Los Angeles Waterkeeper v. Basic Fibres, Inc.

1 Ruben A. Castellón (SBN 154610)

William W. Funderburk Jr. (SBN 176244)

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CASTELLÓN & FUNDERBURK LLP

3 811 Wilshire Blvd., Suite 1025

Los Angeles, CA 90017

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Telephone: (213) 623-7515

5 Facsimile: (213) 532-3984

wfunderburk@candffirm.com

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rcastellon@candffirm.com

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Attorneys for Defendants BASIC FIBRES, INC.

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9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

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LOS ANGELES WATERKEEPER, a Case No. 2:19-cv-10276 CAS (RAOx)

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public benefit non-profit corporation,

13 STIPULATED PROTECTIVE

ORDER1

Plaintiff,

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v.

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BASIC FIBRES, INC., a California

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corporation,

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Defendant.

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1 This Stipulated Protective Order is substantially based on the model protective

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order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

1 1. PURPOSES AND LIMITATIONS

2 1.1 Discovery in this Action is likely to involve production of confidential,

3 proprietary or private information for which special protection from public

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

5 be warranted. Accordingly, Los Angeles Waterkeeper (“LA Waterkeeper”) and

6 Basic Fibres Inc. (“Basic Fibres”) (referred to herein individually as a “Party,” and

7 collectively as the “Parties”) hereby stipulate to and petition the Court to enter the

8 following Stipulated Protective Order (“Order”). The Parties acknowledge that

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

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

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

12 under the applicable legal principles.

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14 2. GOOD CAUSE STATEMENT

15 2.1 This Action is likely to involve trade secrets, customer and pricing lists and

16 other valuable research, development, commercial, financial, technical and/or

17 proprietary information for which special protection from public disclosure and

18 from use for any purpose other than prosecution of this action is warranted. Such

19 confidential and proprietary materials and information consist of, among other

20 things, confidential business or financial information, information regarding

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

22 commercial information (including information implicating privacy rights of third

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

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

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

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

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discovery materials, to adequately protect information the Parties are entitled to

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keep confidential, to ensure that the Parties are permitted reasonable necessary

1 uses of such material in preparation for and in the conduct of trial, to address their

2 handling at the end of the litigation, and serve the ends of justice, a protective order

3 for such information is justified in this matter. It is the intent of the Parties that

4 information will not be designated as confidential for tactical reasons and that

5 nothing be so designated without a good faith belief that it has been maintained in

6 a confidential, non-public manner, and there is good cause why it should not be

7 part of the public record of this case.

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9 3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

10 SEAL

3.1 The Parties further acknowledge, as set forth below, that this Order does not

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entitle them to file confidential information under seal; Local Civil Rule 79-5 sets

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forth the procedures that must be followed and the standards that will be applied

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when a Party seeks permission from the Court to file material under seal. There is

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a strong presumption that the public has a right of access to judicial proceedings

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

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

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

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

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F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

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cause showing). A specific showing of good cause or compelling reasons with

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proper evidentiary support and legal justification, must be made with respect to

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Protected Material that a Party seeks to file under seal. The Parties’ mere

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designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

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

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

26 otherwise protectable—constitute good cause.

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1 3.2 Further, if a Party requests sealing related to a dispositive motion or trial,

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

3 the relief sought shall be narrowly tailored to serve the specific interest to be

4 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.

5 2010). For each item or type of information, document, or thing sought to be filed

6 or introduced under seal in connection with a dispositive motion or trial, the Party

7 seeking protection must articulate compelling reasons, supported by specific facts

8 and legal justification, for the requested sealing order. Again, competent evidence

9 supporting the application to file documents under seal must be provided by

10 declaration.

3.3 Any document that is not confidential, privileged, or otherwise protectable

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in its entirety will not be filed under seal if the confidential portions can be

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

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omitting only the confidential, privileged, or otherwise protectable portions of the

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document, shall be filed. Any application that seeks to file documents under seal in

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

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4. DEFINITIONS

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4.1 Action: Los Angeles Waterkeeper v. Basic Fibres, Inc., Case No. 2:19-cv-

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10276 CAS (RAOx)

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

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information or items under this Order.

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4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it

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

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

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Cause Statement.

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4.4 Counsel: Outside Counsel of Record, House Counsel, and/or Corporate

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Counsel (as well as their support staff).

1 4.5 Designating Party: a Party or Non-Party that designates information or

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

3 “CONFIDENTIAL.”

