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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 

 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

MONTEVILLE SLOAN, JR., RAUL 

SIQUEIROS, TODD AND JILL CRALLEY, 

JOSEPH BRANNAN, LARRY GOODWIN, 

MARC PERKINS, DONALD LUDINGTON, 

THOMAS SHORTER, DERICK BRADFORD, 

GABRIEL DEL VALLE, KEVIN HANNEKEN, 

EDWIN AND KATELYN DOEPEL, DAN 

MADSON, JAMES FAULKNER, JOSEPH 

OLIVIER, SCOTT SMITH, ROSS DAHL, DREW 

PETERSON, MICHAEL WARE, STEVE 

KITCHEN, BARBARA MOLINA, DENNIS 

VITA, STEVEN EHRKE, THOMAS GULLING, 

RONALD JONES, MIKE WARPINSKI, 

WILLIAM MARTELL, JOHN GRAZIANO, 

JOSHUA BYRGE, RUDY SANCHEZ, 

CHRISTOPHER THACKER, RANDY 

CLAUSEN, JAMES ROBERTSON, and JONAS 

BEDNAREK, individually and on behalf of all 

others similarly situated, 

Plaintiffs, 

v. 

GENERAL MOTORS LLC, 

Defendant.

Case No.: 16-cv-07244-EMC

[PROPOSED] STIPULATED 

PROTECTIVE ORDER
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 1 

 

To expedite the flow of discovery material, facilitate the prompt resolution of disputes over 

confidentiality, adequately protect material entitled to be kept confidential, and ensure that protection is 

afforded only to materials so entitled, the parties stipulate and agree to the forms of protective order.

1. Scope of Order. This Order is intended to facilitate the Parties’ production of certain 

Information and documents as part of voluntary disclosure and in response to discovery requests. 

Nothing in this Order is to be construed to expand or limit the Parties’ discovery obligations. This 

Order covers the production and use of all Protected Documents in this action that constitute, contain or 

disclose, in whole or in part, information which the Designating Party designates as “Confidential.” 

This Order is also intended to apply to any documents produced to the Parties by a non-party in 

connection with a subpoena. Nothing in this Order will prevent counsel from using Confidential

Information in connection with any work product created on behalf of that counsel. Subject to the 

provisions of paragraphs 8 and 14 herein, such work product may be retained by the counsel creating it.

2. General Definitions. For purposes of this Order, the following terms have the 

following Messages:

a. “Confidential Information” shall mean information that a Designating Party reasonably 

and in good faith believes contains or reflects information that constitutes confidential, non-public, 

proprietary, and/or commercially sensitive information of an individual or entity. Confidential 

Information may include, but is not limited to (1) engineering documents, including design drawings 

and other technical engineering related specifications, (2) test documents, analysis and testing 

procedures; (3) manufacturing specifications and procedures, including communications with and 

process documents pertaining to Defendant General Motors LLC’s (“GM”) suppliers and supplier 

relationships; (4) internal business or financial information; (5) confidential personal information and 

personal identifying information; and (6) any other similar proprietary, confidential, private 

information, commercially sensitive business information, or competitive intelligence, including but 

not limited to trade secrets.

b. “Highly Confidential Information” shall mean Confidential Information that a 

Designating Party reasonably and in good faith believes contains or reflects information that constitutes 

highly sensitive financial or competitive information of an individual or entity, highly sensitive 
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 2 

 

personal information (e.g. social security numbers), or trade secrets. 

c. “Customers” shall mean any person or entity that purchases or otherwise comes to 

possess GM’s vehicles.

d. “Designating Party” shall mean the Party or non-party designating Discovery Material 

as “Confidential” or “Highly Confidential.”

e. “Discovery Materials” shall mean and include, without limitation, Documents including 

Electronic Stored Information (ESI), responses to interrogatories, requests for admission, or other

discovery requests, physical objects, samples, CD-ROMs, tapes, or other items, deposition transcripts 

and exhibits thereto, and information provided by or on behalf of the Parties or any non-party witness 

pursuant to subpoena or otherwise in the course of discovery.

