Legal Stipulation: KPMG Documents
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Justia.comLegal Stipulation: KPMG Documents
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Justia.com1
2 STIPULATION GOVERNING DOCUMENTS PRODUCED BY KPMG LLP
3 The below-signed parties hereby agree that all records produced by non-party KPMG LLP
4 (“KPMG”) to defendant Nancy R. Heinen in response to the subpoena issued to KPMG dated
5 November 24, 2007, shall be treated in accordance with the provisions of the Stipulated
6 Protective Order that was issued by the United States District Court for the Northern District of
7 California on November 13, 2007 in the case of Securities and Exchange Commission v. Heinen,
8 et al., C-07-2214 (JF). The parties further agree that KPMG shall be the Designating Party under
9 Paragraphs 2.7 and 5 of the Stipulated Protective Order, and that all documents produced will be
10 designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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12 DATED: January 4, 2008 MARC J. FAGEL
ROBERT L. MITCHELL
13 MARK P. FICKES
SAHIL W. DESAI
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By: //s// Mark Fickes
15 Mark P. Fickes
16 Attorneys for Plaintiff
SECURITIES AND EXCHANGE
17 COMMISSION
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DATED: January 4, 2008 MILES EHRLICH
19 ISMAIL RAMSEY
RAMSEY & EHRLICH LLP
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By: //s// Miles Ehrlich
22 Miles Ehrlich
Ismail Ramsey
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Attorneys for Defendant
24 NANCY R. HEINEN
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DATED: January 4, 2008 MARY HUSER
26 STEPHANIE THOMASES
BINGHAM MCCUTCHEN LLP
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STIPULATION GOVERNING KPMG
DOCUMENTS
CASE NO. C-07-2214-JF
1 By: //s// Stephanie Thomases
Mary L. Huser
2 Stephanie Thomases
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4 Attorneys for Non-Party
KPMG
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STIPULATION GOVERNING KPMG
-2- DOCUMENTS
CASE NO. C-07-2214-JF
