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MATA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Sep-13-2012 3:58 pm
Case Number: CGC-11-514980
Filing Date: Sep-13-2012 3:58
Filed by: CYNTHIA HERBERT
Juke Box: 001 Image: 03763103
ORDER
JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS
001C03763103
Instructions:
Please place this sheet on top of the document to be scanned.LAW OFFICES OF JESSICA R. BARSOTTI
Jessica Barsotti, Esq., SBN 209557
5032 Woodminster Lane
Oakland, CA 94602-2614
510.530.4078
510.530.4725 (FAX)
Attorney for Defendant/Cross-Complainant,
Dean Gregory Asimos, dba Drake Realty
JASON EVERETT THOMPSON and
WIRED REAL ESTATE GROUP, INC.
Plaintiffs,
VS.
DEAN GREGORY ASIMOS, DBA DRAKE
REALTY
Defendant.
DEAN GREGORY ASIMOS, DBA DRAKE
REALTY
Cross-Complainant,
vs.
JASON EVERETT THOMPSON and
WIRED REAL ESTATE GROUP, INC.
and DOES 1 through 50.
Cross-Defendants.
STIPULATED PROTECTIVE ORDER
THOMPSON v. ASIMOS.
eS ETT eaee>eneeaesaeseess>s> es
San Francisco County Superior Court
SEP 13 202
on & COURT
spuity Clarke
SUPERIOR COURT OF THE STATE OF CALIFORNIA.
FOR THE COUNTY OF SAN FRANCISCO
Case No.: CGC-11-514980
STIPULATED PHEREON (wy on
AND ORDER THEREON ( wij <
ww
Trial Date: October 9, 2012
Time: 8:30am
duficarth—)
€RECD AUG 81 2012
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JASON EVERETT THOMPSON
Plaintiff, Case No.: CGC-514980
-against-
DEAN ASIMOS
BY-VERIZON- CORPORATE
Defendants. SERVICES GROUPING.
Xx
WHEREAS, the above-captioned parties are engaged in discovery in this
pending action (the “Proceedings”) pursuant to the rules of this Court; and
WHEREAS, defendant, DEAN ASIMOS, served a Deposition Subpoena for
Production of Business Records upon non-party, VERIZON TELEPRODUCTS, INC.,
wherein it requested that VERIZON TELEPRODUCTS, INC. produce certain business
documents;
WHEREAS, non-party, VERIZON CORPORATE SERVICES GROUP, INC.
(hereinafter referred to as “VERIZON”), considers the documents that it will produce in
response to said subpoena to be confidential and/or proprietary;
WHEREAS, it is the intention of non-party, VERIZON, to limit the exchange of
documents that it will produce in response to said subpoena; and
WHEREAS, the purpose of this Agreement is to ensure that information and
documents deemed confidential to VERIZON, which will be disclosed through the
course of discovery in this lawsuit, is not used or disclosed to any party not expressly
authorized herein, and that they are not used for any purpose other than for the
prosecution and defense of the instant litigation.
1
Siescceeme (S|THEREFORE, IT IS HEREBY STIPULATED AND AGREED, as follows:
CONFIDENTIAL DISCOVERY MATERIAL
1, “Confidential Discovery Material” shall mean all documents produced by
VERIZON in this litigation, including contracts, agreements, and any other records.
MANNER OF DESIGNATING CONFIDENTIAL DISCOVERY MATERIAL
2. All documents produced by VERIZON in this litigation that are stamped
“Confidential” will be treated as “Confidential Discovery Material”.
NON-CONFIDENTIAL INFORMATION
3. “Confidential Discovery Material” shall not include documents or
information that: (i) was, prior to disclosure, rightfully in the possession or knowledge of
the requesting party; (ii) is publicly available in substantially the same form in which it
was provided by the producing party claiming confidentiality; or (iii) was, is, or becomes
public knowledge, or is in the public domain or public realm, not in violation of this
Agreement.
LIMITED USE OF CONFIDENTIAL DISCOVERY MATERIAL
4. All Confidential Discovery Material shall solely be used by Plaintiff and
Defendants (hereinafter referred to as the “Parties”) for litigation purposes in connection
with these proceedings, and for no other purpose.
