Oleksandr Nazarchuk v. Geico General Insurance Company

1

2

3

4

5

6

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 OLEKSANDR NAZARCHUK, Case No. 2:20−cv−08396 FMO (GJSx)

12 Plaintiff,

STIPULATED PROTECTIVE

13 v. ORDER

14 GEICO GENERAL INSURANCE

COMPANY, an Iowa Corporation , District Judge Fernando M. Olguin

15 Magistrate Judge Gail J. Standish

Defendant.

16

17 1. A. PURPOSES AND LIMITATIONS

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

19 proprietary or private information for which special protection from public

20 disclosure and from use for any purpose other than prosecuting this litigation may

21 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

22 enter the following Stipulated Protective Order. The parties acknowledge that this

23 Order does not confer blanket protections on all disclosures or responses to

24 discovery and that the protection it affords from public disclosure and use extends

25 only to the limited information or items that are entitled to confidential treatment

26 under the applicable legal principles.

27 B. GOOD CAUSE STATEMENT

1 valuable research, development, commercial, financial, technical and/or proprietary

2 information for which special protection from public disclosure and from use for

3 any purpose other than prosecution of this action is warranted. GEICO contends

4 that such confidential and proprietary materials and information consist of, among

5 other things, confidential business or financial information, information regarding

6 confidential business practices, or other confidential research, development, or

7 commercial information (including information implicating privacy rights of third

8 parties), information otherwise generally unavailable to the public, or which may be

9 privileged or otherwise protected from disclosure under state or federal statutes,

10 court rules, case decisions, or common law. Accordingly, to expedite the flow of

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

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

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

14 such material in preparation for and in the conduct of trial, to address their handling

15 at the end of the litigation, and serve the ends of justice, a protective order for such

16 information is justified in this matter. It is the intent of the parties that information

17 will not be designated as confidential for tactical reasons and that nothing be so

18 designated without a good faith belief that it has been maintained in a confidential,

19 non-public manner, and there is good cause why it should not be part of the public

20 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

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

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

26 to file material under seal.

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

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

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

3 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

4 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

5 require good cause showing), and a specific showing of good cause or compelling

6 reasons with proper evidentiary support and legal justification, must be made with

7 respect to Protected Material that a party seeks to file under seal. The parties’ mere

8 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

9 without the submission of competent evidence by declaration, establishing that the

10 material sought to be filed under seal qualifies as confidential, privileged, or

11 otherwise protectable—constitute good cause.

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

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

14 relief sought shall be narrowly tailored to serve the specific interest to be protected.

15 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

16 each item or type of information, document, or thing sought to be filed or introduced

17 under seal in connection with a dispositive motion or trial, the party seeking

18 protection must articulate compelling reasons, supported by specific facts and legal

19 justification, for the requested sealing order. Again, competent evidence supporting

20 the application to file documents under seal must be provided by declaration.

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

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

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

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

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

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

27 2. DEFINITIONS

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

2 designation of information or items under this Order.

3 2.3 “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY”

4 Information or Items: information (regardless of how it is generated, stored or

5 maintained) or tangible things that qualify for protection under Federal Rule of Civil

6 Procedure 26(c), and as specified above in the Good Cause Statement.

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

8 their support staff).

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

10 items that it produces in disclosures or in responses to discovery as

11 “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.” 2.6

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

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

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

15 generated in disclosures or responses to discovery in this matter.

16 2.7 Expert: a person with specialized knowledge or experience in a matter

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

18 an expert witness or as a consultant in this Action.

19 2.8 House Counsel: attorneys who are employees of a party to this Action.

20 House Counsel does not include Outside Counsel of Record or any other outside

21 counsel.

22 2.9 Non-Party: any natural person, partnership, corporation, association or

23 other legal entity not named as a Party to this action.

24 2.10 Outside Counsel of Record: attorneys who are not employees of a

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

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

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

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

2 support staffs).

3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

4 Discovery Material in this Action.

5 2.13 Professional Vendors: persons or entities that provide litigation

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

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

8 and their employees and subcontractors.

9 2.14 Protected Material: any Disclosure or Discovery Material that is

10 designated as “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL

11 ONLY.”

12 2.15 Receiving Party: a Party that receives Disclosure or Discovery

13 Material from a Producing Party.

14 3. SCOPE

15 The protections conferred by this Stipulation and Order cover not only

16 Protected Material (as defined above), but also (1) any information copied or

17 extracted from Protected Material; (2) all copies, excerpts, summaries, or

18 compilations of Protected Material; and (3) any testimony, conversations, or

19 presentations by Parties or their Counsel that might reveal Protected Material.

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

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

22 4. DURATION

23 FINAL DISPOSITION of the action is defined as the conclusion of any

24 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

25 has run. Except as set forth below, the terms of this protective order apply through

26 FINAL DISPOSITION of the action. The parties may stipulate that the they will be

27 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

1 proceedings in this case are complete.

