# California Surgery Center, Inc. v. Unitedhealthcare, Inc.

> District Court, C.D. California · February 18, 2020

URL: https://www.frixlaw.com/law-library/cases/10037028

## Case

- **Court:** District Court, C.D. California
- **Decided:** February 18, 2020
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

2 cScYhLilVl@IAgr JsOmO.c o (mSBN: 308236)
sjoo@grsm.com
3 GORDON REES SCULLY MANSUKHANI, LLP
633 West Fifth Street, 52nd Floor
4 Los Angeles, CA 90071
Telephone: (213) 576-5000
5 Facsimile: (213) 680-4470
6 Attorneys for Defendants
UNITEDHEALTHCARE, INC. and
7 UNITEDHEALTHCARE INSURANCE COMPANY
8 GARY L. TYSCH (SBN: 128389)
gltysch@pacbell.net
9 LAW OFFICES OF GARY L. TYSCH
16133 Ventura Boulevard, Suite 580
10 Encino, CA 91436
Telephone: (818) 995-9555
11 Facsimile: (818) 995-9550
12 Attorneys for Plaintiffs
CALIFORNIA SURGERY CENTER, INC. and
13 CALIFORNIA SPINE AND PAIN INSTITUTE
14
UNITED STATES DISTRICT COURT
15
CENTRAL DISTRICT OF CALIFORNIA
16
17
CALIFORNIA SURGERY CENTER, ) CASE NO. 2:19-cv-02309-DDP
18 INC. and CALIFORNIA SPINE AND ) (AFMx)
PAIN INSTITUTE, ) District Judge: Hon. Dean D.
19 ) Pregerson
Plaintiff, ) Magistrate Judge: Hon. Alexander F.
20 ) MacKinnon
vs.
)
21
UNITEDHEALTHCARE, INC.; )
22 UNITEDHEALTHCARE INSURANCE ) REVISED STIPULATION AND
COMPANY; and DOES 1-20, inclusive, ) [PROPOSED] PROTECTIVE
23 ) ORDER
Defendants. )
24 )
) DISCOVERY MATTER
25 )
)
26 )
)
27
)
)
28
2 SURGERY CENTER, INC. and CALIFORNIA SPINE AND PAIN INSTITUTE
3 (collectively referred to as “Plaintiffs”) and Defendants UNITEDHEALTHCARE,
4 INC. and UNITEDHEALTHCARE INSURANCE COMPANY (collectively
5 referred to as “UHC”) (Plaintiffs and UHC are together referred to as “the
6 Parties”), by and through their counsel of record, that in order to facilitate the
7 exchange of information and documents which may be subject to confidentiality
8 limitations on disclosure due to federal laws, state laws, and privacy rights, the
9 Parties stipulate as follows:
10 1. In this Stipulation and Protective Order, the words set forth below
11 shall have the following meanings:
12 a. “Proceeding” means the above-entitled proceeding, United
13 States District Court for the Central District of California Case No. 2:19-cv-
14 02309-DDP (AFMx);
15 b. “Court” means District Judge Dean D. Pregerson, Magistrate
16 Judge Alexander F. MacKinnon, or any other Judge to which this Proceeding may
17 be assigned, including Court staff participating in such proceedings.
18 c. “Confidential” means any information which is in the
19 possession of a Designating Party who believes in good faith that such information
20 is entitled to confidential treatment under applicable law, including any patient
21 health information required to be kept confidential under any state or federal law,
22 including 45 C.F.R. Parts 160 and 164 promulgated pursuant to the Health
23 Insurance Portability and Accountability Act of 1996 (see 45 C.F.R. §§ 164.501 &
24 160.103).
25 d. “Confidential Materials” means any Documents, Testimony or
26 Information as defined below designated as “Confidential” pursuant to the
27 provisions of this Stipulation and Protective Order and includes, but is not limited
28 to, materials designated as “Attorney-Eyes Only”.
“Attorney-Eyes Only” means any Confidential Materials which
2 information should not be disclosed to anyone other than a Party’s attorney.
3 f. “Designating Party” means the Party that designates Materials
4 as “Confidential” or “Attorney-Eyes Only”.
5 g. “Disclose” or “Disclosed” or “Disclosure” means to reveal,
6 divulge, give, or make available Materials, or any part thereof, or any information
7 contained therein.
8 h. “Documents” means (i) any “Writing,” “Original,” and
9 “Duplicate” as those terms are defined by California Evidence Code Sections 250,
10 255, and 260, which have been produced in discovery in this Proceeding by any
11 person, and (ii) any copies, reproductions, or summaries of all or any part of the
12 foregoing.
13 i. “Information” means the content of Documents or Testimony.
14 j. “Testimony” means all depositions, declarations or other
15 testimony taken or used in this Proceeding.
16 2. The Designating Party shall have the right to designate as
17 “Confidential” any Documents, Testimony or Information that the Designating
18 Party in good faith believes to contain non-public information that is entitled to
19 confidential treatment under applicable law.
20 3. The Designating Party shall have the right to designate as “Attorney-
21 Eyes Only” any Confidential Materials that the Designating Party in good faith
22 believes to contain non-public information that is entitled to confidential treatment
23 under applicable law and that which should not be seen by any person other than a
24 Party’s attorney.
25 4. The entry of this Stipulation and Protective Order does not alter,
26 waive, modify, or abridge any right, privilege or protection otherwise available to
27 any Party with respect to the discovery of matters, including but not limited to any
28 Party’s right to assert the attorney-client privilege, the attorney work product
doctrine, or other privileges, or any Party’s right to contest any such assertion.
