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BRAYTON*PURCELL LLP
ATTORNEYS AT LAW
222 RUSH LANDING ROAD
P.O BOX 6169
NOVATO, CALIFORNIA 94948-6169
(415) 898-1555
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ALAN R. BRAYTON, ESQ,, S.B. #73685 F
DAVID R. DONADIO, ESQ., S.B. #154436
JANINE M. FIBL-COSSE, ESQ., 8.B.#279377 Syperiey Coun of Caltomia
jfiel-cosso(@bravionlaw.com
YTON*%PURCELL LLP
Auomeys at Law wom OCT 17 2019
ush Landing Roa
P.O. Box 6169 6 CLERK OF THE COURT
Novato, California 94948-6169 BY.
(415) 898-1555 Deputy Clerk
Attomeys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
“COUNTY OF SAN FRANCISCO
CAROL CHULICK, as Successor-in- ASBESTOS
Interest to and as Wrongful Death Heir of No, CGC-19-276757
JOHN CHULICK, Deceased; and
DEBORAH HAGEN and JOLEEN STIPULATED CONFIDENTIALITY
AGREEMENT RE: GOLDEN BEAR.
HAGLER, as Wrongful Death Heirs of
JOHN CHULICK, Deceased, PRODUCTS Tbe DOCUMENTS AND
Plaintiffs,
vs
RILEY POWER INC., et al.,
Defendants. }
IT IS HEREBY STIPULATED that the following Confidentiality Agreement between
the parties shall take effect immediately and be judicially enforceable:
1, Any and all documents produced or to be produced by Golden Bear Products
LLC by and through plaintiffs CAROL CHULICK, JOLEEN HAGLER, and DEBORAH
HAGEN which Golden Bear Products LLC considers to contain confidential, trade secret,
proprietary and privileged information shall be subject to this Confidentiality Agreement.
These documents are referred to as "Confidential Documents" as hereinafter defined and
marked by the parties as “Confidential Documents,” and are to be maintained in a confidential
manner under the procedures as hereinafter set forth. The Confidential Documents will also be
bates stamped.
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2. The term "Confidential Document" as used herein shall mean any document
produced during discovery of this action which is of a proprietary, confidential, trade secret, or
of a commercially and/or competitively sensitive nature and is designated at the time of
production by the producing party to be a "Confidential Document." A "Confidential
Document" shall continue to be a "Confidential Document" until such time as the producing
party expressly agrees in writing that the document is no longer considered to be a "Confidential
Document" or there is a finding by this Court that the document is not the proper subject of
protection under the appropriate provisions of California law.
3. Every "Confidential Document" produced in discovery by Golden Bear Products
LLC in this action will be clearly marked as follows:
CONFIDENTIAL
THIS DOCUMENT IS PROPERTY OF GOLDEN BEAR PRODUCTS LLC. IT IS
PROPRIETARY AND IS PRODUCED SOLELY FOR USE IN THIS CASE:
"CAROL CHULICK ET AL. V. RILEY POWER, INC."
ANYONE HAVING POSSESSION OF THIS DOCUMENT MUST NOT DUPLICATE,
TRANSFER OR DISCLOSE THE CONTENTS OF THIS DOCUMENT
WITHOUT THE PRIOR WRITTEN PERMISSION OF GOLDEN BEAR PRODUCTS
LLC.
\ Any copies made of a “Confidential Document" produced in this action by Golden Bear
Products LLC. shall retain the Confidential marking as described above. :
4. The documents designated and produced as "Confidential Documents" shall be
given confidential treatment as described below,
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STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS5. Without further order of this Court, and without obtaining the prior written
permission of Golden Bear Products LLC, the parties may disclose the contents of a
"Confidential Document" only to the following persons (hereinafter referred to as "Qualified
Persons"):
a. Counsel of record in this action for requesting or receiving party;
b. Regular employees of such counsel assigned to and necessary to assist
such counsel in the preparation or trial of this action; and
G Bona fide independent expert witnesses or consultants retained by
counsel of record for consulting or testimony in this action.
6. All "Confidential Documents" disclosed by Golden Bear Products LLC in this
action, which are the subject of this Confidentiality Agreement, shall be used solely for the
purposes of this specific action and not for any other purpose, including any business purpose or
any other action.
7. Expert witnesses and consultants used by defendants shall be instructed to
maintain the confidentiality of the documents and destroy the documents once the case is
resolved.
8. Any Confidential Documents produced that contain social security numbers shall
be redacted.. If however, a social security number is not redacted prior to production, the
defendants shall notify counsel for Golden Bear Products LLC immediately.
