Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 1 of 18
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`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
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`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
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`Plaintiffs,
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`C.A. No. 19-859-RTH
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`v.
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`THE UNITED STATES OF AMERICA,
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`Defendant.
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`PROTECTIVE ORDER
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`The Court enters the following protective order pursuant to Rule 26(c)(1) of the Rules of
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`the United States Court of Federal Claims (“RCFC”).
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`1.
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`Findings: The Court finds that the parties to this case and third parties may request
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`or produce information involving trade secrets or confidential research and development or
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`commercial information, the disclosure of which is likely to cause harm to the party producing
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`such information.
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`2.
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`Definitions:
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`a.
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`“Party” means any named party to this Action, including all of its
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`employees, consultants, retained experts, and outside counsel and their support staffs.
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`Additionally, for Plaintiff, “Party” includes all of its officers and directors.
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`b.
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`“Producer” means any Party or Third Party that discloses or produces any
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`discovery material in this Action.
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`c.
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`“Recipient” means any Party who receives a Producer’s discovery material
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`in this case.
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`d.
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`“Third Party” means a person, organization or entity who is not a Plaintiff
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 2 of 18
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`or Defendant in this Action.
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`e.
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`“Litigation Support Contractor” means a contractor who is (a) subject to an
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`obligation, either by contract or trade practice, to maintain the confidentiality of any material
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`received in performance of the contracted services; (b) engaged in the business of providing
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`litigation support services; and (c) retained to provide support service with respect to either a
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`lawyer’s general professional activities or specifically in support of the lawyer’s activities in this
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`case. By way of example and not limitation, “litigation support contractor” includes copying
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`services, court reporters, videographers, document storage and management contractors, database
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`management contractors, and information technology and network support contractors. The parties
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`acknowledge that a Recipient may engage or employ contract attorneys, paralegals, or legal
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`administrative personnel who may fall within the definition of Litigation Support Contractor.
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`f.
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`“Confidential Information” means information that contains or reflects
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`confidential, proprietary, and/or commercially sensitive information.
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`g.
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`“Highly Confidential Information” means confidential information that is
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`so sensitive
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`that
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`its dissemination deserves even further
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`limitation beyond
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`that of
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`CONFIDENTIAL information. The Parties agree that the following information, if non-public,
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`shall be presumed to merit the “HIGHLY CONFIDENTIAL” designation: trade secrets, pricing
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`information, financial data, sales information, sales or marketing forecasts or plans, business plans,
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`sales or marketing strategy, product development information, engineering documents, testing
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`documents, employee information, and other non-public information of similar competitive and
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`business sensitivity.
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`h.
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`“Source Code” means Highly Confidential Information that contains or
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`substantially discloses computer or source code, machine language, scripts, assembly, binaries,
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`object code, source code listings and descriptions of source code, object code listings and
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 3 of 18
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`descriptions of object code, Hardware Description Language (HDL) or Register Transfer Level
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`(RTL) files or other similar files that describe the hardware design of any ASIC or other chip, and
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`Computer Aided Design (CAD) or other similar files that describe the hardware design of any
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`component.
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`i.
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`Information is not Confidential, Highly Confidential, or Source Code if it is
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`known or available to the public, was known to the Recipient without obligation of confidentiality
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`before the Producer disclosed it, or is or becomes known to the Recipient by means not constituting
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`a breach of this Order. Information is likewise not Confidential, Highly Confidential or Source
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`Code if a Recipient lawfully obtained it, without restriction as to its further dissemination by such
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`Recipient, independently of this litigation.
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`3.
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`Designation of Information as Confidential, Highly Confidential or Source Code:
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`a.
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`A Producer’s designation of
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`information as Confidential, Highly
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`Confidential, or Source Code means that the Producer believes in good faith, upon reasonable
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`inquiry, that the information qualifies as such.
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`b.
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`A Producer designates information in a document or thing as Confidential
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`by clearly and prominently marking it on its face as “CONFIDENTIAL” (which shall include, at
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`the Producer’s option, adding the word “Confidential” (or an appropriate abbreviation thereof) to
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`the file name of any natively produced computer file).
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`c.
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`A Producer designates information in a document or thing as “Highly
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`Confidential” by clearly and prominently marking it on its face as “HIGHLY CONFIDENTIAL”
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`(which shall include, at the Producer’s option, adding the words “Highly Confidential” (or an
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`appropriate abbreviation thereof) to the file name of any natively produced computer file).
