Evelyn Jimenez v. City of Los Angeles

1 MKAICTHHALEELE NN .A F. EKUEENRE, ACLitYy ,ACtthoirenf eAysSsiBstNan 1t1 C1i5ty2 9Axttorney SBN 212289

2 SCOTT MARCUS, Senior Assistant City Attorney SBN 184980

3 CORY M. BRENTE, Senior Assistant City Attorney SBN 115453

GEOFFREY PLOWDEN, Deputy City Attorney SBN 146602

4 200 No. Main Street, 6th Floor City Hall East DISCOVERY MATTER

5 Los Angeles, California 90012

Email: geoffrey.plowden@lacity.org

6 Phone: (213) 978-7038 Fax No: (213) 978-8785

7 Attorneys for Defendants CITY OF LOS ANGELES, OFFICERS TOMAS

SALAZAR, MORBY RYAN, GABRIEL HOLGUIN, CODY BAUMANN, ERIC

8 OLIVE, RAUL MARTINEZ, HECTOR CARRILLO and AARON GREEN

9

Ralph Rios SBN 80585

10 El Monte Law Group

11 11100 Valley Boulevard, Suite 115

El Monte, California 91763

12

Ph. (626)406-1032 / Fx: (626)522-8520

13 Email: rrios@emlawgroup.com

Attorneys for Plaintiffs, EST. OF BRYAN RODRIGUEZ, BY AND THROUGH HIS

14

SUCCESSOR-IN-INTEREST, EVELYN JIMENEZ

15

16

17 UNITED STATES DISTRICT COURT

18 FOR THE CENTRAL DISTRICT OF CALIFORNIA

19

Estate of Bryan Rodriguez by and through Case No. CV19-05239-ODW-AGR

20

his successor in interest, Evelyn Jimenez, Hon. Otis D. Wright, District Judge

21 Hon. Alicia G. Rosenberg, Magistrate

Plaintiff,

vs. Judge

22

23 City of Los Angeles, Chief of Los Angeles STIPULATION FOR PROTECTIVE

Police Department, John Doe, Supervisor, ORDER; ORDER

24 DOES 1-10,

25

Defendants.

26

1. A. PURPOSES AND LIMITATIONS

27

Discovery in this action is likely to involve the production of confidential,

28

1 and from use for any purpose other than prosecuting this litigation may be warranted.

2 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

3 Stipulated Protective Order. The parties acknowledge that this Order does not confer

4 blanket protections on all disclosures or responses to discovery and that the protection it

5 affords from public disclosure and use extends only to the limited information or items

6 that are entitled to confidential treatment under the applicable legal principles.

7 B. GOOD CAUSE STATEMENT

8 This action is likely to involve Los Angeles Police Department reports and body

9 camera videos for which special protection from public disclosure may be warranted and

10 which may be privileged or otherwise protected from disclosure under state or federal

11 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow

12 of information, to facilitate the prompt resolution of disputes over confidentiality of

13 discovery materials, to adequately protect information the parties are entitled to keep

14 confidential, to ensure that the parties are permitted reasonable necessary uses of such

15 material in preparation for and in the conduct of trial, to address their handling at the end

16 of the litigation, and serve the ends of justice, a protective order for such information is

17 justified in this matter. It is the intent of the parties that information will not be

18 designated as confidential for tactical reasons and that nothing be so designated without

19 a good faith belief that it has been maintained in a confidential, non-public manner, and

20 there is good cause why it should not be part of the public record of this case.

21 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

22 The parties further acknowledge, as set forth in Section 12.3, below, that this

23 Stipulated Protective Order does not entitle them to file confidential information under

24 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the

25 standards that will be applied when a party seeks permission from the court to file

26 material under seal.

27 There is a strong presumption that the public has a right of access to judicial

28 proceedings and records in civil cases. In connection with non-dispositive motions, good

1 cause must be shown to support a filing under seal. See Kamakana v. City and County of

2 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d

3 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,

4 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing),

5 and a specific showing of good cause or compelling reasons with proper evidentiary

6 support and legal justification, must be made with respect to Protected Material that a

7 party seeks to file under seal. The parties’ mere designation of Disclosure or Discovery

8 Material as CONFIDENTIAL does not— without the submission of competent evidence

9 by declaration, establishing that the material sought to be filed under seal qualifies as

10 confidential, privileged, or otherwise protectable—constitute good cause.

