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Fred W. Schwinn (SBN 225575)
Raeon R. Roulston (SBN 255622)
Matthew C. Salmonsen (SBN 302854)
CONSUMER LAW CENTER, INC.
1435 Koll Circle, Suite 104
San Jose, California 95112-4610
Telephone Number: (408) 294-6100
Facsimile Number: (408) 294-6190
Email Address: fred.schwinn@sjconsumerlaw.com
Attorneys for Defendant/Cross-Complainant
MARIA ANTONIA CANUL
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
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VELOCITY INVESTMENTS, LLC, Case No. 16CV300096
ll (Unlimited Civil Case)
Plaintiff,
12 v. STIPULATED PROTECTIVE ORDER
13 MARIA CANUL,
14 Defendant.
MARIA ANTONIA CANUL, on behalf of
15
herself and all others similarly situated,
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Cross-Complainant,
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Vv,
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VELOCITY INVESTMENTS, LLC, a New
19 Jersey limited liability company; and ROES
1 through 10, inclusive,
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21 Cross-Defendants.
22 The parties represent that this litigation does not present any public health or safety concerns
23 and this Order does not deviate from the Model Confidentiality Order published by the Complex
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Division of the Santa Clara County Superior Court.
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In order to protect the confidentiality of confidential information obtained by the parties in
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27 connection with this case, the parties hereby agree as follows:
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
Part One: Use of Confidential Materials in Discovery
1 Any party or non-party may designate as “Confidential Information” (by stamping the
relevant page or as otherwise set forth herein) any document or response to discovery which that party
or non-party considers in good faith to contain information involving trade secrets, or confidential
business or financial information, subject to Rules 8.45, 8.46, 8.47, 8.490, 2.550, 2.551, 2.580, and
2.585 of the California Rules of Court, or under other provisions of California law. Where a document
or response consists of more than one page, the first page and each page on which confidential
information appears shall be so designated.
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2. A party or non-party may designate information disclosed during a deposition or in
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response to written discovery as “confidential” by so indicating in said responses or on the record at the
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13 deposition and requesting the preparation of a separate transcript of such material. In addition, a party
14 or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the
15 deposition transcript for which the designation is proposed, that specific pages of the transcript and/or
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specific responses be treated as “Confidential Information.” Any other party may object to such
17
proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures
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19 described in paragraph 8 below. After any designation made according to the procedure set forth in this
20 paragraph, the designated documents or information shall be treated according to the designation until
21 the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all
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parties shall be responsible for marking all previously unmarked copies of the designated material in
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their possession or control with the specified designation.
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25 3 All Confidential Information produced or exchanged in the course of this case (not
26 including information that is publicly available) shall be used by the party or parties to whom the
27 information is produced solely for the purpose of this case.
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
4 Except with the prior written consent of the other parties, or upon prior order of this
Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any
person other than:
(a) counsel for the respective parties to this litigation, including, in-house counsel
and co-counsel retained for this litigation,
(b) employees of such counsel,
(c) individual parties or officers or employees of a party, to the extent deemed
necessary by counsel for the prosecution or defense of this litigation,
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(d) consultants or expert witnesses retained for the prosecution or defense of this
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litigation, provided that each person shall execute a copy of the Certification annexed to this Order
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13 (which shall be retained by counsel to the party so disclosing the Confidential Information and made
14 available for inspection by opposing counsel during the pendency or after the termination of the action
15 only upon good cause shown and upon order of the Court) before being shown or given any
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Confidential Information, and provided that if the party chooses a consultant or expert employed by the
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defendant or one of its competitors (as listed on Appendix A), the party shall notify the opposing party,
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19 or designating non-party, before disclosing any Confidential Information to that individual and shall
20 give the opposing party an opportunity to move for a protective order preventing or limiting such
21 disclosure;
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(e) any authors or recipients of the Confidential Information;
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@ the Court, Court personnel, and court reporters; and
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25 (g) witnesses (other than persons described in paragraph 4(c) and 4(e)). A witness
26 shall sign the Certification before being shown a confidential document. Confidential Information may
27 be disclosed to a witness who will not sign the Certification only in a deposition in which the party who
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
designated the Confidential Information is represented or has been given notice that Confidential
Information produced by the party may be used. At the request of any party, the portion of the
deposition transcript involving the Confidential Information shall be designated “Confidential”
pursuant to paragraph 2 above. Witnesses shown Confidential Information shall not be allowed to retain
copies.
