Confidential Personnel by marking the
produced disc or drive with the appropriate designation or by accompanying
the ESI production with correspondence which communicates the appropriate
designation.
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Subsequent Designation. The failure of a producing Party to designate information or
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documents as “Confidential,” “Highly Confidential,” or “Confidential Personnel” at the time of the
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initial production of the same shall not prejudice the producing Party’s right to thereafter designate
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such information or documents if the initial failure to designate was inadvertent. A producing Party
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may designate any information or documents previously produced without designation by providing
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written notice of the same to each recipient of the information or documents within thirty (30) days
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of discovery of the inadvertent production of undesignated information or documents. Upon such
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designation, the producing Party shall re-produce the information or documents in a properly
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designated form. Upon production of the re-produced information or documents, recipient Parties
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shall promptly take reasonable steps to ensure that all undesignated copies of such information or
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documents are destroyed and replaced with properly designated copies of such information or
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documents by the producing Party.
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Contesting “Confidential” and/or “Highly Confidential” Designations. A receiving
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Party may object to the designation of information or documents as Confidential or Highly
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Confidential, or the failure of a producing Party to so designate information or documents by
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notifying counsel for the producing Party in writing at any time during the litigation. The Parties
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agree to engage in good faith informal discussions concerning any dispute over the designation of
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information or documents as “Confidential” or “Highly Confidential.” If the matter is not resolved
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by the Parties themselves, the Party challenging the designated status of information or documents
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claimed to be restricted by this Protective Order shall have thirty (30) days from the date of written
notice of objection in which to make a motion challenging the applicability of this Protective Order
with respect to such information or documents. The Parties shall treat the disputed information or
documents as Confidential or Highly Confidential until the Court rules or the Parties reach a written
agreement otherwise. The Party proposing confidentiality designations has the burden of justifying
the designations.
7.
Persons Allowed Access to Confidential Information. Information and documents
designated Confidential shall be maintained in confidence and shall not be disclosed or made
available to any person other than:
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(a)
The attorneys of record in this Action and Defendants’ in-house counsel and
their associated attorneys, legal assistants, and staff members working on the
Action;
(b)
Independent consultants and/or experts retained by the Parties to work on the
Action, provided, however, that before any such consultant or expert is shown
or receives any documents or information, the consultant or expert must agree
in writing to abide by the terms of this Protective Order;
(c)
Named Plaintiffs, class member (in the event that the class is certified),
Defendant Valspar Corporation, and any current and former officers,
directors, employees, advisors, or agents of the Parties, who assist the
attorneys of record in this Action, provided, however, that named Plaintiffs
and class members who are former employees of Defendant Valspar
Corporation may only be shown Confidential Information and may not be
given copies of information or documents containing such Information,
provided, further, that before any person identified in category 8(c) receives
any information or documents, he or she must agree in writing to abide by the
terms of this Protective Order by executing Exhibit A attached hereto;
(d)
A person who prepared or received the Confidential Information prior to its
production in the action, provided that before any person receives or is given
access to any Confidential Information pursuant to this section, he or she shall
execute Exhibit A attached hereto, which includes an agreement to be bound
by this Protective Order;
(e)
(i)
A deponent during a deposition or a witness on examination in
a hearing or at trial, subject to any objection to such disclosure by
counsel for the Party that produced the Confidential Information, and
provided that the witness shall be requested on the record to execute
Exhibit A attached hereto, agreeing to be bound by the Protective
Order, before any Confidential Information may be disclosed to the
witness; or
