# Alex Duarte v. City of Los Angeles

> District Court, C.D. California · September 16, 2024

URL: https://www.frixlaw.com/law-library/cases/10634970

## Case

- **Court:** District Court, C.D. California
- **Decided:** September 16, 2024
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1
2
3 NOTE: CHANGES MADE BY THE COURT
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6
7 UNITED STATES DISTRICT COURT
8 CENTRAL DISTRICT OF CALIFORNIA
9
10 ALEX DUARTE, CASE NO. 2:24-cv-00258 FMO (SKx)
11

Plaintiff(s),
Hon. Judge Fernando M. Olguin, USDC-1st Cthse,
Ctrm. 6D; Hon. Mag. Steve Kim, Roybal Bldg, Ctrm.
12 v. 540

13 CITY OF LOS ANGELES, LOS
STIPULATED PROTECTIVE ORDER
ANGELES POLICE
14 DEPARTMENT, and DOES 1 to RE: DISCLOSURE OF
CONFIDENTIAL INFORMATION
10, inclusive,
15

Defendant(s).

16
17

18 ORDER ON STIPULATION
19 The Court, finding good cause, Orders as follows:
20
1. A. PURPOSES AND LIMITATIONS
21
Discovery in this action is likely to involve production of confidential,
22
proprietary, or private information for which special protection from public
23
disclosure and from use for any purpose other than prosecuting this litigation may
24
be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
26
Order does not confer blanket protections on all disclosures or responses to
27
discovery and that the protection it affords from public disclosure and use extends
28
1 only to the limited information or items that are entitled to confidential treatment
2 under the applicable legal principles. The parties further acknowledge, as set forth
3 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective
4 Order does not entitle them to a file confidential information under seal; Civil Local
5 Rule 79-5 sets forth the procedures that must be followed and the standards that will
6 be applied when a party seeks permission from the court to file material under seal.
7
8 B. GOOD CAUSE STATEMENT
9 This action involves the City of Los Angeles and members of the Los Angeles
10 Police Department. Plaintiff is seeking materials and information that Defendants the
11 City of Los Angeles et al. (“City”) maintains as confidential, such as personnel files
12 of the police officers involved in this incident, Internal Affairs materials and
information, video recordings (including Body-Worn Video recordings and Digital
13
In-Car Video recordings), audio recordings, and information and other administrative
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materials and information currently in the possession of the City and which the City
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believes need special protection from public disclosure and from use for any purpose
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other than prosecuting this litigation. Plaintiff is also seeking official information
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contained in the personnel files of the police officers involved in the subject incident,
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which the City maintains as strictly confidential and which the City believes need
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special protection from public disclosure and from use for any purpose other than
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prosecuting this litigation.
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The City asserts that the confidentiality of the materials and information sought
22
by Plaintiff is recognized by California and federal law, as evidenced inter alia by
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California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,
24
511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not
25
publicly released the materials and information referenced above except under
26 protective order or pursuant to a court order, if at all. These materials and information
27 are of the type that has been used to initiate disciplinary action against Los Angeles
28 Police Department (“LAPD”) officers, and has been used as evidence in disciplinary
1 proceedings, where the officers’ conduct was considered to be contrary to LAPD
2 policy.
3 The City contends that absent a protective order delineating the responsibilities
4 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary
and undue disclosure by one or more of the many attorneys, secretaries, law clerks,
5
paralegals and expert witnesses involved in this case, as well as the corollary risk of
6
embarrassment, harassment and professional and legal harm on the part of the LAPD
7
officers referenced in the materials and information.
8
The City also contends that the unfettered disclosure of the materials and
9
information, absent a protective order, would allow the media to share this
10
information with potential jurors in the area, impacting the rights of the City herein to
11
receive a fair trial.
12
Accordingly, to expedite the flow of information, to facilitate the prompt
13
resolution of disputes over confidentiality of discovery materials, to adequately
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protect information the parties are entitled to keep confidential, to ensure that the
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parties are permitted reasonable necessary uses of such material in preparation for and
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in the conduct of trial, to address their handling at the end of the litigation, and serve
17
the ends of justice, a protective order for such information is justified in this matter.
18 It is the intent of the parties that information will not be designated as confidential for
19 tactical reasons and that nothing be so designated without a good faith belief that it
20 has been maintained in a confidential, non-public manner, and there is good cause
21 why it should not be part of the public record of this case.
22
23 2. DEFINITIONS
24 2.1 Action: Alex Duarte. v. City of Los Angeles, et al. Case No2:24-cv-
25 00258 FMO (SKx).
26 2.2 Challenging Party: a Party or Non-Party that challenges the
27 designation of information or items under this Order.
28 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
1 how it is generated, stored, or maintained) or tangible things that qualify for