> Any persons receiving Confidential Information shall not reveal or discuss such
information to or with any person who is not entitled to receive such information, except as set forth
herein.
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6 In connection with discovery proceedings as to which a party submits Confidential
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Information, confidential documents shall be lodged or filed with a confidential designation by
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13 electronic submission in the manner described in Rule 2.551(d), and pursuant to Local General Rule
14 6B.3. Such records must not be submitted in paper form. All chamber copies containing Confidential
15 Information which are submitted to the Court shall be lodged with the Court in sealed envelopes or
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other appropriate sealed containers by delivery to Court Services addressed to the assigned Department
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or as directed by the Court. On the outside of the envelopes, a copy of the first page of the document
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19 shall be attached. If Confidential Information is included in the first page attached to the outside of the
20 envelopes, it may be deleted from the outside copy. The word “CONFIDENTIAL” shall be stamped
21 on the envelope and a statement substantially in the following form shall also be printed on the
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envelope:
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“This envelope is sealed pursuant to Order of the Court, contains Confidential Information and
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25 is not to be opened or the contents revealed, except by Order of the Court or agreement by the parties.”
26 a A party may designate as “Confidential Information” documents or discovery materials
27 produced by a non-party by providing written notice to all parties of the relevant document numbers or
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
other identification within thirty (30) days after receiving such documents or discovery materials. Any
party or non-party may voluntarily disclose to others without restriction any information designated by
that party or non-party as Confidential Information, although a document may lose its confidential
status if it is made public.
8 If a party contends that any material is not entitled to confidential treatment, such party
may at any time give written notice to the party or non-party who designated the material. The party or
non-party who designated the material shall have twenty-five (25) days from the receipt of such written
notice to apply to the Court for an order designating the material as confidential. The party or non-party
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seeking the order has the burden of establishing that the document is entitled to protection.
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9 Notwithstanding any challenge to the designation of material as Confidential
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13 Information, all documents shall be treated as such and shall be subject to the provisions hereof unless
14 and until one of the following occurs:
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(a) the party or non-party who claims that the material is Confidential Information
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withdraws such designation in writing; or
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(b) the party or non-party who claims that the material is Confidential Information
19 fails to apply to the Court for an order designating the material confidential within the time period
20 specified above after receipt of a written challenge to such designation; or
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(©) the Court rules the material is not Confidential Information.
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10. All provisions of this Order restricting the communication or use of Confidential
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Information shall continue to be binding after the conclusion of the action, unless otherwise agreed or
24
25 ordered. Upon conclusion of the litigation, a party in possession of Confidential Information, other
26 than that which is contained in pleadings, correspondence, and deposition transcripts, shall either (a)
27 return such documents no later than thirty (30) days after conclusion of this action to counsel for the
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
party or non-party who provided such information, or (b) destroy such documents within the time
period upon consent of the party who provided the information and certify in writing within thirty (30)
days that the documents have been destroyed.
11. Nothing herein shall be deemed to waive any applicable privilege or work product
protection, or to affect the ability of a party to seek relief for an inadvertent disclosure of material
protected by privilege or work product protection. Any witness or other person, firm or entity from
which discovery is sought may be informed of and may obtain the protection of this Order by written
advice to the parties’ respective counsel or by oral advice at the time of any deposition or similar
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proceeding.
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Part Two: Use of Confidential Materials in Court
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13 The following provisions govern the treatment of Confidential Information used at trial or
14 submitted as a basis for adjudication of matters other than discovery motions or proceedings. The
15 procedures for use of Confidential Information at trial shall be determined by the trial judge. Trial
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exhibits shall not be filed but must be lodged in paper form with the assigned trial department as set
17
forth in the Court’s Local Civil Rules.