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provided, further, that persons identified in category 8(e)(i) that refuse
on the record to execute Exhibit A and be bound by its terms shall not
be shown any Confidential Information without consent on the record
from counsel for the Party who designated the information
Confidential; and provided, further, that persons identified in category
8(e)(i) that refuse on the record to execute Exhibit A and be bound by
its terms who are shown Confidential Information after consent has
been given on the record by counsel for the Party who designated the
information Confidential, shall not be permitted to retain any
document designated as containing Confidential Information, and
provided, further, that no Plaintiff shall be shown Confidential
Information without executing Exhibit A agreeing to be bound by the
terms of Exhibit A, and
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provided, further, that persons identified in category 8(e)(ii) may only
be shown Confidential Information but may not be given copies of, or
allowed to retain, documents containing such Information;
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a potential deponent or witness who the examining counsel believes in
good faith has relevant information specifically regarding the
Confidential Information that was not obtained in violation of this
Protective Order; provided that prior to the time that any such person
is given access to Confidential Information, such person shall be
provided with a copy of this Protective Order and shall execute Exhibit
A hereto agreeing to be bound by this Protective Order, which shall be
retained by counsel making the disclosure of the Confidential
Information, and provided, further, that named Plaintiffs and class
members who are former employees of Defendant Valspar
Corporation may only be shown Confidential Information and may not
be given copies of information or documents containing such
Information, and
(f)
Clerical and data processing personnel involved in the production,
reproduction, organizing, filing, coding, cataloging, converting, storing,
retrieving, and review of Confidential Information, to the extent reasonably
necessary to assist the Parties in connection with the action;
(g)
Stenographic reporters engaged for depositions or other proceedings necessary
to the conduct of the Action;
(h)
Any third-Party mediator jointly selected by the Parties or appointed by the
Court;
(i)
Such persons as the attorneys of record in this Action shall mutually consent
to in writing or on the record prior to the proposed disclosure; and
(j)
The Court and its authorized staff, and other such persons as the Court may
direct as authorized to receive Confidential Information.
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Nothing contained in the Protective Order shall prevent any Party from disclosing its own
Confidential information and documents as may be consistent with applicable law.
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8.
Persons Allowed Access To Highly Confidential Information. Information and
documents designated Highly Confidential shall be maintained in confidence and shall not be
disclosed or made available to any person other than:
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(a)
The attorneys of record in this Action and their associated attorneys, legal
assistants, and staff members working on the Action;
(b)
Any person involved in the preparation of or who had authorized access to the
contents of the Highly Confidential information or document;
(c)
Independent consultants and/or experts retained by the Parties to work on the
Action, provided, however, that before any such consultant or expert is shown
or receives any information or documents, the consultant or expert must agree
in writing to abide by the terms of this Protective Order;
(d)
A person who prepared or received the Highly Confidential Information prior
to its production in the action, provided that before any person receives or is
given access to any Highly Confidential Information pursuant to this section,
he or she shall execute Exhibit A attached hereto agreeing to be bound by this
Protective Order;
(e)
A deponent during a deposition or a witness on examination in a hearing or at
trial, subject to any objection to such disclosure by counsel for the Party that
produced the Highly Confidential Information, and provided that the witness
shall be requested on the record to execute Exhibit A attached hereto agreeing
to be bound by the Protective Order, before any Highly Confidential
Information may be disclosed to the witness; provided, further, that named
Plaintiffs and class members who are former employees of Defendant Valspar
Corporation may only be shown Highly Confidential Information and may not
be given copies of information or documents containing such Information,
provided, further, that any person identified in this section 9(e) that refuses on
the record to execute Exhibit A and be bound by its terms shall not be shown
any Highly Confidential Information or Confidential Personnel Information,
without consent on the record from counsel for the Party who designated the
information Highly Confidential or Confidential Personnel; and provided,
further, that persons identified in category 9(e) that refuse on the record to
execute Exhibit A and be bound by its terms who are shown Highly
Confidential Information or Confidential Personnel Information after consent
has been given on the record by counsel for the Party who designated the
information Highly Confidential Information or Confidential Personnel
Information, shall not be permitted to retain any document designated as
containing Highly Confidential Information or Confidential Personnel
Information.
