STIPULATED PROTECTIVE ORDER 

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RANDY RENICK (CA Bar No. 179652) 

(Email: rrr@hadsellstormer.com) 

CORNELIA DAI (CA Bar No. 207435) 

(Email: cdai@hadsellstormer.com) 

SPRINGSONG COOPER (CA Bar No. 307845) 

(Email: scooper@hadsellstormer.com) 

HADSELL STORMER & RENICK, LLP 

128 North Fair Oaks Avenue, Suite 204 

Pasadena, California 91103-3645 

Telephone: (626) 585-9600 

Fax: (626) 577-7079 

Lead Plaintiffs’ Counsel 

[Additional Counsel Listed on Next Page] 

IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION 

JON VALLIERE, EILEEN FOSTER, ANTONIO 

GARCIA, and SAMANTHA WEST, individually 

and on behalf of all similarly situated current and 

former employees, 

Plaintiffs, 

v. 

TESORO REFINING AND MARKETING 

COMPANY LLC, TESORO LOGISTICS GP, 

LLC, and DOES 1 through 10, inclusive 

Defendants. 

Case No. 3:17-CV-00123-JST 

Assigned to the Hon. Jon S. Tigar 

CLASS ACTION 

STIPULATED PROTECTIVE ORDER 

JINETRA BONNER, individually, on behalf 

herself and all others similarly situated, 

Plaintiffs, 

v. 

TESORO REFINING & MARKETING 

COMPANY, LLC, a Delaware Limited Liability 

Company; and DOES 1 through 100 inclusive, 

Defendants. 

Case No. 17-CV-03850-JST 
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JAY SMITH (CA Bar No. 166105) 

(Email: js@gslaw.org) 

JOSHUA F. YOUNG (CA Bar No. 232995) 

(Email: jyoung@gslaw.org) 

GILBERT & SACKMAN 

A LAW CORPORATION 

3699 Wilshire Boulevard, Suite 1200 

Los Angeles, California 90010 

Telephone: (323) 938-3000 

Fax: (323) 937-9139 

Attorneys for Plaintiffs JON VALLIERE, EILEEN FOSTER, ANTONIO GARCIA, and 

SAMANTHA WEST, on behalf of themselves and others similarly situated

COHELAN KHOURY & SINGER 

Timothy D. Cohelan (SBN 60827) 

tcohelan@ckslaw.com 

Michael D. Singer (SBN 115301) 

msinger@ckslaw.com 

J. Jason Hill (SBN 179630) 

jhill@ckslaw.com 

605 “C” Street, Suite 200 

San Diego, California 92101 

Telephone: (619) 595-3001 

Facsimile: (619) 595-3000 

Attorneys for Plaintiff, JINETRA BONNER, on behalf of herself and others similarly situated 

SEYFARTH SHAW LLP 

William J. Dritsas (SBN 97523) 

wdritsas@seyfarth.com 

560 Mission Street, 31st Floor 

San Francisco, CA 94105-2930 

Telephone: (415) 397-2823 

Facsimile: (415) 397-8549 

SEYFARTH SHAW LLP 

Michael W. Kopp (SBN 206385) 

mkopp@seyfarth.com 

400 Capitol Mall, Suite 2350 

Sacramento, California 95814-4428 

Telephone: (916) 448-0159 

Facsimile: (916) 558-4839 

SEYFARTH SHAW LLP 

Timothy M. Rusche (SBN 230036) 

E-mail: trusche@seyfarth.com 

Mary Manesis (SBN 150372) 

E-mail: mmanesis@seyfarth.com 

333 S. Hope Street, Suite 3900 

Los Angeles, California 90071 

Telephone: (213) 270-9600 

Facsimile: (213) 270-9601 

Attorneys for Defendants TESORO REFINING & MARKETING COMPANY LLC and TESORO 

LOGISTICS GP, LLC
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1. PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are likely to involve production of confidential, 

proprietary, or private information for which special protection from public disclosure, and from use for 

any purpose other than prosecuting this litigation, may be warranted. Accordingly, the parties hereby 

stipulate to and petition the court to enter the following Stipulated Protective Order. The parties 

acknowledge that this Order does not confer blanket protections on all disclosures or responses to 

discovery and that the protection it affords from public disclosure and use extends only to the limited 

information or items that are entitled to confidential treatment under applicable legal principles. The 

parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 

does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 

procedures that must be followed and the standards that will be applied when a party seeks permission 

from the court to file material under seal. 