4 4.6 Disclosure or Discovery Material: all items or information, regardless of the

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

6 among other things, testimony, transcripts, and tangible things), that are produced

7 or generated in disclosures, inspections, or responses to discovery in this matter.

8 4.7 Expert: a person with specialized knowledge or experience in a matter

9 pertinent to the litigation who has been retained by a Party or its Counsel to serve

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

11 4.8 House Counsel: attorneys who are employees of a Party to this Action.

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

13 counsel.

14 4.9 Non-Party: any natural person, partnership, corporation, association or other

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

16 4.10 Outside Counsel of Record: attorneys who are not employees of a party to

17 this Action but are retained to represent or advise a Party to this Action and have

18 appeared in this Action on behalf of that Party or are affiliated with a law firm that

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

20 4.11 Party: any Party to this Action, including all of its officers, directors,

21 employees, consultants, retained experts, and Counsel (and their support staffs).

22 4.12 Producing Party: a Party or Non-Party that produces Disclosure or

23 Discovery Material in this Action.

24 4.13 Professional Vendors: persons or entities that provide litigation support

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

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

27 and their employees and subcontractors.

1 4.14 Protected Material: any Disclosure or Discovery Material that is designated

2 as “CONFIDENTIAL.”

3 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material

4 from a Producing Party.

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6 5. SCOPE

7 5.1 The protections conferred by this Stipulation and Order cover not only

8 Protected Material (as defined above), but also:

9 (a) any information copied or extracted from Protected Material;

10 (b) all copies, excerpts, summaries, or compilations of Protected Material;

11 and

12 (c) any testimony, conversations, or presentations by Parties or their

13 Counsel that might reveal Protected Material.

14 5.2 Any use of Protected Material at trial shall be governed by the orders of the

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

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17 6. DURATION

18 6.1 Once a case proceeds to trial, information that was designated as

19 CONFIDENTIAL or maintained pursuant to this Order used or introduced as an

20 exhibit at trial becomes public and will be presumptively available to all members

21 of the public, including the press, unless compelling reasons supported by specific

22 factual findings to proceed otherwise are made to the trial judge in advance of the

23 trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing

24 for sealing documents produced in discovery from “compelling reasons” standard

25 when merits-related documents are part of court record).

26 6.2 Accordingly, the terms of this Order do not extend beyond the

27 commencement of the trial.

1

2 7. DESIGNATING PROTECTED MATERIAL

3 Exercise of Restraint and Care in Designating Material for Protection.

4 7.1 Each Party or Non-Party that designates information or items for protection

5 under this Order must take care to limit any such designation to specific material

6 that qualifies under the appropriate standards.

7 7.2 The Designating Party must designate for protection only those parts of

8 material, documents, items or oral or written communications that qualify so that

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

10 protection is not warranted are not swept unjustifiably within the ambit of this

11 Order.

12 7.3 Mass, indiscriminate or routinized designations are prohibited.

13 7.4 Designations that are shown to be clearly unjustified or that have been made

14 for an improper purpose (e.g., to unnecessarily encumber the case development

15 process or to impose unnecessary expenses and burdens on other parties) may

16 expose the Designating Party to sanctions.

17 7.5 If it comes to a Designating Party’s attention that information or items that it

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

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

20 Manner and Timing of Designations.

21 7.6 Except as otherwise provided in this Order (see, e.g., second paragraph of

22 section 7.2(a) below), or as otherwise stipulated or ordered, Disclosure or

23 Discovery Material that qualifies for protection under this Order must be clearly so

24 designated before the material is disclosed or produced.

25 7.7 Designation in conformity with this Order requires:

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

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

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

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

3 contains protected material. If only a portion of the material on a page qualifies for

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

5 (e.g., by making appropriate markings in the margins).

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

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

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

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

10 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

11 documents it wants copied and produced, the Producing Party must determine

12 which documents, or portions thereof, qualify for protection under this Order.

13 Then, before producing the specified documents, the Producing Party must affix

14 the “CONFIDENTIAL legend” to each page that contains Protected Material. If

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

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

17 appropriate markings in the margins).

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

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

20 deposition all protected testimony.

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

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

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

24 “CONFIDENTIAL.” If only a portion or portions of the information warrants

25 protection, the Producing Party, to the extent practicable, shall identify the

26 protected portion(s).

