distinguishing “good cause” 12 showing for sealing documents produced in discovery from “compelling reasons” 13 standard when merits-related documents are part of court record
How later courts described this case
- distinguishing “good cause” 12 showing for sealing documents produced in discovery from “compelling reasons” 13 standard when merits-related documents are part of court record
- even stipulated protective orders 10 require good cause showing
Written by the judges who cited it.
The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
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11 Case No. 2:20-cv-05677-DMG-GJS
FABIAN ARROYO, an individual
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Plaintiff, STIPULATED PROTECTIVE
13 ORDER
v.
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DODGE CORPORATION; FCA US
15 LLC, a Delaware Limited Liability
Corporation; and DOES 1-50,
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Defendant.
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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order.1 The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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1 only to the limited information or items that are entitled to confidential treatment
2 under the applicable legal principles.
3 B. GOOD CAUSE STATEMENT
4 This action is likely to involve trade secrets, customer and pricing lists and
5 other valuable research, development, commercial, financial, technical and/or
6 proprietary information for which special protection from public disclosure and
7 from use for any purpose other than prosecution of this action is warranted. Such
8 confidential and proprietary materials and information consist of, among other
9 things, confidential business or financial information, competitively sensitive
10 information, information regarding confidential business practices, or other
11 confidential research, development, or commercial information (including
12 information implicating privacy rights of third parties), private or confidential
13 personal information, information otherwise generally unavailable to the public, or
14 which may be privileged or otherwise protected from disclosure under state or
15 federal statutes, court rules, case decisions, or common law. Accordingly, to
16 expedite the flow of information, to facilitate the prompt resolution of disputes over
17 confidentiality of discovery materials, to adequately protect information the parties
18 are entitled to keep confidential, to ensure that the parties are permitted reasonable
19 necessary uses of such material in preparation for and in the conduct of trial, to
20 address their handling at the end of the litigation, and serve the ends of justice, a
21 protective order for such information is justified in this matter. It is the intent of the
22 parties that information will not be designated as confidential for tactical reasons
23 and that nothing be so designated without a good faith belief that it has been
24 maintained in a confidential, non-public manner, and there is good cause why it
25 should not be part of the public record of this case.
26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
27 The parties further acknowledge, as set forth in Section 12.3, below, that this
1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
2 and the standards that will be applied when a party seeks permission from the court
3 to file material under seal.
4 There is a strong presumption that the public has a right of access to judicial
5 proceedings and records in civil cases. In connection with non-dispositive motions,
6 good cause must be shown to support a filing under seal. See Kamakana v. City and
7 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
8 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
9 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
10 require good cause showing), and a specific showing of good cause or compelling
11 reasons with proper evidentiary support and legal justification, must be made with
12 respect to Protected Material that a party seeks to file under seal. The parties’ mere
13 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
14 without the submission of competent evidence by declaration, establishing that the
15 material sought to be filed under seal qualifies as confidential, privileged, or
16 otherwise protectable—constitute good cause.
17 Further, if a party requests sealing related to a dispositive motion or trial, then
18 compelling reasons, not only good cause, for the sealing must be shown, and the
19 relief sought shall be narrowly tailored to serve the specific interest to be protected.
20 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
21 each item or type of information, document, or thing sought to be filed or introduced
22 under seal in connection with a dispositive motion or trial, the party seeking
23 protection must articulate compelling reasons, supported by specific facts and legal
24 justification, for the requested sealing order. Again, competent evidence supporting
25 the application to file documents under seal must be provided by declaration.
26 Any document that is not confidential, privileged, or otherwise protectable in
27 its entirety will not be filed under seal if the confidential portions can be redacted.
1 only the confidential, privileged, or otherwise protectable portions of the document,
2 shall be filed. Any application that seeks to file documents under seal in their
3 entirety should include an explanation of why redaction is not feasible.
4 2. DEFINITIONS
5 2.1 Action: this pending federal lawsuit.
6 2.2 Challenging Party: a Party or Non-Party that challenges the
7 designation of information or items under this Order.
8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
9 how it is generated, stored or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
11 the Good Cause Statement.
12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
13 their support staff).
14 2.5 Designating Party: a Party or Non-Party that designates information or
15 items that it produces in disclosures or in responses to discovery as
16 “CONFIDENTIAL.”
17 2.6 Disclosure or Discovery Material: all items or information, regardless
18 of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 generated in disclosures or responses to discovery in this matter.
21 2.7 Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24 2.8 House Counsel: attorneys who are employees of a party to this Action.
25 House Counsel does not include Outside Counsel of Record or any other outside
26 counsel.