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

3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

4 as an exhibit at trial becomes public and will be presumptively available to all

5 members of the public, including the press, unless compelling reasons supported by

6 specific factual findings to proceed otherwise are made to the trial judge in advance

7 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

8 showing for sealing documents produced in discovery from “compelling reasons”

9 standard when merits-related documents are part of court record). Accordingly, for

10 such materials, the terms of this protective order do not extend beyond the

11 commencement of the trial.

12 5. DESIGNATING PROTECTED MATERIAL

13 5.1 Exercise of Restraint and Care in Designating Material for Protection.

14 Each Party or Non-Party that designates information or items for protection under

15 this Order must take care to limit any such designation to specific material that

16 qualifies under the appropriate standards. The Designating Party must designate for

17 protection only those parts of material, documents, items or oral or written

18 communications that qualify so that other portions of the material, documents, items

19 or communications for which protection is not warranted are not swept unjustifiably

20 within the ambit of this Order.

21 Mass, indiscriminate or routinized designations are prohibited. Designations

22 that are shown to be clearly unjustified or that have been made for an improper

23 purpose (e.g., to unnecessarily encumber the case development process or to impose

24 unnecessary expenses and burdens on other parties) may expose the Designating

25 Party to sanctions.

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

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

1 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

4 under this Order must be clearly so designated before the material is disclosed or

5 produced.

6 Designation in conformity with this Order requires:

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

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

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

10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or

11 “CONFIDENTIAL - FOR COUNSEL ONLY” (hereinafter “CONFIDENTIAL -

12 FOR COUNSEL ONLY legend”), to each page that contains protected material. If

13 only a portion of the material on a page qualifies for protection, the Producing Party

14 also must clearly identify the protected portion(s) (e.g., by making appropriate

15 markings in the margins).

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

17 need not designate them for protection until after the inspecting Party has indicated

18 which documents it would like copied and produced. During the inspection and

19 before the designation, all of the material made available for inspection shall be

20 deemed “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.”

21 After the inspecting Party has identified the documents it wants copied and

22 produced, the Producing Party must determine which documents, or portions

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

24 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”

25 or “CONFIDENTIAL - FOR COUNSEL ONLY legend” to each page that contains

26 Protected Material. If only a portion of the material on a page qualifies for

27 protection, the Producing Party also must clearly identify the protected portion(s)

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

2 the Disclosure or Discovery Material on the record, before the close of the

3 deposition all protected testimony.

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

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

6 the exterior of the container or containers in which the information is stored the

7 legend “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.” If

8 only a portion or portions of the information warrants protection, the Producing

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

10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

11 failure to designate qualified information or items does not, standing alone, waive

12 the Designating Party’s right to secure protection under this Order for such material.

13 Upon timely correction of a designation, the Receiving Party must make reasonable

14 efforts to assure that the material is treated in accordance with the provisions of this

15 Order.

16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

18 designation of confidentiality at any time that is consistent with the Court’s

19 Scheduling Order.

20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

21 resolution process under Local Rule 37.1 et seq.

22 6.3 The burden of persuasion in any such challenge proceeding shall be on

23 the Designating Party. Frivolous challenges, and those made for an improper

24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

25 parties) may expose the Challenging Party to sanctions. Unless the Designating

26 Party has waived or withdrawn the confidentiality designation, all parties shall

27 continue to afford the material in question the level of protection to which it is

1 challenge.

2 7. ACCESS TO AND USE OF PROTECTED MATERIAL

3 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

6 Protected Material may be disclosed only to the categories of persons and under the

7 conditions described in this Order. When the Action has been terminated, a

8 Receiving Party must comply with the provisions of section 13 below (FINAL

9 DISPOSITION).

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

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

12 authorized under this Order.

13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

14 otherwise ordered by the court or permitted in writing by the Designating Party, a

15 Receiving Party may disclose any information or item designated

16 “CONFIDENTIAL” only to:

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

18 well as employees of said Outside Counsel of Record to whom it is reasonably

19 necessary to disclose the information for this Action;

20 (b) the officers, directors, and employees (including House Counsel) of

21 the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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

25 (d) the court and its personnel;

26 (e) court reporters and their staff;

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

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

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

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

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

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

6 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

7 not be permitted to keep any confidential information unless they sign the

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

9 agreed by the Designating Party or ordered by the court. Pages of transcribed

10 deposition testimony or exhibits to depositions that reveal Protected Material may

11 be separately bound by the court reporter and may not be disclosed to anyone except

12 as permitted under this Stipulated Protective Order; and

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

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

15 7.3 Disclosure of “CONFIDENTIAL - FOR COUNSEL ONLY”

16 Information or Items.

17 Unless otherwise ordered by the court or permitted in writing by the

18 Designating Party, a Receiving Party may disclose any information or item

19 designated “CONFIDENTIAL - FOR COUNSEL ONLY” to:

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

21 well as employees of said Outside Counsel of Record to whom it is reasonably

22 necessary to disclose the information for this Action;

23 (b) the court and its personnel; and

24 (c) the author or recipient of a document containing the information or a

25 custodian or other person who otherwise possessed or knew the

26 information.