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1 (d) for potential evidence collected (e.g. photos, images, video) during, or

2 that result from (e.g. sample analysis), a Rule 34 site inspection, LA Waterkeeper

3 shall initially treat as Protected Material, and provide copies of the information and

4 items collected/acquired to Basic Fibers within 7 days. Basic Fibres shall designate

5 any items that qualify as CONFIDENTIAL within 7 days of its receipt of copies of

6 the information or items, after which point only information and items designated

7 CONFIDENTIAL will be treated as Protected Material (subject only to paragraph

8 7.8).

9 Inadvertent Failures to Designate.

10 7.8 If timely corrected, an inadvertent failure to designate qualified information

11 or items does not, standing alone, waive the Designating Party’s right to secure

12 protection under this Order for such material. Upon timely correction of a

13 designation, the Receiving Party must make reasonable efforts to assure that the

14 material is treated in accordance with the provisions of this Order.

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16 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

17 Timing of Challenges.

18 8.1 Any Party or Non-Party may challenge a designation of confidentiality at

19 any time that is consistent with the Court’s Scheduling Order.

20 Meet and Confer.

21 8.2 The Challenging Party shall initiate the dispute resolution process under

22 Local Rule 37.1 et seq.

23 8.3 The burden of persuasion in any such challenge proceeding shall be on the

24 Designating Party.

25 8.4 Frivolous challenges, and those made for an improper purpose (e.g., to

26 harass or impose unnecessary expenses and burdens on other Parties) may expose

27 the Challenging Party to sanctions.

1 8.5 Unless the Designating Party has waived or withdrawn the confidentiality

2 designation, all Parties shall continue to afford the material in question the level of

3 protection to which it is entitled under the Producing Party’s designation until the

4 Court rules on the challenge.

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6 9. ACCESS TO AND USE OF PROTECTED MATERIAL

7 Basic Principles.

8 9.1 A Receiving Party may use Protected Material that is disclosed or produced

9 by another Party or by a Non-Party in connection with this Action only for

10 prosecuting, defending or attempting to settle this Action.

11 9.2 Such Protected Material may be disclosed only to the categories of persons

12 and under the conditions described in this Order.

13 9.3 When the Action has been terminated, a Receiving Party must comply with

14 the provisions of section 15 below (FINAL DISPOSITION).

15 9.4 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 Disclosure of “CONFIDENTIAL” Information or Items.

19 9.5 Unless otherwise ordered by the Court or permitted in writing by the

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

21 designated “CONFIDENTIAL” only to:

22 (a) the Receiving Party’s Outside Counsel of Record in this Action or

23 Corporate Counsel, as well as employees of said Outside Counsel of Record or

24 Corporate Counsel to whom it is reasonably necessary to disclose the information

25 for this Action;

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

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

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

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

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

4 (d) the Court and its personnel;

5 (e) court reporters and their staff;

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

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

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

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

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

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

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

13 party requests that the witness sign the form attached as Exhibit A hereto; and (2)

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

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

16 agreed by the Designating Party or ordered by the Court. Pages of transcribed

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

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

19 except as permitted under this Order; and

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

21 mutually agreed upon by any of the Parties engaged in settlement discussions.

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23 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

24 PRODUCED IN OTHER LITIGATION

25 10.1 If a Party is served with a subpoena or a court order issued in other litigation

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

27 “CONFIDENTIAL,” that Party must:

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

2 include a copy of the subpoena or court order;

3 (b) promptly notify in writing the Party who caused the subpoena or order

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

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

6 include a copy of this Order; and

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

8 by the Designating Party whose Protected Material may be affected.

9 10.2 If the Designating Party timely seeks a protective order, the Party served

10 with the subpoena or court order shall not produce any information designated in

11 this action as “CONFIDENTIAL” before a determination by the court from which

12 the subpoena or order issued, unless the Party has obtained the Designating Party’s

13 permission. The Designating Party shall bear the burden and expense of seeking

14 protection in that court of its confidential material and nothing in these provisions

15 should be construed as authorizing or encouraging a Receiving Party in this Action

16 to disobey a lawful directive from another court.

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

19 PRODUCED IN THIS LITIGATION

20 11.1 The terms of this Order are applicable to information produced by a Non-

21 Party in this Action and designated as “CONFIDENTIAL.” Such information

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

23 remedies and relief provided by this Order. Nothing in these provisions should be

24 construed as prohibiting a Non-Party from seeking additional protections.

