Carrico Et.al. v. Samsung Electronics Co., Ltd. et al.

Northern District of California, cand-4:2015-cv-02087

ORDER granting AS MODIFIED Stipulated Protective Order {{28}} filed by Samsung Electronics Co., Ltd. (dmrlc3, COURT STAFF)

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4 Eric C. Kastner (State Bar No. 53858) Luis V. Garcia (State Bar No. 154861) 2 Kastner, Kim LLP 700 E. El Camino Real, Suite 230 3 Mountain View, CA 94040 Telephone: (650)967-7854 4 Facsimile: (650)386-1885 eck@kastrl.erkim .com; lvg@kastnerkim.com 5 Attorneys for Defendant 6 Samsung Electronics Co., LTD. 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 JEFFREY A. CARRICO, and NICOLE R. Civil Action No.: 4:15-CV-02087 DMR SALAS, 11 MODIFIED Plaintiffs, STIPULATED PROTECTIVE ORDER 12 FOR STANDARD LITIGATION vs. 13 YOONHWAPARK, THE HERTZ 14 CORPORATION; SAMSUNG INTERNATIONAL, INC., SAMSUNG 15 ELECTRONICS AMERICA, INC., SAMSUNG ELECTRONICS CO., LTD., 16 SAMSUNG ELECTRONICS NORTH AMERICA, INC. and Does 1 - 40, 17 Defendants. 18 19 1. PURPOSES AND LIMITATIONS 20 Disclosure and discovery activity in this action are likely to involve production of 21 confidential, proprietary, or private information for which special protection from public disclosure 22 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 23 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective 24 Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures 25 or responses to discovery and that the protection it affords from public disclosure and use extends 26 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 only to the limited information or items that are entitled to confidential treatment under the 2 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that 3 this Stipulated Protective Order does not entitle them to file confidential information under seal; 4 Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be 5 applied when a party seeks permission from the court to file material under seal. 6 2. DEFINITIONS 7 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 8 information or items under this Order. 9 2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is I0 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 11 Civil Procedure 26(c). 12 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well 13 as their support staff). 14 2.4 Designating Party: a Party or Non-Party that designates information or items that it 15 produces in disclosures or in responses to discovery as "CONFIDENTIAL." 16 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium 17 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 18 transcripts, and tangible things), that are produced or generated in disclosures or responses to 19 discovery in this matter. 20 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to 21 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 22 consultant in this action. 23 2.7 House Counsel: attorneys who are employees of a party to this action. House 24 Counsel does not include Outside Counsel of Record or any other outside counsel. 25 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 26 2 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 entity not named as a Party to this action. 2 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action 3 but are retained to represent or advise a party to this action and have appeared in this action on 4 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 5 2.1 0 Party: any party to this action, including all of its officers, directors, employees, 6 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 7 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 8 Material in this action. 9 2.12 Professional Vendors: persons or entities that provide litigation support services I0 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 11 storing, or retrieving data in any form or medium) and their employees and subcontractors. 12 2.13 Protected Material: any Disclosure or Discovery Material that is designated as 13 "CONFIDENTIAL." 14 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 15 Producing Party. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected Material (as 18 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 19 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 20 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 21 However, the protections conferred by this Stipulation and Order do not cover the following 22 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 23 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 24 publication not involving a violation of this Order, including becoming part of the public record 25 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 26 3 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 2 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 3 Protected Material at trial shall be governed by a separate agreement or order. 4 4. DURATION 5 Even after final disposition of this litigation, the confidentiality obligations imposed by this 6 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 7 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 8 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 9 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the I0 time limits for filing any motions or applications for extension of time pursuant to applicable law. 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 13 Non-Party that designates information or items for protection under this Order must take care to 14 limit any such designation to specific material that qualifies under the appropriate standards. The 15 Designating Party must designate for protection only those parts of material, documents, items, or 16 oral or written communications that qualify- so that other portions of the material, documents, 17 items, or communications for which protection is not warranted are not swept unjustifiably within 18 the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 20 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 21 encumber or retard the case development process or to impose unnecessary expenses and burdens on 22 other parties) expose the Designating Party to sanctions. 23 If it comes to a Designating Party's attention that information or items that it designated for 24 protection do not qualify for protection, that Designating Party must promptly notify all other Parties 25 that it is withdrawing the mistaken designation. 26 4 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 2 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 3 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 4 designated before the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic documents, but 7 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 8 affix the legend "CONFIDENTIAL" to each page that contains protected material. If only a portion 9 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 10 identify the protected portion(s) (e.g., by making appropriate markings in the margins). II A Party or Non-Party that makes original documents or materials available for inspection need not 12 designate them for protection until after the inspecting Party has indicated which material it would 13 like copied and produced. During the inspection and before the designation, all of the material made 14 available for inspection shall be deemed "CONFIDENTIAL." After the inspecting Party has 15 identified the documents it wants copied and produced, the Producing Party must determine which 16 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 17 specified documents, the Producing Party must affix the "CONFIDENTIAL" legend to each page 18 that contains Protected Material. If only a portion or portions of the material on a page qualifies for 19 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 20 appropriate markings in the margins). 