27 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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

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

3 “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY” that Party

4 must:

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

6 shall include a copy of the subpoena or court order;

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

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

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

10 a copy of this Stipulated Protective Order; and

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

12 pursued by the Designating Party whose Protected Material may be affected.

13 If the Designating Party timely seeks a protective order, the Party served with

14 the subpoena or court order shall not produce any information designated in this

15 action as “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY”

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

17 the Party has obtained the Designating Party’s permission. The Designating Party

18 shall bear the burden and expense of seeking protection in that court of its

19 confidential material and nothing in these provisions should be construed as

20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

21 directive from another court.

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

23 PRODUCED IN THIS LITIGATION

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

25 Non-Party in this Action and designated as “CONFIDENTIAL” or

26 “CONFIDENTIAL - FOR COUNSEL ONLY.” Such information produced by

27 Non-Parties in connection with this litigation is protected by the remedies and relief

1 prohibiting a Non-Party from seeking additional protections.

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

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

4 subject to an agreement with the Non-Party not to produce the Non-Party’s

5 confidential information, then the Party shall:

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

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

8 agreement with a Non-Party;

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

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

11 specific description of the information requested; and

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

13 Non-Party, if requested.

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

15 14 days of receiving the notice and accompanying information, the Receiving Party

16 may produce the Non-Party’s confidential information responsive to the discovery

17 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

18 not produce any information in its possession or control that is subject to the

19 confidentiality agreement with the Non-Party before a determination by the court.

20 Absent a court order to the contrary, the Non-Party shall bear the burden and

21 expense of seeking protection in this court of its Protected Material.

22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

1 and (d) request such person or persons to execute the “Acknowledgment and

2 Agreement to Be Bound” that is attached hereto as Exhibit A.

3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

4 PROTECTED MATERIAL

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

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

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

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

9 procedure may be established in an e-discovery order that provides for production

10 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

11 (e), insofar as the parties reach an agreement on the effect of disclosure of a

12 communication or information covered by the attorney-client privilege or work

13 product protection, the parties may incorporate their agreement in the stipulated

14 protective order submitted to the court.

15 12. MISCELLANEOUS

16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

18 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

23 12.3 Filing Protected Material. A Party that seeks to file under seal any

24 Protected Material must comply with Local Civil Rule 79-5. Protected Material

25 may only be filed under seal pursuant to a court order authorizing the sealing of the

26 specific Protected Material at issue. If a Party’s request to file Protected Material

27 under seal is denied by the court, then the Receiving Party may file the information

1 13. FINAL DISPOSITION

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

3 days of a written request by the Designating Party, each Receiving Party must return

4 all Protected Material to the Producing Party or destroy such material. As used in

5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

6 summaries, and any other format reproducing or capturing any of the Protected

7 Material. Whether the Protected Material is returned or destroyed, the Receiving

8 Party must submit a written certification to the Producing Party (and, if not the same

9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

10 (by category, where appropriate) all the Protected Material that was returned or

11 destroyed and (2) affirms that the Receiving Party has not retained any copies,

12 abstracts, compilations, summaries or any other format reproducing or capturing any

13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

16 reports, attorney work product, and consultant and expert work product, even if such

17 materials contain Protected Material. Any such archival copies that contain or

18 constitute Protected Material remain subject to this Protective Order as set forth in

19 Section 4 (DURATION).

20 / / /

21 / / /

22 / / /

23 / / /

24 / / /

25 / / /

26 / / /

27 / / /

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

5 ||IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

6

7 || Dated: January 25, 2021

8 BRUCE M. WARREN

9 By s/ Bruce M. Warren

10 BRUCE M. WARREN

Attorney for Plaintiff, Oleksandr Nazarchuk

11

12 || Dated: January 25, 2021

13 SHEPPARD, MULLIN, RICHTER & HAMPTON

14 LLP

15 By s/ Jordan S. Derringer

JORDAN S. DERRINGER

16 Attorneys for Defendant GEICO General

17 Insurance Company

18

19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

20

Dated: January 25, 2021

22

23

24

95 HON. GAIL J. STANDISH

United States Magistrate Judge

26

27

28

-|5- Case No. 2:20-cv-08396

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 [date]_____________ in the case of Oleksandr Nazarchuk v. GEICO General

8 Insurance Company, Case No. 2:20−cv−08396 FMO (GJSx). I agree to comply

9 with and to be bound by all the terms of this Stipulated Protective Order and I

10 understand and acknowledge that failure to so comply could expose me to sanctions

11 and punishment in the nature of contempt. I solemnly promise that I will not

12 disclose in any manner any information or item that is subject to this Stipulated

13 Protective Order to any person or entity except in strict compliance with the

14 provisions of this Order.

15 I further agree to submit to the jurisdiction of the United States District Court for the

16 Central District of California for enforcing the terms of this Stipulated Protective

17 Order, even if such enforcement proceedings occur after termination of this action.

18 I hereby appoint __________________________ [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 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25

26 Printed name: _______________________________

27