distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record
Written by the judges who cited it.
The opinion
1 STEPTOE & JOHNSON LLP
ANTHONY J. ANSCOMBE (135883)
2
aanscombe@steptoe.com
3 1 Market Plaza, Suite 3900 Spear Tower
4 San Francisco, CA 94105
Telephone: (415) 365-6700
5
Facsimile: (415) 365-6699
6
STEPTOE & JOHNSON LLP
7
MELANIE A. AYERH (303211)
8 mayerh@steptoe.com
9 MARY BETH BUCKLEY (pro hac vice)
mbuckley@Steptoe.com
10 633 West Fifth Street, Suite 1900
11 Los Angeles, CA 90071-3033
Telephone: (213) 439-9400
12
Facsimile: (213) 439-9599
13
Counsel for Defendants,
14
C.B. FLEET COMPANY, INC., and
15 PRESTIGE CONSUMER HEALTHCARE, INC.
16
17 UNITED STATES DISTRICT COURT
18 CENTRAL DISTRICT OF CALIFORNIA
19 ALLYSON ALLCOTT and MICHELE Case No.: 8:19-cv-01744 JVS (ADSx)
PAYLOR, individually and on behalf of Judge: James V. Selna
20
all other similarly situated, Magistrate Judge: Autumn D. Spaeth
21
Plaintiffs, CLASS ACTION
22
vs.
23 O PRR OD TE ER C R TE IV: S ET OIP RU DL EA RT ED
24 C.B. FLEET COMPANY, INC., a
Virginia corporation and PRESTIGE [DISCOVERY DOCUMENT:
25 CONSUMER HEALTHCARE, INC., a REFERRED TO MAGISTRATE
26 Delaware corporation; and DOES 1-10, JUDGE AUTUMN D. SPAETH]
inclusive,
27
Defendants.
28
1 Based on the Parties’ stipulation and good cause appearing, the Court
2 hereby ENTERS the Protective Order as set forth below:
3 I. PURPOSES AND LIMITATIONS
4 A. Discovery in this action is likely to involve production of confidential,
5 proprietary, or private information for which special protection from public
6 disclosure and from use for any purpose other than prosecuting this litigation may
7 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
8 enter the following Stipulated Protective Order. The parties acknowledge that this
9 Order does not confer blanket protections on all disclosures or responses to
10 discovery and that the protection it affords from public disclosure and use extends
11 only to the limited information or items that are entitled to confidential treatment
12 under the applicable legal principles. The parties further acknowledge, as set forth
13 in Section XIII(C), below, that this Stipulated Protective Order does not entitle them
14 to file confidential information under seal; Civil Local Rule 79-5 sets forth the
15 procedures that must be followed and the standards that will be applied when a party
16 seeks permission from the Court to file material under seal.
17 II. GOOD CAUSE STATEMENT
18 A. This action is likely to involve trade secrets and other valuable research,
19 development, commercial, financial, technical and/or proprietary information for
20 which special protection from public disclosure and from use for any purpose other
21 than prosecution of this action is warranted. Such confidential and proprietary
22 materials and information consist of, among other things, proprietary product
23 formulations, confidential research and development, confidential and proprietary
24 product, ingredient or consumer tests, studies or surveys, confidential and
25 proprietary company policies and procedures, confidential and proprietary financial
26 information, confidential and proprietary vendor or supplier relationships, non-
27 public, personally-identifying information relating to putative class members,
28 confidential and personally sensitive information of Plaintiff, including but not
1 limited to information relating to Plaintiff’s personal health and hygiene practices,
2 and other , information otherwise generally unavailable to the public, or which may
3 be privileged or otherwise protected from disclosure under state or federal statutes,
4 court rules, case decisions, or common law. Accordingly, to expedite the flow of
5 information, to facilitate the prompt resolution of disputes over confidentiality of
6 discovery materials, to adequately protect information the parties are entitled to keep
7 confidential, to ensure that the parties are permitted reasonable necessary uses of
8 such material in preparation for and in the conduct of trial, to address their handling
9 at the end of the litigation, and serve the ends of justice, a protective order for such
10 information is justified in this matter. It is the intent of the parties that information
11 will not be designated as confidential for tactical reasons and that nothing be so
12 designated without a good faith belief that it has been maintained in a confidential,
13 non-public manner, and there is good cause why it should not be part of the public
14 record of this case.
