even 17 stipulated protective orders require good cause showing
How later courts described this case
- even 17 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 TURNER HENNINGSEN WOLF & VANDENBURG, LLP
Matthew C. Wolf (SBN 223051)
2
mwolf@thwvlaw.com
3 Lauren K. VanDenburg (SBN 299957)
lvandenburg@thwvlaw.com
4
Arya Shirani (SBN 350328)
5 ashirani@thwvlaw.com
707 Wilshire Blvd., Suite 3700
6
Los Angeles, CA 90017
7 Tel: 323-653-3900
Fax: 323-653-3021
8
9 Attorneys for Defendant, FCA US, LLC
10
STRATEGIC LEGAL PRACTICES, APC
11 Tioana Carvalho (SBN 299010)
tcarvalho@slpattorney.com
12
Hannah C. Theophil (SBN 334178)
13 htheopil@slpattorney.com
emailservices@slpattomey.com
14
Strategic Legal Practices, APC
15 1888 Century Park East, 19th Floor
Log Angeles, CA 90067
16
Tel: (310) 929-4900
17 Fax: (310) 943-3838
18
Attorneys for Plaintiff, JOSEFINA LOZANO
19
20 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
21 EASTERN DIVISION
22
JOSEFINA LOZANO, Case No. 5:24-cv-2373-CV-DTB
23
24 Plaintiff, JOINT STIPULATED PROTECTIVE
vs. ORDER
25
26 FCA US, LLC; and DOES 1 through 10,
inclusive,
27
Defendants.
1 1. PURPOSES AND LIMITATIONS
2 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 pursuing this litigation may be
5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 enter the following Stipulated Protective Order. The parties acknowledge that this
7 Order does not confer blanket protections on all disclosures or responses to
8 discovery and that the protection it affords from public disclosure and use extends
9 only to the limited information or items that are entitled to confidential treatment
10 under the applicable legal principles.
11
12 2. GOOD CAUSE STATEMENT
13 Draft for good reason on protective order: Documents and materials covered
14 under the protective order contain proprietary, financial, confidential, copyrighted,
15 and sensitive information not intended to be circulated among the general public.
16 This includes copyrighted vehicle information intended for purchase or to be used
17 under license, sensitive personally identifiable information, confidential business
18 practices, and information otherwise generally unavailable to the public. In many
19 instances, redaction is not possible as necessary information would be redacted, and
20 in some instances more information would be redacted than visible.
21 Special protection from public disclosure and from use for any purpose other
22 than prosecution of this action is warranted.
23 Accordingly, to expedite the flow of information, to facilitate the prompt
24 resolution of disputes over confidentiality of discovery materials, to adequately
25 protect information the parties are entitled to keep confidential, to ensure that the
26 parties are permitted reasonable necessary uses of such material in preparation for
27 and in the conduct of trial, to address their handling at the end of the litigation, and
1 matter. It is the intent of the parties that information will not be designated as
2 confidential for tactical reasons and that nothing be so designated without a good
3 faith belief that it has been maintained in a confidential, non-public manner, and
4 there is good cause why it should not be part of the public record of this case.
5
6 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
7 The parties further acknowledge, as set forth in Section 14.3, below, that this
8 Stipulated Protective Order does not entitle them to file confidential information
9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
10 and the standards that will be applied when a party seeks permission from the court
11 to file material under seal. There is a strong presumption that the public has a right
12 of access to judicial proceedings and records in civil cases. In connection with non-
13 dispositive motions, good cause must be shown to support a filing under seal. See
14 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
15 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
16 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
17 stipulated protective orders require good cause showing), and a specific showing of
18 good cause or compelling reasons with proper evidentiary support and legal
19 justification, must be made with respect to Protected Material that a party seeks to
20 file under seal. The parties’ mere designation of Disclosure or Discovery Material as
21 CONFIDENTIAL does not— without the submission of competent evidence by
22 declaration, establishing that the material sought to be filed under seal qualifies as
23 confidential, privileged, or otherwise protectable—constitute good cause.
24 Further, if a party requests sealing related to a dispositive motion or trial, then
25 compelling reasons, not only good cause, for the sealing must be shown, and the
26 relief sought shall be narrowly tailored to serve the specific interest to be protected.
27 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For
1 be filed or introduced under seal, the party seeking protection must articulate
2 compelling reasons, supported by specific facts and legal justification, for the
3 requested sealing order. Again, competent evidence supporting the application to
4 file documents under seal must be provided by declaration.
5 Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted. If
7 documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document,
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
11
12 4. DEFINITIONS
13 4.1 Action: this pending federal lawsuit.
14 4.2 Challenging Party: a Party or Non-Party that challenges the designation of
15 information or items under this Order.