2 “Confidential” or “Attorney-Eyes Only” must be clearly so designated before the
3 Document, Testimony or Information is Disclosed or produced. The parties may
4 agree that the case name and number are to be part of the “Confidential” or
5 “Attorney-Eyes Only” designation. The “Confidential” or “Attorney-Eyes Only”
6 designation should not obscure or interfere with the legibility of the designated
7 Information.
8 a. For Documents (apart from transcripts of depositions or other
9 pretrial or trial proceedings), the Designating Party must affix the legend
10 “Confidential” and/or redact or obscure all confidential information on each page
11 of any Document containing such designated Confidential Material.
12 b. For Testimony given in depositions the Designating Party may
13 either:
14 i. identify on the record, before the close of the deposition,
15 as “Confidential” Testimony, by specifying all portions of the
16 Testimony that qualify as “Confidential;” or
17 ii. designate the entirety of the Testimony at the deposition
18 as “Confidential” (before the deposition is concluded) with the right
19 to identify more specific portions of the Testimony as to which
20 protection is sought within 30 days following receipt of the
21 deposition transcript. In circumstances where portions of the
22 deposition Testimony are designated for protection, the transcript
23 pages containing “Confidential” Information may be separately
24 bound by the court reporter, who must affix to the top of each page
25 the legend “Confidential,” as instructed by the Designating Party.
26 c. For Information produced in some form other than
27 Documents, and for any other tangible items, including, without limitation,
28 compact discs or DVDs, the Designating Party must affix in a prominent place on
the exterior of the container or containers in which the Information or item is
2 the Information or item warrant protection, the Designating Party, to the extent
3 practicable, shall identify the “Confidential” or “Attorney-Eyes Only” portions.
4 6. The inadvertent production by any of the undersigned Parties or non-
5 Parties to the Proceedings of any Document, Testimony or Information during
6 discovery in this Proceeding without a “Confidential” or “Attorney-Eyes Only”
7 designation, shall be without prejudice to any claim that such item is
8 “Confidential” or “Attorney-Eyes Only” and such Party shall not be held to have
9 waived any rights by such inadvertent production. In the event that any Document,
10 Testimony or Information that is subject to a “Confidential” or “Attorney-Eyes
11 Only” designation is inadvertently produced without such designation, the Party
12 that inadvertently produced the document shall give written notice of such
13 inadvertent production within twenty (20) days of discovery of the inadvertent
14 production, together with a further copy of the subject Document, Testimony or
15 Information designated as “Confidential” or “Attorney-Eyes Only” (the
16 “Inadvertent Production Notice”). Upon receipt of such Inadvertent Production
17 Notice, the Party that received the inadvertently produced Document, Testimony or
18 Information shall promptly destroy the inadvertently produced Document,
19 Testimony or Information and all copies thereof, or, at the expense of the
20 producing Party, return such together with all copies of such Document, Testimony
21 or Information to counsel for the producing Party and shall retain only the
22 “Confidential” or “Attorney-Eyes Only” designated Materials. Should the
23 receiving Party choose to destroy such inadvertently produced Document,
24 Testimony or Information, the receiving Party shall notify the producing Party in
25 writing of such destruction within ten (10) days of receipt of written notice of the
26 inadvertent production. This provision is not intended to apply to any inadvertent
27 production of any Information protected by attorney-client or work product
28 privileges. In the event that this provision conflicts with any applicable law
regarding waiver of confidentiality through the inadvertent production of
2 7. In the event that counsel for a Party receiving Documents, Testimony
3 or Information in discovery designated as “Confidential” or “Attorney-Eyes Only”
4 objects to such designation with respect to any or all of such items, said counsel
5 shall advise counsel for the Designating Party, in writing, of such objections, the
6 specific Documents, Testimony or Information to which each objection pertains,
7 and the specific reasons and support for such objections (the “Designation
8 Objections”). Counsel for the Designating Party shall have thirty (30) days from
9 receipt of the written Designation Objections to either (a) agree in writing to de-
10 designate Documents, Testimony or Information pursuant to any or all of the
11 Designation Objections and/or (b) file a motion with the Court seeking to uphold
12 any or all designations on Documents, Testimony or Information addressed by the
13 Designation Objections (the “Designation Motion”). Pending a resolution of the
14 Designation Motion by the Court, any and all existing designations on the