2 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
3 the Good Cause Statement.
4 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
5 their support staff).
6 2.5 Designating Party: a Party or Non-Party that designates information
7 or items that it produces in disclosures or in responses to discovery as
8 “CONFIDENTIAL.”
9 2.6 Disclosure or Discovery Material: all items or information, regardless
10 of the medium or manner in which it is generated, stored, or maintained (including,
11 among other things, testimony, transcripts, and tangible things), that are produced
12 or generated in disclosures or responses to discovery in this matter.
13 2.7 Expert: a person with specialized knowledge or experience in a matter
14 pertinent to the litigation who has been retained by a Party or its counsel to serve as
15 an expert witness or as a consultant in this Action.
16 2.8 House Counsel: attorneys who are employees of a party to this Action.
17 House Counsel does not include Outside Counsel of Record or any other outside
18 counsel.
19 2.9 Non-Party: any natural person, partnership, corporation, association,
20 or other legal entity not named as a Party to this action.
21 2.10 Outside Counsel of Record: attorneys who are not employees of a
22 party to this Action but are retained to represent or advise a party to this Action and
23 have appeared in this Action on behalf of that party or are affiliated with a law firm
24 which has appeared on behalf of that party, including support staff.
25 2.11 Party: any party to this Action, including all of its officers, directors,
26 employees, consultants, retained experts, and Outside Counsel of Record (and their
27 support staffs).
28 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
1 Discovery Material in this Action.
2 2.13 Professional Vendors: persons or entities that provide litigation
3 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
4 demonstrations, and organizing, storing, or retrieving data in any form or medium)
5 and their employees and subcontractors.
6 2.14 Protected Material: any Disclosure or Discovery Material that is
7 designated as “CONFIDENTIAL.”
8 2.15 Receiving Party: a Party that receives Disclosure or Discovery
9 Material from a Producing Party.
10
11 3. SCOPE
12 The protections conferred by this Stipulation and Order cover not only
13 Protected Material (as defined above), but also (1) any information copied or
14 extracted from Protected Material; (2) all copies, excerpts, summaries, or
15 compilations of Protected Material; and (3) any testimony, conversations, or
16 presentations by Parties or their Counsel that might reveal Protected Material.
17 Any use of Protected Material at trial shall be governed by the orders of the
18 trial judge. This Order does not govern the use of Protected Material at trial.
19 4. DURATION
20 Once a case proceeds to trial, all of the information that was designated as
21 confidential or maintained pursuant to this protective order all of the information
22 that was designated as confidential or maintained as such pursuant to this protective
23 order and that is introduced or admitted as an exhibit at trial becomes public and
24 will be presumptively available to all members of the public, including the press,
25 unless compelling reasons supported by specific factual findings to proceed
26 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City
27 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing
28 “good cause” showing for sealing documents produced in discovery from
1 “compelling reasons” standard when merits-related documents are part of court
2 record). Accordingly, the terms of this protective order do not extend to that
3 Protected Material admitted into evidence beyond the commencement of the trial.
4 Even after final disposition of this litigation, the confidentiality obligations
5 imposed by this Order shall remain in effect as to all Protected Material that was not
6 introduced or not admitted into evidence at trial, until a Designating Party agrees
7 otherwise in writing or a court order otherwise directs. Final disposition shall be
8 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
9 or without prejudice; and (2) final judgment herein after the completion and
10 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
11 including the time limits for filing any motions or applications for extension of time
12 pursuant to applicable law.
13
14 5. DESIGNATING PROTECTED MATERIAL
15 5.1 Exercise of Restraint and Care in Designating Material for Protection.
16 Each Party or Non-Party that designates information or items for protection under
17 this Order must take care to limit any such designation to specific material that
18 qualifies under the appropriate standards. The Designating Party must designate for
19 protection only those parts of material, documents, items, or oral or written
20 communications that qualify so that other portions of the material, documents,
21 items, or communications for which protection is not warranted are not swept
22 unjustifiably within the ambit of this Order.
23 Mass, indiscriminate, or routinized designations are prohibited. Designations
24 that are shown to be clearly unjustified or that have been made for an improper
25 purpose (e.g., to unnecessarily encumber the case development process or to impose
26 unnecessary expenses and burdens on other parties) may expose the Designating
27 Party to sanctions.
28 If it comes to a Designating Party’s attention that information or items that it
1 designated for protection do not qualify for protection, that Designating Party must
2 promptly notify all other Parties that it is withdrawing the inapplicable designation.
3 5.2 Manner and Timing of Designations. Except as otherwise provided in
4 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
5 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
6 under this Order must be clearly so designated before the material is disclosed or
7 produced.
8 Designation in conformity with this Order requires:
9 (a) for information in documentary form (e.g., paper or electronic
10 documents, but excluding transcripts of depositions or other pretrial or trial
11 proceedings), that the Producing Party affix at a minimum, the legend