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`d.
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`A Producer designates information in a document or thing as “Source Code”
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`by clearly and prominently marking it on its face as “HIGHLY CONFIDENTIAL – SOURCE
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`CODE” (which shall include, at the Producer’s option, adding the words “Highly Confidential –
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`Source Code” (or an appropriate abbreviation thereof) to the file name of any natively produced
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`computer file).
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`e.
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`A Producer may make documents or things containing Confidential, Highly
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`Confidential, or Source Code information available for inspection and copying without marking
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`them as such without forfeiting a claim of confidentiality, so long as the Producer causes copies
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`of the documents or things to be marked as Confidential, Highly Confidential, or Source Code
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`before providing them to the Recipient.
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`f.
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`A Producer designates information in deposition testimony as Confidential,
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`Highly Confidential, or Source Code by stating on the record at the deposition that the information
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`is Confidential, Highly Confidential, or Source Code, or by advising the Recipients, Parties, and
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`the stenographer and videographer in writing, within fourteen (14) days after receipt of the non-
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`rough deposition transcript, that the information is Confidential, Highly Confidential, or Source
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`Code. Until a Producer makes a designation pursuant to this paragraph, or the expiration of the
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`fourteen (14)-day period described herein, whichever occurs earlier, deposition testimony shall be
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`treated as Highly Confidential.
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`g.
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`Notwithstanding the foregoing, a Producer’s failure to designate a
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`document, thing, or testimony as Confidential, Highly Confidential, or Source Code neither (i)
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`waives any right hereunder, upon realizing such failure, to later promptly so designate such
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`document, thing, or testimony, nor (ii) constitutes forfeiture of a claim of confidentiality as to any
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`other document, thing, or testimony.
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`h.
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`A Producer who has designated information as Confidential, Highly
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`Confidential, or Source Code may withdraw the designation by written notification to all
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`Recipients.
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`i.
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`If a Recipient disputes a Producer’s designation of information as
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`Confidential, Highly Confidential or Source Code, the Recipient shall notify the Producer in
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`writing of the basis for the dispute, identifying the specific documents or things as to which the
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`designation is disputed and proposing a new or lack of designation for such materials. The
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`Recipient and the Producer shall then meet and confer to attempt to resolve the dispute without
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`involvement of the Court. In conferring, the Recipient must explain the basis for its belief that the
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`confidentiality designation was not proper and must give the Producer an opportunity to review
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`the designated material, to reconsider the designation, and, if no change in designation is offered,
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`to explain the basis for the designation. A Recipient that elects to challenge a confidentiality
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`designation may file and serve a motion that identifies the challenged materials and sets forth in
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`detail the bases for the challenge. Each such motion must be accompanied by a competent
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`declaration that affirms that the movant has complied with the meet and confer requirement of this
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`procedure. The burden of persuasion in any such challenge shall be on the Producer. Until the
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`Court rules on the challenge, all parties shall continue to treat the materials as Confidential
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`Information, Highly Confidential Information, or Source Code under the terms of this Order.
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`4.
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`Use and Disclosure of Confidential, Highly Confidential, or Source Code
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`Information:
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`a.
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`Confidential, Highly Confidential, and Source Code information may be
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`used exclusively for purposes of this litigation, subject to the restrictions of this Order.
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`b.
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`Absent written permission from the Producer or further order by the Court,
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`the Recipient may not disclose information designated as Confidential other than to the
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`following:
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`i. a Recipient’s outside counsel of record,1 including paralegal, secretarial,
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`and clerical personnel assisting such counsel, and Litigation Support
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`Contractors whether employed to assist outside counsel generally or
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`specifically with respect to this case;
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`ii. a Recipient’s in-house counsel,2 including paralegal, secretarial, and clerical
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`personnel assisting such counsel, and Litigation Support Contractors
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`whether employed to assist in-house counsel generally or specifically with
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`respect to this case;
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`iii. Up to a maximum of three (3) employees of Recipient’s directly involved
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`in this case whose access to the information is reasonably required to
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`supervise, manage, or participate in this case and additionally officers and
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`directors of Plaintiffs’;
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`iv. a witness at deposition and/or trial that is an employee of the Producing
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`Party, that is an expert or consultant retained by the Producing Party, or that
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`the Producing Party has called or designated (excluding a witness that is
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`hostile to the Producing Party and to whom the provisions of this Order
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`1 For purposes of this Order, attorneys of the Department of Justice shall be considered “outside
`counsel of record” for the United States. Additionally, attorneys, paralegals and staff at law firms
`retained by accused agencies who have agreed to be bound by this Protective Order and provided a
`signed undertaking (Appendix 1) to Plaintiff’s counsel shall also be considered outside counsel of
`record.