15 Documents, Testimony or Information at issue in such Motion shall remain in
16 place. The Designating Party shall have the burden on any Designation Motion of
17 establishing the applicability of its “Confidential” or “Attorney-Eyes Only”
18 designation. In the event that the Designation Objections are neither timely agreed
19 to nor timely addressed in the Designation Motion, then such Documents,
20 Testimony or Information shall be de-designated in accordance with the
21 Designation Objection applicable to such material.
22 8. Access to and/or Disclosure of Confidential Materials designated as
23 “Confidential” shall be permitted only to the following persons:
24 a. the Court;
25 b. (1) Attorneys of record in the Proceedings and their affiliated
26 attorneys, paralegals, clerical and secretarial staff employed by such attorneys who
27 are actively involved in the Proceedings and are not employees of any Party. (2)
28 In-house counsel to the undersigned Parties and the paralegal, clerical and
secretarial staff employed by such counsel. Provided, however, that each non-
2 are being Disclosed pursuant to, and are subject to, the terms of this Stipulation
3 and Protective Order and that they may not be Disclosed other than pursuant to its
4 terms;
5 c. those officers, directors, partners, members, employees and
6 agents of all non-designating Parties that counsel for such Parties deems necessary
7 to aid counsel in the prosecution and defense of this Proceeding; provided,
8 however, that prior to the Disclosure of Confidential Materials to any such officer,
9 director, partner, member, employee or agent, counsel for the Party making the
10 Disclosure shall deliver a copy of this Stipulation and Protective Order to such
11 person, shall explain that such person is bound to follow the terms of such Order,
12 and shall secure the signature of such person on a statement in the form attached
13 hereto as Exhibit A;
14 d. court reporters in this Proceeding (whether at depositions,
15 hearings, or any other proceeding);
16 e. any deposition, trial or hearing witness in the Proceeding who
17 previously has had access to the Confidential Materials, or who is currently or was
18 previously an officer, director, partner, member, employee or agent of an entity
19 that has had access to the Confidential Materials;
20 f. any deposition or non-trial hearing witness in the Proceeding
21 who previously did not have access to the Confidential Materials; provided,
22 however, that each such witness given access to Confidential Materials shall be
23 advised that such Materials are being Disclosed pursuant to, and are subject to, the
24 terms of this Stipulation and Protective Order and that they may not be Disclosed
25 other than pursuant to its terms;
26 g. mock jury participants, provided, however, that prior to the
27 Disclosure of Confidential Materials to any such mock jury participant, counsel for
28 the Party making the Disclosure shall deliver a copy of this Stipulation and
Protective Order to such person, shall explain that such person is bound to follow
2 statement in the form attached hereto as Exhibit A;
3 h. outside experts or expert consultants consulted by the
4 undersigned Parties or their counsel in connection with the Proceeding, whether or
5 not retained to testify at any oral hearing; provided, however, that prior to the
6 Disclosure of Confidential Materials to any such expert or expert consultant,
7 counsel for the Party making the Disclosure shall deliver a copy of this Stipulation
8 and Protective Order to such person, shall explain its terms to such person, and
9 shall secure the signature of such person on a statement in the form attached hereto
10 as Exhibit A. It shall be the obligation of counsel, upon learning of any breach or
11 threatened breach of this Stipulation and Protective Order by any such expert or
12 expert consultant, to promptly notify counsel for the Designating Party of such
13 breach or threatened breach;
14 i. third party witnesses whether or not they will testify at any oral
15 hearing; provided, however, that prior to the Disclosure of Confidential Materials
16 to any such third party witness, counsel for the Party making the Disclosure shall
17 deliver a copy of this Stipulation and Protective Order to such person, shall explain
18 its terms to such person, and shall secure the signature of such person on a
19 statement in the form attached hereto as Exhibit A; and
20 j. any other person that the Designating Party agrees to in writing.
21 9. Access to and/or Disclosure of Confidential Materials designated as
22 “Attorney-Eyes Only” shall be permitted only to the following persons:
23 (1) Attorneys of record in the Proceedings and their affiliated
24 attorneys, paralegals, clerical and secretarial staff employed by such
25 attorneys who are actively involved in the Proceedings and are not
26 employees of any Party.
27 (2) In-house counsel to the undersigned Parties and the paralegal,
28 clerical and secretarial staff employed by such counsel. Provided,
however, that each non-lawyer given access to Confidential Materials