25 11.2 In the event that a Party is required, by a valid discovery request, to produce

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

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

2 information, then the Party shall:

3 (a) promptly notify in writing the Requesting Party and the Non-Party that

4 some or all of the information requested is subject to a confidentiality agreement

5 with a Non-Party;

6 (b) promptly provide the Non-Party with a copy of this Order, the relevant

7 discovery request(s), and a reasonably specific description of the information

8 requested; and

9 (c) make the information requested available for inspection by the Non-

10 Party, if requested.

11 11.3 If the Non-Party fails to seek a protective order from this court within 14

12 days of receiving the notice and accompanying information, the Receiving Party

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

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

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

16 confidentiality agreement with the Non-Party before a determination by the Court.

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

18 expense of seeking protection in this Court of its Protected Material.

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20 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

21 12.1 If a Receiving Party learns that, by inadvertence or otherwise, it has

22 disclosed Protected Material to any person or in any circumstance not authorized

23 under this Stipulated Protective Order, the Receiving Party must immediately:

24 (a) notify in writing the Designating Party of the unauthorized disclosures,

25 (b) use its best efforts to retrieve all unauthorized copies of the Protected

26 Material,

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1 (c) inform the person or persons to whom unauthorized disclosures were

2 made of all the terms of this Order, and

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

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

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6 13. INADVERTENT PRODUCTION OF PRIVILEGED OR

7 OTHERWISE PROTECTED MATERIAL

8 13.1 When a Producing Party gives notice to Receiving Parties that certain

9 inadvertently produced material is subject to a claim of privilege or other

10 protection, the obligations of the Receiving Parties are those set forth in Federal

11 Rule of Civil Procedure 26(b)(5)(B).

12 13.2 This provision is not intended to modify whatever procedure may be

13 established in an e-discovery order that provides for production without prior

14 privilege review.

15 13.3 Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the Parties

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

17 covered by the attorney-client privilege or work product protection, the Parties

18 may incorporate their agreement in the stipulated protective order submitted to the

19 court.

20

21 14. MISCELLANEOUS

22 Right to Further Relief.

23 14.1 Nothing in this Order abridges the right of any person to seek its

24 modification by the Court in the future.

25 Right to Assert Other Objections.

26 14.2 By stipulating to the entry of this Order, no Party waives any right it

27 otherwise would have to object to disclosing or producing any information or item

1 on any ground not addressed in this Order. Similarly, no Party waives any right to

2 object on any ground to use in evidence of any of the material covered by this

3 Order.

4 Filing Protected Material.

5 14.3 A Party that seeks to file under seal any Protected Material must comply

6 with Local Civil Rule 79-5. Protected Material may only be filed under seal

7 pursuant to a court order authorizing the sealing of the specific Protected Material

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

9 Court, then the Receiving Party may file the information in the public record

10 unless otherwise instructed by the Court.

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12 15. FINAL DISPOSITION

13 15.1 After the final disposition of this Action, as defined above, within 60 days of

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

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

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

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

18 Material.

19 15.2 Whether the Protected Material is returned or destroyed, the Receiving Party

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

21 person or entity, to the Designating Party) by the 60 day deadline that:

22 (a) identifies (by category, where appropriate) all the Protected Material that

23 was returned or destroyed and

24 (b) affirms that the Receiving Party has not retained any copies, abstracts,

25 compilations, summaries or any other format reproducing or capturing any of the

26 Protected Material.

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1 |} 15.3 Notwithstanding this provision, Counsel are entitled to retain an archival

2 || copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

3 ||memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

4 || work product, and consultant and expert work product, even if such materials

5 contain Protected Material. Any such archival copies that contain or constitute

6 || Protected Material remain subject to this Order as set forth in Section 6

7 ||(DURATION).

8

9 |}16. VIOLATION

10 {16.1 Any violation of this Order may be punished by appropriate measures

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

12

13 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

14

DATE “AIG Be O

15

16 Fer

Attorneys for Plaintiff Los Angeles Waterkeeper

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DATED: May 12, 2020

19 4

tick

20 || Atforneys for Defendant Basic Fibres, Inc.

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

23

DATED: May 14, 2020

Raphi Q2~

25 | HON. ROZELLA A. OLIVER

26 || United States Magistrate Judge

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1S

Stipulated Protective Order

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 March _, 2020 in the case of Los Angeles Waterkeeper v. Basic Fibres, Inc.

9 Case No. 2:19-cv-10276 CAS (RAOx). I agree to comply with and to be bound by

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

11 that failure to so comply could expose me to sanctions and punishment in the

12 nature of contempt. I solemnly promise that I will not disclose in any manner any

13 information or item that is subject to this Stipulated Protective Order to any person

14 or entity except in strict compliance with the provisions of this Order. I further

15 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 Printed name: _______________________________

26 Signature: __________________________________

27