`2 For purposes of this Order, Defendant’s in-house counsel are attorneys of the Securities and
`Exchange Commission (“SEC”) and any other agency or department of the United States involved
`in this litigation.
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 7 of 18
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`v.
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`do not otherwise permit disclosure), provided that such witnesses may not
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`retain copies of such designated information unless permitted by other
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`provisions of this Order;
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`vi. v. With respect to a particular document, an individual who is shown on the
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`face of the document to have been an author, source, or recipient of the
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`document, provided that such witnesses may not retain copies of the
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`designated document unless permitted by other provisions of this Order;
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`vii. a stenographer and videographer recording testimony concerning the
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`information;
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`viii. subject to the provisions of paragraph 4(e) of this Order, experts,
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`consultants, and their staff whom a Recipient retains for purposes of this
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`ix.
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`x.
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`litigation only;
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`the Court and personnel assisting the Court; and
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`any mediator who is assigned to hear this matter, and his or her staff, subject
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`to their agreement to maintain confidentiality to the same degree as required
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`by this Order.
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`c.
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`Absent written permission from the Producer or further order by the Court,
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`the Recipient may not disclose information designated as Highly Confidential other than to the
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`following: those identified in paragraph 4(b)(i), (ii) (so long as such disclosure is limited to a
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`maximum of four (4) in-house counsel who are directly involved in supervising and managing this
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`litigation), and 4(b)(iv)-(ix).
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`d.
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`Absent written permission from the Producer or further order by the Court,
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`and subject to the terms and conditions set forth in herein, the Recipient may not disclose
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 8 of 18
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`information designated as Source Code other to than to the following: those identified in paragraph
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`4(b)(i), and (v)-(viii).
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`e.
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`The Recipient may not disclose Confidential, Highly Confidential, or
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`Source Code information to an expert or consultant pursuant to paragraphs 4(b)-(d) of this Order
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`until after the expert or consultant has signed an undertaking in the form of Appendix 1 to this
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`Order. The Recipient obtaining the undertaking must serve it on the Producer and all Parties within
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`ten business days (10) after its execution. At least ten (10) business days before the first disclosure
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`of Confidential, Highly Confidential, or Source Code information to an expert or consultant (or
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`member of their staff), the Recipient proposing to make the disclosure must serve the Producer
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`with written identification of the expert or consultant and a copy of his or her curriculum vitae and
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`a list of all matters in which the expert or consultant has testified, been deposed, or consulted
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`within the last five (5) years. If the Producer has good cause to object to the disclosure (which does
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`not include challenging the qualifications of the expert or consultant), it must serve the Recipient
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`proposing to make the disclosure with a written objection within ten (10) business days after
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`service of the identification. If the Recipient and Producer fail resolve the dispute within ten (10)
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`business days after service of the objection, the Producer may thereafter within five (5) business
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`days move the Court for a ruling on its objection to the disclosure of designated information to the
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`expert or consultant. If the Producer so moves, the Recipient may not disclose the Confidential,
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`Highly Confidential, or Source Code information to the expert or consultant without the Court’s
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`approval. However, if the Producer fails to so move, then the Recipient may disclose the
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`Confidential, Highly Confidential, or Source Code information to the expert or consultant.
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`f.
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`Notwithstanding paragraph 4(a)-(d), a Recipient may disclose a document
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`or source code designated Confidential, Highly Confidential, or Source Code information to any
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`Party or Third Party who lawfully received the designated information before this case was filed.
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`g.
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`A Recipient who wishes to disclose Confidential, Highly Confidential, or
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`Source Code information to an entity or person not authorized under paragraphs 4(b)-(d) must first
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`make a reasonable attempt to obtain the Producer’s permission. If the Recipient is unable to obtain
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`permission, it may move the Court to obtain permission.
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`5.