27 2.9 Non-Party: any natural person, partnership, corporation, association or
1 2.10 Outside Counsel of Record: attorneys who are not employees of a
2 party to this Action but are retained to represent or advise a party to this Action and
3 have appeared in this Action on behalf of that party or are affiliated with a law firm
4 that has appeared on behalf of that party, and includes support staff.
5 2.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 2.13 Professional Vendors: persons or entities that provide litigation
11 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 2.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as “CONFIDENTIAL.”
16 2.15 Receiving Party: a Party that receives Disclosure or Discovery
17 Material from a Producing Party.
3. SCOPE
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The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or
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extracted from Protected Material; (2) all copies, excerpts, summaries, or
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compilations of Protected Material; and (3) any testimony, conversations, or
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presentations by Parties or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial shall be governed by the orders of the
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trial judge. This Order does not govern the use of Protected Material at trial.
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4. DURATION
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FINAL DISPOSITION of the action is defined as the conclusion of any
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1 has run. Except as set forth below, the terms of this protective order apply through
2 FINAL DISPOSITION of the action. The parties may stipulate that they will be
3 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
4 but will have to file a separate action for enforcement of the agreement once all
5 proceedings in this case are complete.
6 Once a case proceeds to trial, information that was designated as
7 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
8 as an exhibit at trial becomes public and will be presumptively available to all
9 members of the public, including the press, unless compelling reasons supported by
10 specific factual findings to proceed otherwise are made to the trial judge in advance
11 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
12 showing for sealing documents produced in discovery from “compelling reasons”
13 standard when merits-related documents are part of court record). Accordingly, for
14 such materials, the terms of this protective order do not extend beyond the
15 commencement of the trial.
16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items or oral or written
22 communications that qualify so that other portions of the material, documents, items
23 or communications for which protection is not warranted are not swept unjustifiably
24 within the ambit of this Order.
25 Mass, indiscriminate or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
1 unnecessary expenses and burdens on other parties) may expose the Designating
2 Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in
7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic
13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix at a minimum, the legend “Produced
15 Subject to Protective Order in Arroyo v FCA US LLC, Et Al” (hereinafter
16 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
17 portion of the material on a page qualifies for protection, the Producing Party also
18 must clearly identify the protected portion(s) (e.g., by making appropriate markings
19 in the margins).
20 A Party or Non-Party that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must determine which
26 documents, or portions thereof, qualify for protection under this Order. Then,
27 before producing the specified documents, the Producing Party must affix the
1 portion of the material on a page qualifies for protection, the Producing Party also
2 must clearly identify the protected portion(s) (e.g., by making appropriate markings
3 in the margins).
4 (b) in any deposition, if the deponent's testimony is deemed Confidential, a
5 party will notify opposing counsel in writing of the page and line numbers of the
6 testimony deemed confidential within 30 days of receiving the deposition transcript.
7 Any testimony read from or directly referencing Protected Material is automatically
8 deemed to be confidential, including any Protected Materials that are used as
9 deposition exhibits..
10 (c) for information produced in some form other than documentary and
11 for any other tangible items, that the Producing Party affix in a prominent place on
12 the exterior of the container or containers in which the information is stored the
13 legend “CONFIDENTIAL.” If only a portion or portions of the information
14 warrants protection, the Producing Party, to the extent practicable, shall identify the
15 protected portion(s).
16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
17 failure to designate qualified information or items does not, standing alone, waive
18 the Designating Party’s right to secure protection under this Order for such material.
19 Upon timely correction of a designation, the Receiving Party must make reasonable
20 efforts to assure that the material is treated in accordance with the provisions of this
21 Order.
22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
24 designation of confidentiality at any time that is consistent with the Court’s
25 Scheduling Order.
26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
27 resolution process under Local Rule 37.1 et seq.
1 6.3 The burden of persuasion in any such challenge proceeding shall be on
2 the Designating Party. Frivolous challenges, and those made for an improper
3 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
4 parties) may expose the Challenging Party to sanctions. Unless the Designating
5 Party has waived or withdrawn the confidentiality designation, all parties shall
6 continue to afford the material in question the level of protection to which it is
7 entitled under the Producing Party’s designation until the Court rules on the
8 challenge.