f. “Documents” shall mean and include, without limitation, all written material, 

videotapes, and all other tangible items, produced in whatever format (e.g., hard copy, electronic, 

digital, etc.) and on whatever media (e.g., hard copy, videotape, computer diskette, CD-ROM, DVD, 

hard-drive or otherwise) defined as permitted under FED. R. CIV. P. 34. 

g. “Party” or “Parties” shall mean and include the parties to this litigation.

h. “Pleadings” shall mean and include, without limitation, all papers, motions, briefs, 

affidavits, declarations, exhibits, etc., filed with the Court.

i. “Protected Documents” shall mean documents and materials to be produced in this 

litigation which contain Confidential or Highly Confidential Information.

3. Designating Confidential Information

a. All designations of Confidential and Highly Confidential Information shall be made in 

good faith by the Designating Party and made at the time of disclosure, production or tender

b. The designation of Confidential Information may be made by marking or placing the 

applicable notice “Subject to Protective Order,” “Confidential,” or substantially similar notice on the 

document, or, where a copy of the original document is to be produced, on that copy.

c. The designation of Highly Confidential Information may be made by marking or placing 

the applicable notice “Highly Confidential,” or substantially similar notice on the document, or, where 

a copy of the original document is to be produced, on that copy.
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 3 

 

d. Any document or any information designated as “Subject to the Protective Order,” 

“Highly Confidential,” “Confidential,” or similar language in accordance with the provisions of this 

Order shall only be used, shown, or disclosed as provided in this Order.

e. The burden of proving that a Protected Document contains Confidential of Highly 

Confidential Information is on the Designating Party. Prior to designating any material as 

“Confidential” or “Highly Confidential,” the Designating Party must make a bona fide determination 

that the material is, in fact, appropriately designated.

f. If a Party disagrees with the “Confidential” or “Highly Confidential” designation of any 

Protected Document, the Party will so notify the Designating Party in writing. Counsel shall confer in 

good faith in an effort to resolve any dispute concerning such designation or redaction. The Parties 

shall follow the procedures set forth in Civil Local Rule 37-1 governing discovery disputes to resolve 

whether the Confidential or Highly Confidential Information should be treated as “Confidential” or 

“Highly Confidential.” If the objection cannot be resolved by agreement, the party challenging the 

Confidential or Highly Confidential designation shall file and serve a motion to remove this 

designation, the timing of which shall be conducted in accordance with applicable Local Rules. The 

document or information whose “Confidential” or “Highly Confidential” designation or redaction is 

objected to shall continue to be treated as “Confidential” or “Highly Confidential,” as applicable, until 

the motion has been decided by the Court.

4. Use and Disclosure of Protected Documents.

a. Protected Documents and any copies thereof received pursuant to this Protective Order 

shall be maintained as confidential by the receiving party, his/her attorney, other representatives, and 

expert witnesses, and shall be used only for purposes of this action, subject to the limitations set forth 

herein. The persons or entities identified in Paragraphs 4(b) and 4(c), below, to whom Protected

Documents are disclosed pursuant to this Order shall keep all such materials and information, and any 

copies, notes, extracts, summaries or descriptions of such material, within their exclusive possession 

and control, shall treat all such copies, notes, extracts, summaries, or descriptions of the Protected 

Documents or any portion thereof as confidential shall take all necessary and prudent measures to 

maintain the confidentiality of all such materials or information and shall not disseminate such 
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 4 

 

Protected Documents other than in accordance with this Order.

b. Confidential Documents shall be disclosed only to the following “Qualified Persons”: 