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`Special considerations for Source Code information:
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`a.
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`Source Code information produced by any Party or Third Party is to be
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`made available for inspection in electronic form and maintained on a computer at the offices of
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`outside/inside counsel for the Producer or at such other place agreed to in writing by the Producer.
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`b.
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`Each computer on which Source Code information is made available for
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`inspection by a Party or Third Party shall be known as a “Source Code Computer.”
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`c.
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`Each Source Code Computer must (i) at all times during the pendency of
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`this case be a stand-alone, non-networked, password-protected computer terminal, (ii) be disabled
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`from having external storage devices attached to it, and (iii) maintain Source Code information in
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`encrypted format when the Source Code information is not being inspected.
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`d.
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`Access to a Source Code Computer shall be limited to three (3) outside
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`counsel representing the Recipient and four (4) experts or consultants retained by the Recipient for
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`the purpose of this litigation and approved to access such designated materials pursuant to
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`paragraph 4(e) above. A maximum of three (3) individuals may be physically present for an
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`inspection of a Source Code Computer at any one time. The Recipient must provide reasonable
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`notice to the Producer that it wishes to inspect a Source Code Computer. At the time of providing
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`notice, the Recipient must identify the individual(s) who will be inspect the Source Code
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`Computer. The Recipient shall restrict its request for access to a Source Code Computer to normal
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`business hours, which for purposes of this section shall be on Monday – Friday from 9:00 am to
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 10 of 18
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`5:00 pm. However, upon reasonable notice from the Recipient, the Producer shall make reasonable
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`efforts to accommodate the Recipient’s request for access to a Source Code Computer outside of
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`normal business hours, though the Producer is not under any obligation to do so.
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`e.
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`The Producer shall provide the Recipient with information explaining how
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`to start, log on to, and operate a Source Code Computer in order to inspect the produced Source
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`Code. The Recipient shall be entitled to a specific identification (e.g., by name, version number,
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`and date of release) of the Source Code being made available for inspection, if reasonably
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`available. If specific identification is not reasonably available at such time, the Producer shall
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`provide notice to the Recipient that specific identification is not reasonably available and explain
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`the reason(s) why specific identification is not reasonably available.
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`f.
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`The Recipient may opt to have source code analysis and/or emulator tools
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`loaded onto the Source Code Computer to facilitate its review. If the Recipient so opts, it must
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`provide a copy of the software program to the Producer at least seven (7) business days prior to
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`the first date on which it wishes to utilize that software program during a scheduled inspection of
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`a Source Code Computer. The Producer may object to the use of any tool provided by the Recipient
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`pursuant to this paragraph, but must do so by notifying the Recipient of its objections and the
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`reasons for its objections at least five (5) business days before the scheduled inspection of a Source
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`Code Computer. The parties shall endeavor to resolve any dispute regarding tools to be loaded
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`onto the Source Code Computer within seven (7) business days of any objection being made by
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`the Producer. If the parties cannot resolve the dispute within such time, the Recipient may petition
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`the Court for resolution of the matter. The burden shall be on the Producer to show that the software
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`program in question will present a risk to the integrity of the Source Code Computer or the
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`confidentiality of the Source Code information. At the termination of the litigation as set forth in
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`Section 14, below, any source code analysis and/or emulator tools loaded onto a Source Code
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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 11 of 18
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`Computer pursuant to this paragraph shall be removed by the Recipient or its outside counsel. The
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`Producer or its outside counsel may at its election be present for such removal.
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`g.