12 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
13 contains protected material. If only a portion or portions of the material on a page
14 qualifies for protection, the Producing Party also must clearly identify the protected
15 portion(s) (e.g., by making appropriate markings in the margins).
16 A Party or Non-Party that makes original documents available for
17 inspection need not designate them for protection until after the inspecting Party has
18 indicated which documents it would like copied and produced. During the
19 inspection and before the designation, all of the material made available for
20 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
21 identified the documents it wants copied and produced, the Producing Party must
22 determine which documents, or portions thereof, qualify for protection under this
23 Order. Then, before producing the specified documents, the Producing Party must
24 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
25 If only a portion or portions 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 (b) for testimony given in depositions that the Designating Party identify
1 the Disclosure or Discovery Material on the record, before the close of the
2 deposition all protected testimony.
3 (c) for information produced in some form other than documentary and
4 for any other tangible items, that the Producing Party affix in a prominent place on
5 the exterior of the container or containers in which the information is stored the
6 legend “CONFIDENTIAL.” If only a portion or portions of the information
7 warrants protection, the Producing Party, to the extent practicable, shall identify the
8 protected portion(s).
9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
10 failure to designate qualified information or items does not, standing alone, waive
11 the Designating Party’s right to secure protection under this Order for such material.
12 Upon timely correction of a designation, the Receiving Party must make reasonable
13 efforts to assure that the material is treated in accordance with the provisions of this
14 Order.
15
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 Civil Local Rule 37-1 et seq.
22 6.3 The burden of persuasion in any such challenge proceeding shall be
23 on 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
28 is entitled under the Producing Party’s designation until the Court rules on the
1 challenge.
2
3 7. ACCESS TO AND USE OF PROTECTED MATERIAL
4 7.1 Basic Principles. A Receiving Party may use Protected Material that
5 is disclosed or produced by another Party or by a Non-Party in connection with
6 this Action only for prosecuting, defending, or attempting to settle this Action.
7 Such Protected Material may be disclosed only to the categories of persons and
8 under the conditions described in this Order. When the Action has been
9 terminated, a Receiving Party must comply with the provisions of Section 13 below
10 (FINAL DISPOSITION).
11 Protected Material must be stored and maintained by a Receiving Party at
12 a location and in a secure manner that ensures that access is limited to the
13 persons authorized under this Order.
14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
15 otherwise ordered by the Court or permitted in writing by the Designating Party, a
16 Receiving Party may disclose any information or item designated
17 “CONFIDENTIAL” only to:
18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
19 well as employees of said Outside Counsel of Record to whom it is reasonably
20 necessary to disclose the information for this Action;
21 (b) the officers, directors, and employees (including House Counsel) of
22 the Receiving Party to whom disclosure is reasonably necessary for this Action;
23 (c) Experts (as defined in this Order) of the Receiving Party to whom
24 disclosure is reasonably necessary for this Action and who have signed the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 (d) the Court and its personnel;
27 (e) court reporters and their staff;
28 (f) professional jury or trial consultants, mock jurors, and Professional
1 Vendors to whom disclosure is reasonably necessary for this Action and who have
2 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 (g) the author or recipient of a document containing the information or a
4 custodian or other person who otherwise possessed or knew the information;
5 (h) during their depositions, witnesses, and attorneys for witnesses, in
6 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
7 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
8 they will not be permitted to keep any confidential information unless they sign the
9 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
10 agreed by the Designating Party or ordered by the Court. Pages of transcribed
11 deposition testimony or exhibits to depositions that reveal Protected Material may
12 be separately bound by the court reporter and may not be disclosed to anyone except
13 as permitted under this Stipulated Protective Order; and
14 (i) any mediator or settlement officer, and their supporting personnel,
15 mutually agreed upon by any of the parties engaged in settlement discussions.
16
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
18 IN OTHER LITIGATION
19 If a Party is served with a subpoena or a court order issued in other litigation
20 that compels disclosure of any information or items designated in this Action as
21 “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such notification
23 shall include a copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or order
25 to issue in the other litigation that some or all of the material covered by the
26 subpoena or order is subject to this Protective Order. Such notification shall include
27 a copy of this Stipulated Protective Order; and
28 (c) cooperate with respect to all reasonable procedures sought to be
1 pursued by the Designating Party whose Protected Material may be affected.
2 If the Designating Party timely seeks a protective order, the Party served with
3 the subpoena or court order shall not produce any information designated in this
4 action as “CONFIDENTIAL” before a determination by the court from which the