15 III. DEFINITIONS
16 A. Action: This pending federal lawsuit.
17 B. Challenging Party: A Party or Non-Party that challenges the
18 designation of information or items under this Order.
19 C. “CONFIDENTIAL” Information or Items: Information (regardless of
20 how it is generated, stored or maintained) or tangible things that qualify for
21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
22 the Good Cause Statement D. Counsel: Outside Counsel of Record and House
23 Counsel (as well as their support staff).
24 E. Designating Party: A Party or Non-Party that designates information
25 or items that it produces in disclosures or in responses to discovery as
26 “CONFIDENTIAL.”
27 F. Disclosure or Discovery Material: All items or information, regardless
28 of the medium or manner in which it is generated, stored, or maintained (including,
1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery in this matter.
3 G. Expert: A person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6 H. HIGHLY CONFIDENTIAL: Information (regardless of how it is
7 generated, stored or maintained) or tangible things that concern specifics about
8 product formulations, prospective product research and development, or confidential
9 vendor or supplier relationships that would prejudice the Producing Party in its
10 ongoing or reasonably prospective business relationships including the specific
11 percentages of ingredients used, trade secret formulas provided by third party
12 suppliers, and pricing negotiated with third party suppliers of ingredients.
13 I. House Counsel: Attorneys who are employees of a party to this Action.
14 House Counsel does not include Outside Counsel of Record or any other outside
15 counsel.
16 J. Non-Party: Any natural person, partnership, corporation, association,
17 or other legal entity not named as a Party to this action.
18 K. Outside Counsel of Record: Attorneys who are not employees of a
19 party to this Action but are retained to represent or advise a party to this Action and
20 have appeared in this Action on behalf of that party or are affiliated with a law firm
21 which has appeared on behalf of that party, and includes support staff.
22 L. Party: Any party to this Action, including all of its officers, directors,
23 employees, consultants, retained experts, and Outside Counsel of Record (and their
24 support staffs).
25 M. Producing Party: A Party or Non-Party that produces Disclosure or
26 Discovery Material in this Action.
27 N. Professional Vendors: Persons or entities that provide litigation
28 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
1 demonstrations, and organizing, storing, or retrieving data in any form or medium)
2 and their employees and subcontractors.
3 O. Protected Material: Any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL”.
5 P. Receiving Party: A Party that receives Disclosure or Discovery
6 Material from a Producing Party.
7 IV. SCOPE
8 A. The protections conferred by this Stipulation and Order cover not only
9 Protected Material (as defined above), but also (1) any information copied or
10 extracted from Protected Material; (2) all copies, excerpts, summaries, or
11 compilations of Protected Material; and (3) any testimony, conversations, or
12 presentations by Parties or their Counsel that might reveal Protected Material.
13 B. Any use of Protected Material at trial shall be governed by the orders
14 of the trial judge. This Order does not govern the use of Protected Material at trial.
15 V. DURATION
16 Once a case proceeds to trial, all of the information that was designated as
17 confidential or maintained pursuant to this Protective Order becomes public and will
18 be presumptively available to all members of the public, including the press, unless
19 compelling reasons supported by specific factual findings to proceed otherwise are
20 made to the trial judge in advance of the trial. See Kamakana v. City and County of
21 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
22 showing for sealing documents produced in discovery from “compelling reasons”
23 standard when merits-related documents are part of court record). Accordingly, the
24 terms of this Protective Order do not extend beyond the commencement of the trial.
25
26 VI. DESIGNATING PROTECTED MATERIAL
27 A. Exercise of Restraint and Care in Designating Material for Protection
28
1 1. Each Party or Non-Party that designates information or items for
2 protection under this Order must take care to limit any such designation to specific
3 material that qualifies under the appropriate standards. The Designating Party must
4 designate for protection only those parts of material, documents, items, or oral or
5 written communications that qualify so that other portions of the material,
6 documents, items, or communications for which protection is not warranted are not
7 swept unjustifiably within the ambit of this Order.
8 2. Mass, indiscriminate, or routinized designations are prohibited.
9 Designations that are shown to be clearly unjustified or that have been made for an
10 improper purpose (e.g., to unnecessarily encumber the case development process or
11 to impose unnecessary expenses and burdens on other parties) may expose the
12 Designating Party to sanctions.
13 3. If it comes to a Designating Party’s attention that information or
14 items that it designated for protection do not qualify for protection, that Designating
15 Party must promptly notify all other Parties that it is withdrawing the inapplicable
16 designation.