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`The Recipient will not copy, remove, or otherwise transfer any Source Code
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`from a Source Code Computer including, without limitation, copying, removing, or transferring
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`the Source Code onto any recordable media or recordable device. The Recipient will not transmit
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`any Source Code information in any way from the room containing a Source Code Computer. No
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`copies of any portion of the Source Code may leave the room in which the Source Code is inspected
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`except as herein provided. The Recipient may take notes regarding the content of the Source Code
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`information, so long as such note taking does not constitute transcription of more than fifty (50)
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`consecutive lines of Source Code. By the end of each inspection day, Recipient is responsible for
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`removing all notes and other Recipient work product and confidential materials from the room in
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`which the Source Code is inspected. No expectation of confidentiality or privilege shall attach to
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`Recipient materials left in the room in which the Source Code is inspected after the end of the
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`inspection day. In addition, the Recipient may request from the Producer printed copies of limited
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`portions of the Source Code believed to be reasonably necessary for the preparation of court filings,
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`pleadings, expert reports or other papers or for deposition or trial. Only one (1) printed copy of each
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`consecutive block of Source Code will be provided. The Recipient shall not request the printing of
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`Source Code in order to review blocks of Source Code elsewhere in the first instance, i.e., as an
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`alternative to reviewing that Source Code electronically on the Source Code Computer. Such
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`printouts will be made on paper containing Bates numbers and the designation ‘HIGHLY
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`CONFIDENTIAL – SOURCE CODE.” If the Producer objects that the printed portions are
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`excessive (e.g., greater than 400 printed pages) and/or not reasonably necessary to any case
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`preparation activity, the Producer shall make such objection known to the Recipient within seven
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`(7) business days of the Recipient’s request for printed copies. If, after meeting and conferring, the
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`Producer and the Recipient cannot resolve the objection within seven (7) business days, the
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`Recipient shall be entitled to seek a Court resolution of whether the printed source code in question
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`is narrowly tailored and reasonably necessary to any case preparation activity as provided herein.
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`The burden shall be on the Recipient to demonstrate that such printed portions are narrowly tailored
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`and no more than is reasonably necessary for a permitted purpose and not merely printed for the
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`purposes of review and analysis elsewhere. In the absence of any objection, or upon resolution of
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`any such dispute by the Court, the Producer shall provide one (1) copy set of such pages to the
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`Recipient within five (5) business days.
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`h.
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`The Recipient may not make any copies of any printouts containing Source
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`Code information provided pursuant to this paragraph, except that the Recipient may make one (1)
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`copy for each technical expert or consultant who has signed the undertaking under paragraph 4(e)
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`of this order, and may make one (1) additional copy for outside counsel (such that outside counsel
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`may have a total of two (2) copies), so long as the total number of copies of any portion of the
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`Source Code does not exceed five (5). The Recipient may only provide printed copies of Source
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`Code to individuals authorized to view Source Code information under paragraph 4(d). The
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`Recipient must keep a log of anyone who has reviewed or taken custody of any printed copy of
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`Source Code provided pursuant to this paragraph. The log shall include the names of the reviewers
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`and/or recipients of paper copies and locations where the paper copies are stored. Any printouts
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`obtained pursuant to sub-paragraph (i) above must be kept in a secure, locked area in the offices
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`of outside counsel or expert or consultant retained by Recipient and authorized to view Source
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`Code information pursuant to paragraph 4(d) above.
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`i.
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`Excepting laptop computers, no recording devices, recordable media, or
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`other electronic devices (including but not limited to sound recorders, cellular telephones,
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`peripheral equipment, cameras, CDs, DVDs, floppy drives, zip drives, thumb drives, USB memory
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`sticks, portable hard drives, BlackBerry® devices, iPhone® devices, Dictaphones, or telephone
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`jacks) will be permitted inside the room in which Source Code is subject to inspection.
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`Notwithstanding the foregoing, Recipient shall not use any laptop computer to record or store
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`images or copies of Source Code except to the extent expressly permitted herein for notetaking.
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`j.
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`A Recipient shall omit Source Code information in any form from pleadings
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`whenever possible, and when not possible, shall petition the Court, pursuant to Paragraph 7 below,
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`for permission to file such document under seal.
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`6.
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`Non-Waiver of Privileged or Work Product Material. Pursuant to Fed. R. Evid.
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`502(d), the production of a privileged or work-product-protected document in this case, whether
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`inadvertent or otherwise, is not a waiver of privilege or protection from discovery in this case or in
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`any other federal or state proceeding. For example, the mere production of privileged or work-
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`product-protected documents in this case along with non-privileged or non-work-product-
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`protected documents shall not function as a waiver of any privilege or work-product protections in
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`this case or in any other federal or state proceeding. The factors listed in Fed. R. Evid. 502(b) shall
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`not control or contribute to any part of any analysis related to the return of materials subject to a
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`claim of privilege, work-product or any other protection. The proper procedure for the notification
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`and return of privileged or protected information produced in this matter is governed by RCFC
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`26(b)(5)(B).
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`7.
