Evans v. Experian Information Solutions Inc et al, No. 2:2022cv00199 - Document 54 (E.D. Wash. 2023)

Court Description: ORDER granting ECF No. 53 Motion for Stipulated Protective Order. Signed by Judge Thomas O. Rice.

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Evans v. Experian Information Solutions Inc et al Case 2:22-cv-00199-TOR Doc. 54 ECF No. 54 filed 06/20/23 5 Beth E. Terrell, WSBA #26759 Jennifer Rust Murray, WSBA #36983 TERRELL MARSHALL LAW GROUP PLLC 936 North 34th Street, Suite 300 Seattle, Washington 98103 Telephone: (206) 816-6603 Facsimile: (206) 319-5450 Email: bterrell@terrellmarshall.com Email: jmurray@terrellmarshall.com 6 Attorneys for Plaintiff 7 [Additional Counsel Appear on Signature Page] 1 2 3 4 8 9 PageID.434 Page 1 of 20 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON REBECCA A. EVANS, Case No. 2:22-cv-00199-TOR Plaintiff, 10 vs. STIPULATED PROTECTIVE ORDER 11 EXPERIAN INFORMATION SOLUTIONS, INC., TRANS UNION, LLC, AND WELLS 12 FARGO BANK, N.A., Defendants. 13 14 15 I. STIPULATION Plaintiff Rebecca A. Evans, by and through her undersigned counsel, and 16 Defendants Experian Information Solutions, Inc., Trans Union, LLC, and Wells Fargo 17 Bank, N.A., by and through their undersigned counsel, propose the following 18 stipulated protective order to protect personal, private, confidential, or proprietary 19 information which may be produced in this action. 20 STIPULATED PROTECTIVE ORDER - 1 Case No. 2:22-cv-00199-TOR Dockets.Justia.com Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.435 Page 2 of 20 1 1. Purposes and Limitations 2 Discovery in this action is likely to involve production of personal, private, 3 confidential, or proprietary information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 2. “Confidential” Material 12 “Confidential” material shall include the following documents and tangible 13 things produced or otherwise exchanged: documents and information that have 14 been and may be sought, produced or exhibited by and among the parties to this 15 action relating to trade secrets, confidential research, development, technology; 16 confidential business or financial information; information regarding confidential 17 business practices; confidential commercial and/or personal information (including 18 information implicating privacy rights of third parties); information otherwise 19 generally unavailable to the public, or which may be privileged or otherwise 20 STIPULATED PROTECTIVE ORDER - 2 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.436 Page 3 of 20 1 protected from disclosure under state or federal statutes, court rules, case 2 decisions, or common law; other proprietary information belonging to Defendants, 3 and/or personal identifying, income, credit and other confidential information of 4 Plaintiff and/or non-parties (including but not limited to DOB, SSN, full account 5 information). 6 3. 7 The protections conferred by this agreement cover not only confidential 8 material (as defined above), but also (1) any information copied or extracted from 9 confidential material; (2) all copies, excerpts, summaries, or compilations of Scope 10 confidential material; and (3) any testimony, conversations, or presentations by 11 parties or their counsel that might reveal confidential material. 12 However, the protections conferred by this agreement do not cover 13 information that is in the public domain or becomes part of the public domain not 14 involving a violation of this Order, including through trial or otherwise. Any use of 15 confidential material at trial shall be governed by the orders of the trial judge. This 16 Order does not govern the use of confidential material at trial. 17 4. Access to and Use of Confidential Material 18 4.1 Basic Principles. A receiving party may use confidential material that is 19 disclosed or produced by another party or by a non-party in connection with this 20 STIPULATED PROTECTIVE ORDER - 3 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.437 Page 4 of 20 1 case only for prosecuting, defending, or attempting to settle this litigation. 2 Confidential material may be disclosed only to the categories of persons and under 3 the conditions described in this agreement. Confidential material must be stored 4 and maintained by a receiving party at a location and in a secure manner that 5 ensures that access is limited to the persons authorized under this agreement. 6 When the Action has been terminated, a receiving party must comply with the 7 provisions of section 11 below (NON-TERMINATION AND RETURN OF 8 DOCUMENTS). 