11 Further, if a party requests sealing related to a dispositive motion or trial, then

12 compelling reasons, not only good cause, for the sealing must be shown, and the relief

13 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

14 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type

15 of information, document, or thing sought to be filed or introduced under seal in

16 connection with a dispositive motion or trial, the party seeking protection must articulate

17 compelling reasons, supported by specific facts and legal justification, for the requested

18 sealing order. Again, competent evidence supporting the application to file documents

19 under seal must be provided by declaration.

20 Any document that is not confidential, privileged, or otherwise protectable in

21 its entirety will not be filed under seal if the confidential portions can be redacted.

22 If documents can be redacted, then a redacted version for public viewing, omitting

23 only the confidential, privileged, or otherwise protectable portions of the document,

24 shall be filed. Any application that seeks to file documents under seal in their

25 entirety should include an explanation of why redaction is not feasible.

26 2. DEFINITIONS

27 2.1 Action: Evelyn Jimenez, v. City of Los Angeles et al., Case No. 2:19-CV-

28 05329ODW-AGRx

1 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

2 information or items under this Order.

3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is

4 generated, stored or maintained) or tangible things that qualify for protection under

5 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

6 Statement.

7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

8 support staff).

9 2.5 Designating Party: a Party or Non-Party that designates information or items

10 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

11 2.6 Disclosure or Discovery Material: all items or information, regardless of the

12 medium or manner in which it is generated, stored, or maintained (including, among

13 other things, testimony, transcripts, and tangible things), that are produced or generated

14 in disclosures or responses to discovery in this matter.

15 2.7 Expert: a person with specialized knowledge or experience in a matter

16 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

17 expert witness or as a consultant in this Action.

18 2.8 House Counsel: attorneys who are employees of a party to this Action. House

19 Counsel does not include Outside Counsel of Record or any other outside counsel.

20 2.9 Non-Party: any natural person, partnership, corporation, association or other

21 legal entity not named as a Party to this action.

22 2.10 Outside Counsel of Record: attorneys who are not employees of a party to

23 this Action but are retained to represent or advise a party to this Action and have

24 appeared in this Action on behalf of that party or are affiliated with a law firm that has

25 appeared on behalf of that party, and includes support staff.

26 2.11 Party: any party to this Action, including all of its officers, directors,

27 employees, consultants, retained experts, and Outside Counsel of Record (and their

28 support staffs).

1 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

2 Material in this Action.

3 2.13 Professional Vendors: persons or entities that provide litigation support

4 services (e.g., photocopying, videotaping, translating, preparing exhibits or

5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

6 their employees and subcontractors.

7 2.14 Protected Material: any Disclosure or Discovery Material that is designated

8 as “CONFIDENTIAL.”

9 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from

10 a Producing Party.

11 3. SCOPE

12 The protections conferred by this Stipulation and Order cover not only Protected

13 Material (as defined above), but also (1) any information copied or extracted from

14 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

15 Material; and (3) any testimony, conversations, or presentations by Parties or their

16 Counsel that might reveal Protected Material.

17 Any use of Protected Material at trial shall be governed by the orders of the trial

18 judge. This Order does not govern the use of Protected Material at trial.

19 4. DURATION

20 Once a case proceeds to trial, information that was designated as

21 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as

22 an exhibit at trial becomes public and will be presumptively available to all members of

23 the public, including the press, unless compelling reasons supported by specific factual

24 findings to proceed otherwise are made to the trial judge in advance of the trial. See

25 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing

26 documents produced in discovery from “compelling reasons” standard when merits-

27 related documents are part of court record). Accordingly, the terms of this protective

28 order do not extend beyond the commencement of the trial.