Qualified Persons are limited to:

i. The Court and its personnel;

ii. The Parties to this Litigation;

iii. Counsel of record in this litigation, as well as document review vendors, paralegals, 

technical, administrative, and clerical employees working under the direct supervision of such counsel; 

iv. Experts and non-attorney consultants retained by the Parties for the preparation or trial 

of this case, provided that no disclosure shall be made to any expert or consultant who is currently 

employed by an automobile manufacturer competitor of GM;

v. A potential, anticipated, or actual fact witness whom counsel for the disclosing Party 

believes in good faith is likely to have knowledge pertaining to the content of the Protected Documents 

to be disclosed;

vi. The author(s) or any recipient of the document.

vii. Litigation expert consultants and vendors who provide litigation support services (e.g. 

photocopying, electronic discovery, videotaping, translating, preparing exhibits or demonstrations, 

etc.);

viii. Court reporters recording and/or transcribing deposition testimony; and

ix. Any person expressly named and agreed to in writing by the Parties or by further Order 

of the Court.

c. Highly Confidential Documents shall only be disclosed to those Qualified Persons listed 

at paragraphs 4(b)(i), (iii)-(iv), and (vi-ix). 

d. While the Parties may provide Protected Documents in accordance with the provisions 

of this Protective Order in an electronic form, such documents may not be posted on any website or 

internet accessible document repository that is accessible to anyone other than “Qualified Persons” 

listed above.

e. All persons described in Paragraphs 4(b) and 4(c) above shall not under any 

circumstance sell, offer for sale, advertise, or publicize the Protected Documents and the information 
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 5 

 

contained therein or the fact that such persons have obtained such documents or information.

f. All persons described in Paragraphs 4(b)(iv), (v), (vii) and (ix) above shall not have 

access to Protected Documents without having first read, acknowledged, and agreed to be bound by this 

Order by executing the Agreement to be Bound attached as Exhibit A (the “Agreement to Be Bound”).

5. Each Party’s counsel shall retain each such executed Agreement to Be Bound and shall 

keep a list identifying (a) all persons referenced in Paragraphs 4(b)(iv), (v), (vii) and (ix) above to 

whom Protected Documents have been disclosed, and (b) all Protected Documents disclosed to such 

persons. Each executed Agreement to Be Bound shall not be made available to the Designating Party 

during the pendency of the litigation but shall be available for an in camera inspection by the Court if 

good cause for review is demonstrated by the Designating Party. During the pendency of the litigation 

or after the termination of the litigation, subject to the attorney work product doctrine/attorney-client 

privilege and for good cause shown, the Court may order any party to provide to the Designating Party 

the list referenced above and any executed Agreement to Be Bound. However, each such Agreement to 

Be Bound and list shall be submitted to counsel for the Designating Party at the termination of this 

litigation.

6. Designation of Deposition Testimony.

a. Deposition testimony that counsel for the Party or non-party witness tendering such 

testimony, in good faith, believes refers to Protected Documents or information obtained therefrom 

shall be designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” as applicable, by such 

counsel by making a statement on the record for inclusion in the deposition transcript or, in writing, 

within thirty (30) calendar days after the date of the deposition. Any portion of a deposition transcript 

that has not been designated as Highly Confidential on the record shall be treated as Confidential for 

the thirty (30) days following the date of the deposition.

b. When Protected Documents or information obtained therefrom is designated as 

“Confidential” or “Highly Confidential” in a deposition transcript, the counsel making the designation 

shall instruct the reporter to imprint the legend “THIS TRANSCRIPT CONTAINS CONFIDENTIAL 

INFORMATION” on the cover page of the transcript and to include, at the front of the transcript, a 

page identifying all pages and lines designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” 
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 6 

 

in the transcript.

c. To the extent that Protected Documents or information obtained therefrom are used in 

the taking of depositions and/or used as exhibits at trial, such documents or information shall remain 

subject to the provisions of this Order, along with the transcript pages of the deposition testimony 

and/or trial testimony dealing with the Protected Documents or information.

d. Any court reporter or transcriber who reports or transcribes testimony in this action shall 

agree that all Confidential or Highly Confidential Information designated as such under this Order shall 

remain Confidential or Highly Confidential and shall not be disclosed by them, except pursuant to the 

terms of this Order, and that any notes or transcriptions of such testimony (and any accompanying 

exhibits) will be retained by the reporter or delivered to counsel of record.