5. Any person in possession of Confidential Discovery Material shall maintain
it in a secure manner so as to avoid disclosure of its contents in accordance with the
terms of this Agreement.6. The Parties shall not make or permit the making of more copies of any
“Confidential Discovery Material” than are necessary for the conduct of discovery,
motions, appeals, settlement negotiations, mediation, arbitration, or trial.
7. “Confidential Discovery Material” shall not be physically provided to any
persons and entities other than those expressly provided in this Agreement, without the
express written consent of VERIZON or its attorneys, or without there being an order of
the Court.
8. Additionally, the contents of the “Confidential Discovery Material” shall not
orally be disclosed to any person or entity other than those expressly provided in this
Agreement, without the express written consent of VERIZON or its attorneys, or without
there being an order of the Court.
PERSONS TO WHOM “CONFIDENTIAL DISCOVERY MATERIAL” MAY BE
DISCLOSED WITHOUT THE CONSENT OF VERIZON, AND THE TERMS AND
CONDITIONS OF DISCLOSURE
9. “Confidential Discovery Material” may be disclosed only to the following
persons without the prior approval of VERIZON:
(a) The Parties and their officers, directors, and employees who
actually are engaged to assist in the litigation of this Proceeding; and
(b) the Parties’ attorneys in this Proceeding, and the partners,
associates, employees and/or interns of such attorneys who are actually involved in the
litigation of this Proceeding, including attorneys acting as of counsel to the firm; and
(c) the judge(s), personnel of the Court involved in this Proceeding,
mediators, arbitrators, and jurors; and
(d) any persons who authored or received the “Confidential Discovery
Material” during the ordinary course of their business.
3PERSONS TO WHOM “CONFIDENTIAL DISCOVERY MATERIAL” MAY BE
DISCLOSED WITH WRITTEN ACKNOWLEGEMENT OF THIS AGREEMENT, AND
TERMS AND CONDITIONS OF DISCLOSURE
10. Any independent experts engaged to assist the Parties in the litigation of
this Proceeding, prior to being given access to any “Confidential Discovery Material’,
shall be provided with a copy of this Agreement and shall be requested to execute an
Acknowledgement in the form attached hereto as Exhibit A.
11. “Confidential Discovery Material” shall not be disclosed to any person
described in paragraph 9 who refuses to execute the annexed Acknowledgement.
12. All signed Acknowledgements shall be provided to the attorneys for all
Parties and to VERIZON or its attorneys within seven (7) business days of receipt by
the requesting attorney or Party.
13. Within ten (10) business days of receipt of the signed Acknowledgement,
VERIZON may serve a written notice of objection to the person proposed for approval if
facts available to VERIZON give it reason to believe that there is a reasonable likelihood
that the proposed person may use the “Confidential Discovery Material” for purposes
other than the prosecution or defense of this lawsuit. Failure to serve a written notice
of objection within the time designated herein to a person proposed shall be deemed
approval by VERIZON of disclosure of Confidential Discovery Material to that person. If
an objection to a person proposed for approval pursuant to this paragraph is not
resolved within ten (10) business days of service of the written notice of objection by
VERIZON, or such other period of time as shall be agreed to by the Parties in the
course of attempting to resolve an objection, the Party seeking to have the person
approved may make application to the Court with respect to such objection. The
disclosure of “Confidential Discovery Material” to such proposed person shall be
4withheld pending the ruling of the Court on such application. Any objections made by
VERIZON without a reasonable basis in fact are subject to sanctions and attorney's
fees incurred in making the motion to have the person approved.
14. As the Parties agree to be bound by the terms of this Agreement, they are
not required to sign an Acknowledgement in order to receive “Confidential Discovery
Material’.
15. “Confidential Discovery Material’ may be disclosed to persons other than
those listed above only if all Parties, by their attorneys, and VERIZON or its attorneys,
agree in a writing to be annexed to this Agreement, or if the Court so Orders.
INADVERTENT DISCLOSURE OF “CONFIDENTIAL DISCOVERY MATERIAL”
16. The inadvertent production of a document without a “Confidential”
designation shall not be a waiver of such designation by VERIZON, provided that
VERIZON indicates in writing that the document should be treated as “Confidential”
promptly upon discovering its production without the appropriate designation, and
provides the receiving party with a copy marked “Confidential”.
