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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

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12 TOTAL SWEETENERS, INC. D/B/A CASE NO. 8:20-cv-00346-JLS-JDE 13 BATORY FOODS, an Illinois corporation, STIPULATED PROTECTIVE 14 ORDER 15 Plaintiff,

16 vs. 17 CHRISTOPHER QUEVEDO, an 18 individual, and KATHERINE 19 QUEVEDO, an individual,

20 Defendants. 21 _________________________________

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23 Pursuant to the parties’ Stipulation (Dkt. 32), and good cause appearing 24 therefor, it is hereby found and ordered as follows. 25 / / / 26 / / / 27 / / / 28 / / / 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the Parties hereby stipulate to and petition the Court to 6 enter the following Order. The Parties acknowledge that this Order does not confer 7 blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the Parties are entitled to 25 keep confidential, to ensure that the Parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a protective order 28 for such information is justified in this matter. It is the intent of the parties that 1 information will not be designated as confidential for tactical reasons and that 2 nothing will be so designated without a good faith belief that it has been maintained 3 in a confidential, non-public manner, and there is good cause why it should not be 4 part of the public record of this case. 5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 6 The Parties further acknowledge, as set forth in Section 14.3, below, that this 7 Order does not entitle them to file confidential information under seal; Local Civil 8 Rule 79-5 sets forth the procedures that must be followed and the standards that 9 will be applied when a Party seeks permission from the court to file material under 10 seal. There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 16 require good cause showing), and a specific showing of good cause or compelling 17 reasons with proper evidentiary support and legal justification, must be made with 18 respect to Protected Material that a Party seeks to file under seal. The Parties’ mere 19 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 20 without the submission of competent evidence by declaration, establishing that the 21 material sought to be filed under seal qualifies as confidential, privileged, or 22 otherwise protectable—constitute good cause. 23 Further, if a Party requests sealing related to a dispositive motion or trial, 24 then compelling reasons, not only good cause, for the sealing must be shown, and 25 the relief sought shall be narrowly tailored to serve the specific interest to be 26 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 27 2010). For each item or type of information, document, or thing sought to be filed 28 or introduced under seal, the Party seeking protection must articulate compelling 1 reasons, supported by specific facts and legal justification, for the requested sealing 2 order. Again, competent evidence supporting the application to file documents 3 under seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in its 5 entirety will not be filed under seal if the confidential portions can be redacted. If 6 documents can be redacted, then a redacted version for public viewing, omitting 7 only the confidential, privileged, or otherwise protectable portions of the document, 8 shall be filed. Any application that seeks to file documents under seal in their 9 entirety should include an explanation of why redaction is not feasible. 10 4. DEFINITIONS 11 4.1 Action: TOTAL SWEETENERS INC. D/B/A BATORY FOODS, an 12 Illinois corporation v. CHRISTOPHER QUEVEDO, an individual, KATHERINE 13 QUEVEDO, an individual, and SOLRYZA, LLC. 14 4.2 Challenging Party: a Party or Non-Party that challenges the 15 designation of information or items under this Order. 16 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 19 the Good Cause Statement. 20 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 21 their support staff). 22 4.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 4.6 Disclosure or Discovery Material: all items or information, regardless 26 of the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced 28 or generated in disclosures or responses to discovery. 1 4.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 4.8 House Counsel: attorneys who are employees of a Party to this 5 Action. House Counsel does not include Outside Counsel of Record or any other 6 outside counsel. 7 4.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 4.10 Outside Counsel of Record: attorneys who are not employees of a 10 Party to this Action but are retained to represent a Party to this Action and have 11 appeared in this Action on behalf of that Party or are affiliated with a law firm that 12 has appeared on behalf of that Party, and includes support staff. 13 4.12 Party: any Party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 4.13 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 4.14 Professional Vendors: persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 4.15 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 4.16 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 5. SCOPE 27 The protections conferred by this Order cover not only Protected Material (as 28 defined above), but also (1) any information copied or extracted from Protected 1 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 2 and (3) any testimony, conversations, or presentations by the Parties or their 3 Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge and other applicable authorities. This Order does not govern the use of 6 Protected Material at trial. 7 6. DURATION 8 Once a case proceeds to trial, information that was designated as 9 CONFIDENTIAL or maintained pursuant to this protective order used or 10 introduced as an exhibit at trial becomes public and will be presumptively available 11 to all members of the public, including the press, unless compelling reasons 12 supported by specific factual findings to proceed otherwise are made to the trial 13 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 14 “good cause” showing for sealing documents produced in discovery from 15 “compelling reasons” standard when merits-related documents are part of court 16 record). Accordingly, the terms of this Order do not extend beyond the 17 commencement of the trial. 18 7. DESIGNATING PROTECTED MATERIAL 19 7.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection under 21 this Order must take care to limit any such designation to specific material that 22 qualifies under the appropriate standards. The Designating Party must designate for 23 protection only those parts of material, documents, items or oral or written 24 communications that qualify so that other portions of the material, documents, 25 items or communications for which protection is not warranted are not swept 26 unjustifiably within the ambit of this Order. 27 Mass, indiscriminate or routinized designations are prohibited. Designations 28 that are shown to be clearly unjustified or that have been made for an improper 1 purpose (e.g., to unnecessarily encumber the case development process or to 2 impose unnecessary expenses and burdens on other parties) may expose the 3 Designating Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 designated for protection do not qualify for protection, that Designating Party must 6 promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 7.2 Manner and Timing of Designations. Except as otherwise provided in 8 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 9 that qualifies for protection under this Order must be clearly so designated before 10 the material is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) 18 (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine 25 which documents, or portions thereof, qualify for protection under this Order. Then, 26 before producing the specified documents, the Producing Party must affix the 27 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 28 portion of the material on a page qualifies for protection, the Producing Party also 1 must clearly identify the protected portion(s) (e.g., by making appropriate markings 2 in the margins). 3 (b) for testimony given in depositions that the Designating Party 4 identifies the Disclosure or Discovery Material on the record, before the close of 5 the deposition all protected testimony. When it is impractical to identify separately 6 each portions of the testimony that is entitled to protection and it appears that 7 substantial portion of the testimony may qualify for protection, the Designating 8 Party may invoke on the record (before the deposition is concluded) the right to 9 have up to 21 days to identify the specific portions of the testimony as to which 10 protection is south and to specify the level of protection being asserted. Only those 11 portions of the testimony that are appropriately designated for protection within the 12 21-day period shall be covered by the provision of this Order. Alternatively, a 13 Designating Party may specify, at the deposition, or up to 21 days afterwards if that 14 period is properly invoked, that the entire transcript shall be treated as 15 “CONFIDENTIAL.” 16 Parties shall give the other Parties notice if they reasonably expect a 17 deposition to include Protected Material so that the other Parties can ensure that 18 only authorized individuals who have signed the “Acknowledgement and 19 Agreement to be Bound (Exhibit A) are present at the deposition. The use of a 20 document as an exhibit at a deposition shall not in any way affect its designation as 21 “CONFIDENTIAL.” 