(f)
Clerical and data processing personnel involved in the production,
reproduction, organizing, filing, coding, cataloging, converting, storing,
retrieving, and review of Highly Confidential Information, to the extent
reasonably necessary to assist the Parties in connection with the action; and
(g)
Stenographic reporters engaged for depositions or other proceedings necessary
to the conduct of the Action;
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(h)
Any third-Party mediator jointly selected by the Parties or appointed by the
Court;
(i)
Such persons as the attorneys of record in this Action shall mutually consent
to in writing or on the record prior to the proposed disclosure; and
(j)
The Court and its authorized staff, and other such persons as the Court may
direct as authorized to receive Highly Confidential Information.
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Nothing contained in the Protective Order shall prevent any Party from disclosing its own Highly
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Confidential information and documents as may be consistent with applicable law.
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Named Plaintiffs and class members may not be shown Highly Confidential information
Confidential Information prior to its production in the action, provided that before any person
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unless the Named Plaintiff or class member is a person who prepared or received the Highly
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receives or is given access to any Confidential Information pursuant to this section, he or she shall
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execute Exhibit A attached hereto agreeing to be bound by this Protective Order. Named Plaintiffs
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and class members may not be shown Confidential Personnel information unless: (i) the personnel
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information pertains to that specific named Plaintiff or class member; or (ii) the employee who the
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personnel information pertains to waives confidentiality of that information in writing;
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Use of Confidential Information in Deposition. No person may refuse to answer any
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question at a deposition on the sole ground that the question requires the person to reveal
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Confidential or Highly Confidential material. The deposition must proceed upon the following
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basis: Prior to answering the deposition question or questions all persons present shall be advised of
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the terms and conditions of this Stipulation and Protective Order and, at the request of the
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designating Party, all persons not authorized to receive Confidential or Highly Confidential material
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under this Stipulation and Protective Order shall leave the room during the time in which this
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material is disclosed or discussed.
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10.
Use of Confidential Information at Trial. The use of Confidential or Highly
Confidential Information shall be governed by Local Rule 141.1(b)(2).
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No Publication. No Confidential or Highly Confidential information or documents
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shall be published or disseminated by the Parties or their counsel without the permission of the Party
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designating such information or documents as Confidential or Highly Confidential. Portions of
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affidavits and briefs quoting Highly Confidential information or documents shall not be published or
disseminated by the Parties or their counsel without the permission of the Party designating such
information, documents or materials as Confidential or Highly Confidential.
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12.
Disclosures Required By Law. If a Party who received Confidential Information or
Highly Confidential Information is later required by law, regulation, subpoena, or order to disclose
or provide Confidential Information or Highly Confidential Information to any person or to any
judicial, governmental, or administrative body, the Party being required to disclose or provide the
Confidential Information or Highly Confidential Information (the “Disclosing Party”) shall give
written notice of such proposed disclosure to the attorneys of record of the producing Party and the
other Parties to this Action at least five (5) days before such disclosure. If the law, regulation, or
order requires disclosure in a way that renders five (5) days’ notice impracticable, the Disclosing
Party shall give such notice by telephone as soon as practicable, but in any event before disclosure is
made.
13.
Court Filings. Any information or documents designated Confidential or Highly
Confidential, as well as portions of affidavits and briefs quoting or referencing Confidential
Information or Highly Confidential Information may be filed with the Court only after a sealing
order is obtained in compliance with Local Rule 141. If a receiving Party’s request to seal pursuant
to Local Rule 141 is denied by the Court, the receiving Party may file the information in the public
record unless otherwise instructed by the Court.
14.