9 4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 10 ordered by the court or permitted in writing by the designating party, a receiving 11 party may disclose any confidential material only to: 12 (a) the receiving party’s counsel of record in this action, as well as 13 employees of counsel to whom it is reasonably necessary to disclose the 14 information for this litigation; 15 (b) the officers, directors, and employees (including in house counsel) of 16 the receiving party to whom disclosure is reasonably necessary for this litigation 17 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 18 A); 19 20 STIPULATED PROTECTIVE ORDER - 4 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR 1 (c) ECF No. 54 filed 06/20/23 PageID.438 Page 5 of 20 experts and consultants to whom disclosure is reasonably necessary 2 for this litigation and who have signed the “Acknowledgment and Agreement to Be 3 Bound” (Exhibit A); 4 (d) the court, court personnel, and court reporters and their staff; 5 (e) copy or imaging services retained by counsel to assist in the 6 duplication of confidential material, provided that counsel for the party retaining 7 the copy or imaging service instructs the service not to disclose any confidential 8 material to third parties and to immediately return all originals and copies of any 9 confidential material; 10 (f) during their depositions, witnesses in the action to whom disclosure is 11 reasonably necessary , unless otherwise agreed by the designating party or ordered 12 by the court. Pages of transcribed deposition testimony or exhibits to depositions 13 that reveal confidential material must be separately bound by the court reporter 14 and may not be disclosed to anyone except as permitted under this agreement. It 15 shall be the obligation of the designating party to identify confidential testimony 16 and exhibits for the court reporter as set forth in section 5.2(b) below; 17 (g) the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 20 STIPULATED PROTECTIVE ORDER - 5 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR 1 2 3 (h) ECF No. 54 filed 06/20/23 PageID.439 Page 6 of 20 any mediators or settlement officers and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions; (i) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 6 4.3 Filing Confidential Material. Before filing confidential material or 7 discussing or referencing such material in court filings, the filing party may confer 8 with the designating party to determine whether the designating party will remove 9 the confidential designation, whether the document can be redacted, or whether 10 a motion to seal or stipulation and proposed order is warranted. 11 12 5. Designating Protected Material 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each party or non-party that designates information or items for protection under 15 this agreement must take care to limit any such designation to specific material 16 that qualifies under the appropriate standards. The designating party must 17 designate for protection only those materials, documents, items, or oral or written 18 communications that qualify, so that non-confidential documents, items, or 19 communications are not swept unjustifiably within the ambit of this agreement. 20 STIPULATED PROTECTIVE ORDER - 6 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.440 Page 7 of 20 1 Mass, indiscriminate or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to 4 impose unnecessary expenses and burdens on other parties) may expose the 5 designating party to sanctions if the Court finds that such party acts unreasonably 6 when requested to waive the confidential designation under Rule 37 and applicable 7 local rules. 8 If it comes to a designating party’s attention that information or items that 9 it designated for protection do not qualify for protection, that designating party 10 must promptly notify all other Parties that it is withdrawing the inapplicable 11 designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this agreement, or as otherwise stipulated or ordered, disclosure or discovery 14 material that qualifies for protection under this agreement must be clearly so 15 designated before or when the material is disclosed or produced. 16 (a) Information in documentary form: (e.g., paper or electronic 17 documents and deposition exhibits, but excluding transcripts of depositions or 18 other pretrial or trial proceedings), the designating party must affix at a minimum 19 the word “CONFIDENTIAL” to each page that contains confidential material. 20 STIPULATED PROTECTIVE ORDER - 7 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.441 Page 8 of 20 1 A party or non-party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting party has 3 indicated which documents it would like copied and produced. During the 4 inspection and before the designation, all of the material made available for 5 inspection shall be deemed “CONFIDENTIAL.” After the inspecting party has 6 identified the documents it wants copied and produced, the producing party must 7 determine which documents, or portions thereof, qualify for protection under this 8 Order. Then, before producing the specified documents, the producing party must 9 affix the “CONFIDENTIAL legend” to each page that contains confidential Material. 