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19 These provisions are subject to Rules 8.46, 8.490, 2.550, 2.551, 2.580, and 2.585 of the
20 California Rules of Court and must be construed in light of those Rules.
21 12. A party that files with the Court, or seeks to use at trial, materials designated as
22
Confidential Information, and who seeks to have the record containing such information sealed, shall
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submit to the Court a motion to seal, pursuant to California Rules of Court 2.551.
24
25 13. A party that files with the Court, or seeks to use at trial, materials designated as
26 Confidential Information by anyone other than itself, and who does not seek to have the record
27 containing such information sealed, shall comply with either of the following requirements:
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
(a) At least ten (10) business days prior to the filing or use of the Confidential
Information, the submitting party shall give notice to all parties, and to any non-party that designated
the materials as Confidential Information pursuant to this Order, of the submitting party’s intention to
file or use the Confidential Information, including specific identification of the Confidential
Information. Any affected party or non-party may then file a motion to seal, pursuant to California
Rules of Court 2.551; or
(b) At the time of filing or desiring to use the Confidential Information, the
submitting party shall submit the materials electronically with a confidential designation pursuant to the
10
lodging-under-seal provision of California Rule of Court 2.551(d) and Local General Rule 6B(3), and at
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the same time file in the public record redacted versions of the same documents. Any affected party or
12
13 non-party may then file a motion to seal, pursuant to the California Rule of Court 2.551(b), within ten
14 (10) business days after such lodging. Documents lodged pursuant to California Rule of Court 2.551(d)
15 shall bear a legend stating that such materials shall be unsealed upon the expiration of ten (10) business
16
days, absent the filing of a motion to seal pursuant to Rule 2.551(b) or Court Order
17
14. In connection with a request to have materials sealed pursuant to Section 12 or Section
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19 13, the moving party’s declaration pursuant to California Rule of Court 2.551(b)(1) shall contain
20 sufficient particularity with respect to the particular Confidential Information and the basis for sealing
21 to enable the Court to make the findings required by California Rule of Court 2.550(d) without being
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required to review each item of Confidential Information.
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15. This Stipulated Protective Order creates no right to file Confidential Information under
24
25 seal without complying with California Rules of Court, Rules 2.550 et seq.
26 00000
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
CONSUMER LAW CENTER, INC.
Dated: February 11, 2021 By: /s/ Matthew C. Salmonsen
(Fred W. Schwinn (SBN 225575)
ORaeon R. Roulston (SBN 255622)
Matthew C. Salmonsen (SBN 302854)
Attorneys for Cross-Complainant
MARIA ANTONIA CANUL
CHAPMAN GLUCKSMAN DEAN & ROEB
10 Dated: February 11, 2021 By:
OGregory K. Sabo (S 169760)
ll Molshree Gupta (SBN 275101)
12
Attorneys for Cross-Defendant
13 VELOCITY INVESTMENTS, LLC
14
15
16 IT IS SO ORDERED.
2
17 Dated:
The Honorable Patricia M. Lucas
18 Judge of the Superior Court
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
CERTIFICATION
I hereby certify my understanding that Confidential Information is being provided to me
pursuant to the terms and restrictions Ol the Stipulated Protective _ Orde dated
, 2021, in Velocity Investments, LLC v. Maria Canul, et al., Case No.
16CV300096. I have been given a copy of that Order and read it.
I agree to be bound by the Order. I will not reveal the Confidential Information to anyone,
except as allowed by the Order. I will maintain all such Confidential Information — including copies,
notes, or other transcriptions made therefrom — in a secure matter to prevent unauthorized access to it.