2 and are subject to, the terms of this Stipulation and Protective Order
3 and that they may not be Disclosed other than pursuant to its terms.
4 10. Confidential Materials shall be used by the persons receiving them
5 only for the purposes of preparing for, conducting, participating in the conduct of,
6 and/or prosecuting and/or defending the Proceeding, and not for any business or
7 other purpose whatsoever.
8 11. Any Party to the Proceeding (or other person subject to the terms of
9 this Stipulation and Protective Order) may ask the Court, after appropriate notice to
10 the other Parties to the Proceeding, to modify or grant relief from any provision of
11 this Stipulation and Protective Order.
12 12. Entering into, agreeing to, and/or complying with the terms of this
13 Stipulation and Protective Order shall not:
14 a. operate as an admission by any person that any particular
15 Document, Testimony or Information marked “Confidential” or “Attorney-Eyes
16 Only” contains or reflects trade secrets, proprietary, confidential or competitively
17 sensitive business, commercial, financial or personal information; or
18 b. prejudice in any way the right of any Party (or any other
19 person subject to the terms of this Stipulation and Protective Order):
20 i. to seek a determination by the Court of whether any
21 particular Confidential Material should be subject to protection as
22 “Confidential” or “Attorney-Eyes Only” under the terms of this
23 Stipulation and Protective Order; or
24 ii. to seek relief from the Court on appropriate notice to all
25 other Parties to the Proceeding from any provision(s) of this
26 Stipulation and Protective Order, either generally or as to any
27 particular Document, Material or Information.
28 / /
/ /
2 Protective Order as of the time it is presented to the Court for signature may
3 thereafter become a Party to this Stipulation and Protective Order by its counsel’s
4 signing and dating a copy thereof and filing the same with the Court, and serving
5 copies of such signed and dated copy upon the other Parties to this Stipulation and
6 Protective Order.
7 14. Any Information that may be produced by a non-Party witness in
8 discovery in the Proceeding pursuant to subpoena or otherwise may be designated
9 by such non-Party as “Confidential” or “Attorney-Eyes Only” under the terms of
10 this Stipulation and Protective Order, and any such designation by a non-Party
11 shall have the same force and effect, and create the same duties and obligations, as
12 if made by one of the undersigned Parties hereto. Any such designation shall also
13 function as a consent by such producing Party to the authority of the Court in the
14 Proceeding to resolve and conclusively determine any motion or other application
15 made by any person or Party with respect to such designation, or any other matter
16 otherwise arising under this Stipulation and Protective Order.
17 15. If any person subject to this Stipulation and Protective Order who has
18 custody of any Confidential Materials receives a subpoena or other process
19 (“Subpoena”) from any government or other person or entity demanding
20 production of Confidential Materials, the recipient of the Subpoena shall promptly
21 give notice of the same by electronic mail transmission, followed by either express
22 mail or overnight delivery to counsel of record for the Designating Party, and shall
23 furnish such counsel with a copy of the Subpoena. Upon receipt of this notice, the
24 Designating Party may, in its sole discretion and at its own cost, move to quash or
25 limit the Subpoena, otherwise oppose production of the Confidential Materials,
26 and/or seek to obtain confidential treatment of such Confidential Materials from
27 the subpoenaing person or entity to the fullest extent available under law. The
28 recipient of the Subpoena may not produce any Documents, Testimony or
Information pursuant to the Subpoena prior to the date specified for production on
2 16. Nothing in this Stipulation and Protective Order shall be construed to
3 preclude either Party from asserting in good faith that certain Confidential
4 Materials require additional protection. The Parties shall meet and confer to agree
5 upon the terms of such additional protection.
6 17. If, after execution of this Stipulation and Protective Order, any
7 Confidential Materials submitted by a Designating Party under the terms of this
8 Stipulation and Protective Order is Disclosed by a non-Designating Party to any
9 person other than in the manner authorized by this Stipulation and Protective
10 Order, the non-Designating Party responsible for the Disclosure shall bring all
11 pertinent facts relating to the Disclosure of such Confidential Materials to the
12 immediate attention of the Designating Party.
13 18. This Stipulation and Protective Order is entered into without prejudice
14 to the right of any Party to knowingly waive the applicability of this Stipulation
15 and Protective Order to any Confidential Materials designated by that Party. If the
16 Designating Party uses Confidential Materials in a non-Confidential manner, then
17 the Designating Party shall advise that the designation no longer applies.