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`Filing with the Court: This Order pre-authorizes the filing under seal of any
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`document containing Confidential, Highly Confidential, or Source Code information. Leave of
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`court is not required for any such document to be filed under seal. If a Party files a document under
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`seal, it must also (unless excused by the Court) file within ten (10) business days a public- record
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`version that excludes or redacts any Confidential, Highly Confidential, or Source Code information
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`after consulting with any relevant Producer.
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`8.
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`Document Disposal: Within thirty (30) days of final termination of this Action, each
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`Recipient must return to the Producer all documents and copies of documents containing the
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`Producer’s Confidential, Highly Confidential, or Source Code information, and must destroy all
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`notes, memoranda, or other materials derived from or in any way revealing Confidential, Highly
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`Confidential, or Source Code. Alternatively, if the Producer agrees, the Recipient may destroy all
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`documents and copies of documents containing the Producer’s Confidential, Highly Confidential,
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`or Source Code information. The Recipient returning and/or destroying the Producer’s
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`Confidential, Highly Confidential, or Source Code information must promptly certify in writing
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`its compliance with the requirements of this paragraph. Notwithstanding the requirements of this
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`paragraph, (i) a Party and its outside counsel may each retain one complete set of all documents
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`filed with the Court, and may retain more than one complete set when required by federal law or
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`regulation; and (ii) outside counsel for each Party may retain one (1) copy of all work product,
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`whether or not derived from a Producer’s Confidential, Highly Confidential, or Source Code
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`information. Any retained copies shall remain subject to all requirements of this Order.
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`9.
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`Originals: A legible photocopy of a document may be used as the “original” for all
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`purposes in this action. The actual “original,” in whatever form the Producer has it, must be made
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`available for inspection at an agreed location and time to a Recipient of the legible photocopy
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`within ten (10) business days after a reasonable written request.
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`10.
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`Producer’s Use of its Own Information. Nothing in this Order shall limit any
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`Producer’s use of its own information or prevent a Producer from disclosing its own information
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`to any person.
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`11.
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`Survival of obligations: This Order’s obligations regarding Confidential, Highly
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`Confidential, and Source Code information survive the conclusion of this case.
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`12.
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`Further modifications: Any party may move the court for a modification of this
`-14-
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`

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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 15 of 18
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`Protective Order and nothing in this Protective Order will be construed to prevent a party from
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`seeking such further provisions enhancing or limiting access to documents as may be appropriate.
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`IT IS SO ORDERED.
`
`s/ Ryan T. Holte
`RYAN T. HOLTE
`Judge
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`-15-
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`

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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 16 of 18
`Case 1:19—cv-00859—RTH Document 41 Filed 12/23/20 Page 16 of 18
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`APPENDIX 1
`APPENDIX 1
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`-16-
`-16-
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`

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`Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 17 of 18
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`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
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`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
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`Plaintiffs,
`
`C.A. No. 19-859-RTH
`
`v.
`
`THE UNITED STATES OF AMERICA,
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`Defendant.
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`UNDERTAKING OF __________________________
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`I, ____________________, state the following under penalties of perjury as provided by
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`law:
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`I have been retained by ____________________ as an expert or consultant in connection
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`with this case. I will be receiving [Confidential, Highly Confidential, and/or Source Code]
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`information that is covered by the Court’s protective order dated _______________. I have read
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`the Court’s protective order and understand that the [Confidential, Highly Confidential, and/or
`
`Source Code] information is provided pursuant to the terms and conditions in that Order.
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`I agree to be bound by the Court’s Protective Order. I agree to use the [Confidential, Highly
`
`Confidential, and/or Source Code] information solely for purposes of this case and in accord with
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`the terms and conditions of the Court’s Protective Order.
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`I agree to return the [Confidential, Highly Confidential, and/or Source Code] information
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`and any notes concerning that information to the attorney for ________________ or to destroy the
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`information and any notes upon that attorney’s request.
`
`-17-
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`

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`
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`Case 1:19-cv-00859-RTH Document 39-2 Filed 12/21/20 Page 3 of 3Case 1:19-cv-00859-RTH Document 41 Filed 12/23/20 Page 18 of 18
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`I submit to the jurisdiction of the Court that issued the Protective Order for purposes of
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`enforcing that Order. I give up any objections I might have to that Court’s jurisdiction over me or
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`the propriety of venue in that Court.
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`Dated: ___________________
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`___________________________________
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`-18-
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`