1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

3 Party or Non-Party that designates information or items for protection under this Order

4 must take care to limit any such designation to specific material that qualifies under the

5 appropriate standards. The Designating Party must designate for protection only those

6 parts of material, documents, items or oral or written communications that qualify so that

7 other portions of the material, documents, items or communications for which protection

8 is not warranted are not swept unjustifiably within the ambit of this Order.

9 Mass, indiscriminate or routinized designations are prohibited. Designations that

10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

11 to unnecessarily encumber the case development process or to impose unnecessary

12 expenses and burdens on other parties) may expose the Designating Party to sanctions.

13 If it comes to a Designating Party’s attention that information or items that it

14 designated for protection do not qualify for protection, that Designating Party must

15 promptly notify all other Parties that it is withdrawing the inapplicable designation.

16 5.2 Manner and Timing of Designations. Except as otherwise provided in this

17 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

18 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

19 must be clearly so designated before the material is disclosed or produced.

20 Designation in conformity with this Order requires:

21 (a) for information in documentary form (e.g., paper or electronic

22 documents, but excluding transcripts of depositions or other pretrial or trial

23 proceedings), that the Producing Party affix at a minimum, the legend

24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains

25 protected material. If only a portion of the material on a page qualifies for protection, the

26 Producing Party also must clearly identify the protected portion(s) (e.g., by making

27 appropriate markings in the margins).

28 A Party or Non-Party that makes original documents available for inspection need

1 not designate them for protection until after the inspecting Party has indicated which

2 documents it would like copied and produced. During the inspection and before the

3 designation, all of the material made available for inspection shall be deemed

4 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

5 copied and produced, the Producing Party must determine which documents, or portions

6 thereof, qualify for protection under this Order. Then, before producing the specified

7 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

8 that contains Protected Material. If only a portion of the material on a page qualifies for

9 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

10 by making appropriate markings in the margins).

11 (b) for testimony given in depositions that the Designating Party identifies

12 the Disclosure or Discovery Material on the record, before the close of the deposition all

13 protected testimony.

14 (c) for information produced in some form other than documentary and for

15 any other tangible items, that the Producing Party affix in a prominent place on the

16 exterior of the container or containers in which the information is stored the legend

17 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,

18 the Producing Party, to the extent practicable, shall identify the protected portion(s).

19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

20 to designate qualified information or items does not, standing alone, waive the

21 Designating Party’s right to secure protection under this Order for such material. Upon

22 timely correction of a designation, the Receiving Party must make reasonable efforts to

23 assure that the material is treated in accordance with the provisions of this Order.

24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of

26 confidentiality at any time that is consistent with the Court’s Scheduling Order.

27 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

28 process under Local Rule 37.1 et seq.

1 6.3 The burden of persuasion in any such challenge proceeding shall be on the

2 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

3 to harass or impose unnecessary expenses and burdens on other parties) may expose the

4 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

5 the confidentiality designation, all parties shall continue to afford the material in

6 question the level of protection to which it is entitled under the Producing Party’s

7 designation until the Court rules on the challenge.

8 7. ACCESS TO AND USE OF PROTECTED MATERIAL

9 7.1 Basic Principles. A Receiving Party may use Protected Material that is

10 disclosed or produced by another Party or by a Non-Party in connection with this Action

11 only for prosecuting, defending or attempting to settle this Action. Such Protected

12 Material may be disclosed only to the categories of persons and under the conditions

13 described in this Order. When the Action has been terminated, a Receiving Party must

14 comply with the provisions of section 13 below (FINAL DISPOSITION).

15 Protected Material must be stored and maintained by a Receiving Party at a

16 location and in a secure manner that ensures that access is limited to the persons

17 authorized under this Order.