9 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1 Basic Principles. A Receiving Party may use Protected Material that is
11 disclosed or produced by another Party or by a Non-Party in connection with this
12 Action only for prosecuting, defending or attempting to settle this Action. Such
13 Protected Material may be disclosed only to the categories of persons and under the
14 conditions described in this Order. Any recipient of confidential information, by
15 accepting its receipt, agrees to be subject to the jurisdiction of this court in
16 connection with any proceeding or hearing relating to the Confidential information
17 and/or this Protective Order, including but not limited to, any proceeding relating to
18 the enforcement of this Protective Order. When the Action has been terminated, a
19 Receiving Party must comply with the provisions of section 13 below (FINAL
20 DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons
23 authorized under this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating Party, a
26 Receiving Party may disclose any information or item designated
27 “CONFIDENTIAL” only to:
1 well as employees of said Outside Counsel of Record to whom it is reasonably
2 necessary to disclose the information for this Action;
3 (b) the officers, directors, and employees (including House Counsel) of
4 the Receiving Party to whom disclosure is reasonably necessary for this Action;
5 (c) Experts (as defined in this Order) of the Receiving Party to whom
6 disclosure is reasonably necessary for this Action and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (d) the court and its personnel;
9 (e) court reporters and their staff;
10 (f) professional jury or trial consultants, mock jurors, and Professional
11 Vendors to whom disclosure is reasonably necessary for this Action and who have
12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (g) the author or recipient of a document containing the information or a
14 custodian or other person who otherwise possessed or knew the information;
15 (h) during their depositions, witnesses, and attorneys for witnesses, in the
16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
17 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
18 not be permitted to keep any confidential information unless they sign the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
20 agreed by the Designating Party or ordered by the court. Pages of transcribed
21 deposition testimony or exhibits to depositions that reveal Protected Material may
22 be separately bound by the court reporter and may not be disclosed to anyone except
23 as permitted under this Stipulated Protective Order; and
24 (i) any mediator or settlement officer, and their supporting personnel,
25 mutually agreed upon by any of the parties engaged in settlement discussions.
26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
27 IN OTHER LITIGATION
1 that compels disclosure of any information or items designated in this Action as
2 “CONFIDENTIAL,” that Party must:
3 (a) promptly notify in writing the Designating Party. Such notification
4 shall include a copy of the subpoena or court order;
5 (b) promptly notify in writing the party who caused the subpoena or order
6 to issue in the other litigation that some or all of the material covered by the
7 subpoena or order is subject to this Protective Order. Such notification shall include
8 a copy of this Stipulated Protective Order; and
9 (c) cooperate with respect to all reasonable procedures sought to be
10 pursued by the Designating Party whose Protected Material may be affected.
11 If the Designating Party timely seeks a protective order, the Party served with
12 the subpoena or court order shall not produce any information designated in this
13 action as “CONFIDENTIAL” before a determination by the court from which the
14 subpoena or order issued, unless the Party has obtained the Designating Party’s
15 permission. The Designating Party shall bear the burden and expense of seeking
16 protection in that court of its confidential material and nothing in these provisions
17 should be construed as authorizing or encouraging a Receiving Party in this Action
18 to disobey a lawful directive from another court.
19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
20 PRODUCED IN THIS LITIGATION
21 (a) The terms of this Order are applicable to information produced by a
22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
23 produced by Non-Parties in connection with this litigation is protected by the
24 remedies and relief provided by this Order. Nothing in these provisions should be
25 construed as prohibiting a Non-Party from seeking additional protections.
26 (b) In the event that a Party is required, by a valid discovery request, to
27 produce a Non-Party’s confidential information in its possession, and the Party is
1 confidential information, then the Party shall:
2 (1) promptly notify in writing the Requesting Party and the Non-Party
3 that some or all of the information requested is subject to a confidentiality
4 agreement with a Non-Party;
5 (2) promptly provide the Non-Party with a copy of the Stipulated
6 Protective Order in this Action, the relevant discovery request(s), and a reasonably
7 specific description of the information requested; and
8 (3) make the information requested available for inspection by the
9 Non-Party, if requested.
10 (c) If the Non-Party fails to seek a protective order from this court within
11 14 days of receiving the notice and accompanying information, the Receiving Party
12 may produce the Non-Party’s confidential information responsive to the discovery
13 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
14 not produce any information in its possession or control that is subject to the
15 confidentiality agreement with the Non-Party before a determination by the court.
16 Absent a court order to the contrary, the Non-Party shall bear the burden and
17 expense of seeking protection in this court of its Protected Material.
18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
20 Protected Material to any person or in any circumstance not authorized under this
21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
24 persons to whom unauthorized disclosures were made of all the terms of this Order,
25 and (d) request such person or persons to execute the “Acknowledgment and
26 Agreement to Be Bound” that is attached hereto as Exhibit A.
27 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
1 When a Producing Party gives notice to Receiving Parties that certain
2 inadvertently produced material is subject to a claim of privilege or other protection,
3 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
4 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
5 procedure may be established in an e-discovery order that provides for production
6 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
7 (e), insofar as the parties reach an agreement on the effect of disclosure of a
8 communication or information covered by the attorney-client privilege or work
9 product protection, the parties may incorporate their agreement in the stipulated
10 protective order submitted to the court.