7. Filing Under Seal. If any party wishes to file or lodge Protected Documents, portions 

of Protected Documents, or information taken from Protected Documents with the Court, that party 

must first seek agreement from the Designating Party, failing which the party must seek to file under 

seal pursuant to Civil Local Rule 79-5(d) and serve the Designating Party on the same day with a copy 

of the declaration identifying the documents or portions that contain designated confidential material. 

Civil L.R. 79-5(e). Within four (4) days of this notification, the Designating Party must file a 

responsive declaration under Civil Local Rule 79-5(d)(1)(A) to establish that the material is sealable. 

Pending determination of the motion, the lodged document(s) will be conditionally under seal. Until 

such time as the Court issues an order sealing the Protected Documents, the party seeking to use the 

Protected Documents may refer only to a redacted version. Upon granting of an order sealing the 

record, the Protected Documents will be sealed and labeled by the court clerk and treated according to 

Civil Local Rule 79-5(g). Upon denial of such an order, the documents may be filed in the public 

record no earlier than four (4) days and no later than ten (10) days after the motion is denied. Civil 

L.R. 79-5(e)(2).

8. Return and Destruction of Protected Documents. Within ninety (90) days after the 

conclusion of this case (including all appeals or other appellate proceedings), counsel for the Party who 

has received Protected Documents shall either: (a) return to the Designating Party the Protected 

Documents, including any documents which any such Party disclosed to any Qualified Person, or (b) 
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 7 

 

securely destroy the Protected Documents including any documents which any such Party disclosed to 

any Qualified Person, and certify in writing such destruction to the Designating Party.

9. Inadvertent Production.

a. Inadvertent or unintentional production of documents or information containing 

information which should have been designated as Confidential or Highly Confidential shall not be 

deemed a waiver in whole or in part of the Party’s claims of confidentiality. If a Party has 

inadvertently or unintentionally produced information which should have been designated as 

Confidential or Highly Confidential, the producing Party will notify the receiving Party within twentyone (21) days of discovery of the inadvertent production and request that the Confidential or Highly 

Confidential designation be applied to such documents or information. If a receiving party objects to 

the producing Party’s Confidentiality designation, it will notify the producing Party of its objections in 

writing within seven (7) business days of receipt of the notification described above. Within seven (7) 

business days, the producing Party may then move the Court for an order compelling the protection of 

such information. Pending the Court’s ruling, a receiving Party agrees to maintain the documents as 

Confidential or Highly Confidential under the terms of this Order.

b. Inadvertent or unintentional production of documents or information containing 

information that should have been designated as privileged or protected by the work-product doctrine 

shall not be deemed a waiver in whole or in part of the Party’s claims of privilege or work-product 

protection. Pursuant to FED. R. EVID. 502(b)-(d), if a Party has inadvertently or unintentionally 

produced information subject to a claim of immunity or privilege, upon written request made by the 

producing Party within twenty-one (21) days of discovery, all copies of such information shall be 

returned to the producing Party within seven (7) business days of such request unless the receiving 

party intends to challenge the producing Party’s assertion of privilege or immunity. If a receiving party 

objects to the return of such information within the seven (7) business day period described above, the 

producing Party may move the Court for an order compelling the return of such information. Pending 

the Court’s ruling, a receiving Party must sequester the inadvertently or unintentionally produced 

documents and shall not make any use of such information.

///
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 8 

 

10. Right to Use Own Information. Nothing in this Order shall limit any Party’s right to 

disclose to any person, or use for any purpose, its own information and Documents.

11. Subpoena or Order. If a Party is served with a subpoena or an order issued in other 

litigation that would compel disclosure of any information or items designated in this action as 

Confidential or Highly Confidential, counsel for the receiving Party must promptly notify counsel for 

the Designating Party in writing, and in no event, more than five (5) business days after receiving the 

subpoena or order. Counsel for the receiving Party also must inform, in writing, the Party who caused 

the subpoena or order to issue in the other litigation that some or all the material covered by the 

subpoena or order is the subject of this Order.