THE USE OF “CONFIDENTIAL DISCOVERY MATERIAL” IN
MOTIONS, APPEALS, AND AT TRIAL
17. A Party making a motion that includes “Confidential Discovery Material’ as
an exhibit, shall file the motion papers without exhibits attached and, on the return date,
submit the exhibits directly to the Court in an envelope, and make an application to the
Court requesting that the documents and motion be sealed. The motion must comply
with all applicable court rules.
18. No party shall file a Record on Appeal containing “Confidential Discovery
Material” without first requesting that the appellate court seal the appropriate portions ofthe Record on Appeal.
19. Attrial, any Party seeking to introduce for identification or into evidence a
document designated Confidential pursuant to this Agreement shall make an application
to the Court requesting that the document be sealed from the public record and that the
jury be given an instruction not to divulge the contents of said documents outside the
scope of this litigation.
TREATMENT OF “CONFIDENTIAL DISCOVERY MATERIAL” AT
THE CONCLUSION OF THIS PROCEEDING
20. All provisions of this Agreement restricting the use, disclosure or
communications of any “Confidential Discovery Material” shall continue to be binding
upon the Parties and their successors, assigns, and heirs, after the conclusion of this
Proceeding.
NON-WAIVER OF RIGHTS
21. Nothing in this Agreement is intended to constitute an agreement
regarding the scope of discovery. The designation of documents as “Confidential” shall
not be deemed to have narrowed or broadened the scope of permissible discovery or
the use of documents for trial.
22. Nothing in this Agreement shall preclude its signatories from fulfilling their
obligations under local, State and Federal laws, rules, and regulations, or court orders,
to disclose information.
23. Nothing in this Agreement shall be deemed to limit the right of the Parties
to challenge a designation of discovery materials as “Confidential”.24. ‘The fact that discovery material is designated as “Confidential” shall not
limit, prevent, or prejudice the Parties from introducing, or objecting to, the introduction
of such “Confidential Discovery Material’ at any hearing, trial or appeal in these
Proceedings.
JURISDICTION
25. While this Action is pending in the Superior Court of California, County of
San Francisco, jurisdiction to enforce this Agreement shall lie exclusively in said court.
GOVERNING LAW
26. This Agreement shall be governed by and construed and enforced in
accordance with the laws of the State of California.
PERSONS BOUND BY THIS AGREEMENT
27. This Agreement is binding upon, and shall inure in the benefit of the
Parties, VERIZON, and its successors, parents subsidiaries, affiliates, assigns,
transferees, agents, directors, officers, employees, attorneys and or sharelholders.
ENFORCEABILITY OF AGREEMENT
28. ‘If at any time after the date of the execution of this Agreement, any
provision of this Agreement shall be held by any court of competent jurisdiction to be
illegal, void or unenforceable, such provisions shall be of no force but shall not affect the
legality or enforceability of any other provisions of this Agreement.
OTHER AGREEMENTS
29. This agreement shall not be construed to supersede and replace any
Protective Order entered into by the Parties and does not affect any existing orders
preventing disclosure of documents or information designated by any party as
“attorneys eyes only.”ENTIRE UNDERSTANDING
30. This Agreement constitutes the entire understanding of the Parties and
VERIZON. No other understandings or agreements are part of this Agreement unless
they are made in writing, signed by counsel for the Parties and by VERIZON or its
attorneys, and they are annexed to this Agreement as a Rider. This Agreement shall
not be modified or amended in any way unless the modifications or amendments are in
writing and signed by counsel for the Parties and by VERIZON or its attorneys.
SIGNING IN COUNTERPARTS
31, This Agreement may be signed in counterparts.