After the Litigation. The obligations of this Stipulated Protective Order are
continuing and shall not terminate at the conclusion of this litigation. Upon settlement or final
determination of this litigation, all Confidential Information or Highly Confidential Information and
all available copies, summaries, compilations, abstracts or any other document or material setting
forth the contents of any such information or documents shall be returned to the Party who produced
such Confidential Information or Highly Confidential Information within sixty (60) days after
litigation is concluded. A Party who has received Confidential or Highly Confidential information
or documents may destroy electronic copies of such information or documents in their possession
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within sixty (60) days after litigation is concluded, provided that Party certifies in writing to the
Party who produced such information or documents that such electronic information or documents,
and any and all copies, summaries, compilations, abstracts or any other document or material setting
forth the contents of any such information or documents, have been fully and completely deleted and
destroyed from any and all electronic systems and/or storage media. This Court will retain
jurisdiction over enforcement of the terms of this Protective Order for sixty (60) days after litigation
is concluded or until the Clerk has closed the action, which ever date occurs later.
15.
Work Product and Briefs. Counsel may maintain their work product and all briefs,
pleadings or other filings with the Court that include information or documents designated
Confidential or Highly Confidential, but these information or documents shall remain subject to the
terms of this Protective Order.
16.
No Waiver of Confidentiality, Highly Confidential, Attorney-Client Privilege or
Work Product Doctrine. Nothing in this Stipulation and Order shall be deemed to require disclosure
of Confidential Information, Highly Confidential Information, or material protected by the attorneyclient privilege, the work product doctrine, or any other applicable privileges. The inadvertent
production of any document during this litigation shall be without prejudice to any claim of
confidentiality, Highly Confidential status, attorney-client privilege, work product doctrine, or any
other legally recognized privilege, and the producing Party shall not be held to have waived any
rights by an inadvertent production. If the Party who inadvertently produced such documents
demands return of the document on the grounds that it is privileged and/or work product, the Party to
whom the document has been produced shall return the materials or document promptly and not
retain any copies, summaries or other abstracts. The Party to whom the privileged or protected
materials were produced may file a motion to challenge the claim of privilege or protection and to
compel production of the document or materials; lacking that, the demanded documents and all
copies shall be returned to the Parties that produced them.
17.
Limitations. Nothing in this Stipulation and Order shall be construed to limit any
Party from opposing discovery on any grounds otherwise available. Nor shall anything in this
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Stipulation and Order restrict a Party or its trial counsel from using or disclosing information that
they already possess or may acquire by proper means in the future independent of the formal
discovery process in this Action. Further, the Parties do not intend to waive any rights via this
Stipulation with regard to the manner in which Court proceedings are conducted and the use of
Confidential or Highly Confidential documents at trial. Nothing in this Stipulated Protective Order
shall bar or otherwise restrict any attorney from rendering advice to a Party-client in this Action and,
in the course thereof, relying upon such attorneys’ examination of “Confidential” and/or “Highly
Confidential” information, documents, materials and testimony; provided, however, that in rendering
such advice and in otherwise communicating with such client, the attorney shall not disclose the
specific contents of any “Confidential” or “Highly Confidential” information, documents, materials
and testimony to any unauthorized person.
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Disclosure. Should any “Confidential” or “Highly Confidential” information,
documents, materials or testimony be disclosed, through inadvertence or otherwise, by any receiving
Party to any person or entity not authorized to receive or see such information, documents, materials
or testimony under the terms of this Stipulated Protective Order, the Party responsible for such
disclosure shall (a) use its best efforts to obtain the return of any such “Confidential” or “Highly
Confidential” information, documents, materials or testimony; (b) within three (3) business days of
the discovery of such disclosure, inform the unauthorized recipient in writing of the terms of this
Protective Order, request immediate return of the material in question, and request that the
unauthorized recipient agree to be bound by the terms of this Protective Order; (c) within five (5)
business days of the discovery of such disclosure, inform counsel for all Parties in this Action in
writing of the fact and circumstances of the unauthorized disclosure, all efforts made to recover any
“Confidential” or “Highly Confidential” information, documents, materials or testimony, and the
results of such efforts; and (d) within seven (7) business days of the discovery of such disclosure,
and provided that efforts to secure the return of the material in question are unsuccessful, inform the
Court in writing of the fact and circumstances of the unauthorized disclosure and all efforts made to
recover any “Confidential” or “Highly Confidential” information, documents, materials or
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testimony, and request that the Court direct the unauthorized recipient to return the material(s) in
question.