9. To the extent that any “Confidential Document” or information obtained
therefrom is used in the taking of depositions, all such “Confidential Documents” and
information shall remain subject to the provisions of this Confidentiality Agreement, along with
the transcript of pages of the deposition testimony dealing with the content of the “Confidential
Documents.” At the time any “Confidential Document” is used in any deposition, the reporter
shall be informed of this Confidentiality Agreement and shall be required to operate in a manner
consistent with this Confidentiality Agreement, and the reporter shall mark the deposition
transcript as “Confidential.” Any “Confidential Documents” marked as exhibits shall be kept in
a separate sealed envelope, with the envelope appropriately marked that the contents are subject
KAlnjures.2624a\PLD\Stip Ood Conf Aereement tip.wod 3 IME
STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSCm NY A HW Aw DY
to a Confidentiality Agreement. In the event that the deposition is videotaped, the original and
all copies of the videotape shall be marked by the video technician to indicate that the contents
of the videotape are subject to this Confidentiality Agreement in substantially the same form as
follows: .
The videotape contains confidential testimony used in this case and is not to be
viewed or the contents thereof displayed, or revealed except by order of the Court, or
pursuant to written stipulation of the parties,
10. Confidential Documents filed with the Court, or with any other public agency, if
otherwise permitted by this Confidentiality Agreement, for any purpose will be filed under seal.
Portions of any discovery materials, including deposition transcripts, interrogatory answers,
responses to requests for admission, and any tangible things which contain confidential
information from Confidential Documents shall be treated as Confidential Documents under
this Confidentiality Agreement.
11. Before any "Confidential Document" covered by this Confidentiality Agreement
is disclosed to individuals beyond those listed in Paragraph 5, including disclosures at a
deposition, in Court filings or at the trial of this action, counsel for the party wanting to make
such further disclosure must advise counsel for Golden Bear Products LLC. The notice of intent
to make further disclosure must be provided sufficiently in advance of the planned disclosure so
as to permit counsel to have a reasonable "meet and confer" discussion over necessary
protective measures for the planned further disclosure of the "Confidential Document" (and
expedited judicial intervention if no agreement can be reached).
12. This Confidentiality Agreement shall be binding upon the parties hereto, upon
their attorneys, and upon the parties and their attorneys' successors, executors, personal
representatives, administrators, heirs, representatives, assigns, subsidiaries, divisions,
employees, agents, retained experts, and the persons or organizations over which they have
control.
13. Any party may submit a request in writing to the designating party that the
“Confidential Document” designation be withdrawn. If the designating party does not agree to
withdraw the “Confidential Document” designation within five (5) days, the requesting party
Alnjurexh26244\PLD\Stip On Conf Agreement stip. vod
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STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSCon AW BP WN
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may move for relief from the Court, The burden is upon the moving party to show why the
confidential designation is improper. A motion requesting that the designation be withdrawn
must set forth with the court the reasons why the moving party believes the designation is
improper. Upon such motion, the designating party must respond with why the "Confidential
Document" designation is proper.
14. In producing these Confidential Documents plaintiff does not waive the right to
object to their use at trial or other case proceedings, including but not limited to objections
based on privacy, relevance, confidential proprietary information, taxpayer privilege, and
objections under California Evidence Code Section 352.
15. This Stipulated Confidentiality Agreement may be executed in one or more
counterparts, each of which shall be considered an original, but all of which shall constitute one
and the same document.
Dated: _ 10/8/19 BRAYTON%PURCELL LLP
By: /s/ Janine M,_Fiel-Cosse
anine M. Fiel-Cosse
Attorneys for Plaintiffs
Dated: ALSTON & BIRD LLP
By:
Attornbys for Defendanyf
ANHBUSER-BUSCH, ELC (FKA
(QD ‘ANHEUSER-BUSCH/INC,)
Dated: lopay I BEC NNETT & SCHWEITZER
By:
Attorneys for Defendant
W. L. HICKEY SONS, INC.
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BISHOP BARRY
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, Attéimeys for Defendant \
RUDOLPH AND SLETTEN,INC.
FOLEY & MANSFIELD PLLP
By:
Al e¥s for Defendants
COLUMBIA MECHANICAL
CONTRACTORS
VAY
By: :
" Kitomeys for Defendants
MARC INI PLASTERING COMPANY,
IMAI, TADLOCK, KEENEY & CORDERY, LLP
By:
, ‘Attorneys for Defendant
MONTEREY MECHANICAL CO.
LEWIS BRISBOIS BISGAARD & SMITH, LLP -
SAN FRANCISCO
By:
, Attorneys for Defendant
COOPER BROS., INC.
MORGAN, LEWIS & BOCKIUS LLP
By
, Attomeys for Defendants
GRINNELL LLC (FKA GRINNELL
CORPORATION, AKA GRINNELL FIRE)
MORGAN, LEWIS & BOCKIUS LLP
By:
, Attorneys for Defendants
JOHNSON CONTROLS, INC.