21 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 22 Designating Party identify on the record, before the close of the deposition, hearing, or other 23 proceeding, all protected testimony. 24 (c) for information produced in some form other than documentary and for any other 25 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 26 5 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 containers in which the information or item is stored the legend "CONFIDENTIAL." If only a 2 portion or portions of the information or item warrant protection, the Producing Party, to the extent 3 practicable, shall identify the protected portion(s). 4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 5 designate qualified information or items does not, standing alone, waive the Designating Party's 6 right to secure protection under this Order for such material. Upon timely correction of a 7 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in 8 accordance with the provisions of this Order. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 11 confidentiality at any time. Unless a prompt challenge to a Designating Party's confidentiality 12 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 13 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 14 confidentiality designation by electing not to mount a challenge promptly after the original 15 designation is disclosed. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 17 by providing written notice of each designation it is challenging and describing the basis for each 18 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 19 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 20 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 21 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 22 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 23 Party must explain the basis for its belief that the confidentiality designation was not proper and 24 must give the Designating Party an opportunity to review the designated material, to reconsider the 25 circumstances, and, if no change in designation is offered, to explain the basis for the chosen 26 6 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 designation. A Challenging Party may proceed to the next stage ofthe challenge process only if it 2 has engaged in this meet and confer process first or establishes that the Designating Party is 3 unwilling to participate in the meet and confer process in a timely manner. 4 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court the parties shall follow the procedure set forth in the 5 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil judge's Standing Order. 6 Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days ofthe 7 initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process 8 will not resolve their dispute, whichever is earlier. Each such motion must be accompanied by a 9 competent declaration affirming that the movant has complied with the meet and. confer I0 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a 11 motion including the required declaration within 21 days (or 14 days, if applicable) shall 12 automatically waive the confidentiality designation for each challenged designation. In addition, the 13 Challenging Party may file a motion challenging a confidentiality designation at any time if there is 14 good cause for doing so, including a challenge to the designation of a deposition transcript or any 15 portions thereof. Any motion brought pursuant to this provision must be accompanied by a 16 competent declaration affirming that the movant has complied with the meet and confer 17 requirements imposed by the preceding paragraph. 18 The burden of persuasion in any such challenge proceeding shall be on the Designating 19 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 20 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. 21 Unless the Designating Party has waived the confidentiality designation by failing to file a motion to 22 retain confidentiality as described above, all parties shall continue to afford the material in question 23 the level of protection to which it is entitled under the Producing Party's designation until the court 24 rules on the challenge. 25 26 7 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action 1'/o.: 4:15-CV-02087 DMR 28 4 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 3 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 4 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 5 the categories of persons and under the conditions described in this Order. When the litigation has 6 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 7 DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a location and in a 9 secure manner that ensures that access is limited to the persons authorized under this Order. 10 7.2 Disclosure of"CONFIDENTIAL" Information or Items. Unless otherwise ordered by 11 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 12 information or item designated "CONFIDENTIAL" only to: 13 ·(a) the Receiving Party's Outside Counsel of Record in this action, as well as employees 14 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for 15 this litigation and who have signed the "Acknowledgment and Agreement to Be Bound" that is 16 attached hereto as Exhibit A; 17 (b) the officers, directors, and employees (including House Counsel) of the Receiving 18 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 19 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 20 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 21 reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement 22 to Be Bound" (Exhibit A); 23 (d) the court and its personnel; 24 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 25 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 26 8 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 2 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 3 necessary and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A), 4 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 5 deposition testimony or exhibits to depositions that reveal Protected Material must be separately 6 bound by the court reporter and may not be disclosed to anyone except as permitted under this 7 Stipulated Protective Order. 8 (g) the author or recipient of a document containing the information or a custodian or 9 other person who otherwise possessed or knew the information. 