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No later than thirty (30) days after the conclusion of this action, I will return the Confidential
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Information — including copies, notes or other transcriptions made therefrom — to the counsel who
12
13 provided me with the Confidential Information. I hereby consent to the jurisdiction of the California
14 Superior Court, County of Santa Clara, for the purpose of enforcing the Stipulated Protective Order.
15 I declare under penalty of perjury that the foregoing is true and correct and that this certificate is
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execution this day of , 20 sat
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19 By:
20 Address:
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Phone:
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STIPULATED PROTECTIVE ORDER Case No. 16CV300096
Preview
Fred W. Schwinn (SBN 225575) Raeon R. Roulston (SBN 255622) Matthew C. Salmonsen (SBN 302854) CONSUMER LAW CENTER, INC. 1435 Koll Circle, Suite 104 San Jose, California 95112-4610 Telephone Number: (408) 294-6100 Facsimile Number: (408) 294-6190 Email Address: fred.schwinn@sjconsumerlaw.com Attorneys for Defendant/Cross-Complainant MARIA ANTONIA CANUL SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA 10 VELOCITY INVESTMENTS, LLC, Case No. 16CV300096 ll (Unlimited Civil Case) Plaintiff, 12 v. STIPULATED PROTECTIVE ORDER 13 MARIA CANUL, 14 Defendant. MARIA ANTONIA CANUL, on behalf of 15 herself and all others similarly situated, 16 Cross-Complainant, 17 Vv, 18 VELOCITY INVESTMENTS, LLC, a New 19 Jersey limited liability company; and ROES 1 through 10, inclusive, 20 21 Cross-Defendants. 22 The parties represent that this litigation does not present any public health or safety concerns 23 and this Order does not deviate from the Model Confidentiality Order published by the Complex 24 Division of the Santa Clara County Superior Court. 25 In order to protect the confidentiality of confidential information obtained by the parties in 26 27 connection with this case, the parties hereby agree as follows: 28 M1 -1- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 Part One: Use of Confidential Materials in Discovery 1 Any party or non-party may designate as “Confidential Information” (by stamping the relevant page or as otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain information involving trade secrets, or confidential business or financial information, subject to Rules 8.45, 8.46, 8.47, 8.490, 2.550, 2.551, 2.580, and 2.585 of the California Rules of Court, or under other provisions of California law. Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated. 10 2. A party or non-party may designate information disclosed during a deposition or in ll response to written discovery as “confidential” by so indicating in said responses or on the record at the 12 13 deposition and requesting the preparation of a separate transcript of such material. In addition, a party 14 or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the 15 deposition transcript for which the designation is proposed, that specific pages of the transcript and/or 16 specific responses be treated as “Confidential Information.” Any other party may object to such 17 proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures 18 19 described in paragraph 8 below. After any designation made according to the procedure set forth in this 20 paragraph, the designated documents or information shall be treated according to the designation until 21 the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all 22 parties shall be responsible for marking all previously unmarked copies of the designated material in 23 their possession or control with the specified designation. 24 25 3 All Confidential Information produced or exchanged in the course of this case (not 26 including information that is publicly available) shall be used by the party or parties to whom the 27 information is produced solely for the purpose of this case. 28 -2- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 4 Except with the prior written consent of the other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than: (a) counsel for the respective parties to this litigation, including, in-house counsel and co-counsel retained for this litigation, (b) employees of such counsel, (c) individual parties or officers or employees of a party, to the extent deemed necessary by counsel for the prosecution or defense of this litigation, 10 (d) consultants or expert witnesses retained for the prosecution or defense of this ll litigation, provided that each person shall execute a copy of the Certification annexed to this Order 12 13 (which shall be retained by counsel to the party so disclosing the Confidential Information and made 14 available for inspection by opposing counsel during the pendency or after the termination of the action 15 only upon good cause shown and upon order of the Court) before being shown or given any 16 Confidential Information, and provided that if the party chooses a consultant or expert employed by the 17 defendant or one of its competitors (as listed on Appendix A), the party shall notify the opposing party, 18 19 or designating non-party, before disclosing any Confidential Information to that individual and shall 