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Geoffrey Pecover and andrew Owens, On Behalf of v. Licensing Company In In Re Ncaa Student-Athlete Name

February 16, 2012

GEOFFREY PECOVER AND ANDREW OWENS, ON BEHALF OF THEMSELVES AND A CLASS OF 20 PERSON SIMILARLY SITUATED, PLAINTIFFS,
v.
LICENSING COMPANY IN IN RE NCAA STUDENT-ATHLETE NAME & ELECTRONIC ARTS INC., A DELAWARE LIKENESS LICENSING LITIGATION CORPORATION,
DEFENDANT.



The opinion of the court was delivered by: Honorable Bernard Zimmerman United States Magistrate Judge

Shana E. Scarlett (217895) HAGENS BERMAN SOBOL SHAPIRO LLP 715 Hearst Avenue, Suite 202 Berkeley, CA 94710 Telephone: (510) 725-3000 Facsimile: (510) 725-3001 shanas@hbsslaw.com Stuart M. Paynter (226147) THE PAYNTER LAW FIRM PLLC 1200 G Street N.W., Suite 800 Washington, DC 20005 Telephone: (202) 626-4486 Facsimile: (866) 734-0622 stuart@smplegal.com Steve W. Berman (Pro Hac Vice) HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 Seattle, WA 98101 Telephone: (206) 623-7292 Facsimile: (206) 623-0594 steve@hbsslaw.com Class Counsel

STIPULATION AND [PROPOSED] ORDER RE PRODUCTION OF DOCUMENTS BY COLLEGIATE

ACTION FILED: June 5, 2008

(NC)(the "NCAA action"); 4

5 requesting production of documents to the Collegiate Licensing Company; 6 7 Plaintiffs in the Pecover litigation; 9 and produce documents in the Pecover litigation; 11

WHEREAS the Collegiate Licensing Company is a defendant in the related action, In re NCAA Student-Athlete Name & Likeness Licensing Litigation, Case No. 4:09-cv-1967 CW 3 WHEREAS Plaintiffs in Pecover v. Electronic Arts Inc. have issued a number of subpoenas WHEREAS the subject matter of the documents produced in In re NCAA Student-Athlete Name & Likeness Licensing Litigation overlap to some extent with the document requests by 8 WHEREAS rather than requiring third party Collegiate Licensing Company to re-review 1. It is hereby stipulated by and between the Plaintiffs and third-party Collegiate Licensing Company in this action that all documents produced by Collegiate Licensing Company 13 in the In re NCAA Student-Athlete Name & Likeness Licensing Litigation, Case No. 4:09-cv-1967 14 CW (NC) will be deemed produced in the Pecover litigation and may be used in that litigation as if 15 produced in that litigation. This stipulation is conditioned on Plaintiffs entering into a stipulation 16 with all other parties to the Pecover action, including Electronic Arts, to supplement the Protective 17

Order, to allow CLC's materials produced in the NCAA action to be subject to the same 19 protections and confidentiality designations as apply in the NCAA action. A copy of the proposed 20

Stipulation and Proposed Order re Confidentiality of CLC Documents and Materials is attached 21 hereto as Exhibit 1. 22

Order in the Pecover action, and the Court entering an order supplementing the Pecover Protective 18

2. Plaintiffs and CLC agree that any confidentiality designation made in In re NCAA Student-Athlete Name & Likeness Licensing Litigation, Case No. 4:09-cv-1967 CW (NC) shall be 24 deemed made in the Pecover litigation. 25 26 treated as CONFIDENTIAL in accordance with the Protective Order entered in the Pecover 27 litigation. Such materials will be deemed produced in the Pecover litigation without any further 28 3. Any materials designated by CLC as CONFIDENTIAL in the NCAA case will be supplementation of the Pecover Protective Order or stipulation among the parties in Pecover. 2

4. Plaintiffs and CLC further agree that any CLC materials produced in NCAA action and designated as COUNSEL ONLY will not be deemed to be produced in Pecover unless and 4 until the Court supplements the Pecover Protective Order, pursuant to the proposed Stipulation 5 attached as Exhibit 1, to afford these materials the same protections in the Pecover action as they 6 are afforded in the NCAA action. 7

IT IS SO STIPULATED

IT IS SO ORDERED.

CERTIFICATE OF SERVICE

I hereby certify that on February 16, 2012, I electronically filed the foregoing document

3 using the CM/ECF system which will send notification of such filing to the e-mail addresses 4 registered in the CM/ECF system, as denoted on the Electronic Mail Notice List, and I hereby 5 certify that I have mailed a paper copy of the foregoing document via the United States Postal 6

Service to the non-CM/ECF participants indicated on the Manual Notice List generated by the 7

CM/ECF system. 8

/s/ Shana E. Scarlett

SHANA E. SCARLETT

EXHIBIT 1

Shana E. Scarlett (217895) HAGENS BERMAN SOBOL SHAPIRO LLP 2 715 Hearst Avenue, Suite 202 Berkeley, CA 94710 3 Telephone: (510) 725-3000 Facsimile: (510) 725-3001 4 shanas@hbsslaw.com 5 Stuart M. Paynter (226147) THE PAYNTER LAW FIRM PLLC 6 1200 G Street N.W., Suite 800 7 Washington, DC 20005 Telephone: (202) 626-4486 8 Facsimile: (866) 734-0622 stuart@smplegal.com 9 Steve W. Berman (Pro Hac Vice) 10 HAGENS BERMAN SOBOL SHAPIRO LLP 11 1918 Eighth Avenue, Suite ...


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