2. DEFINITIONS 

2.1 Challenging Party: a Party or Non-Party that challenges the designation of information 

or items as “Confidential” under this Order. 

2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 

generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil 

Procedure 26(c). 

2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as 

their support staff). 

2.4 Designating Party: a Party or Non-Party that designates information or items that it 

produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 

2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or 

manner in which it is generated, stored, or maintained (including, among other things, testimony, 

transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery 

in this matter. 

/ / / 

/ / / 
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2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 

litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant 

in this action. 

2.7 House Counsel: attorneys who are employees of a party to this action. House Counsel 

does not include Outside Counsel of Record or any other outside counsel. 

2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity 

not named as a Party to this action. 

2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action but 

are retained to represent or advise a party to this action and have appeared in this action on behalf of that 

party or are affiliated with a law firm that has appeared on behalf of that party. 

2.10 Party: any party to this action, including all of its officers, directors and employees 

(including House Counsel), consultants, retained experts, and Outside Counsel of Record (and their 

support staffs), which for purposes of this Order does not include any putative class or class members 

other than Jon Valliere, Eileen Foster, Anotonio Garcia, Samantha West, and Jinetra Bonner. 

2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in 

this action. 

2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., 

photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or 

retrieving data in any form or medium) and their employees and subcontractors. 

2.13 Protected Material: any Disclosure or Discovery Material that is designated as 

“CONFIDENTIAL.” 

2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 

Producing Party. 

3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material (as 

defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, 

excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or 

presentations by Parties or their Counsel that might reveal Protected Material. However, the protections 
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conferred by this Stipulation and Order do not cover the following information: (a) any information that 

is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public 

domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this 

Order, including becoming part of the public record through trial or otherwise; and (b) any information 

known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the 

disclosure from a source who obtained the information lawfully and under no obligation of 

confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a 

separate agreement or protective order. 

4. DURATION

Even after final disposition of this litigation, the confidentiality obligations imposed by this 

Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 

otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 

defenses in this action, with or without prejudice; and (2) final judgment herein after the completion and 

exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time limits 

for filing any motions or applications for extension of time pursuant to applicable law. 

5. DESIGNATING PROTECTED MATERIAL 

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or NonParty that designates information or items for protection under this Order must take care to limit any 

such designation to specific material that qualifies under the appropriate standards. The Designating 

Party must designate for protection only those parts of material, documents, items, or oral or written 

communications that qualify – so that other portions of the material, documents, items, or 

communications for which protection is not warranted are not swept unjustifiably within the ambit of 

this Order. 

Mass, indiscriminate, or routinized designations for protection under this Order are prohibited. 

Designations that are shown to be clearly unjustified or that have been made for an improper purpose 

(e.g., to unnecessarily encumber or slow the case development process or to impose unnecessary 

expenses and burdens on other parties) expose the Designating Party to sanctions. If it comes to a 

Designating Party’s attention that information or items that it designated for protection do not qualify for 
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protection, that Designating Party must promptly notify all other Parties that it is withdrawing the 

mistaken designation. 

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 

e.g., second paragraph of Section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 

Discovery Material that qualifies for protection under this Order must be clearly designated before the 

material is disclosed or produced. 

Designation in conformity with this Order requires: 

(a) For information in documentary form (e.g., paper or electronic documents, but 

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix 

the legend “CONFIDENTIAL” to each page that contains Protected Material. 

A Party or Non-Party that makes original documents or materials available for inspection need not 

designate them for protection until after the inspecting Party has indicated which material it would like 

copied and produced. During the inspection and before the designation, all of the material made available 

for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the 

documents it wants copied and produced, the Producing Party must determine which documents, or 

portions thereof, qualify for protection under this Order. Then, before producing the specified documents, 

the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains Protected 

Material. If only a portion or portions of the material on a page qualifies for protection, the Producing 

Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the 

margins). 