17 B. Manner and Timing of Designations
18 1. Except as otherwise provided in this Order (see, e.g., Section
19 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery
20 Material that qualifies for protection under this Order must be clearly so designated
21 before the material is disclosed or produced.
22 2. Designation in conformity with this Order requires the
23 following:
24 a. For information in documentary form (e.g., paper or
25 electronic documents, but excluding transcripts of depositions or other pretrial or
26 trial proceedings), that the Producing Party affix at a minimum, the legend
27 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” to each page that contains
28 Protected Material. If only a portion or portions of the material on a page qualifies
1 for protection, the Producing Party also must clearly identify the protected portion(s)
2 (e.g., by making appropriate markings in the margins).
3 b. A Party or Non-Party that makes original documents
4 available for inspection need not designate them for protection until after the
5 inspecting Party has indicated which documents it would like copied and produced.
6 During the inspection and before the designation, all of the material made available
7 for inspection shall be deemed “HIGHLY CONFIDENTIAL.” After the inspecting
8 Party has identified the documents it wants copied and produced, the Producing
9 Party must determine which documents, or portions thereof, qualify for protection
10 under this Order. Then, before producing the specified documents, the Producing
11 Party must affix the “CONFIDENTIAL or “HIGHLY CONFIDENTIAL” legend,
12 as appropriate, to each page that contains Protected Material. If only a portion or
13 portions of the material on a page qualifies for protection, the Producing Party also
14 must clearly identify the protected portion(s) (e.g., by making appropriate markings
15 in the margins).
16 c. For testimony given in depositions, that the Designating
17 Party identify the Disclosure or Discovery Material on the record, before the close
18 of the deposition all protected testimony.
19 d. For information produced in form other than document
20 and for any other tangible items, that the Producing Party affix in a prominent place
21 on the exterior of the container or containers in which the information is stored the
22 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion or
23 portions of the information warrants protection, the Producing Party, to the extent
24 practicable, shall identify the protected portion(s).
25 C. Inadvertent Failure to Designate
26 1. If timely corrected, an inadvertent failure to designate qualified
27 information or items does not, standing alone, waive the Designating Party’s right
28 to secure protection under this Order for such material. Upon timely correction of a
1 designation, the Receiving Party must make reasonable efforts to assure that the
2 material is treated in accordance with the provisions of this Order.
3 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 A. Timing of Challenges
5 1. Any party or Non-Party may challenge a designation of
6 confidentiality at any time that is consistent with the Court’s Scheduling Order.
7 B. Meet and Confer
8 1. The Challenging Party shall initiate the dispute resolution
9 process under Local Rule 37.1 et seq.
10 C. The burden of persuasion in any such challenge proceeding shall be on
11 the Designating Party. Frivolous challenges, and those made for an improper
12 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
13 parties) may expose the Challenging Party to sanctions. Unless the Designating
14 Party has waived or withdrawn the confidentiality designation, all parties shall
15 continue to afford the material in question the level of protection to which it is
16 entitled under the Producing Party’s designation until the Court rules on the
17 challenge.
18 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
19 A. Basic Principles
20 1. A Receiving Party may use Protected Material that is disclosed
21 or produced by another Party or by a Non-Party in connection with this Action only
22 for prosecuting, defending, or attempting to settle this Action. Such Protected
23 Material may be disclosed only to the categories of persons and under the conditions
24 described in this Order. When the Action has been terminated, a Receiving Party
25 must comply with the provisions of Section XIV below.
26 2. Protected Material must be stored and maintained by a Receiving
27 Party at a location and in a secure manner that ensures that access is limited to the
28 persons authorized under this Order.