11 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
13 person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 Protective Order, no Party waives any right it otherwise would have to object to
16 disclosing or producing any information or item on any ground not addressed in this
17 Stipulated Protective Order. Similarly, no Party waives any right to object on any
18 ground to use in evidence of any of the material covered by this Protective Order.
19 12.3 Filing Protected Material. A Party that seeks to file under seal any
20 Protected Material must comply with Local Civil Rule 79-5. Protected Material
21 may only be filed under seal pursuant to a court order authorizing the sealing of the
22 specific Protected Material at issue. If a Party’s request to file Protected Material
23 under seal is denied by the court, then the Receiving Party may file the information
24 in the public record unless otherwise instructed by the court.
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60
27 days, each Receiving Party must return all Protected Material to the Producing Party
1 includes all copies, abstracts, compilations, summaries, and any other format
2 reproducing or capturing any of the Protected Material. Whether the Protected
3 Material is returned or destroyed, the Receiving Party must submit a written
4 certification to the Producing Party (and, if not the same person or entity, to the
5 Designating Party) by the 60 day deadline that (1) identifies (by category, where
6 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
7 that the Receiving Party has not retained any copies, abstracts, compilations,
8 summaries or any other format reproducing or capturing any of the Protected
9 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
10 copy of all pleadings, motion papers, trial, deposition from this Action, and hearing
11 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
12 reports, attorney work product, and consultant and expert work product, even if such
13 materials contain Protected Material. Any such archival copies that contain or
14 constitute Protected Material remain subject to this Protective Order as set forth in
15 Section 4 (DURATION).
16 The parties stipulate they are contractually bound by the terms of this
17 agreement beyond Final Disposition as to all Confidential information provided by a
18 Producing Party but will have to file a separate action for enforcement of the
19 agreement if the proceedings in this case are complete. The Court shall retain
20 jurisdiction over all recipients of such Confidential information for purposes of
21 enforcing the provisions of this agreement.
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1 14. VIOLATION
2 Any violation of this Order may be punished by appropriate measures
3 including, without limitation, contempt proceedings and/or monetary sanctions.
4 15. FCA’S NHTSA PROVISION
5 The terms of this Protective Order do not preclude FCA US from providing
6 confidential and/or protected information and documents to the National Highway
7 Traffic Safety Administration (“NHTSA”), either voluntarily or in connection with
8 FCA US’s obligations under the National Traffic and Motor Vehicle Safety Act of
9 1966 (“Safety Act”), 49 U.S.C. § 30101, et seq.
16. SALE, ADVERTISE, PUBLICIZE UNDER NO CIRCUMSTANCES Neither
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11 plaintiff(s) nor defendant(s) or their respective counsel, experts, or other persons
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retained by them to assist in the preparation of this action shall under any circumstances,
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sell, offer for sale, advertise, or publicize the contents of Confidential information.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED September 1, 2020
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/s/ Trevor Weinberg
21 Attorneys for Plaintiff
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DATED: September 1, 2020
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/s/ Anum Amin
26 Attorneys for Defendant
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1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 |} DATED: _ October 2, 2020
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6 United Sites Magistrate Judge
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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
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on [date] in the case of Fabian Arroyo v FCA US LLC; Case No. 2:20-cv-05677. I
9 agree to comply with and to be bound by all the terms of this Stipulated Protective
10 Order and I understand and acknowledge that failure to so comply could expose me
11 to sanctions and punishment in the nature of contempt. I solemnly promise that I
12 will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order, and that such information or documents shall be used
15 only for the purposes of the legal proceeding in which they are produced. I further
16 agree and attest to my understanding that my obligation to honor the confidentiality
17 of such information or documents will continue even after the termination of this
18 legal proceeding Action. I further agree to submit to the jurisdiction of the United
19 States District Court for the Central District of California for enforcing the terms of
20 this Stipulated Protective Order, even if such enforcement proceedings occur after
21 termination of this action. I hereby appoint __________________________ [print
22 or type full name] of _______________________________________ [print or type
23 full address and telephone number] as my California agent for service of process in
24 connection with this action or any proceedings related to enforcement of this
25 Stipulated Protective Order.
26 Date: ______________________________________
27 City and State where sworn and signed: _________________________________
1 Printed name: _______________________________
2
3 Signature: __________________________________
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4828-7903-7641.2
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