5 subpoena or order issued, unless the Party has obtained the Designating Party’s
6 permission. The Designating Party shall bear the burden and expense of seeking
7 protection in that court of its confidential material, and nothing in these provisions
8 should be construed as authorizing or encouraging a Receiving Party in this Action
9 to disobey a lawful directive from another court.
10
11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12 PRODUCED 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
16 remedies and relief provided by this Order. Nothing in these provisions should be
17 construed as 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
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party shall:
22 (1) promptly notify in writing the Requesting Party and the Non-Party
23 that some or all of the information requested is subject to a confidentiality agreement
24 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 Non-
1 Party, if requested.
2 (c) If the Non-Party fails to seek a protective order from this Court within
3 14 days of receiving the notice and accompanying information, the Receiving Party
4 may produce the Non-Party’s confidential information responsive to the discovery
5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
6 not produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the Court.
8 Absent a court order to the contrary, the Non-Party shall bear the burden and
9 expense of seeking protection in this Court of its Protected Material.
10
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
17 or persons to whom unauthorized disclosures were made of all the terms of this
18 Order, and (d) request such person or persons to execute the “Acknowledgment and
19 Agreement to Be Bound” that is attached hereto as Exhibit A.
20
21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
22 PROTECTED MATERIAL
23 When a Producing Party gives notice to Receiving Parties that certain
24 inadvertently produced material is subject to a claim of privilege or other protection,
25 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
26 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
27 procedure may be established in an e-discovery order that provides for production
28 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
1 (e), insofar as the parties reach an agreement on the effect of disclosure of a
2 communication or information covered by the attorney-client privilege or work
3 product protection, the parties may incorporate their agreement in the stipulated
4 protective order submitted to the Court.
5
6 12. MISCELLANEOUS
7 12.1 Right to Relief. Nothing in this Order abridges the right of any person
8 to seek its modification by the Court in the future.
9 12.2 Right to Assert Other Objections. By stipulating to the entry of this
10 Protective Order, no Party waives any right it otherwise would have to object to
11 disclosing or producing any information or item on any ground not addressed in this
12 Stipulated Protective Order. Similarly, no Party waives any right to object on any
13 ground to use in evidence of any of the material covered by this Protective Order.
14 12.3 Filing Protected Material. A Party that seeks to file under seal any
15 Protected Material must comply with Civil Local Rule 79-5. Protected Material
16 may only be filed under seal pursuant to a court order authorizing the sealing of the
17 specific Protected Material at issue. If a Party’s request to file Protected Material
18 under seal is denied by the court, then the Receiving Party may file the information
19 in the public record unless otherwise instructed by the court.
20 13. FINAL DISPOSITION
21 After the final disposition of this Action, as defined in Section 4
22 (DURATION), within 30 days of a written request by the Designating Party, each
23 Receiving Party must return all Protected Material to the Producing Party or destroy
24 such material. As used in this subdivision, “all Protected Material” includes all
25 copies, abstracts, compilations, summaries, and any other format reproducing or
26 capturing any of the Protected Material. Whether the Protected Material is returned
27 or destroyed, the Receiving Party must submit a written certification to the
28 Producing Party (and, if not the same person or entity, to the Designating Party) by
1 the 30 day deadline that (1) identifies (by category, where appropriate) all the
2 Protected Material that was returned or destroyed; and (2) affirms that the Receiving
3 Party has not retained any copies, abstracts, compilations, summaries, or any other
4 format reproducing or capturing any of the Protected Material. Notwithstanding this
5 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
6 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
7 deposition and trial exhibits, expert reports, attorney work product, and consultant
8 and expert work product, even if such materials contain Protected Material. Any
9 such archival copies that contain or constitute Protected Material remain subject to
10 this Protective Order as set forth in Section 4 (DURATION).
11 14. Any violation of this Order may be punished by any and all appropriate
12 measures including, without limitation, contempt proceedings and/or
13 monetary sanctions.
14
15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16
17 MGDESYAN LAW FIRM
Dated: March 26, 2024 /s/ Araksya Boyadzhyan
18

19 ______________________________
GEORGE G. MGDESYAN, ESQ.
20
ARAKSYA BOYADZHYAN, ESQ.
21 Attorneys for Plaintiff

22
Dated: August 26, 2024 HEIDI FELDSTEIN SOTO, City Attorney
23 DENISE C. MILLS, Chief Deputy City
Attorney
24 KATHLEEN KENEALY, Chief Asst. City
Atty. CORY M. BRENTE, Senior Asst. City
25 Atty.

26
By: /s/ Ty Ford
27 TY FORD, Deputy City Attorney
28
1 Attorneys for Defendants CITY OF LOS
ANGELES and LOS ANGELES POLICE
2 DEPARTMENT
3
4| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
5
DATED: September 16, 2024
7 [ge ee
8 oS Gem
9 | Honorable Steve Kim
0 United States 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 Alex Duarte. v. City of Los Angeles, et al. Case No2:24-cv-
9 00258 FMO (SKx).. I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order, and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10634970. Public record. Not legal advice.