12. Non-Party Discovery. Any documents or information produced by a non-party witness 

in discovery in the action pursuant to subpoena or otherwise may be designated by such non-party as 

“Confidential” or Highly Confidential under the terms of this Order, and such designation shall have 

the same force and effect, and create the same duties, obligations, and remedies as if made by one of 

the parties hereto.

13. Modification. This Protective Order may not be waived, modified, abandoned or 

terminated, in whole or part, except by an instrument in writing signed by the Parties or pursuant to 

further Court Order. If any provision of this Protective Order shall be held invalid for any reason 

whatsoever, the remaining provisions shall not be affected thereby.

14. Duration.

a. After termination of this litigation, the provisions of this Order shall continue to be 

binding. This Court retains and shall have jurisdiction over the parties and recipients of the Protected 

Documents for enforcement of the provisions of this Order following termination of this litigation.

b. This Protective Order shall be binding upon the parties hereto, upon their attorneys, and 

upon the Parties’ and their attorneys’ successors, executors, personal representatives, administrators, 

heirs, legal representatives, assigns, subsidiaries, divisions, employees, agents, independent contractors, 

or other persons or organizations over which they have control.

Approved as to form and content and respectfully submitted by:
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 9 

 

Dated: March 14, 2018

/s/ Adam J. Levitt 

Adam J. Levitt (pro hac vice)

John E. Tangren (pro hac vice)

Daniel R. Ferri (pro hac vice)

DICELLO LEVITT & CASEY LLC

Ten North Dearborn Street, Eleventh Floor

Chicago, Illinois 60602

Telephone: 312-214-7900

alevitt@dlcfirm.com 

jtangren@dlcfirm.com

dferri@dlcfirm.com

Jennie Lee Anderson

Lori E. Andrus 

ANDRUS ANDERSON LLP

155 Montgomery Street, Suite 900

San Francisco, California 94104 

Telephone: 415-986-1400

jennie@andrusanderson.com

lori@andrusanderson.com

W. Daniel "Dee" Miles, III (pro hac vice)

H. Clay Barnett, III (pro hac vice)

Archie I. Grubb, II (pro hac vice)

Andrew E. Brashier (pro hac vice)

BEASLEY, ALLEN, CROW,

METHVIN, PORTIS & MILES, P.C.

272 Commerce Street

Montgomery, Alabama 36104

Telephone: 334-269-2343

Dee.Miles@Beasleyallen.com

Clay.Bamett@BeasleyAllen.com

Archie.Grubb@Beasleyallen.com

Andrew.Brashier@Beasleyallen.com

Nicholas R. Rockforte (pro hac vice motion to be 

filed)

Christopher L. Coffin (pro hac vice motion to be 

filed)

PENDLEY, BAUDIN & COFFIN, L.L.P.

1515 Poydras Street, Suite 1400

New Orleans, Louisiana 70112

Telephone: 504-355-0086

nrockforte@pbclawfirm.com

ccoffin@pbclawfirm.com

Dated: March 14, 2018

/s/ Joseph J. Ybarra

Joseph J. Ybarra 

HUANG YBARRA SINGER AND MAY LLP

550 South Hope Street, Suite 1850

Los Angeles, California 90071

Telephone: 213-884-4900

Joseph.ybarra@hysmlaw.com

Gregory R. Oxford

ISAACS CLOUSE CROSE & OXFORD LLP

21515 Hawthorne Boulevard

Suite 950

Torrance, California 90503

Telephone: 310-316-1990

goxford@icclawfirm.com

Counsel for Defendant General Motors LLC
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 10 

 

Marcus Rael (pro hac vice motion to be filed)

ROBLES, RAEL & ANAYA, P.C.