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PRINDLE, GOETZ, BARNES & REINHOLTZ
By:
Attorneys for Defendant
TEXACO INC.
SELMAN BREITMAN, LLP
By:
Attomeys for Defendant
SCOTT CO. OF CALIFORNIA
SINUNU BRI LP
By; =
ieys for. Defendant
ROSENDIN ELECTRIC, INC.
STEPTOE & JOHNSON LLP
By:
Attomeys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
WFBM, LLP
By:
Attorneys for Defendants
COSCO FIRE PROTECTION, INC.;
WFBM, LLP
By:
Attorneys for Defendants
D. ZELINSKY & SONS, INCORPORATED
WFBM, LLP
By:
Attorneys for Defendants
FDCC CALIFORNIA, INC.
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STIPULATED CONF DENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSeC em IND HW PF WN
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Dated:
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Dated: October 9, 2019
Dated:
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ULATED CONFIDE!
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[Al AGREEMENT RE GO!
PRINDLE, GOETZ, BARNES & REINHOLTZ
By:
Attomeys for Defendant
TEXACO INC,
SELMAN BREITMAN, LLP
By:
” Ritomeys for Defendant
SCOTT CO. OF CALIFORNIA
SINUNU BRUNI LLP
By:
‘ Attorneys for Defendant
ROSENDIN ELECTRIC, INC.
STEPTOE & JOHNSON LLP
By:
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
WFBM, LLP
By:
Attorneys for Defendants
COSCO FIRE PROTECTION, INC.;
WFBM, LLP
lan P. Dillon
: Attorneys for Defendants
D. ZELINSKY & SONS, INCORPORATED
WFBM, LLP
By:
Attorneys for Defendants
FDCC CALIFORNIA, INC.
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Dated: October 9, 2019
IT IS SO ORDERED
Dated:
WEBM, LLP
lan P. Dillon
‘ Attomeys for Defendants
GEORGE H. WILSON, INC.
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TALITY AGRI
Judge of the Superior Court
8
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. STIPULATED CONFIDE N ALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS
BISHOP BARRY
By:
Attomeys for Defendant
RUDOLPH AND SLETTEN, INC,
FOLEY & MANSFIELD PLLP
By:
Attorneys for Defendants
COLUMBIA MECHANICAL
CONTRACTORS
FOLEY & MANSFIELD PLLP
By:
Attorneys for Defendants
MARCONI PLASTERING COMPANY,
IMAI, TADLOCK, KEENEY & CORDERY, LLP
By:
Attorneys for Defendant
MONTEREY MECHANICAL CO.
LEWIS BRISBOIS BISGAARD & SMITH, LLP -
SAN FRANCISCO
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" Attomoys Tor Defendant [ |
COOPER BROS., INC.
MORGAN, LEWIS & BOCKNJS LLP
By:
* Attorneys for Defendants
GRINNELL LLC (FKA GRINNELL
CORPORATION, AKA GRINNELL FIRE)
MORGAN, LEWIS & BOCKIUS LLP
By:
: Attorneys for Defendants
JOHNSON CONTROLS, INC.Coo IN Aw PF BN
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may move for relief from the Court, The burden is upon the moving party to show why the
confidential designation is improper. A motion requesting that the designation be withdrawn
must set forth with the court the reasons why the moving party believes the designation is
improper. Upon such motion, the designating party must respond with why the "Confidential
Document" designation is proper.
14. In producing these Confidential Documents plaintiff does not waive the right to
- object to their use at trial or other case proceedings, including but not limited to objections
based on privacy, relevance, confidential proprietary information, taxpayer privilege, and
objections under California Evidence Code Section 352.,
15. This Stipulated Confidentiality Agreement may be executed in one or more
counterparts, each of which shall be considered an original, but all of which shall constitute one
and the same document.
Dated: _ 10/8/19 BRAYTON*PURCELL LLP
By: /s/ Janine M. Fiel-Cosse
_ Janine M. Fiel-Cosse
Attorneys for Plaintiffs
Dated: ALSTON & BIRD LLP
By:
” ‘Attorneys for Defendant
ANHEUSER-BUSCH, LLC (FKA
ANHEUSER-BUSCH, INC.)
Dated: \o/ 8 l ] TM
By
, Attorneys forDéfendant
W. L. HICKEY SONS, INC.
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FAX 415 978 2008 SELMAN BREITMAN SF 003/003
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“By:
PRINDLE, GOETZ, BARNES & REINHOLTZ
By:
Attorneys for Defendant
TEXACO INC,
SELMAN BREITMAN, LLP
By:
vneys ‘or Defendant
SCOTT'CO, OF CALIFORNIA
SINUNU BRUNI LLP
Attomeys for Defendant
ROSENDIN ELECTRIC, INC,
STEPTGE & JOHNSON LLP
By:
Attomeys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
WFBM, LLP
By:
Attomeys for Defendants
COSCO FIRE PROTECTION, INC;
WFBM, LLP
By:
Attorne for Defendant
2ELINSKY & eons INCORPORATED
WEBM, LLP
Attgmeys for Defendants
FDCC CALIFORNIA, INC.
