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