(b) For testimony given in deposition or in other pretrial or trial proceedings, that the 

Designating Party identifies on the record, before the close of the deposition, completion of the 

deponent’s time to review the deposition transcript, or end of the hearing or other proceeding, all 

protected testimony. 

(c) For information produced in some form other than documentary or testimonial, 

including other tangible items, that the Producing Party affix in a prominent place on the exterior of the 

container or containers in which the information or item is stored the legend “CONFIDENTIAL.” If 

only a portion or portions of the information or item warrant protection, the Producing Party, to the 
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extent practicable, shall identify the protected portion(s). 

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate 

information or items that qualify for protection does not, standing alone, waive the Designating Party’s 

right to secure protection under this Order for such material. Upon timely correction of a designation, 

the Receiving Party must make reasonable efforts to assure that the material is treated in accordance 

with the provisions of this Order. 

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 

confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 

designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or 

a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 

confidentiality designation by electing not to mount a challenge promptly after the original designation 

is disclosed. 

6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by 

providing written notice to the Designating Party and all parties to this action, of each designation the 

Challenging Party is challenging and describing the basis for each challenge. To avoid ambiguity as to 

whether a challenge has been made, the written notice must recite that the challenge to confidentiality is 

being made in accordance with this specific paragraph of the Protective Order. The parties shall attempt 

to resolve each challenge in good faith and must begin the process by conferring directly (in voice to 

voice dialogue; other forms of communication are not sufficient) within 14 days of the date of service of 

notice. In conferring, the Challenging Party must explain the basis for its belief that the confidentiality 

designation was not proper and must give the Designating Party an opportunity to review the designated 

material, to reconsider the circumstances, and, if no change in designation is offered, to explain the basis 

for the chosen designation. A Challenging Party may proceed to the next stage of the challenge process 

only if it has engaged in this meet and confer process first or establishes that the Designating Party is 

unwilling to participate in the meet and confer process in a timely manner. 

6.3 Judicial Intervention. If the parties cannot resolve a challenge without court intervention, 

the Designating Party may file and serve a motion to retain confidentiality under Civil Local Rule 7 (and 
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in compliance with Civil Local Rule 79-5, if applicable) within 21 days of receipt by the Designating 

Party of the initial notice of challenge or within 14 days of the parties agreeing that the meet and confer 

process will not resolve their dispute, whichever is earlier. Failure by the Designating Party to make 

such a motion within 21 days or 14 days, as applicable, shall automatically waive the confidentiality 

designation for each challenged designation. In addition, the Challenging Party may file a motion 

challenging a confidentiality designation at any time if there is good cause for doing so, including a 

challenge to the designation of a deposition transcript or any portions thereof. Any motion brought 

pursuant to this provision by the Designating Party or the Challenging Party must be accompanied by a 

competent declaration affirming that the movant has complied with the meet and confer requirements 

imposed by the preceding paragraph. 

The burden of persuasion in any proceeding concerning a challenge shall be on the Designating 

Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 

unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. 

Unless the Designating Party has waived the confidentiality designation by failing to timely file a 

motion to retain confidentiality as described above, all parties shall continue to afford the material in 

question the level of protection to which it is entitled under the Designating Party’s designation until the 

court rules on the challenge. 

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 

produced by another Party or by a Non-Party in connection with this case only for prosecuting, 

defending, or attempting to settle this litigation. Protected Material must be stored and maintained by a 

Receiving Party at a location and in a secure manner that ensures that access is limited to the persons 

authorized under this Order. Protected Material may be disclosed only to the categories of persons and 

under the conditions described in this Order. When the litigation has been terminated, a Receiving Party 

must comply with the provisions of Section 13 below. 