SO STIPULATED:
By: Signed: § | 20 , 2012
VERIZON LEGAL COMPLIANCE
On behalf of Verizon Corporate Services Group
By: Signed: , 2012
Neil Schmidt
99 Shawan Road, Room 133
Cockeysville, MD 21030
By: Signed: 5 (7 , 2012
REAL ESTATE GROUP, INC.ENTIRE UNDERSTANDING ;
30. This Agreement constitutes the entire understanding of the Parties and
VERIZON. No other understandings or agreements are part of this Agreement unless
they are made in writing, signed by coungel for the Partles and by VERIZON or its
attomeys, and they are annexed to this Agreement as a Rider. This Agraement shall
fot be modified or amended in any way unless the modifications or amendments are in
writing and signad by counsel for the Partias and by VERIZON or its attorneys.
8 cou
34, This Agreement may be signed in counterparts.
sores 8 20,22
SO STIPULATED:
Complainant
DEAN , DBA DRAKE
REALTY
VERIZON LEGAL COMPLIANCE
Corporate Services Group
LH signet: _& le t 2012
$9 Shawan Road, Room 133
Cockeysville, MD 21030
by: Coa Signed: 5 / (72a
on Todd
Intiffe/Cross-Defendants
aASON THOMPSON and WIRED
REAL ESTATE GROUP, INC,
By:
&Modification .
Noe
Provided that nothing in this order determines that any document marked
“confidential” qualifies for sealing under CRC 2.550 or relieves any party from
following the procedure on CRC 2.551."
ORDER
So Oo IH HH & Ww
orthis:Protective-Order, itiswo.ordered:
SEP 13 2012 eu ZL YO
~- JUDGE OF THE SUPERIOR COURT
SB = Ss
DATED:
22 .
vp e
Se S$ 6 eR aA DRG
wv NY N
*EXHIBIT A
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JASON EVERETT THOMPSON
Plaintiff, Case No.: CGC-514980
-against-
ACKNOWLEDGEMENT OF
CONFIDENTIALITY
AGREEMENT CONCERNING
DEAN ASIMOS DOCUMENTS PRODUCED
BY VERIZON CORPORATE
Defendants. SERVICES GROUP, INC.
X
ACKNOWLEDGEMENT
I, , certify that | am employed by
, that my job title is
and that | have received and read a copy of the Confidentiality Agreement entered into
in the above-captioned action and that | agree to be bound by the terms thereof. |
consent and agree to be subject to the jurisdiction and authority of any Court in which
the captioned lawsuit is pending and venued, for purposes of enforcement of the
Confidentiality Agreement.
A copy of my curriculum vitae is attached.
Dated:
Signature
Printed Name
10
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MATA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Sep-13-2012 3:58 pm Case Number: CGC-11-514980 Filing Date: Sep-13-2012 3:58 Filed by: CYNTHIA HERBERT Juke Box: 001 Image: 03763103 ORDER JASON EVERETT THOMPSON et al VS. DEAN GREGORY ASIMOS 001C03763103 Instructions: Please place this sheet on top of the document to be scanned.LAW OFFICES OF JESSICA R. BARSOTTI Jessica Barsotti, Esq., SBN 209557 5032 Woodminster Lane Oakland, CA 94602-2614 510.530.4078 510.530.4725 (FAX) Attorney for Defendant/Cross-Complainant, Dean Gregory Asimos, dba Drake Realty JASON EVERETT THOMPSON and WIRED REAL ESTATE GROUP, INC. Plaintiffs, VS. DEAN GREGORY ASIMOS, DBA DRAKE REALTY Defendant. DEAN GREGORY ASIMOS, DBA DRAKE REALTY Cross-Complainant, vs. JASON EVERETT THOMPSON and WIRED REAL ESTATE GROUP, INC. and DOES 1 through 50. Cross-Defendants. STIPULATED PROTECTIVE ORDER THOMPSON v. ASIMOS. eS ETT eaee>eneeaesaeseess>s> es San Francisco County Superior Court SEP 13 202 on & COURT spuity Clarke SUPERIOR COURT OF THE STATE OF CALIFORNIA. FOR THE COUNTY OF SAN FRANCISCO Case No.: CGC-11-514980 STIPULATED PHEREON (wy on AND ORDER THEREON ( wij < ww Trial Date: October 9, 2012 Time: 8:30am duficarth—) €RECD AUG 81 2012 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO JASON EVERETT THOMPSON Plaintiff, Case No.: CGC-514980 -against- DEAN ASIMOS BY-VERIZON- CORPORATE Defendants. SERVICES GROUPING. Xx WHEREAS, the above-captioned parties are engaged in discovery in this pending action (the “Proceedings”) pursuant to the rules of this Court; and WHEREAS, defendant, DEAN ASIMOS, served a Deposition Subpoena for Production of Business Records upon non-party, VERIZON TELEPRODUCTS, INC., wherein it requested that VERIZON TELEPRODUCTS, INC. produce certain business documents; WHEREAS, non-party, VERIZON CORPORATE SERVICES GROUP, INC. (hereinafter referred to as “VERIZON”), considers the documents that it will produce in response to said subpoena to be confidential and/or proprietary; WHEREAS, it is the intention of non-party, VERIZON, to limit the exchange of documents that it will produce in response to said subpoena; and WHEREAS, the purpose of this Agreement is to ensure that information and documents deemed confidential to VERIZON, which will be disclosed through the course of discovery in this lawsuit, is not used or disclosed to any party not expressly authorized herein, and that they are not used for any purpose other than for the prosecution and defense of the instant litigation. 