18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

19 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

20 may disclose any information or item designated “CONFIDENTIAL” only to:

21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

22 as employees of said Outside Counsel of Record to whom it is reasonably necessary to

23 disclose the information for this Action;

24 (b) the Receiving party, including its officers, directors, and employees

25 (including House Counsel) to whom disclosure is reasonably necessary for this Action;

26 (c) Experts (as defined in this Order) of the Receiving Party to whom

27 disclosure is reasonably necessary for this Action and who have signed the

28 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

1 (d) the court and its personnel;

2 (e) court reporters and their staff;

3 (f) professional jury or trial consultants, mock jurors, and Professional

4 Vendors to whom disclosure is reasonably necessary for this Action and who have

5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

6 (g) the author or recipient of a document containing the information or a

7 custodian or other person who otherwise possessed or knew the information;

8 (h) during their depositions, witnesses, and attorneys for witnesses, in the

9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

10 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not

11 be permitted to keep any confidential information unless they sign the

12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

13 by the Designating Party or ordered by the court. Pages of transcribed deposition

14 testimony or exhibits to depositions that reveal Protected Material may be separately

15 bound by the court reporter and may not be disclosed to anyone except as permitted

16 under this Stipulated Protective Order; and

17 (i) any mediator or settlement officer, and their supporting personnel,

18 mutually agreed upon by any of the parties engaged in settlement discussions.

19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

20 IN OTHER LITIGATION

21 If a Party is served with a subpoena or a court order issued in other litigation that

22 compels disclosure of any information or items designated in this Action as

23 “CONFIDENTIAL,” that Party must:

24 (a) promptly notify in writing the Designating Party. Such notification shall

25 include a copy of the subpoena or court order;

26 (b) promptly notify in writing the party who caused the subpoena or order

27 to issue in the other litigation that some or all of the material covered by the

28 subpoena or order is subject to this Protective Order. Such notification shall include

1 a copy of this Stipulated Protective Order; and

2 (c) cooperate with respect to all reasonable procedures sought to be pursued

3 by the Designating Party whose Protected Material may be affected. If the Designating

4 Party timely seeks a protective order, the Party served with the subpoena or court order

5 shall not produce any information designated in this action as “CONFIDENTIAL”

6 before a determination by the court from which the subpoena or order issued, unless the

7 Party has obtained the Designating Party’s permission. The Designating Party shall bear

8 the burden and expense of seeking protection in that court of its confidential material

9 and nothing in these provisions should be construed as authorizing or encouraging a

10 Receiving Party in this Action to disobey a lawful directive from another court.

11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

12 IN THIS LITIGATION

13 (a) The terms of this Order are applicable to information produced by a

14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

15 produced by Non-Parties in connection with this litigation is protected by the remedies

16 and relief provided by this Order. Nothing in these provisions should be construed as

17 prohibiting a Non-Party from seeking additional protections.

18 (b) In the event that a Party is required, by a valid discovery request, to

19 produce a Non-Party’s confidential information in its possession, and the Party is subject

20 to an agreement with the Non-Party not to produce the Non-Party’s confidential

21 information, then the Party shall:

22 (1) promptly notify in writing the Requesting Party and the Non-

23 Party that some or all of the information requested is subject to a confidentiality

24 agreement with a Non-Party;

25 (2) promptly provide the Non-Party with a copy of the Stipulated

26 Protective Order in this Action, the relevant discovery request(s), and a reasonably

27 specific description of the information requested; and

28 (3) make the information requested available for inspection by the

1 Non-Party, if requested.

2 (c) If the Non-Party fails to seek a protective order from this court within 14

3 days of receiving the notice and accompanying information, the Receiving Party may

4 produce the Non-Party’s confidential information responsive to the discovery request. If

5 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

6 information in its possession or control that is subject to the confidentiality agreement

7 with the Non-Party before a determination by the court. Absent a court order to the

8 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

9 court of its Protected Material.

10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

12 Protected Material to any person or in any circumstance not authorized under this

13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

14 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

15 all unauthorized copies of the Protected Material, (c) inform the person or persons to

16 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

17 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

18 that is attached hereto as Exhibit A.

19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

20 PROTECTED MATERIAL

21 When a Producing Party gives notice to Receiving Parties that certain

22 inadvertently produced material is subject to a claim of privilege or other protection, the

23 obligations of the Receiving Parties are those set forth in Federal Rule of Civil

24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

25 may be established in an e-discovery order that provides for production without prior

26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

27 parties reach an agreement on the effect of disclosure of a communication or information

28 covered by the attorney-client privilege or work product protection, the parties may

1 incorporate their agreement in the stipulated protective order submitted to the court.