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the 

court or permitted in writing by the Designating Party, a Receiving Party may disclose any information 

or item designated “CONFIDENTIAL” only to: 
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(a) the Receiving Party’s Outside Counsel of Record in this action, as well as 

employees of such Outside Counsel of Record to whom it is reasonably necessary to disclose the 

information for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 

that is attached hereto as Exhibit A; 

(b) the officers, directors, and employees (including House Counsel) of the Receiving 

Party to whom disclosure is reasonably necessary for this litigation and who have signed the 

“Acknowledgment and Agreement to Be Bound” (Exhibit A); 

(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 

reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to 

Be Bound” (Exhibit A); 

(d) the court and its personnel; 

(e) court reporters and their staff, professional jury or trial consultants, mock jurors, 

and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 

(f) during their depositions, witnesses in the action to whom disclosure is reasonably 

necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 

otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition 

testimony or exhibits to depositions that reveal Protected Material must be separately bound by the court 

reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order; 

and 

(g) the author or recipient of a document containing the information or a custodian or 

other person who otherwise possessed or knew the information. 

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 

LITIGATION 

If a Party is served with a subpoena or a court order issued in other litigation that compels 

disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party must: 

(a) promptly notify in writing the Designating Party. Such notification shall include a 

copy of the subpoena or court order; 
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(b) promptly notify in writing the party who caused the subpoena or order to issue in 

the other litigation that some or all of the material covered by the subpoena or order is subject to this 

Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 

(c) cooperate with respect to all reasonable procedures sought to be pursued by the 

Designating Party whose Protected Material may be affected. 

If the Designating Party timely seeks a protective order, the Party served with the subpoena or 

court order shall not produce any information designated in this action as “CONFIDENTIAL” before a 

determination by the court from which the subpoena or order issued, unless the Party has obtained the 

Designating Party’s permission. The Designating Party shall bear the burden and expense of seeking 

protection in that court of its confidential material – and nothing in these provisions should be construed 

as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from another 

court. 

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 

LITIGATION

(a) The terms of this Order are applicable to information produced by a Non-Party in 

this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 

connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in 

these provisions should be construed as prohibiting a Non-Party from seeking additional protections. 

(b) In the event that a Party is required, by a valid discovery request, to produce a 

Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the 

Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 

(1) promptly notify in writing the Party requesting the confidential 

information and the Non-Party that some or all of the information requested is subject to a 

confidentiality agreement with a Non-Party; 

(2) promptly provide the Non-Party with a copy of the Stipulated Protective 

Order in this litigation, the relevant discovery request(s), and a reasonably specific description of the 

information requested; and 

(3) make the information requested available for inspection by the Non-Party. 
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(4) if the Non-Party fails to object or seek a protective order from this court 

within 14 days of receiving notice that the confidential information is requested and the opportunity to 

inspect the information, the Receiving Party may produce the Non-Party’s confidential information 

responsive to the discovery request. If the Non-Party timely seeks a protective order, the Party in 

possession of the information shall not produce such information that is subject to the confidentiality 

agreement with the Non-Party before a determination by the court. 

(c) Absent a court order to the contrary, the Non-Party shall bear the burden and 

expense of seeking protection in this court of its Protected Material. 

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material 

to any person or in any circumstance not authorized under this Stipulated Protective Order, the 

Receiving Party must immediately (a) notify the Designating Party in writing of the unauthorized 

disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 

inform the person or persons to whom unauthorized disclosures were made of all the terms of this Order, 

and (d) request that such person or persons execute the “Acknowledgment and Agreement to Be Bound” 

that is attached hereto as Exhibit A. 

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 

MATERIAL

When a Producing Party gives notice to a Receiving Party that certain inadvertently produced 

material is subject to a claim of privilege or other protection, the obligations of the Receiving Party are 

those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 

any procedure that may be established in an e-discovery order that provides for production without prior 

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an 

agreement on the effect of disclosure of a communication or information covered by the attorney-client 

privilege or work product protection, the parties may incorporate their agreement in the Stipulated 

Protective Order submitted to the court. 

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its 
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modification by the court in the future. 

12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, no 

Party waives any right it otherwise would have to object to disclosing or producing any information or 

item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any 

right to object on any ground to use in evidence of any of the material covered by this Protective Order. 