500 Marquette NW, Suite 700

Albuquerque, New Mexico 87102

Telephone: 505-242-2228

marcus@roblesrael.com

Anthony J. Garcia, Esq. (pro hac vice)

AG LAW

742 South Village Circle

Tampa, Florida 33606

Telephone: 813-259-9555

anthony@aglawinc.com

Timothy J. Becker (pro hac vice)

Jennell K. Shannon (pro hac vice)

JOHNSON BECKER, PLLC

444 Cedar Street, Suite 1800

St. Paul, Minnesota 55101

Telephone: 612-436-1800

tbecker@johnsonbecker.com

jshannon@johnsonbecker.com

Ben Finley (pro hac vice motion to be filed)

THE FINLEY FIRM, P.C.

200 13th Street

Columbus, Georgia 31901

Telephone: 706-322-6226

bfinley@thefinleyfirm.com

Eric J. Haag (pro hac vice)

ATTERBURY, KAMMER, & HAAG, S.C.

8500 Greenway Boulevard, Suite 103

Middleton, Wisconsin 53562

Telephone: 608-821-4600

ehaag@wiscinjurylawyers.com

Counsel for Plaintiffs and the Proposed Classes
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[PROPOSED] STIPULATED Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 11 

 

ECF CERTIFICATION

Pursuant to Civil L.R. 5-1(i)(3), the filing attorney attests that she has obtained concurrence 

regarding the filing of this document from the signatories to the document.

Date: March 14, 2018

By: /s/ Jennie Lee Anderson

Jennie Lee Anderson

Jennie Lee Anderson

Lori E. Andrus

ANDRUS ANDERSON LLP

155 Montgomery Street, Suite 900

San Francisco, California 94104

Telephone: 415-986-1400

jennie@andrusanderson.com

lori@andrusanderson.com

PURSUANT TO STIPULATION, SO ORDERED.

Dated this ___ day of _________, 2018

__________________________________

THE HONORABLE EDWARD M. CHEN

UNITED STATES DISTRICT JUDGE

14th March

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Edward M. Chen
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EXHIBIT A TO Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 12 

 

 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

MONTEVILLE SLOAN, JR., RAUL 

SIQUEIROS, TODD AND JILL CRALLEY, 

JOSEPH BRANNAN, LARRY GOODWIN, 

MARC PERKINS, DONALD LUDINGTON, 

THOMAS SHORTER, DERICK BRADFORD, 

GABRIEL DEL VALLE, KEVIN HANNEKEN, 

EDWIN AND KATELYN DOEPEL, DAN 

MADSON, JAMES FAULKNER, JOSEPH 

OLIVIER, SCOTT SMITH, ROSS DAHL, DREW 

PETERSON, MICHAEL WARE, STEVE 

KITCHEN, BARBARA MOLINA, DENNIS 

VITA, STEVEN EHRKE, THOMAS GULLING, 

RONALD JONES, MIKE WARPINSKI, 

WILLIAM MARTELL, JOHN GRAZIANO, 

JOSHUA BYRGE, RUDY SANCHEZ, 

CHRISTOPHER THACKER, RANDY 

CLAUSEN, JAMES ROBERTSON, and JONAS 

BEDNAREK, individually and on behalf of all 

others similarly situated, 

Plaintiffs, 

v. 

GENERAL MOTORS LLC, 

Defendant.

Case No.: 16-cv-07244-EMC

AGREEMENT TO BE BOUND 

EXHIBIT A TO PROTECTIVE ORDER
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EXHIBIT A TO Case No. 16-cv-07244-EMC

PROTECTIVE ORDER 13 

 

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 Protective Order that 

was issued by the United States District Court for the Northern District of California on 

______________ [date] in the above-captioned case.

I agree to comply with and to be bound by all the terms of this 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 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 Protective Order, 

even if such enforcement proceedings occur after termination of this action.

Date:_______________________

City and State where signed:__________________________ 

Signature:_____________________________

Printed Name:__________________________

______________________________________

[Address]

______________________________________

______________________________________

[Telephone Number]______________________