1 Siescceeme (S|THEREFORE, IT IS HEREBY STIPULATED AND AGREED, as follows: CONFIDENTIAL DISCOVERY MATERIAL 1, “Confidential Discovery Material” shall mean all documents produced by VERIZON in this litigation, including contracts, agreements, and any other records. MANNER OF DESIGNATING CONFIDENTIAL DISCOVERY MATERIAL 2. All documents produced by VERIZON in this litigation that are stamped “Confidential” will be treated as “Confidential Discovery Material”. NON-CONFIDENTIAL INFORMATION 3. “Confidential Discovery Material” shall not include documents or information that: (i) was, prior to disclosure, rightfully in the possession or knowledge of the requesting party; (ii) is publicly available in substantially the same form in which it was provided by the producing party claiming confidentiality; or (iii) was, is, or becomes public knowledge, or is in the public domain or public realm, not in violation of this Agreement. LIMITED USE OF CONFIDENTIAL DISCOVERY MATERIAL 4. All Confidential Discovery Material shall solely be used by Plaintiff and Defendants (hereinafter referred to as the “Parties”) for litigation purposes in connection with these proceedings, and for no other purpose. 5. Any person in possession of Confidential Discovery Material shall maintain it in a secure manner so as to avoid disclosure of its contents in accordance with the terms of this Agreement.6. The Parties shall not make or permit the making of more copies of any “Confidential Discovery Material” than are necessary for the conduct of discovery, motions, appeals, settlement negotiations, mediation, arbitration, or trial. 7. “Confidential Discovery Material” shall not be physically provided to any persons and entities other than those expressly provided in this Agreement, without the express written consent of VERIZON or its attorneys, or without there being an order of the Court. 8. Additionally, the contents of the “Confidential Discovery Material” shall not orally be disclosed to any person or entity other than those expressly provided in this Agreement, without the express written consent of VERIZON or its attorneys, or without there being an order of the Court. PERSONS TO WHOM “CONFIDENTIAL DISCOVERY MATERIAL” MAY BE DISCLOSED WITHOUT THE CONSENT OF VERIZON, AND THE TERMS AND CONDITIONS OF DISCLOSURE 9. “Confidential Discovery Material” may be disclosed only to the following persons without the prior approval of VERIZON: (a) The Parties and their officers, directors, and employees who actually are engaged to assist in the litigation of this Proceeding; and (b) the Parties’ attorneys in this Proceeding, and the partners, associates, employees and/or interns of such attorneys who are actually involved in the litigation of this Proceeding, including attorneys acting as of counsel to the firm; and (c) the judge(s), personnel of the Court involved in this Proceeding, mediators, arbitrators, and jurors; and (d) any persons who authored or received the “Confidential Discovery Material” during the ordinary course of their business. 3PERSONS TO WHOM “CONFIDENTIAL DISCOVERY MATERIAL” MAY BE DISCLOSED WITH WRITTEN ACKNOWLEGEMENT OF THIS AGREEMENT, AND TERMS AND CONDITIONS OF DISCLOSURE 10. Any independent experts engaged to assist the Parties in the litigation of this Proceeding, prior to being given access to any “Confidential Discovery Material’, shall be provided with a copy of this Agreement and shall be requested to execute an Acknowledgement in the form attached hereto as Exhibit A. 11. “Confidential Discovery Material” shall not be disclosed to any person described in paragraph 9 who refuses to execute the annexed Acknowledgement. 12. All signed Acknowledgements shall be provided to the attorneys for all Parties and to VERIZON or its attorneys within seven (7) business days of receipt by the requesting attorney or Party. 