20 give the opposing party an opportunity to move for a protective order preventing or limiting such 21 disclosure; 22 (e) any authors or recipients of the Confidential Information; 23 @ the Court, Court personnel, and court reporters; and 24 25 (g) witnesses (other than persons described in paragraph 4(c) and 4(e)). A witness 26 shall sign the Certification before being shown a confidential document. Confidential Information may 27 be disclosed to a witness who will not sign the Certification only in a deposition in which the party who 28 -3- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 designated the Confidential Information is represented or has been given notice that Confidential Information produced by the party may be used. At the request of any party, the portion of the deposition transcript involving the Confidential Information shall be designated “Confidential” pursuant to paragraph 2 above. Witnesses shown Confidential Information shall not be allowed to retain copies. > Any persons receiving Confidential Information shall not reveal or discuss such information to or with any person who is not entitled to receive such information, except as set forth herein. 10 6 In connection with discovery proceedings as to which a party submits Confidential ll Information, confidential documents shall be lodged or filed with a confidential designation by 12 13 electronic submission in the manner described in Rule 2.551(d), and pursuant to Local General Rule 14 6B.3. Such records must not be submitted in paper form. All chamber copies containing Confidential 15 Information which are submitted to the Court shall be lodged with the Court in sealed envelopes or 16 other appropriate sealed containers by delivery to Court Services addressed to the assigned Department 17 or as directed by the Court. On the outside of the envelopes, a copy of the first page of the document 18 19 shall be attached. If Confidential Information is included in the first page attached to the outside of the 20 envelopes, it may be deleted from the outside copy. The word “CONFIDENTIAL” shall be stamped 21 on the envelope and a statement substantially in the following form shall also be printed on the 22 envelope: 23 “This envelope is sealed pursuant to Order of the Court, contains Confidential Information and 24 25 is not to be opened or the contents revealed, except by Order of the Court or agreement by the parties.” 26 a A party may designate as “Confidential Information” documents or discovery materials 27 produced by a non-party by providing written notice to all parties of the relevant document numbers or 28 -4- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 other identification within thirty (30) days after receiving such documents or discovery materials. Any party or non-party may voluntarily disclose to others without restriction any information designated by that party or non-party as Confidential Information, although a document may lose its confidential status if it is made public. 8 If a party contends that any material is not entitled to confidential treatment, such party may at any time give written notice to the party or non-party who designated the material. The party or non-party who designated the material shall have twenty-five (25) days from the receipt of such written notice to apply to the Court for an order designating the material as confidential. The party or non-party 10 seeking the order has the burden of establishing that the document is entitled to protection. ll 9 Notwithstanding any challenge to the designation of material as Confidential 12 13 Information, all documents shall be treated as such and shall be subject to the provisions hereof unless 14 and until one of the following occurs: 15 (a) the party or non-party who claims that the material is Confidential Information 16 withdraws such designation in writing; or 17 18 (b) the party or non-party who claims that the material is Confidential Information 19 fails to apply to the Court for an order designating the material confidential within the time period 20 specified above after receipt of a written challenge to such designation; or 21 (©) the Court rules the material is not Confidential Information. 22 10. All provisions of this Order restricting the communication or use of Confidential 23 Information shall continue to be binding after the conclusion of the action, unless otherwise agreed or 24 25 ordered. Upon conclusion of the litigation, a party in possession of Confidential Information, other 26 than that which is contained in pleadings, correspondence, and deposition transcripts, shall either (a) 27 return such documents no later than thirty (30) days after conclusion of this action to counsel for the 28 -5- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 party or non-party who provided such information, or (b) destroy such documents within the time period upon consent of the party who provided the information and certify in writing within thirty (30) days that the documents have been destroyed. 