16 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how
17 it is generated, stored or maintained) or tangible things that qualify for protection
18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
19 Cause Statement.
20 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
21 support staff).
22 4.5 Designating Party: a Party or Non-Party that designates information or
23 items that it produces in disclosures or in responses to discovery as
24 “CONFIDENTIAL.”
25 4.6 Disclosure or Discovery Material: all items or information, regardless of
26 the medium or manner in which it is generated, stored, or maintained (including,
27 among other things, testimony, transcripts, and tangible things), that are produced or
1 4.7 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4 4.8 House Counsel: attorneys who are employees of a party to this Action.
5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7 4.9 Non-Party: any natural person, partnership, corporation, association or
8 other legal entity not named as a Party to this action.
9 4.10 Outside Counsel of Record: attorneys who are not employees of a party to
10 this Action but are retained to represent a party to this Action and have appeared in
11 this Action on behalf of that party or are affiliated with a law firm that has appeared
12 on behalf of that party, and includes support staff.
13 4.11 Party: any party to this Action, including all of its officers, directors,
14 employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
16 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
17 Discovery Material in this Action.
18 4.13 Professional Vendors: persons or entities that provide litigation support
19 services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
22 4.14 Protected Material: any Disclosure or Discovery Material that is
23 designated as “CONFIDENTIAL.”
24 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
25 from a Producing Party.
26
27 5. SCOPE
1 The protections conferred by this Stipulation and Order cover not only
2 Protected Material (as defined above), but also (1) any information copied or
3 extracted from Protected Material; (2) all copies, excerpts, summaries, or
4 compilations of Protected Material; and (3) any testimony, conversations, or
5 presentations by Parties or their Counsel that might reveal Protected Material.
6 Any use of Protected Material at trial shall be governed by the orders of the trial
7 judge and other applicable authorities. This Order does not govern the use of
8 Protected Material at trial.
9
10 6. DURATION
11 Once a case proceeds to trial, information that was designated as
12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
13 as an exhibit at trial becomes public and will be presumptively available to all
14 members of the public, including the press, unless compelling reasons supported by
15 specific factual findings to proceed otherwise are made to
16 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
17 (distinguishing “good cause” showing for sealing documents produced in discovery
18 from “compelling reasons” standard when merits-related documents are part of court
19 record). Accordingly, the terms of this protective order do not extend beyond the
20 commencement of the trial.
21
22 7. DESIGNATING PROTECTED MATERIAL
23 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each
24 Party or Non-Party that designates information or items for protection under this
25 Order must take care to limit any such designation to specific material that qualifies
26 under the appropriate standards. The Designating Party must designate for
27 protection only those parts of material, documents, items or oral or written
1 or communications for which protection is not warranted are not swept unjustifiably
2 within the ambit of this Order.
3 Mass, indiscriminate or routinized designations are prohibited. Designations
4 that are shown to be clearly unjustified or that have been made for an improper
5 purpose (e.g., to unnecessarily encumber the case development process or to impose
6 unnecessary expenses and burdens on other parties) may expose the Designating
7 Party to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 7.2 Manner and Timing of Designations. Except as otherwise provided in this
12 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that
13 qualifies for protection under this Order must be clearly so designated before the
14 material is disclosed or produced.
15 Designation in conformity with this Order requires:
16 (a) for information in documentary form (e.g., paper or electronic documents,
17 but excluding transcripts of depositions or other pretrial or trial proceedings), that
18 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
19 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
20 portion of the material on a page qualifies for protection, the Producing Party also
21 must clearly identify the protected portion(s) (e.g., by making appropriate markings
22 in the margins).
23 A Party or Non-Party that makes original documents available for inspection
24 need not designate them for protection until after the inspecting Party has indicated
25 which documents it would like copied and produced.
26 During the inspection and before the designation, all of the material made
27 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting
1 Party must determine which documents, or portions thereof, qualify for protection
2 under this Order. Then, before producing the specified documents, the Producing
3 Party must affix the “CONFIDENTIAL legend” to each page that contains Protected
4 Material. If only a portion of the material on a page qualifies for protection, the
5 Producing Party also must clearly identify the protected portion(s) (e.g., by making
6 appropriate markings in the margins).
7 (b) for testimony given in depositions that the Designating Party identifies the
8 Disclosure or Discovery Material on the record, before the close of the deposition all
9 protected testimony.
10 (c) for information produced in some form other than documentary and for any
11 other tangible items, that the Producing Party affix in a prominent place on the
12 exterior of the container or containers in which the information is stored the legend
13 “CONFIDENTIAL.” If only a portion or portions of the information warrants
14 protection, the Producing Party, to the extent practicable, shall identify the protected
15 portion(s).