10 If only a portion of the material on a page qualifies for protection, the producing 11 party also must clearly identify the protected portion(s) (e.g., by making 12 appropriate markings in the margins). 13 (b) Testimony given in deposition or in other pretrial proceedings: the 14 parties and any participating non-parties must identify on the record, during the 15 deposition, hearing, or other pretrial proceeding, whether a transcript is designed 16 confidential, without prejudice to their right to so designate the transcript after 17 reviewing the transcript. Any party or non-party may, within twenty-one days after 18 the transcript of the deposition or other pretrial proceeding becomes available, 19 designate the transcript or portions thereof, or exhibits thereto, as confidential. If 20 STIPULATED PROTECTIVE ORDER - 8 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.442 Page 9 of 20 1 a party or nonparty desires to protect confidential information at trial, the issue 2 should be addressed during the final pre-trial conference. 3 (c) Other tangible items: the producing party must affix in a prominent 4 place on the exterior of the container or containers in which the information or 5 item is stored the word “CONFIDENTIAL.” If only a portion or portions of the 6 information or item warrant protection, the producing party, to the extent 7 practicable, shall identify the protected portion(s). 8 9 5.3 Attorney’s Eyes Only Designation. Except with the prior written consent of the individual or entity designating a document or portions of a 10 document as “Confidential—Attorneys’ Eyes Only,” or pursuant to prior Order after 11 notice, any document, transcript or pleading given “Confidential—Attorneys’ Eyes 12 Only” treatment under this Order, and any information contained in or derived 13 from any such materials (including but not limited to, all deposition testimony that 14 refers to, reflects or otherwise discusses any information designated 15 “Confidential—Attorneys’ Eyes Only” hereunder) may not be disclosed other than 16 in accordance with this Order and may not be disclosed to any person other than: 17 (a) a party’s retained outside counsel of record in this action, as well as employees 18 of said outside counsel to whom it is reasonably necessary to disclose the 19 information for this litigation; (b) experts specifically retained as consultants or 20 STIPULATED PROTECTIVE ORDER - 9 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.443 Page 10 of 20 1 expert witnesses in connection with this litigation who have signed the 2 “Declaration of Compliance” (Exhibit A); (c) the Court and its personnel; (d) court 3 reporters, their staff, and professional vendors to whom disclosure is reasonably 4 necessary for this litigation; and (e) the author of the document or the original 5 source of the information or corporate representative of the designating party. 6 5.4 Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 failure to designate qualified information or items does not, standing alone, waive 8 the designating party’s right to secure protection under this agreement for such 9 material. Upon timely correction of a designation, the receiving party must make 10 reasonable efforts to ensure that the material is treated in accordance with the 11 provisions of this agreement. 12 6. Challenging Confidentiality Designations 13 6.1 Timing of Challenges. Any party or non-party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order, but should endeavor in good faith to promptly raise objections 16 to confidentiality designations. Delaying a challenge to a confidentiality designation 17 in an effort to gain a strategic or unfair advantage, or where it is reasonably 18 foreseeable that the delay may cause substantial unfairness, unnecessary 19 20 STIPULATED PROTECTIVE ORDER - 10 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.444 Page 11 of 20 1 economic burden, or a significant disruption or delay of the litigation, may expose 2 the challenging party to sanctions. 3 6.2 Meet and Confer. The parties must make every attempt to resolve any 4 dispute regarding confidential designations without court involvement. Any motion 5 regarding confidential designations or for a protective order must include a 6 certification, in the motion or in a declaration or affidavit, that the movant has 7 engaged in a good faith meet and confer conference with other affected parties in 8 an effort to resolve the dispute without court action. The certification must list the 9 date, manner, and participants to the conference. A good faith effort to confer 10 requires a face-to-face meeting or a telephone conference. 