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 11 12 If a Party is served with a subpoena or a court order issued in other litigation that compels 13 disclosure of any information or items designated in this action as "CONFIDENTIAL," that Party 14 must: 15 (a) promptly notify in writing the Designating Party. Such notification shall include a 16 copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to issue in the 18 other litigation that some or all of the material covered by the subpoena or order is subject to this 19 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 21 Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with the subpoena 23 or court order shall not produce any information designated in this action as "CONFIDENTIAL" 24 before a determination by the court from which the subpoena or order issued, unless the Party has 25 obtained the Designating Party's permission. The Designating Party shall bear the burden and 26 9 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 expense of seeking protection in that court of its confidential material - and nothing in these 2 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 3 disobey a lawful directive from another court. 4 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 5 6 (a) The terms of this Order are applicable to information produced by a Non-Party in this 7 action and designated as "CONFIDENTIAL." Such information produced by Non-Parties in 8 connection with this litigation is protected by the remedies and relief provided by this Order. 9 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional 10 protections. 11 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 12 Party's confidential information in its possession, and the Party is subject to an agreement with the 13 Non-Party not to produce the Non-Party's confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 15 all of the information requested is subject to a confidentiality agreement with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in 17 this litigation, the relevant discovery request(s), and a reasonably specific description of the 18 information requested; and 19 (3) make the information requested available for inspection by the Non-Party. 20 (c) If the Non-Party fails to object or seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may produce the 22 Non-Party's confidential information responsive to the discovery request. If the Non-Party timely 23 seeks a protective order, the Receiving Party shall not produce any information in its possession or 24 control that is subject to the confidentiality agreement with the Non-Party before a determination by 25 the court. Absent a court order to the contrary; the Non-Party shall bear the burden and expense of 26 10 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 seeking protection in this court of its Protected Material. 2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 4 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 5 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 6 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 7 inform the person or persons to whom unauthorized disclosures were made of all the terms of this 8 Order, and (d) request such person or persons to execute the "Acknowledgment and Agreement to 9 Be Bound" that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 11 12 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 13 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 14 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 15 modify whatever procedure may be established in an e-discovery order that provides for production 16 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 17 parties reach an agreement on the effect of disclosure of a communication or information covered by 18 the attorney-client privilege or work product protection, the parties may incorporate their agreement 19 in the stipulated protective order submitted to the court. 20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek 22 its modification by the court in the future. 23 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order 24 no Party waives any right it otherwise would have to object to disclosing or producing any 25 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 26 11 27 STIPULATED PROTECTIVE ORDER FORSTANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 Party waives any right to object on any ground to use in evidence of any of the material covered by 2 this Protective Order. 3 12.3 Filing Protected Material. Without written permission from the Designating Party or a 4 court order secured after appropriate notice to all interested persons, a Party may not file in the 5 public record in this action any Protected Material. A Party that seeks to file under seal any Protected 6 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 7 pursuant to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant 8 to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that the 9 Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to 10 protection under the law. If a Receiving Party's request to file Protected Material under seal pursuant 11 to Civil Local Rule 79-5(d) is denied by the court, then the Receiving Party may file the information 12 in the public record pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court. 13 13. FINAL DISPOSITION 14 Within 60 days after the final disposition of this action, as defined in paragraph 4, each 15 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 16 As used in this subdivision, "all Protected Material" includes all copies, abstracts, compilations, 17 summaries, and any other format reproducing or capturing any of the Protected Material. Whether 18 the Protected Material is returned or destroyed, the Receiving Party must submit a written 19 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) 20 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 21 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, 22 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected 23 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 24 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 25 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant 26 12 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION Civil Action No.: 4:15-CV-02087 DMR 28 4 1 and expert work product, even if such materials contain Protected Material. Any such archival copies 2 that contain or constitute Protected Material remain subject to this Protective Order as set forth in 3 Section 4 (DURATION). 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 DATED: _L__,c(_2___._[_\_)_ __ 7 8 9 10 DATED: --------------------- Eric C. Kastner 11 Luis V. Garcia Kastner Kim LLP 12 Attorneys for Defendant Samsung Electronics Co., Ltd. 13 14 PURSUANT TO STIPULATION, IT IS SO ORDERED. 15 16 DATED: ___________________ 17 United States District/Magistrate Judge 18 19 20 21 22 23 24 25 26 13 27 STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION. Civil Action No.: 4:15-CV-02087 DMR 28 4 and expert work product, even if such materials contain Protected Material. Any such archival copies 2 that contain or constitute Protected Material remain subject to this Protective Order as set forth in 3 Section 4 (DURATION). 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 DATED: _t_D-+---~.--:t_) _ _ __ ~CJL_ Adam M. Carlson 7 Casper, Meadows, Schwartz & Cook Attorneys for Plaintiffs 8 Jeffrey A. Carrico and Nicole R. Salas 9 10 DATED: ftJ/f;/1_5" I l II Luis V. Garcia Kastner Kim LLP 12 Attorneys for Defendant Samsung Electronics Co., Ltd. 13 14 ISTRIC ES D PURSUANT TO STIPULATION, IT IS SO ORDERED. 15 T TC TA O S 16 U October 7, 2015 __ ED DATED: ________________ RT DERED Judge UNIT 17 O OR United States District/Magistrate IT IS S DIFIED AS MO 18 19 R NIA u a M. Ry NO onn Judge D FO 20 RT LI 21 ER H A N C 22 D IS T IC T OF R 23 24 25 26 13 27 STIPULATED PROTECTlVE OlU>ER FOR STANDARD LITIGATION. Civil Action No.: 4:15-CV-02087 DMR 28