1 B. Disclosure of “CONFIDENTIAL” Information or Items:
2 1. Unless otherwise ordered by the Court or permitted in writing by
3 the Designating Party, material designated as “CONFIDENTIAL” may be disclosed
4 only to:
5 a. The Receiving Party;
6 b. The Receiving Party’s Outside Counsel of Record in this
7 Action, as well as employees of said Outside Counsel of Record to whom it is
8 reasonably necessary to disclose the information for this Action;
9 c. The officers, directors, and employees (including House
10 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this
11 Action;
12 d. Experts (as defined in this Order) of the Receiving Party
13 to whom disclosure is reasonably necessary for this Action and who have signed the
14 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 e. The Court and its personnel;
16 f. Court reporters and their staff;
17 g. Professional jury or trial consultants, mock jurors, and
18 Professional Vendors to whom disclosure is reasonably necessary or this Action and
19 who have signed the “Acknowledgment and Agreement to be Bound” attached as
20 Exhibit A hereto;
21 h. The author or recipient of a document containing the
22 information or a custodian or other person who otherwise possessed or knew the
23 information;
24 i. During their depositions, witnesses, and attorneys for
25 witnesses, in the Action to whom disclosure is reasonably necessary provided: (i)
26 the deposing party requests that the witness sign the “Acknowledgment and
27 Agreement to Be Bound;” and (ii) they will not be permitted to keep any confidential
28 information unless they sign the “Acknowledgment and Agreement to Be Bound,”
1 unless otherwise agreed by the Designating Party or ordered by the Court. Pages of
2 transcribed deposition testimony or exhibits to depositions that reveal Protected
3 Material may be separately bound by the court reporter and may not be disclosed to
4 anyone except as permitted under this Stipulated Protective Order;
5 j. Any mediator or settlement officer, and their supporting
6 personnel, mutually agreed upon by any of the parties engaged in settlement
7 discussions; and
8 k. Any person as may be designated by written agreement of
9 the Designating Party.
10 C. Disclosure of “HIGHLY CONFIDENTIAL” Information or Items:
11 1. Unless otherwise ordered by the Court or permitted in writing by
12 the Designating Party, material designated as “HIGHLY CONFIDENTIAL” may be
13 disclosed only to:
14 a. The Receiving Party’s Outside Counsel of Record in this
15 Action, as well as employees of said Outside Counsel of Record to whom it is
16 reasonably necessary to disclose the information for this Action;
17 b. The officers, directors, and employees (including House
18 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this
19 Action;
20 c. Experts (as defined in this Order) of the Receiving Party
21 to whom disclosure is reasonably necessary for this Action and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 d. The Court and its personnel;
24 e. Professional Vendors to whom disclosure is reasonably
25 necessary or this Action and who have signed the “Acknowledgment and Agreement
26 to be Bound” attached as Exhibit A hereto;
27
28
1 f. The author or recipient of a document containing the
2 information or a custodian or other person who otherwise possessed or knew the
3 information; and
4 g. Any person as may be designated by written agreement of
5 the Designating Party.
6 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED
7 PRODUCED IN OTHER LITIGATION
8 A. If a Party is served with a subpoena or a court order issued in other
9 litigation that compels disclosure of any information or items designated in this
10 Action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL”, that Party must:
11 1. Promptly notify in writing the Designating Party. Such
12 notification shall include a copy of the subpoena or court order;
13 2. Promptly notify in writing the party who caused the subpoena or
14 order to issue in the other litigation that some or all of the material covered by the
15 subpoena or order is subject to this Protective Order. Such notification shall include
16 a copy of this Stipulated Protective Order; and
17 3. Cooperate with respect to all reasonable procedures sought to be
18 pursued by the Designating Party whose Protected Material may be affected.
19 B. If the Designating Party timely seeks a protective order, the Party
20 served with the subpoena or court order shall not produce any information
21 designated in this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL”
22 before a determination by the Court from which the subpoena or order issued, unless
23 the Party has obtained the Designating Party’s permission. The Designating Party
24 shall bear the burden and expense of seeking protection in that court of its
25 confidential material and nothing in these provisions should be construed as
26 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
27 directive from another court.
28
1 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 A. The terms of this Order are applicable to information produced by a
4 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
5 CONFIDENTIAL.” Such information produced by Non-Parties in connection with
6 this litigation is protected by the remedies and relief provided by this Order. Nothing
7 in these provisions should be construed as prohibiting a Non-Party from seeking
8 additional protections.