11 6.3 Judicial Intervention. If the parties cannot resolve a challenge without 12 court intervention, the challenging party may file and serve a motion to challenge 13 the confidentiality designation. The burden of persuasion in any such motion shall 14 be on the designating party. Frivolous challenges, and those made for an improper 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 parties) may expose the challenging party to sanctions. All parties shall continue to 17 maintain the material in question as confidential until the court rules on the 18 challenge. 19 20 STIPULATED PROTECTIVE ORDER - 11 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR 1 2 7. ECF No. 54 filed 06/20/23 PageID.445 Page 12 of 20 Protected Material Subpoenaed or Ordered Produced in Other Litigation 3 If a party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this action as 5 “CONFIDENTIAL,” that party must: 6 7 8 9 (a) promptly notify the designating party in writing and include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the designating party whose confidential material may be affected. 14 15 16 17 18 19 20 STIPULATED PROTECTIVE ORDER - 12 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.446 Page 13 of 20 1 8. Unauthorized Disclosure of Protected Material 2 If a receiving party learns that, by inadvertence or otherwise, it has disclosed 3 confidential material to any person or in any circumstance not authorized under 4 agreement, the receiving party must immediately (a) notify in writing the 5 designating party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the protected material, (c) inform the person or persons 7 to whom unauthorized disclosures were made of all the terms of this Protective 8 Order, and (d) request that such person or persons execute the “Acknowledgment 9 and Agreement to Be Bound” that is attached hereto as Exhibit A. 10 9. Inadvertent Production of Privileged or Otherwise Protected Material 11 When a producing party gives notice to receiving parties that certain 12 inadvertently produced material is subject to a claim of privilege or other 13 protection, the obligations of the receiving parties are those set forth in Federal 14 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 15 whatever procedure may be established in an e-discovery order or agreement that 16 may provide for production without prior privilege review. 17 The parties agree to the entry of a non-waiver order under Fed. R. Evid. 18 502(d) and (e) as set forth herein. 19 10. Miscellaneous 20 STIPULATED PROTECTIVE ORDER - 13 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR 1 2 ECF No. 54 filed 06/20/23 PageID.447 Page 14 of 20 10.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its modification by the Court in the future. 3 10.2 Right to Assert Other Objections. By stipulating to the entry of this 4 Order, no party waives any right it otherwise would have to object to disclosing or 5 producing any information or item on any ground not addressed in this Stipulated 6 Order. Similarly, no party waives any right to object on any ground to use in 7 evidence of any of the material covered by this Order. 8 9 11. Non-Termination and Return of Documents: Within 60 days after the termination of this action, including all appeals, each receiving party must return 10 all confidential material to the producing party, including all copies, abstracts, 11 extracts, compilations, summaries, and any other format reproducing or capturing 12 any of the confidential material thereof. Alternatively, the parties may agree upon 13 appropriate methods of destruction. Whether the confidential material is returned 14 or destroyed, the receiving party must submit a written certification to the 15 producing party (and, if not the same person or entity, to the designating party) by 16 the 60-day deadline that affirms that the receiving party has not retained any 17 copies, abstracts, compilations, summaries or any other format reproducing or 18 capturing any of the confidential material. 19 20 STIPULATED PROTECTIVE ORDER - 14 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.448 Page 15 of 20 1 Notwithstanding this provision, counsel are entitled to retain one archival 2 copy of all documents filed with the court, trial, deposition, and hearing transcripts, 3 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 4 attorney work product, and consultant and expert work product, even if such 5 materials contain confidential material. Any such archival copies that contain or 6 constitute confidential material remain subject to this Order as set forth in Section 7 3 (SCOPE). 