16 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
17 to designate qualified information or items does not, standing alone, waive the
18 Designating Party’s right to secure protection under this Order for such material.
19 Upon timely correction of a designation, the Receiving Party must make reasonable
20 efforts to assure that the material is treated in accordance with the provisions of this
21 Order.
22
23 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
24 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
25 designation of confidentiality at any time that is consistent with the Court’s
26 Scheduling Order.
27 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
1 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
2 stipulation pursuant to Local Rule 37-2.
3 8.4 The burden of persuasion in any such challenge proceeding shall be on the
4 Designating Party. Frivolous challenges, and those made for an improper purpose
5 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
6 expose the Challenging Party to sanctions. Unless the Designating Party has waived
7 or withdrawn the confidentiality designation, all parties shall continue to afford the
8 material in question the level of protection to which it is entitled under the
9 Producing Party’s designation until the Court rules on the challenge.
10
11 9. ACCESS TO AND USE OF PROTECTED MATERIAL
12 9.1 Basic Principles. A Receiving Party may use Protected Material that is
13 disclosed or produced by another Party or by a Non-Party in connection with this
14 Action only for prosecuting, defending or attempting to settle this Action. Such
15 Protected Material may be disclosed only to the categories of persons and under the
16 conditions described in this Order. When the Action has been terminated, a
17 Receiving Party must comply with the provisions of section 15 below (FINAL
18 DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Order.
22 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
23 ordered by the court or permitted in writing by the Designating Party, a Receiving
24 Party may disclose any information or item designated “CONFIDENTIAL” only to:
25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
26 employees of said Outside Counsel of Record to whom it is reasonably necessary to
27 disclose the information for this Action;
1 (b) the officers, directors, and employees (including House Counsel) of the
2 Receiving Party to whom disclosure is reasonably necessary for this Action;
3 (c) Experts (as defined in this Order) of the Receiving Party to whom
4 disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A)
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
9 to whom disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (g) the author or recipient of a document containing the information or a
12 custodian or other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, in the
14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
16 will not be permitted to keep any confidential information unless they sign the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
18 agreed by the Designating Party or ordered by the court. Pages of transcribed
19 deposition testimony or exhibits to depositions that reveal Protected Material may
20 be separately bound by the court reporter and may not be disclosed to anyone except
21 as permitted under this Stipulated Protective Order; and (i) any mediators or
22 settlement officers and their supporting personnel, mutually agreed upon by any of
23 the parties engaged in settlement discussions.
24
25 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
26 OTHER LITIGATION
27
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,” that Party must:
4 (a) promptly notify in writing the Designating Party. Such notification shall
5 include a copy of the subpoena or court order;
6 (b) promptly notify in writing the party who caused the subpoena or order to
7 issue in the other litigation that some or all of the material covered by the subpoena
8 or order is subject to this Protective Order. Such notification shall include a copy of
9 this Stipulated Protective Order; and
10 (c) cooperate with respect to all reasonable procedures sought to be pursued by
11 the Designating Party whose Protected Material may be affected. If the Designating
12 Party timely seeks a protective order, the Party served with the subpoena or court
13 order shall not produce any information designated in this action as
14 “CONFIDENTIAL” before a determination by the court from which the subpoena
15 or order issued, unless the Party has obtained the Designating Party’s permission.
16 The Designating Party shall bear the burden and expense of seeking protection in
17 that court of its confidential material and nothing in these provisions should be
18 construed as authorizing or encouraging a Receiving Party in this Action to disobey
19 a lawful directive from another court.
20
21 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
22 IN THIS LITIGATION
23 (a) The terms of this Order are applicable to information produced by a Non-
24 Party in this Action and designated as “CONFIDENTIAL.” Such information
25 produced by Non-Parties in connection with this litigation is protected by the
26 remedies and relief provided by this Order. Nothing in these provisions should be
27 construed as prohibiting a Non-Party from seeking additional protections.
1 (b) In the event that a Party is required, by a valid discovery request, to produce
2 a Non-Party’s confidential information in its possession, and the Party is subject to
3 an agreement with the Non-Party not to produce the Non-Party’s confidential
4 information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the Non-Party that
6 some or all of the information requested is subject to a confidentiality agreement
7 with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
9 Order in this Action, the relevant discovery request(s), and a reasonably specific
10 description of the information requested; and
11 (3) make the information requested available for inspection by the Non-Party,
12 if requested.
13 (c) If the Non-Party fails to seek a protective order from this court within 14
14 days of receiving the notice and accompanying information, the Receiving Party
15 may produce the Non-Party’s confidential information responsive to the discovery
16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
17 not produce any information in its possession or control that is subject to the
18 confidentiality agreement with the Non-Party before a determination by the court.
19 Absent a court order to the contrary, the Non-Party shall bear the burden and
20 expense of seeking protection in this court of its Protected Material.