9 B. In the event that a Party is required, by a valid discovery request, to
10 produce a Non-Party’s confidential information in its possession, and the Party is
11 subject to an agreement with the Non-Party not to produce the Non-Party’s
12 confidential information, then the Party shall:
13 1. Promptly notify in writing the Requesting Party and the Non-
14 Party that some or all of the information requested is subject to a confidentiality
15 agreement with a Non-Party;
16 2. Promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s), and a reasonably
18 specific description of the information requested; and
19 3. Make the information requested available for inspection by the
20 Non-Party, if requested.
21 C. If the Non-Party fails to seek a protective order from this court within
22 14 days of receiving the notice and accompanying information, the Receiving Party
23 may produce the Non-Party’s confidential information responsive to the discovery
24 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
25 not produce any information in its possession or control that is subject to the
26 confidentiality agreement with the Non-Party before a determination by the court.
27 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
28 of seeking protection in this court of its Protected Material.
1 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 A. If a Receiving Party learns that, by inadvertence or otherwise, it has
3 disclosed Protected Material to any person or in any circumstance not authorized
4 under this Stipulated Protective Order, the Receiving Party must immediately (1)
5 notify in writing the Designating Party of the unauthorized disclosures, (2) use its
6 best efforts to retrieve all unauthorized copies of the Protected Material, (3) inform
7 the person or persons to whom unauthorized disclosures were made of all the terms
8 of this Order, and (4) request such person or persons to execute the
9 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit
10 A.
11 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 A. When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as
19 the parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the Stipulated Protective Order submitted
22 to the Court.
23 XIII. MISCELLANEOUS
24 A. Right to Further Relief
25 1. Nothing in this Order abridges the right of any person to seek its
26 modification by the Court in the future.
27 B. Right to Assert Other Objections
28
1 1. By stipulating to the entry of this Protective Order, no Party
2 waives any right it otherwise would have to object to disclosing or producing any
3 information or item on any ground not addressed in this Stipulated Protective Order.
4 Similarly, no Party waives any right to object on any ground to use in evidence of
5 any of the material covered by this Protective Order.
6 C. Filing Protected Material
7 1. A Party that seeks to file under seal any Protected Material must
8 comply with Civil Local Rule 79-5. Protected Material may only be filed under seal
9 pursuant to a court order authorizing the sealing of the specific Protected Material at
10 issue. If a Party's request to file Protected Material under seal is denied by the Court,
11 then the Receiving Party may file the information in the public record unless
12 otherwise instructed by the Court.
13 XIV. FINAL DISPOSITION
14 A. After the final disposition of this Action, as defined in Section V, within
15 sixty (60) days of a written request by the Designating Party, each Receiving Party
16 must return all Protected Material to the Producing Party or destroy, at the option of
17 the Receiving Party, such material. As used in this subdivision, “all Protected
18 Material” includes all copies, abstracts, compilations, summaries, and any other
19 format reproducing or capturing any of the Protected Material. Whether the
20 Protected Material is returned or destroyed, the Receiving Party must submit a
21 written certification to the Producing Party (and, if not the same person or entity, to
22 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
23 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
24 that the Receiving Party has not retained any copies, abstracts, compilations,
25 summaries or any other format reproducing or capturing any of the Protected
26 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
27 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
28 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
1 work product, and consultant and expert work product, even if such materials contain
2 Protected Material. Any such archival copies that contain or constitute Protected
3 Material remain subject to this Protective Order as set forth in Section V.
4 B. Any violation of this Order may be punished by any and all appropriate
5 measures including, without limitation, contempt proceedings and/or monetary
6 sanctions.
7
8 IT IS SO ORDERED.
9
10
11 DATED: February 11, 2020
_____/_s_/ _A_u_t_u_m_n_ _D_._ S_p_a_e_t_h_____________
12 HONORABLE AUTUMN D. SPAETH
13 UNITED STATES MAGISTRATE JUDGE
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28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, [print or type full name], of
5 [print or type full address], declare under penalty of perjury that I have
6 read in its entirety and understand the Stipulated Protective Order that was issue by
7 the United States District Court for the Central District of California on [DATE] in
8 the case of [insert formal name of the case and the
9 number and initials assigned to it by the Court]. I agree to comply with and to be
10 bound by all the terms of this Stipulated Protective Order and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and punishment
12 in the nature of contempt. I solemnly promise that I will not disclose in any manner
13 any information or item that is subject to this Stipulated Protective Order to any
14 person or entity except in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint [print or
19 type full name] of [print or type full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date:
24 City and State where sworn and signed:
25 Printed Name:
26 Signature:
27
28