10/08/2019 2:40PM (GMT~07:00)Co td Aw ew DN
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Dated:
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Dated: 10/8/19
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PRINDLE, GOETZ, BARNES & REINHOLTZ
By:
Attorneys for Defendant
TEXACO INC.
SELMAN BREITMAN, LLP
By:
Attorneys for Defendant
SCOTT CO. OF CALIFORNIA
SINUNU BRUNI LLP
By:
Attorneys for Defendant
ROSENDIN ELECTRIC, INC.
STEPTOE & JOHNSON LLP
By:
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
WFBM, LLP
By:
Attorneys for Defendants
COSCO FIRE PROTECTION, INC.;
WFBM, LLP
By:
Attorneys for Defendants
D. ZELINSKY & SONS, INCORPORATED
WFBM, LLP \e Lier
By:
Attorneys for Defendants
FDCC CALIFORNIA, INC.
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Dated: October 14,
tober 14, 201
Dated: October 14, 2019
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STIPULATED FIDENTIAI
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EMENT DEN B! ODU! w )OCUMENT:
BISHOP BARRY
B
ys
‘Attorneys for Defendant
RUDOLPH AND SLETTEN, INC.
FOLEY & MANSFIELD PLLP
By:
, Attorneys for Defendants
COLUMBIA MECHANICAL
CONTRACTORS
FOLEY & MANSFIELD PLLP
By:
, Attorneys for Defendants
MARCONI PLASTERING COMPANY,
IMAI, TADLOCK, KEENEY & CORDERY, LLP
By:
‘ Attorneys for Defendant
MONTEREY MECHANICAL CO.
LEWIS BRISBOIS BISGAARD & SMITH, LLP -
SAN FRANCISCO
By:
Attorneys for Defendant
COOPER BROS,, INC,
MORGAN, LEWIS & BOCKIUS LLP
by: gle —
, Attomeys for Defendants
GRINNELL LLC (FKA GRINNELL
CORPORATION, AKA GRINNELL FIRE)
MORGAN, LEWIS & ous LLP
By: Ghyll
, Attorneys for Defendants
JOHNSON CONTROLS, INC.
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PRINDLE, GOETZ, BARNES & REINHOLTZ
By:
TEXACO INC for Defendant
TEXACO
SELMAN BREITMAN, LLP
By:
Attomeys for Defendant
SCOTT CO. OF CALIFORNIA.
SINUNU BRUNI LLP
By:
Attormeys for Defendant
ROSENDIN ELECTRIC, INC.
STEPTOE & JOHNSON LLP
By:
‘Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
WEBM, L!
By:
‘Attoyneys/ibr Defendants
CO; PROTECTION, INC.;
WFBM, LLP
Y Strome: tor Defendant
D EP & SONS, INCORPORATED
WFBM, LLP .
for Defendants
ALIFORNIA, INC.“
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Dated:
IT IS SO ORDERED
Dated:
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STIPULATED CONFIDENTIALIT Y AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS
WFBM, LLP
By:
: Attorneys for Defendants
GEORGE H. WILSON, INC.