8 9 10 12. Violation 11 Any violation of this Order may be punished by appropriate measures 12 including, without limitation, contempt proceedings and/or monetary sanctions. 13 The confidentiality obligations imposed by this agreement shall remain in 14 effect until a designating party agrees otherwise in writing or a court orders 15 otherwise. 16 STIPULATED TO, DATED AND RESPECTFULLY SUBMITTED this 16th day of 17 June, 2023. 18 19 20 STIPULATED PROTECTIVE ORDER - 15 Case No. 2:22-cv-00199-TOR By: /s/ Jennifer Rust Murray TERRELL MARSHALL LAW GROUP PLLC Beth E. Terrell, WSBA #26759 Case 2:22-cv-00199-TOR ECF No. 54 1 2 3 4 5 6 7 8 filed 06/20/23 PageID.449 Page 16 of 20 Jennifer Rust Murray, WSBA #36983 936 N. 34th Street, Suite 300 Seattle, WA 98103 bterrell@terrellmarshall.com jmurray@terrellmarshall.com BERGER MONTAGUE PC John G. Albanese* Ivy L. Marsnik* 1229 Tyler Street NE Suite 205 Minneapolis, MN 55413 Tel: 612-594-5997 Fax: 612-584-4470 jalbanese@bm.net imarsnik@bm.net *Admitted Pro Hac Vice 9 Attorneys for Plaintiff 10 11 12 13 14 By: /s/Whitney Anya Cantrell Thompson STOEL RIVES LLP Sara J. Wadsworth, WSBA #55952 600 University Street, Suite 3600 Seattle, WA 98101 Tel: (206) 624-0900 Fax: (206) 386-750 sara.wadsworth@stoel.com 18 JONES DAY Whitney Anya Cantrell Thompson* 555 South Flower St., 50th Floor Los Angeles, CA 90071 Tel: (949) 553-7541 wthompson@jonesday.com *Admitted Pro Hac Vice 19 JONES DAY 15 16 17 20 STIPULATED PROTECTIVE ORDER - 16 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 1 2 filed 06/20/23 PageID.450 Page 17 of 20 Cheryl L. O'Connor 3161 Michelson Drive, Suite 800 Irvine, California 92612-4408 coconnor@jonesday.com 3 4 5 6 7 8 9 Attorneys for Experian Information Solutions, Inc. By: /s/ Savannah M. Loftis SCHUCKIT & ASSOCIATES, P.C. Savannah M. Loftis* 4545 Northwestern Drive Zionsville, IN 46077 Tel: (317) 363-2400, Ext. 140 Fax: (317) 363-2257 sloftis@schuckitlaw.com *Admitted Pro Hac Vice 13 Nicholas Ranallo, (WSBA 51439) SCHUCKIT & ASSOCIATES, P.C. 5058 57th Ave. S Seattle, WA 98118 Tel: 831-607-9299 Fax: 831-533-5073 nick@ranallolawoffice.com 14 Attorneys for Trans Union, LLC 10 11 12 15 16 17 18 19 20 STIPULATED PROTECTIVE ORDER - 17 Case No. 2:22-cv-00199-TOR By: /s/ Gregory N. Blase K&L GATES LLP Peter A. Talevich, WSBA #42644 Raina V. Wagner, WSBA # 45701 925 Fourth Ave., Suite 2900 Seattle, WA 98104-1158 Tel: (206) 623-7580 peter.talevich@klgates.com Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.451 Page 18 of 20 1 raina.wagner@klgates.com 2 6 Andrew C. Glass* Gregory N. Blase* State Street Financial Center One Lincoln Street Boston, MA 02109 (617) 261-3100 andrew.glass@klgates.com gregory.blase@klgates.com *Admitted Pro Hac Vice 7 Attorneys for Wells Fargo Bank, N.A. 3 4 5 8 9 II. ORDER 10 PURSUANT TO STIPULATION, IT IS HEREBY ORDERED. 11 DATED this 20th day of June 2023. 12 13 14 15 16 17 18 19 20 STIPULATED PROTECTIVE ORDER - 18 Case No. 2:22-cv-00199-TOR Thomas O. Rice United States District Judge Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.452 Page 19 of 20 EXHIBIT A 1 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 ___________________________________________________ [print or type full 5 address], declare under penalty of perjury that I have read in its entirety and 6 understand the Protective Order that was issued by the United States District Court 7 for the Eastern District of Washington on _______________ [date] in the case of 8 Rebecca A. Evans v Experian Information Solutions, Inc., et al, Case No. 2:22-cv- 9 00199-TOR. I agree to comply with and to be bound by all the terms of this 10 Protective Order and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is 13 subject to this Protective Order to any person or entity except in strict compliance 14 with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Eastern District of Washington for the purpose of enforcing the terms of this 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. 19 20 STIPULATED PROTECTIVE ORDER - 19 Case No. 2:22-cv-00199-TOR Case 2:22-cv-00199-TOR ECF No. 54 filed 06/20/23 PageID.453 Page 20 of 20 1 I hereby appoint __________________________ [print or type full name] of 2 _______________________________________ [print or type full address and 3 telephone number] as my Washington agent for service of process in connection 4 with this action or any proceedings related to enforcement of this Protective Order. 5 Date: _____________________________________ 6 City and State where sworn and signed: _____________________________ 7 Printed name: _______________________________ 8 Signature: __________________________________ 9 10 11 12 13 14 15 16 17 18 19 20 STIPULATED PROTECTIVE ORDER - 20 Case No. 2:22-cv-00199-TOR

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