13. Within ten (10) business days of receipt of the signed Acknowledgement, VERIZON may serve a written notice of objection to the person proposed for approval if facts available to VERIZON give it reason to believe that there is a reasonable likelihood that the proposed person may use the “Confidential Discovery Material” for purposes other than the prosecution or defense of this lawsuit. Failure to serve a written notice of objection within the time designated herein to a person proposed shall be deemed approval by VERIZON of disclosure of Confidential Discovery Material to that person. If an objection to a person proposed for approval pursuant to this paragraph is not resolved within ten (10) business days of service of the written notice of objection by VERIZON, or such other period of time as shall be agreed to by the Parties in the course of attempting to resolve an objection, the Party seeking to have the person approved may make application to the Court with respect to such objection. The disclosure of “Confidential Discovery Material” to such proposed person shall be 4withheld pending the ruling of the Court on such application. Any objections made by VERIZON without a reasonable basis in fact are subject to sanctions and attorney's fees incurred in making the motion to have the person approved. 14. As the Parties agree to be bound by the terms of this Agreement, they are not required to sign an Acknowledgement in order to receive “Confidential Discovery Material’. 15. “Confidential Discovery Material’ may be disclosed to persons other than those listed above only if all Parties, by their attorneys, and VERIZON or its attorneys, agree in a writing to be annexed to this Agreement, or if the Court so Orders. INADVERTENT DISCLOSURE OF “CONFIDENTIAL DISCOVERY MATERIAL” 16. The inadvertent production of a document without a “Confidential” designation shall not be a waiver of such designation by VERIZON, provided that VERIZON indicates in writing that the document should be treated as “Confidential” promptly upon discovering its production without the appropriate designation, and provides the receiving party with a copy marked “Confidential”. THE USE OF “CONFIDENTIAL DISCOVERY MATERIAL” IN MOTIONS, APPEALS, AND AT TRIAL 17. A Party making a motion that includes “Confidential Discovery Material’ as an exhibit, shall file the motion papers without exhibits attached and, on the return date, submit the exhibits directly to the Court in an envelope, and make an application to the Court requesting that the documents and motion be sealed. The motion must comply with all applicable court rules. 18. No party shall file a Record on Appeal containing “Confidential Discovery Material” without first requesting that the appellate court seal the appropriate portions ofthe Record on Appeal. 19. Attrial, any Party seeking to introduce for identification or into evidence a document designated Confidential pursuant to this Agreement shall make an application to the Court requesting that the document be sealed from the public record and that the jury be given an instruction not to divulge the contents of said documents outside the scope of this litigation. TREATMENT OF “CONFIDENTIAL DISCOVERY MATERIAL” AT THE CONCLUSION OF THIS PROCEEDING 20. All provisions of this Agreement restricting the use, disclosure or communications of any “Confidential Discovery Material” shall continue to be binding upon the Parties and their successors, assigns, and heirs, after the conclusion of this Proceeding. NON-WAIVER OF RIGHTS 21. Nothing in this Agreement is intended to constitute an agreement regarding the scope of discovery. The designation of documents as “Confidential” shall not be deemed to have narrowed or broadened the scope of permissible discovery or the use of documents for trial. 22. Nothing in this Agreement shall preclude its signatories from fulfilling their obligations under local, State and Federal laws, rules, and regulations, or court orders, to disclose information. 