(o}17 [20174
Judge of thé Superior Court
CYNTHIA MING-MEI LEE
Preview
BRAYTON*PURCELL LLP ATTORNEYS AT LAW 222 RUSH LANDING ROAD P.O BOX 6169 NOVATO, CALIFORNIA 94948-6169 (415) 898-1555 CoC mo ND HW PF WN bom YN NY NN NN Yee Be Be ee Be eB old AA KOH KF SO HAA UH PB wWKH HEH DO ALAN R. BRAYTON, ESQ,, S.B. #73685 F DAVID R. DONADIO, ESQ., S.B. #154436 JANINE M. FIBL-COSSE, ESQ., 8.B.#279377 Syperiey Coun of Caltomia jfiel-cosso(@bravionlaw.com YTON*%PURCELL LLP Auomeys at Law wom OCT 17 2019 ush Landing Roa P.O. Box 6169 6 CLERK OF THE COURT Novato, California 94948-6169 BY. (415) 898-1555 Deputy Clerk Attomeys for Plaintiffs SUPERIOR COURT OF CALIFORNIA “COUNTY OF SAN FRANCISCO CAROL CHULICK, as Successor-in- ASBESTOS Interest to and as Wrongful Death Heir of No, CGC-19-276757 JOHN CHULICK, Deceased; and DEBORAH HAGEN and JOLEEN STIPULATED CONFIDENTIALITY AGREEMENT RE: GOLDEN BEAR. HAGLER, as Wrongful Death Heirs of JOHN CHULICK, Deceased, PRODUCTS Tbe DOCUMENTS AND Plaintiffs, vs RILEY POWER INC., et al., Defendants. } IT IS HEREBY STIPULATED that the following Confidentiality Agreement between the parties shall take effect immediately and be judicially enforceable: 1, Any and all documents produced or to be produced by Golden Bear Products LLC by and through plaintiffs CAROL CHULICK, JOLEEN HAGLER, and DEBORAH HAGEN which Golden Bear Products LLC considers to contain confidential, trade secret, proprietary and privileged information shall be subject to this Confidentiality Agreement. These documents are referred to as "Confidential Documents" as hereinafter defined and marked by the parties as “Confidential Documents,” and are to be maintained in a confidential manner under the procedures as hereinafter set forth. The Confidential Documents will also be bates stamped. Kljured\26244\PLD'Stip Ord Conf Agreement stip. 1 IME A FIDE! Al AGREEMENT RE GOLDEN BEAR PRODU! LLC DOCUM!Ceo rI DA UW FF wWN HE a 2. The term "Confidential Document" as used herein shall mean any document produced during discovery of this action which is of a proprietary, confidential, trade secret, or of a commercially and/or competitively sensitive nature and is designated at the time of production by the producing party to be a "Confidential Document." A "Confidential Document" shall continue to be a "Confidential Document" until such time as the producing party expressly agrees in writing that the document is no longer considered to be a "Confidential Document" or there is a finding by this Court that the document is not the proper subject of protection under the appropriate provisions of California law. 3. Every "Confidential Document" produced in discovery by Golden Bear Products LLC in this action will be clearly marked as follows: CONFIDENTIAL THIS DOCUMENT IS PROPERTY OF GOLDEN BEAR PRODUCTS LLC. IT IS PROPRIETARY AND IS PRODUCED SOLELY FOR USE IN THIS CASE: "CAROL CHULICK ET AL. V. RILEY POWER, INC." ANYONE HAVING POSSESSION OF THIS DOCUMENT MUST NOT DUPLICATE, TRANSFER OR DISCLOSE THE CONTENTS OF THIS DOCUMENT WITHOUT THE PRIOR WRITTEN PERMISSION OF GOLDEN BEAR PRODUCTS LLC. \ Any copies made of a “Confidential Document" produced in this action by Golden Bear Products LLC. shall retain the Confidential marking as described above. : 4. The documents designated and produced as "Confidential Documents" shall be given confidential treatment as described below, Ml Wt Ml KAlnjored26244,PLD\Stip Ord Conf Agreement stip. wed 2 IME STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS5. Without further order of this Court, and without obtaining the prior written permission of Golden Bear Products LLC, the parties may disclose the contents of a "Confidential Document" only to the following persons (hereinafter referred to as "Qualified Persons"): a. Counsel of record in this action for requesting or receiving party; b. Regular employees of such counsel assigned to and necessary to assist such counsel in the preparation or trial of this action; and G Bona fide independent expert witnesses or consultants retained by counsel of record for consulting or testimony in this action. 6. All "Confidential Documents" disclosed by Golden Bear Products LLC in this action, which are the subject of this Confidentiality Agreement, shall be used solely for the purposes of this specific action and not for any other purpose, including any business purpose or any other action. 