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Modification. This Stipulation and Order does not prevent disclosure beyond its
terms if the producing Party consents to the disclosure in writing, or if the Court orders such a
disclosure. Further, the Parties may modify this Agreement in writing and with approval by the
Court. Any Party may request modification of this Order from the Court, after written notice to the
other Party.
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STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY
CASE NO. 2:10-CV-02400-KJM-CKD
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Dated: October 26, 2011
WINSTON & STRAWN LLP
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By: /s/ Emilie C. Woodhead (as authorized on 10/26/11)
Emilie C. Woodhead
email: ewoodhead@winston.com
WINSTON & STRAWN LLP
333 South Grand Avenue, Suite 3800
Los Angeles, CA 90071-1543
Telephone: 213-615-1700
Facsimile: 213-615-1750
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Attorneys for Defendant,
VALSPAR CORPORATION
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333 S. Grand Avenue
Los Angeles, CA 90071-1543
Winston & Strawn LLP
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Dated: November 17, 2011
KHORRAMI POLLARD & ABIR LLP
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By: /s/ Shawn Khorrami (as authorized on 11/17/11)
Shawn Khorrami
KHORRAMI POLLARD & ABIR, LLP
444 S. Flower Street, 33rd Floor
Los Angeles, CA 90071
Telephone: (213) 596-6000
Facsimile: (213) 596-6010
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By: /s/ Robert J. Drexler, Jr. (as authorized on 11/17/11)
Robert J. Drexler, Jr.
KHORRAMI POLLARD & ABIR, LLP
444 S. Flower Street, 33rd Floor
Los Angeles, CA 90071
Telephone: (213) 596-6000
Facsimile: (213) 596-6010
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By: /s/ Launa Adolph
Launa Adolph
KHORRAMI POLLARD & ABIR, LLP
444 S. Flower Street, 33rd Floor
Los Angeles, CA 90071
Telephone: (213) 596-6000
Facsimile: (213) 596-6010
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12
STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY
CASE NO. 2:10-CV-02400-KJM-CKD
1
Dated: ________ __, 2011
POGUST, BRASLOW & MILLROOD LLC
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3
By:
Andrew J. Sciolla (Pro Hac Vice)
POGUST, BRASLOW & MILLROOD LLC
Eight Tower Bridge, Suite 1520
161 Washington Street
Conshohocken, PA 19428
Telephone: (610) 941-4204
Facsimile: (610) 941-4245
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Attorneys for Plaintiffs,
LUKE HALTON and DENNIS BIER
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ORDER
333 S. Grand Avenue
Los Angeles, CA 90071-1543
Winston & Strawn LLP
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IT IS SO ORDERED.
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Dated: November 21, 2011
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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
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STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY
CASE NO. 2:10-CV-02400-KJM-CKD
1
EXHIBIT A
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AGREEMENT TO BE BOUND BY A PROTECTIVE ORDER
The undersigned hereby acknowledges and declares, subject to the penalty of perjury, that he
or she has received a copy of the Joint Stipulated Protective Order Regarding Confidential Discovery
Matters in Luke Halton, et al. v. Valspar Corporation, et. al., Case No. 2:10-CV-02400, has read
such Joint Stipulated Protective Order Regarding Confidential Discovery Matters, agrees to be
bound by all of the terms thereof, and further agrees that the United States District Court for the
Eastern District of California may exercise jurisdiction over him/her to enforce such Joint Stipulated
Protective Order Regarding Confidential Discovery Matters, as necessary.
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333 S. Grand Avenue
Los Angeles, CA 90071-1543
Winston & Strawn LLP
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Dated: _________________________
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___________________________________
SIGNATURE
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___________________________________
PRINT NAME
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234b0d4o
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STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY
CASE NO. 2:10-CV-02400-KJM-CKD
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