23. Nothing in this Agreement shall be deemed to limit the right of the Parties to challenge a designation of discovery materials as “Confidential”.24. ‘The fact that discovery material is designated as “Confidential” shall not limit, prevent, or prejudice the Parties from introducing, or objecting to, the introduction of such “Confidential Discovery Material’ at any hearing, trial or appeal in these Proceedings. JURISDICTION 25. While this Action is pending in the Superior Court of California, County of San Francisco, jurisdiction to enforce this Agreement shall lie exclusively in said court. GOVERNING LAW 26. This Agreement shall be governed by and construed and enforced in accordance with the laws of the State of California. PERSONS BOUND BY THIS AGREEMENT 27. This Agreement is binding upon, and shall inure in the benefit of the Parties, VERIZON, and its successors, parents subsidiaries, affiliates, assigns, transferees, agents, directors, officers, employees, attorneys and or sharelholders. ENFORCEABILITY OF AGREEMENT 28. ‘If at any time after the date of the execution of this Agreement, any provision of this Agreement shall be held by any court of competent jurisdiction to be illegal, void or unenforceable, such provisions shall be of no force but shall not affect the legality or enforceability of any other provisions of this Agreement. OTHER AGREEMENTS 29. This agreement shall not be construed to supersede and replace any Protective Order entered into by the Parties and does not affect any existing orders preventing disclosure of documents or information designated by any party as “attorneys eyes only.”ENTIRE UNDERSTANDING 30. This Agreement constitutes the entire understanding of the Parties and VERIZON. No other understandings or agreements are part of this Agreement unless they are made in writing, signed by counsel for the Parties and by VERIZON or its attorneys, and they are annexed to this Agreement as a Rider. This Agreement shall not be modified or amended in any way unless the modifications or amendments are in writing and signed by counsel for the Parties and by VERIZON or its attorneys. SIGNING IN COUNTERPARTS 31, This Agreement may be signed in counterparts. SO STIPULATED: By: Signed: § | 20 , 2012 VERIZON LEGAL COMPLIANCE On behalf of Verizon Corporate Services Group By: Signed: , 2012 Neil Schmidt 99 Shawan Road, Room 133 Cockeysville, MD 21030 By: Signed: 5 (7 , 2012 REAL ESTATE GROUP, INC.ENTIRE UNDERSTANDING ; 30. This Agreement constitutes the entire understanding of the Parties and VERIZON. No other understandings or agreements are part of this Agreement unless they are made in writing, signed by coungel for the Partles and by VERIZON or its attomeys, and they are annexed to this Agreement as a Rider. This Agraement shall fot be modified or amended in any way unless the modifications or amendments are in writing and signad by counsel for the Partias and by VERIZON or its attorneys. 8 cou 34, This Agreement may be signed in counterparts. sores 8 20,22 SO STIPULATED: Complainant DEAN , DBA DRAKE REALTY VERIZON LEGAL COMPLIANCE Corporate Services Group LH signet: _& le t 2012 $9 Shawan Road, Room 133 Cockeysville, MD 21030 by: Coa Signed: 5 / (72a on Todd Intiffe/Cross-Defendants aASON THOMPSON and WIRED REAL ESTATE GROUP, INC, By: &Modification . Noe Provided that nothing in this order determines that any document marked “confidential” qualifies for sealing under CRC 2.550 or relieves any party from following the procedure on CRC 2.551." ORDER So Oo IH HH & Ww orthis:Protective-Order, itiswo.ordered: SEP 13 2012 eu ZL YO ~- JUDGE OF THE SUPERIOR COURT SB = Ss DATED: 22 . vp e Se S$ 6 eR aA DRG wv NY N *EXHIBIT A SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO JASON EVERETT THOMPSON Plaintiff, Case No.: CGC-514980 -against- ACKNOWLEDGEMENT OF CONFIDENTIALITY AGREEMENT CONCERNING DEAN ASIMOS DOCUMENTS PRODUCED BY VERIZON CORPORATE Defendants. SERVICES GROUP, INC. X ACKNOWLEDGEMENT I, , certify that | am employed by , that my job title is and that | have received and read a copy of the Confidentiality Agreement entered into in the above-captioned action and that | agree to be bound by the terms thereof. | consent and agree to be subject to the jurisdiction and authority of any Court in which the captioned lawsuit is pending and venued, for purposes of enforcement of the Confidentiality Agreement. A copy of my curriculum vitae is attached. Dated: Signature Printed Name 10