12.3 Filing Protected Material. Without written permission from the Designating Party or a 

court order secured after appropriate notice to all interested persons, a Party may not file in the public 

record in this action any Protected Material. A Party that seeks to file under seal any Protected Material 

must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a 

court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Civil Local 

Rule 79-5, a sealing order will issue only upon a request establishing that the Protected Material at issue 

is privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If a 

Receiving Party's request to file Protected Material under seal pursuant to Civil Local Rule 79-5(d) is 

denied by the court, then the Receiving Party may file the information in the public record pursuant to 

Civil Local Rule 79-5(e) unless otherwise instructed by the court. 

13. FINAL DISPOSITION 

Within 60 days after the final disposition of this action, as defined in Section 4 above, each 

Receiving Party must return all Protected Material to the Producing Party or destroy such material. As 

used in this section, “all Protected Material” includes all copies, abstracts, compilations, summaries, and 

any other format reproducing or capturing any of the Protected Material. Whether the Protected Material 

is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party 

(and, if not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 

(by category, where appropriate) all the Protected Material that was returned or destroyed and (2) 

affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any 

other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, 

Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 

hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, 

attorney work product, and consultant and expert work product, even if such materials contain Protected 
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Material. Any such archival copies that contain or constitute Protected Material remain subject to this 

Protective Order as set forth in Section 4 above. 

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 

DATED: February 12, 2018 GILBERT & SACKMAN 

HADSELL STORMER & RENICK, LLP 

By: /s/ Randy Renick

Randy Renick 

Cornelia Dai 

Springsong Cooper 

Attorneys for Plaintiffs 

JON VALLIERE, EILEEN FOSTER, 

ANTONIO GARCIA, and SAMANTHA WEST 

DATED: February 12, 2018 GILBERT & SACKMAN 

By: /s/ Joshua F. Young 

Jay Smith 

Joshua F. Young 

Attorneys for Plaintiffs 

JON VALLIERE, EILEEN FOSTER, 

ANTONIO GARCIA, and SAMANTHA WEST 
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STIPULATED PROTECTIVE ORDER 

3:17-CV-00123-JST/17-CV-03850-JST 

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DATED: February 12, 2018 COHELAN KHOURY & SINGER

By: /s/ J. Jason Hill 

Timothy D. Cohelan 

Michael D. Singer 

J. Jason Hill 

Attorneys for Plaintiff 

JENITRA BONNER 

DATED: February 12, 2018 SEYFARTH SHAW LLP 

By: /s/ Michael W. Kopp 

William J. Dritsas 

Timothy M. Rusche 

Michael W. Kopp 

Mary D. Manesis 

Attorneys for Defendants 

TESORO REFINING & MARKETING 

COMPANY LLC and 

TESORO LOGISTICS GP, LLC 

Attestation Regarding Signatures: 

I, Randy Renick, hereby attest that all other signatories listed, and on whose behalf the filing is 

submitted, concur in the filing’s content and have authorized the filing. 

By: /s/ Randy Renick 

Randy Renick 

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

DATED: ________________________ _____________________________________ 

 United States District Judge Jon S. Tigar 

 

March 5, 2018
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STIPULATED PROTECTIVE ORDER 

3:17-CV-00123-JST/17-CV-03850-JST 

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EXHIBIT A 

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 

I, _____________________________ [print or type full name], of _________________ [print or type full 

address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated 

Protective Order that was issued by the United States District Court for the Northern District of California 

on [date] in the case of JON VALLIERE, et al. v. TESORO REFINING AND MARKETING COMPANY 

LLC, Case No. 3:17-CV-00123-JST and JINETRA BONNER, et al. v. TESORO REFINING & 

MARKETING COMPANY, LLC, Case No. 17-CV-03850-JST. I agree to comply with and to be bound 

by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so 

comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I 

will not disclose in any manner any information or item that is subject to this Stipulated Protective Order 

to any person or entity except in strict compliance with the provisions of this Order. 

I further agree to submit to the jurisdiction of the United States District Court for the Northern District of 

California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such 

enforcement proceedings occur after termination of this action.

I hereby appoint __________________________ [print or type full name] of 

_______________________________________ [print or type full address and telephone number] as my 

California agent for service of process in connection with this action or any proceedings related to 

enforcement of this Stipulated Protective Order. 

Date: ______________________________________ 

City and State where sworn and signed: _________________________________ 

Printed name: _______________________________ 

Signature: __________________________________