7. Expert witnesses and consultants used by defendants shall be instructed to maintain the confidentiality of the documents and destroy the documents once the case is resolved. 8. Any Confidential Documents produced that contain social security numbers shall be redacted.. If however, a social security number is not redacted prior to production, the defendants shall notify counsel for Golden Bear Products LLC immediately. 9. To the extent that any “Confidential Document” or information obtained therefrom is used in the taking of depositions, all such “Confidential Documents” and information shall remain subject to the provisions of this Confidentiality Agreement, along with the transcript of pages of the deposition testimony dealing with the content of the “Confidential Documents.” At the time any “Confidential Document” is used in any deposition, the reporter shall be informed of this Confidentiality Agreement and shall be required to operate in a manner consistent with this Confidentiality Agreement, and the reporter shall mark the deposition transcript as “Confidential.” Any “Confidential Documents” marked as exhibits shall be kept in a separate sealed envelope, with the envelope appropriately marked that the contents are subject KAlnjures.2624a\PLD\Stip Ood Conf Aereement tip.wod 3 IME STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSCm NY A HW Aw DY to a Confidentiality Agreement. In the event that the deposition is videotaped, the original and all copies of the videotape shall be marked by the video technician to indicate that the contents of the videotape are subject to this Confidentiality Agreement in substantially the same form as follows: . The videotape contains confidential testimony used in this case and is not to be viewed or the contents thereof displayed, or revealed except by order of the Court, or pursuant to written stipulation of the parties, 10. Confidential Documents filed with the Court, or with any other public agency, if otherwise permitted by this Confidentiality Agreement, for any purpose will be filed under seal. Portions of any discovery materials, including deposition transcripts, interrogatory answers, responses to requests for admission, and any tangible things which contain confidential information from Confidential Documents shall be treated as Confidential Documents under this Confidentiality Agreement. 11. Before any "Confidential Document" covered by this Confidentiality Agreement is disclosed to individuals beyond those listed in Paragraph 5, including disclosures at a deposition, in Court filings or at the trial of this action, counsel for the party wanting to make such further disclosure must advise counsel for Golden Bear Products LLC. The notice of intent to make further disclosure must be provided sufficiently in advance of the planned disclosure so as to permit counsel to have a reasonable "meet and confer" discussion over necessary protective measures for the planned further disclosure of the "Confidential Document" (and expedited judicial intervention if no agreement can be reached). 12. This Confidentiality Agreement shall be binding upon the parties hereto, upon their attorneys, and upon the parties and their attorneys' successors, executors, personal representatives, administrators, heirs, representatives, assigns, subsidiaries, divisions, employees, agents, retained experts, and the persons or organizations over which they have control. 13. Any party may submit a request in writing to the designating party that the “Confidential Document” designation be withdrawn. If the designating party does not agree to withdraw the “Confidential Document” designation within five (5) days, the requesting party Alnjurexh26244\PLD\Stip On Conf Agreement stip. vod 4 IMF STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSCon AW BP WN Be BRRBRBORESSESUARDESES AS may move for relief from the Court, The burden is upon the moving party to show why the confidential designation is improper. A motion requesting that the designation be withdrawn must set forth with the court the reasons why the moving party believes the designation is improper. Upon such motion, the designating party must respond with why the "Confidential Document" designation is proper. 