18 19. The Parties shall meet and confer regarding the procedures for use of
19 Confidential Materials during the Proceeding and shall seek the entry of an
20 appropriate order, if necessary.
21 20. Nothing in this Stipulation and Protective Order shall affect the
22 admissibility into evidence of Confidential Materials, or abridge the rights of any
23 person to seek judicial review or to pursue other appropriate judicial action with
24 respect to any ruling made by the Court concerning the issue of the status of
25 Protected Material.
26 21. This Stipulation and Protective Order shall continue to be binding
27 after the conclusion of this Proceeding and all subsequent proceedings arising from
28 this Proceeding, except that a Party may seek the written permission of the
Designating Party or may move the Court for relief from the provisions of this
2 retain jurisdiction to enforce, modify, or reconsider this Stipulation and Protective
3 Order, even after the Proceeding is terminated.
4 22. Upon written request made within thirty (30) days after the settlement
5 or other termination of the Proceeding, the undersigned Parties shall have thirty
6 (30) days to either (a) promptly return to counsel for each Designating Party all
7 Confidential Materials and all copies thereof (except that counsel for each Party
8 may maintain in its files, in continuing compliance with the terms of this
9 Stipulation and Protective Order, all work product, and one copy of each pleading
10 filed with the Court [and one copy of each deposition together with the exhibits
11 marked at the deposition)]*, (b) agree with counsel for the Designating Party upon
12 appropriate methods and certification of destruction or other disposition of such
13 Confidential Materials, or (c) as to any Documents, Testimony or other
14 Information not addressed by sub-paragraphs (a) and (b), file a motion seeking a
15 Court order regarding proper preservation of such Materials. To the extent
16 permitted by law the Court shall retain continuing jurisdiction to review and rule
17 upon the motion referred to in sub-paragraph (c) herein. *[The bracketed portion of
18 this provision shall be subject to agreement between counsel for the Parties in each
19 case.]
20 23. After this Stipulation and Protective Order has been signed by counsel
21 for all Parties, it shall be presented to the Court for entry. Counsel agree to be
22 bound by the terms set forth herein with regard to any Confidential Materials that
23 have been produced before the Court signs this Stipulation and Protective Order.
24 24. The Parties and all signatories to the Certification attached hereto as
25 Exhibit A agree to be bound by this Stipulation and Protective Order pending its
26 approval and entry by the Court. In the event that the Court modifies this
27 Stipulation and Protective Order, or in the event that the Court enters a different
28 Protective Order, the Parties agree to be bound by this Stipulation and Protective
Order until such time as the Court may enter such a different Order. It is the
2 pending its entry so as to allow for immediate production of Confidential Materials
3 under the terms herein.
4 25. The Court may only enter a protective order upon a showing of good
5 cause. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th
6 Cir. 2006). Here, good cause exists for the entry of a protective order because the
7 information in this matter contained in the Documents involves patient personal
8 health information, which is protected by the Health Insurance Portability and
9 Accountability Act (HIPAA) and the right to privacy. A protective order is
10 therefore necessary to ensure the confidential information is protected.
11 26. This Stipulation and Protective Order does not govern the use of
12 confidential information at trial. Use of confidential information at trial shall be
13 governed by orders of the trial judge.
14 27. Under Seal Filings: Parties shall make every effort to limit the number
15 and volume of under seal filings. In most circumstances, parties should seek to file
16 under seal only the specific portions or exhibits or documents for which there is a
17 valid basis for filing under seal. Requests to file memoranda of points and
18 authorities under seal are disfavored. Pursuant to Local Rule 79-5.2.2, except in
19 sealed civil cases, “no document may be filed under seal without prior approval by
20 the Court.” When seeking the Court’s approval for an under-seal filing, the
21 submitting party shall comply with the procedures established in Local Rule 79-
22 5.2.2(a). Because documents filed under seal are only visible on CM/ECF or Pacer
23 to Court personnel and the party that filed the document, a party electronically
24 filing a document under seal may not rely on the Court’s CM/ECF System to effect
25 service as provided in Local Rule 5-3.2.1. Therefore, documents filed
26 electronically under seal must be served in accordance with Federal Rule of Civil
27 Procedure 5.
28 / /
/ /
1 This Stipulation and Protective Order may be executed in counterparts.
2 ||Dated: February 4, 2020 GORDON REES SCULLY
3 MANSUKHANI, LLP