11. Nothing herein shall be deemed to waive any applicable privilege or work product protection, or to affect the ability of a party to seek relief for an inadvertent disclosure of material protected by privilege or work product protection. Any witness or other person, firm or entity from which discovery is sought may be informed of and may obtain the protection of this Order by written advice to the parties’ respective counsel or by oral advice at the time of any deposition or similar 10 proceeding. ll Part Two: Use of Confidential Materials in Court 12 13 The following provisions govern the treatment of Confidential Information used at trial or 14 submitted as a basis for adjudication of matters other than discovery motions or proceedings. The 15 procedures for use of Confidential Information at trial shall be determined by the trial judge. Trial 16 exhibits shall not be filed but must be lodged in paper form with the assigned trial department as set 17 forth in the Court’s Local Civil Rules. 18 19 These provisions are subject to Rules 8.46, 8.490, 2.550, 2.551, 2.580, and 2.585 of the 20 California Rules of Court and must be construed in light of those Rules. 21 12. A party that files with the Court, or seeks to use at trial, materials designated as 22 Confidential Information, and who seeks to have the record containing such information sealed, shall 23 submit to the Court a motion to seal, pursuant to California Rules of Court 2.551. 24 25 13. A party that files with the Court, or seeks to use at trial, materials designated as 26 Confidential Information by anyone other than itself, and who does not seek to have the record 27 containing such information sealed, shall comply with either of the following requirements: 28 -6- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 (a) At least ten (10) business days prior to the filing or use of the Confidential Information, the submitting party shall give notice to all parties, and to any non-party that designated the materials as Confidential Information pursuant to this Order, of the submitting party’s intention to file or use the Confidential Information, including specific identification of the Confidential Information. Any affected party or non-party may then file a motion to seal, pursuant to California Rules of Court 2.551; or (b) At the time of filing or desiring to use the Confidential Information, the submitting party shall submit the materials electronically with a confidential designation pursuant to the 10 lodging-under-seal provision of California Rule of Court 2.551(d) and Local General Rule 6B(3), and at ll the same time file in the public record redacted versions of the same documents. Any affected party or 12 13 non-party may then file a motion to seal, pursuant to the California Rule of Court 2.551(b), within ten 14 (10) business days after such lodging. Documents lodged pursuant to California Rule of Court 2.551(d) 15 shall bear a legend stating that such materials shall be unsealed upon the expiration of ten (10) business 16 days, absent the filing of a motion to seal pursuant to Rule 2.551(b) or Court Order 17 14. In connection with a request to have materials sealed pursuant to Section 12 or Section 18 19 13, the moving party’s declaration pursuant to California Rule of Court 2.551(b)(1) shall contain 20 sufficient particularity with respect to the particular Confidential Information and the basis for sealing 21 to enable the Court to make the findings required by California Rule of Court 2.550(d) without being 22 required to review each item of Confidential Information. 23 15. This Stipulated Protective Order creates no right to file Confidential Information under 24 25 seal without complying with California Rules of Court, Rules 2.550 et seq. 26 00000 27 28 -7- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 CONSUMER LAW CENTER, INC. Dated: February 11, 2021 By: /s/ Matthew C. Salmonsen (Fred W. Schwinn (SBN 225575) ORaeon R. Roulston (SBN 255622) Matthew C. Salmonsen (SBN 302854) Attorneys for Cross-Complainant MARIA ANTONIA CANUL CHAPMAN GLUCKSMAN DEAN & ROEB 10 Dated: February 11, 2021 By: OGregory K. Sabo (S 169760) ll Molshree Gupta (SBN 275101) 12 Attorneys for Cross-Defendant 13 VELOCITY INVESTMENTS, LLC 14 15 16 IT IS SO ORDERED. 2 17 Dated: The Honorable Patricia M. Lucas 18 Judge of the Superior Court 19 20 21 22 23 24 25 26 27 28 -8- STIPULATED PROTECTIVE ORDER Case No. 16CV300096 CERTIFICATION I hereby certify my understanding that Confidential Information is being provided to me pursuant to the terms and restrictions Ol the Stipulated Protective _ Orde dated , 2021, in Velocity Investments, LLC v. Maria Canul, et al., Case No. 16CV300096. I have been given a copy of that Order and read it. I agree to be bound by the Order. I will not reveal the Confidential Information to anyone, except as allowed by the Order. I will maintain all such Confidential Information — including copies, notes, or other transcriptions made therefrom — in a secure matter to prevent unauthorized access to it. 10 No later than thirty (30) days after the conclusion of this action, I will return the Confidential ll Information — including copies, notes or other transcriptions made therefrom — to the counsel who 12 13 provided me with the Confidential Information. I hereby consent to the jurisdiction of the California 14 Superior Court, County of Santa Clara, for the purpose of enforcing the Stipulated Protective Order. 15 I declare under penalty of perjury that the foregoing is true and correct and that this certificate is 16 execution this day of , 20 sat 17 18 19 By: 20 Address: 21 22 Phone: 23 24 25 26 27 28 -9- STIPULATED PROTECTIVE ORDER Case No. 16CV300096