22 Transcripts containing Protected Material shall have an obvious legend on 23 the title page that the transcript contains Protected Material, and the title page shall 24 be followed by a list of all pages (including line numbers as appropriate) that have 25 been designated as Protected Material and the level of protection being asserted by 26 the Designating Party. The Designating Party shall inform the court reported of 27 these requirements. Any transcript that is prepared before the expiration of a 21- 28 day period for designation shall be treated during that period as it if had been 1 designated “CONFIDENTIAL” in its entirely unless otherwise agreed and 2 documented. After the expiration of that period, the transcript shall be treated only 3 as actually designated. 4 (c) for information produced in some form other than documentary and 5 for any other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information is stored the 7 legend “CONFIDENTIAL.” If only a portion or portions of the information 8 warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party’s right to secure protection under this Order for such 13 material. Upon timely correction of a designation, the Receiving Party must make 14 reasonable efforts to assure that the material is treated in accordance with the 15 provisions of this Order. 16 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37-1 et seq. To avoid ambiguity as to whether 22 a challenge has been made, the written notice must recite that the challenge to 23 confidentiality is being made in accordance with this specific paragraph of the 24 Order. 25 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 26 joint stipulation pursuant to Local Rule 37-2. 27 8.4 The burden of persuasion in any such challenge proceeding shall be on 28 the Designating Party. Frivolous challenges, and those made for an improper 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all Parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 9. ACCESS TO AND USE OF PROTECTED MATERIAL 8 9.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 15 below (i.e., FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 (c) Experts (as defined in this Order) of the Receiving Party to whom 28 disclosure is reasonably necessary for this Action and who have signed the 1 “Acknowledgment and Agreement to Be Bound” (attached hereto as Exhibit A); 2 (d) the court and its personnel; 3 (e) court reporters and their staff; 4 (f) professional jury or trial consultants, mock jurors, and Professional 5 Vendors to whom disclosure is reasonably necessary for this Action and who have 6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (g) the author or recipient of a document containing the information or 8 a custodian or other person who otherwise possessed or knew the information; 9 (h) during their depositions, witnesses, and attorneys for witnesses, in 10 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 11 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 12 they will not be permitted to keep any confidential information unless they sign the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 14 agreed by the Designating Party or ordered by the court. Pages of transcribed 15 deposition testimony or exhibits to depositions that reveal Protected Material may 16 be separately bound by the court reporter and may not be disclosed to anyone 17 except as permitted under this Stipulated Protective Order; and 18 (i) any mediators or settlement officers and their supporting personnel, 19 mutually agreed upon by any of the parties engaged in settlement discussions. 20 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 21 IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification 26 shall include a copy of the subpoena or court order; 27 (b) promptly notify in writing the Party who caused the subpoena or 28 order to issue in the other litigation that some or all of the material covered by the 1 subpoena or order is subject to this Order. Such notification shall include a copy of 2 this Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” before a determination by the court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action 12 to disobey a lawful directive from another court. 13 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as “CONFIDENTIAL.” Such information 17 produced by Non-Parties in connection with this litigation is protected by the 18 remedies and relief provided by this Order. Nothing in these provisions should be 19 construed as prohibiting a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to 21 produce a Non-Party’s confidential information in its possession, and the Party is 22 subject to an agreement with the Non-Party not to produce the Non-Party’s 23 confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement 26 with a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 28 Order in this Action, the relevant discovery request(s), and a reasonably specific 1 description of the information requested; and 2 (3) make the information requested available for inspection by the 3 Non-Party, if requested. 4 (c) If the Non-Party fails to seek a protective order from this court 5 within 14 days of receiving the notice and accompanying information, the 6 Receiving Party may produce the Non-Party’s confidential information responsive 7 to the discovery request. If the Non-Party timely seeks a protective order, the 8 Receiving Party shall not produce any information in its possession or control that 9 is subject to the confidentiality agreement with the Non-Party before a 10 determination by the court. Absent a court order to the contrary, the Non-Party shall 11 bear the burden and expense of seeking protection in this court of its Protected 12 Material. 13 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Order, the Receiving Party must immediately (a) notify in writing the Designating 17 Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 18 unauthorized copies of the Protected Material, (c) inform the person or persons to 19 whom unauthorized disclosures were made of all the terms of this Order, and (d) 20 request such person or persons to execute the “Acknowledgment an Agreement to 21 Be Bound” attached hereto as Exhibit A. 22 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other 26 protection, the obligations of the Receiving Parties are those set forth in Federal 27 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 28 whatever procedure may be established in an e-discovery order that provides for 1 production without prior privilege review. Pursuant to Federal Rule of Evidence 2 502(d) and (e), the Parties agree that the inadvertent production or disclosure of any 3 material that is subject to a claim of privilege or other protection does not waive the 4 privilege or protection in connection with inadvertently disclosed material in the 5 Action or any other federal or state proceeding. 6 14. MISCELLANEOUS 7 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the Court in the future. 9 14.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Order, no Party waives any right it otherwise would have to object to disclosing or 11 producing any information or item on any ground not addressed in this Order. 12 Similarly, no Party waives any right to object on any ground to use in evidence of 13 any of the material covered by this Protective Order. 14 14.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Local Civil Rule 79-5. Protected Material 16 may only be filed under seal pursuant to a court order authorizing the sealing of the 17 specific Protected Material. If a Party’s request to file Protected Material under seal 18 is denied by the court, then the Receiving Party may file the information in the 19 public record unless otherwise instructed by the court. 20 15. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 6, within 60 22 days of a written request by the Designating Party, each Receiving Party must 23 return all Protected Material to the Producing Party or destroy such material. As 24 used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of the 26 Protected Material. Whether the Protected Material is returned or destroyed, the 27 Receiving Party must submit a written certification to the Producing Party (and, if 28 not the same person or entity, to the Designating Party) by the 60-day deadline that 1 || C1) identifies (by category, where appropriate) all the Protected Material that was 2 || returned or destroyed and (2) affirms that the Receiving Party has not retained any 3 || copies, abstracts, compilations, summaries or any other format reproducing or 4 || capturing any of the Protected Material. Notwithstanding this provision, Outside 5 || Counsel of Record are entitled to retain an archival copy of all pleadings, motion 6 || papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 7 || deposition and trial exhibits, expert reports, attorney work product, and consultant g || and expert work product, even if such materials contain Protected Material. Any 9 || such archival copies that contain or constitute Protected Material remain subject to 10 || this Protective Order as set forth in Section 6 (DURATION). 11 || 16. VIOLATION 12 Any violation of this Order may be punished by appropriate measures 13 || Including, without limitation, contempt proceedings and/or monetary sanctions. 14 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 1g || DATED: September 16, 2020 19 io 20