14. In producing these Confidential Documents plaintiff does not waive the right to object to their use at trial or other case proceedings, including but not limited to objections based on privacy, relevance, confidential proprietary information, taxpayer privilege, and objections under California Evidence Code Section 352. 15. This Stipulated Confidentiality Agreement may be executed in one or more counterparts, each of which shall be considered an original, but all of which shall constitute one and the same document. Dated: _ 10/8/19 BRAYTON%PURCELL LLP By: /s/ Janine M,_Fiel-Cosse anine M. Fiel-Cosse Attorneys for Plaintiffs Dated: ALSTON & BIRD LLP By: Attornbys for Defendanyf ANHBUSER-BUSCH, ELC (FKA (QD ‘ANHEUSER-BUSCH/INC,) Dated: lopay I BEC NNETT & SCHWEITZER By: Attorneys for Defendant W. L. HICKEY SONS, INC. Ml Mf Ul K Aljuredh26264\PLD'Stip Ord Conf Agr 5 JME STIPULATED CONFIDEN TALIT AGREEMENT RE GOLDEN BEA! DUCTS LL iToom nd AH PF WN HY yo Boe ee QBPNRMBRBRBBRBSBSUABREEHK EAS Dated: Dated: i Dated: | ld Dated: (OfollF Dated: Dated: Dated: a 4 \PLD\Stp Ord Cont Agree ATED CONFIDEN TALITY A 6 EMENT RE BEAR BISHOP BARRY mlb , Attéimeys for Defendant \ RUDOLPH AND SLETTEN,INC. FOLEY & MANSFIELD PLLP By: Al e¥s for Defendants COLUMBIA MECHANICAL CONTRACTORS VAY By: : " Kitomeys for Defendants MARC INI PLASTERING COMPANY, IMAI, TADLOCK, KEENEY & CORDERY, LLP By: , ‘Attorneys for Defendant MONTEREY MECHANICAL CO. LEWIS BRISBOIS BISGAARD & SMITH, LLP - SAN FRANCISCO By: , Attorneys for Defendant COOPER BROS., INC. MORGAN, LEWIS & BOCKIUS LLP By , Attomeys for Defendants GRINNELL LLC (FKA GRINNELL CORPORATION, AKA GRINNELL FIRE) MORGAN, LEWIS & BOCKIUS LLP By: , Attorneys for Defendants JOHNSON CONTROLS, INC. IME LEC DOC!Co wm IA HA HW PWD Dated: Dated: Dated: Dated: Wt Dated: Dated: Dated: LoL MF PRINDLE, GOETZ, BARNES & REINHOLTZ By: Attorneys for Defendant TEXACO INC. SELMAN BREITMAN, LLP By: Attomeys for Defendant SCOTT CO. OF CALIFORNIA SINUNU BRI LP By; = ieys for. Defendant ROSENDIN ELECTRIC, INC. STEPTOE & JOHNSON LLP By: Attomeys for Defendant METROPOLITAN LIFE INSURANCE COMPANY WFBM, LLP By: Attorneys for Defendants COSCO FIRE PROTECTION, INC.; WFBM, LLP By: Attorneys for Defendants D. ZELINSKY & SONS, INCORPORATED WFBM, LLP By: Attorneys for Defendants FDCC CALIFORNIA, INC. K.Slnjured\26244\PLDIGtip Ord Cont Agreement sti 7 IME STIPULATED CONF DENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTSeC em IND HW PF WN ° 11 Dated: Dated: Dated: Dated: Dated: Dated: October 9, 2019 Dated: Mt K:Ninjuredi2624aNPLD\Stip Ord Conf Agreement stip. ULATED CONFIDE! 4 7 [Al AGREEMENT RE GO! PRINDLE, GOETZ, BARNES & REINHOLTZ By: Attomeys for Defendant TEXACO INC, SELMAN BREITMAN, LLP By: ” Ritomeys for Defendant SCOTT CO. OF CALIFORNIA SINUNU BRUNI LLP By: ‘ Attorneys for Defendant ROSENDIN ELECTRIC, INC. STEPTOE & JOHNSON LLP By: Attorneys for Defendant METROPOLITAN LIFE INSURANCE COMPANY WFBM, LLP By: Attorneys for Defendants COSCO FIRE PROTECTION, INC.; WFBM, LLP lan P. Dillon : Attorneys for Defendants D. ZELINSKY & SONS, INCORPORATED WFBM, LLP By: Attorneys for Defendants FDCC CALIFORNIA, INC. IME R PRODUCTS LLC Di ENTSCo ew IN DA A Rw N 10 Dated: October 9, 2019 IT IS SO ORDERED Dated: WEBM, LLP lan P. Dillon ‘ Attomeys for Defendants GEORGE H. WILSON, INC. Anjured\26248\PLDIStip Ord Cont rent TALITY AGRI Judge of the Superior Court 8 NT RE GOL! EARP. ‘TS LLC DOCUM! JM iEDated: Dated: Dated: Dated: Dated. : \O/ B/\4 Dated: Dated: KAtnjneh26264:P LO Sip Ord Cunt Agreement. 6 JME . STIPULATED CONFIDE N ALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS BISHOP BARRY By: Attomeys for Defendant RUDOLPH AND SLETTEN, INC, FOLEY & MANSFIELD PLLP By: Attorneys for Defendants COLUMBIA MECHANICAL CONTRACTORS FOLEY & MANSFIELD PLLP By: Attorneys for Defendants MARCONI PLASTERING COMPANY, IMAI, TADLOCK, KEENEY & CORDERY, LLP By: Attorneys for Defendant MONTEREY MECHANICAL CO. LEWIS BRISBOIS BISGAARD & SMITH, LLP - SAN FRANCISCO eo " Attomoys Tor Defendant [ | COOPER BROS., INC. MORGAN, LEWIS & BOCKNJS LLP By: * Attorneys for Defendants GRINNELL LLC (FKA GRINNELL CORPORATION, AKA GRINNELL FIRE) MORGAN, LEWIS & BOCKIUS LLP By: : Attorneys for Defendants JOHNSON CONTROLS, INC.Coo IN Aw PF BN wee eee eee ee BRXRBRRPRBBF FS SSBB AwB Ew’ EO may move for relief from the Court, The burden is upon the moving party to show why the confidential designation is improper. A motion requesting that the designation be withdrawn must set forth with the court the reasons why the moving party believes the designation is improper. Upon such motion, the designating party must respond with why the "Confidential Document" designation is proper. 