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Inland Concrete Enterprises, Inc. Employee Stock Ownership Plan v. Kraft Americas

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA


February 25, 2011

INLAND CONCRETE ENTERPRISES, INC. EMPLOYEE STOCK OWNERSHIP PLAN; NICHOLAS L. SAAKVITNE, AS TRUSTEE OF THE INLAND CONCRETE ENTERPRISES, INC. EMPLOYEE STOCK OWNERSHIP PLAN; AND INLAND CONCRETE ENTERPRISES, INC., A CALIFORNIA CORPORATION, PLAINTIFFS,
v.
KRAFT AMERICAS, LP., A LIMITED PARTNERSHIP; RUNE KRAFT, AN INDIVIDUAL; AND DOES 1 THROUGH 5, INCLUSIVE, DEFENDANTS.

The opinion of the court was delivered by: Honorable Oswald Parada

[DISCOVERY MATTER]

ORDER RE

PROTECTIVE ORDER

Action Filed: March 11, 2010 Trial Date: May 24, 2011

The Court having reviewed the Protective Order (the "Protective Order") filed on February 18, 2011 by Plaintiffs Inland Concrete Enterprises, Inc. Employee Stock Ownership Plan and Inland Concrete Enterprises, Inc., a California corporation, and Plaintiff Nicholas L. Saakvitne, as Trustee of the Inland Concrete Enterprises, Inc. Employee Stock Ownership Plan, through their attorneys of record, Michael A. Vanic and Ryan R. Salsig of Reish & Reicher, and good cause appearing therefor:

IT IS ORDERED THAT the terms of the Protective Order as set forth in paragraphs 2 through 14, inclusive, thereof shall be, and hereby are, approved and entered as the Protective Order of the Court and that they shall be, and hereby are, binding upon all of the parties in this action and upon all subsequent signatories to the Acknowledgement Of Receipt Of Protective Order Regarding Confidential Information And Agreement To Be Bound Thereby, in the form attached as Exhibit "A" hereto.

Hon. Oswald Parada United States Magistrate Judge

Exhibit "A"

ACKNOWLEDGEMENT OF RECEIPT OF STIPULATION FOR PROTECTIVE ORDER AND PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION AND AGREEMENT TO BE BOUND THEREBY

I hereby acknowledge receipt of and I have read a copy of Protective Order in the action entitled Inland Concrete Enterprises Inc. Employee Stock Ownership Plan, et al. v. Kraft Americas, LP, etc., et al., United States District Court Case No. CV10 1779 VBF (OPx). I understand that Confidential Information, as that term is defined in the Order, will or may be disclosed to me. I understand that said Confidential Information is being provided to me pursuant to the provisions of the Protective Order. I agree that I will be bound by the provisions of the Protective Order with respect to any Confidential Information provided to me. I agree to abide by the Protective Order and not to reveal or otherwise communicate to anyone or utilize any of the information designated "Confidential" that is disclosed to me except in accordance with the terms of the Protective Order. I also agree to return all Confidential Information to the party who has delivered said Confidential Information to me within the time period set forth in paragraph 7 of the Order. I further understand that if I fail to comply with the terms of the Order, I may be subject to sanctions by the Court, and I hereby consent to personal jurisdiction in the State of California with respect to any matter relating to, or arising out of, the Order.

Executed this day of , 2010 at .

[Name]

20110225

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