21
22 12. 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 an
2 Agreement to Be Bound” attached hereto as Exhibit A.
3
4 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection,
8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\
9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without
11 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
12 as the parties reach an agreement on the effect of disclosure of a communication or
13 information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement in the stipulated protective order submitted
15 to the court.
16
17 14. MISCELLANEOUS
18 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
19 person to seek its modification by the Court in the future.
20 14.2 Right to Assert Other Objections. By stipulating to the entry of this
21 Protective Order, no Party waives any right it otherwise would have to object to
22 disclosing or producing any information or item on any ground not addressed in this
23 Stipulated Protective Order. Similarly, no Party waives any right to object on any
24 ground to use in evidence of any of the material covered by this Protective Order.
25 14.3 Filing Protected Material. A Party that seeks to file under seal any
26 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
27 only be filed under seal pursuant to a court order authorizing the sealing of the
1 is denied by the court, then the Receiving Party may file the information in the
2 public record unless otherwise instructed by the court.
3
4 15. FINAL DISPOSITION
5 After the final disposition of this Action, as defined in paragraph 6, within 60
6 days of a written request by the Designating Party, each Receiving Party must return
7 all Protected Material to the Producing Party or destroy such material. As used in
8 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
9 summaries, and any other format reproducing or capturing any of the Protected
10 Material. Whether the Protected Material is returned or destroyed, the Receiving
11 Party must submit a written certification to the Producing Party (and, if not the same
12 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
13 (by category, where appropriate) all the Protected Material that was returned or
14 destroyed and (2) affirms that the Receiving Party has not retained any copies,
15 abstracts, compilations, summaries or any other format reproducing or capturing any
16 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
17 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
19 reports, attorney work product, and consultant and expert work product, even if such
20 materials contain Protected Material. Any such archival copies that contain or
21 constitute Protected Material remain subject to this Protective Order as set forth in
22 Section 6 (DURATION).
23
24 16. VIOLATION
25 Any violation of this Order may be punished by appropriate measures
26 including, without limitation, contempt proceedings and/or monetary sanctions.
27 ///
□□ IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 || DATED: March 10, 2025 /s/ Elizabeth Larocque
Elizabeth Larocque
4 Attorneys for Plaintiff
5 JOSEFINA LOZANO
6|| DATED: March 10, 2025 /s/ Matthew C. Wolf
7 Matthew C. Wolf
Attorneys for Defendant
8 FCA US, LLC
Pursuant to Civil Local Rule 5-4.3.4(a)(2), I hereby attest that all signatories listed,
10
11 || and on whose behalf the filing is submitted, concur in the filing’s content and have
12 || authorized the filing.
13
|| DATED: _March 11, 2025 /s/ Matthew C. Wolf
Matthew C. Wolf
15 Attorneys for Defendant
16 FCA US, LLC
17
18
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19
” M ship / fat
DATED: arch 13, 2025 .
21
HON. DAVID T7BRISTOW
22
United States Magistrate Judge
23
24
25
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28
1¢
1 EXHIBIT A
2
3 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS
4
5 I hereby acknowledged that I, ______________________________ [NAME],
6 ____________________________________________ [POSITION AND
7 EMPLOYER], am about to receive Confidential Materials supplied in connection
8 with the proceeding, 5:24-cv-2373-CV-DTB. I certify that I understand the
9 Confidential Materials are provided to me subject to the terms and restrictions of the
10 Stipulation and Protective Order filed in this Proceeding. I have been given a copy
11 of this Stipulation and Protective Order; I have read it, and I agree to be bound by its
12 terms.
13 I understand that Confidential Materials, as defined in the Stipulation and
14 Protective Order, including any notes or other records that may be made regarding
15 any such materials, shall not be Disclosed to anyone except as expressly permitted
16 by the Stipulation and Protective Order. I will not copy or use, except solely for the
17 purposes of this Proceeding, any Confidential Materials obtained pursuant to this
18 Protective Order, except as provided therein or otherwise ordered by the Court in the
19 Proceeding.
20 I further understand that I am to retain all copies of all Confidential Materials
21 provided to me in the Proceeding in a secure manner and that all copies of such
22 Materials are to remain in my personal custody until termination of my participation
23 in the Proceeding, whereupon the copies of such Materials will be returned to
24 counsel who provided me with such Materials.
25 ///
26 ///
27 ///
1 I declare under penalty of perjury, under the laws of the State of California,
2 that the foregoing is true and correct. Executed this_____ day of _____, 20_____, at
3 _________________.
4
5 DATED: _______________________ BY: _______________________________
6 Signature
7 ______________________________
8 Title
9 ______________________________
10 Address
11 ______________________________
12 City, State, Zip
13 ______________________________
14 Telephone Number
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