2 12. MISCELLANEOUS

3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

4 person to seek its modification by the Court in the future.

5 12.2 Right to Assert Other Objections. By stipulating to the entry of this

6 Protective Order, no Party waives any right it otherwise would have to object to

7 disclosing or producing any information or item on any ground not addressed in this

8 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground

9 to use in evidence of any of the material covered by this Protective Order.

10 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected

11 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed

12 under seal pursuant to a court order authorizing the sealing of the specific Protected

13 Material at issue. If a Party’s request to file Protected Material under seal is denied by

14 the court, then the Receiving Party may file the information in the public record unless

15 otherwise instructed by the court.

16 13. FINAL DISPOSITION

17 After the final disposition of this Action, as defined in paragraph 4, within 60 days

18 of a written request by the Designating Party, each Receiving Party must return all

19 Protected Material to the Producing Party or destroy such material. As used in this

20 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

21 summaries, and any other format reproducing or capturing any of the Protected Material.

22 Whether the Protected Material is returned or destroyed, the Receiving Party must

23 submit a written certification to the Producing Party (and, if not the same person or

24 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,

25 where appropriate) all the Protected Material that was returned or destroyed and (2)

26 affirms that the Receiving Party has not retained any copies, abstracts, compilations,

27 summaries or any other format reproducing or capturing any of the Protected Material.

28 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

1 | pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

2 | correspondence, deposition and trial exhibits, expert reports, attorney work product, and

3 | consultant and expert work product, even if such materials contain Protected Material.

4 | Any such archival copies that contain or constitute Protected Material remain subject to

5 | this Protective Order as set forth in Section 4 (DURATION).

6] 14. VIOLATION

7 Any violation of this Order may be punished by appropriate measures including,

8 | without limitation, contempt proceedings and/or monetary sanctions.

9

10 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

11

D DATED: September 18, 2020 EL MONTE LAW GROUP

By: /s/ Ralph Rio

14 Attorney for Plaintiffs

15 | DATED: September 18, 2020 MICHAEL N. FEUER, City Attorney

16 KATHLEEN A. KENEALY, Chief Asst. City Atty.

SCOTT MARCUS, Senior Asst. City Attorney

17 CORY M. BRENTE, Senior Asst. City Atty.

18 D ay

By: /S/ - Geoffrey Pluwden

19 GEOFFREY PLOWDEN, Deputy City Atty.

20 Attorneys for Defendant City of Los Angeles

21 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22

23 | DATED: October 7, 2020

24

| beat J Knberg,

26 HON. ALICIA G. ROSENBERG

7 United States Magistrate Judge

28

STIPULATED PROTECTIVE ORDER -]3-

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [print or type full name], of

4 _________________ [print or type full address], declare under penalty of perjury

5 that I have read in its entirety and understand the Stipulated Protective Order that

6 was issued by the United States District Court for the Central District of California

7 on [______________] in the case of Estate of Bryan Rodriguez v. City of Los Angeles,

8 et al. (Case No. CV19-05239 ODW (AGR). I agree to comply with and to be bound by

9 all the terms of this Stipulated Protective Order and I understand and acknowledge that

10 failure to so comply could expose me to sanctions and punishment in the nature of

11 contempt.

12 I solemnly promise that I will not disclose in any manner any information or item

13 that is subject to this Stipulated Protective Order to any person or entity except in

14 strict compliance with the provisions of this Order. I further agree to submit to the

15 jurisdiction of the United States District Court for the Central District of California for

16 enforcing the terms of this Stipulated Protective Order, even if such enforcement

17 proceedings occur after termination of this action. I hereby appoint

18 __________________________ [print or type full name] of

19 _______________________________________ [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

24 Date: ______________________________________

25 City and State where sworn and signed: _________________________________

26 Printed name: _______________________________

27 Signature: __________________________________

28