4 By: Sylvia Joo
5 Courtney C. Hill
Sylvia Joo
6 Attorneys for Defendants
4 UNITEDHEALTHCARE, INC.
and UNITEDHEALTHCARE
8 INSURANCE COMPANY
9 ||Dated: February 4, 2020 LAW OFFICES OF GARY L. TYSCH
10
ul By: /4s/Gary L. Tysch
Gary L. Tysch
12 Attorney for Plaintiffs
CALIFORNIA SURGERY
= 13 CENTER, INC. AND
CALIFORNIA SPINE AND PAIN
14 INSTITUTE
15 || Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures, I,
16 || Sylvia Joo, hereby attest that all other signatories listed concur in the content of

2 17 || this document and have authorized its filing.

18
/s/ Sylvia Joo
19 ylvia Joo
20 ORDER
21 GOOD CAUSE APPEARING, the Court hereby approves this Stipulation
22 || and Protective Order.
23 IT IS SO ORDERED. °
24
25 || Dated: 2/18/2020
Alexander F. MacKinnon
26 United States Magistrate Judge
27
28

1A.

2 EXHIBIT A
3 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS
4 I hereby acknowledge that I, ____________[NAME],
5 ___________________ [POSITION AND EMPLOYER], am about to receive
6 Confidential Materials supplied in connection with the Proceeding, Central District
7 of California Case No. 2:19-cv-02309-DDP (AFMx). I certify that I understand
8 that the Confidential Materials are provided to me subject to the terms and restrict-
9 ions of the Stipulation and Protective Order filed in this Proceeding. I have been
10 given a copy of the Stipulation and Protective Order; I have read it, and I agree to
11 be bound by its terms. I understand that Confidential Materials, as defined in the
12 Stipulation and Protective Order, including any notes or other records that may be
13 made regarding any such materials, shall not be Disclosed to anyone except as
14 expressly permitted by the Stipulation and Protective Order. I will not copy or use,
15 except solely for the purposes of this Proceeding, any Confidential Materials
16 obtained pursuant to this Protective Order, except as provided therein or otherwise
17 ordered by the Court in the Proceeding. I further understand that I am to retain all
18 copies of all Confidential Materials provided to me in the Proceeding in a secure
19 manner, and that all copies of such Materials are to remain in my personal custody
20 until termination of my participation in this Proceeding, whereupon the copies of
21 such Materials will be returned to counsel who provided me with such Materials.
22 I declare under penalty of perjury, under the laws of the United States of
23 America that the foregoing is true and correct. Executed this _____ day of
24 _________, 20__, at _________________.
25 DATED: BY:
Signature
26
Title
27
Address -City, State, Zip
28
Telephone Number

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10037028. Public record. Not legal advice.