J OBR D. EARLY ; Z

ited States Magistrate Judge 22 23 24 25 26 27 28 4816-0658-8607.8 -14-

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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11 TOTAL SWEETENERS, INC. D/B/A CASE NO. 8:20-cv-346-JLS-JDE 12 BATORY FOODS, an Illinois corporation, EXHIBIT A TO STIPULATED 13

PROTECTIVE ORDER

14 Plaintiff,

15 vs. 16 CHRISTOPHER QUEVEDO, an 17 individual, and KATHERINE 18 QUEVEDO, an individual,

19 Defendants. 20 21 ACKNOWLEDGEMENT AND

AGREEMENT TO BE BOUND

22 23 The undersigned hereby acknowledges that he/she has read the Confidentiality 24 Order dated September 16, 2020 in the above-captioned action and attached hereto, 25 understands the terms thereof, and agrees to be bound by its terms. The 26 undersigned submits to the jurisdiction of the United States District Court for the 27 Central District of California in matters relating to the Confidentiality Order and 28 understands that the terms of the Confidentiality Order obligate him/her to use 1 materials designated as Confidential Information in accordance with the Order 2 solely for the purposes of the above-captioned action, and not to disclose any such 3 Confidential Information to any other person, firm or concern. The undersigned 4 acknowledges that violation of the Confidentiality Order may result in penalties for 5 contempt of court. 6 Signature: __________________________________ Name: __________________________________ 7 Employer: __________________________________ Job Title: __________________________________ 8 Business Address: __________________________________ Email/Phone: __________________________________ 9

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