14. In producing these Confidential Documents plaintiff does not waive the right to - object to their use at trial or other case proceedings, including but not limited to objections based on privacy, relevance, confidential proprietary information, taxpayer privilege, and objections under California Evidence Code Section 352., 15. This Stipulated Confidentiality Agreement may be executed in one or more counterparts, each of which shall be considered an original, but all of which shall constitute one and the same document. Dated: _ 10/8/19 BRAYTON*PURCELL LLP By: /s/ Janine M. Fiel-Cosse _ Janine M. Fiel-Cosse Attorneys for Plaintiffs Dated: ALSTON & BIRD LLP By: ” ‘Attorneys for Defendant ANHEUSER-BUSCH, LLC (FKA ANHEUSER-BUSCH, INC.) Dated: \o/ 8 l ] TM By , Attorneys forDéfendant W. L. HICKEY SONS, INC. u Kure Pumam Mt MW IME KANlnjyresiog24aPLD\Stip Ord Conf Agreement stip. 5 $1 IPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS10/08/2019 14:40 eo NH tH FWD FAX 415 978 2008 SELMAN BREITMAN SF 003/003 Dated: Dated: Dated: Dated: Dated: Dated: MW “By: PRINDLE, GOETZ, BARNES & REINHOLTZ By: Attorneys for Defendant TEXACO INC, SELMAN BREITMAN, LLP By: vneys ‘or Defendant SCOTT'CO, OF CALIFORNIA SINUNU BRUNI LLP Attomeys for Defendant ROSENDIN ELECTRIC, INC, STEPTGE & JOHNSON LLP By: Attomeys for Defendant METROPOLITAN LIFE INSURANCE COMPANY WFBM, LLP By: Attomeys for Defendants COSCO FIRE PROTECTION, INC; WFBM, LLP By: Attorne for Defendant 2ELINSKY & eons INCORPORATED WEBM, LLP Attgmeys for Defendants FDCC CALIFORNIA, INC. 10/08/2019 2:40PM (GMT~07:00)Co td Aw ew DN 10 Dated: Dated: Dated: Dated: Dated: Dated: Dated: 10/8/19 Ml Knfnjurot262445PLDStip Oni Cont, PRINDLE, GOETZ, BARNES & REINHOLTZ By: Attorneys for Defendant TEXACO INC. SELMAN BREITMAN, LLP By: Attorneys for Defendant SCOTT CO. OF CALIFORNIA SINUNU BRUNI LLP By: Attorneys for Defendant ROSENDIN ELECTRIC, INC. STEPTOE & JOHNSON LLP By: Attorneys for Defendant METROPOLITAN LIFE INSURANCE COMPANY WFBM, LLP By: Attorneys for Defendants COSCO FIRE PROTECTION, INC.; WFBM, LLP By: Attorneys for Defendants D. ZELINSKY & SONS, INCORPORATED WFBM, LLP \e Lier By: Attorneys for Defendants FDCC CALIFORNIA, INC. 1 STIPULATED CONFIDENTIALITY AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENT: ="Co YN Aw PR WN Boe ee a BBR = Oo 16 Dated: Dated: Dated: Dated: Dated: 14, 2019 Dated: October 14, tober 14, 201 Dated: October 14, 2019 KNojusedt26244\PLO\Stip Ord Conf Agreement stip STIPULATED FIDENTIAI 8 ITY At EMENT DEN B! ODU! w )OCUMENT: BISHOP BARRY B ys ‘Attorneys for Defendant RUDOLPH AND SLETTEN, INC. FOLEY & MANSFIELD PLLP By: , Attorneys for Defendants COLUMBIA MECHANICAL CONTRACTORS FOLEY & MANSFIELD PLLP By: , Attorneys for Defendants MARCONI PLASTERING COMPANY, IMAI, TADLOCK, KEENEY & CORDERY, LLP By: ‘ Attorneys for Defendant MONTEREY MECHANICAL CO. LEWIS BRISBOIS BISGAARD & SMITH, LLP - SAN FRANCISCO By: Attorneys for Defendant COOPER BROS,, INC, MORGAN, LEWIS & BOCKIUS LLP by: gle — , Attomeys for Defendants GRINNELL LLC (FKA GRINNELL CORPORATION, AKA GRINNELL FIRE) MORGAN, LEWIS & ous LLP By: Ghyll , Attorneys for Defendants JOHNSON CONTROLS, INC. MECoO ADA F WN root = 6 Dated: Dated: Dated: Dated: Dated: Dated: Dated: (§ get 2019 PRINDLE, GOETZ, BARNES & REINHOLTZ By: TEXACO INC for Defendant TEXACO SELMAN BREITMAN, LLP By: Attomeys for Defendant SCOTT CO. OF CALIFORNIA. SINUNU BRUNI LLP By: Attormeys for Defendant ROSENDIN ELECTRIC, INC. STEPTOE & JOHNSON LLP By: ‘Attorneys for Defendant METROPOLITAN LIFE INSURANCE COMPANY WEBM, L! By: ‘Attoyneys/ibr Defendants CO; PROTECTION, INC.; WFBM, LLP Y Strome: tor Defendant D EP & SONS, INCORPORATED WFBM, LLP . for Defendants ALIFORNIA, INC.“ Co wow IA HA PR YN Dated: IT IS SO ORDERED Dated: KAfniurod\26246\PLDISuin Ord Conf Agreement stip.wwpd 8 ME STIPULATED CONFIDENTIALIT Y AGREEMENT RE GOLDEN BEAR PRODUCTS LLC DOCUMENTS WFBM, LLP By: : Attorneys for Defendants GEORGE H. WILSON, INC. (o}17 [20174 Judge of thé Superior Court CYNTHIA MING-MEI LEE