# Opinion

> District Court, C.D. California · October 16, 2025

URL: https://www.frixlaw.com/law-library/cases/11176109

## Case

- **Full name:** Swan Stegemann v. United States District Court for the Central District of California
- **Court:** District Court, C.D. California
- **Decided:** October 16, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 Alex Farzan (SBN 312771)
THE LAW OFFICE OF ALEX FARZAN
2
10940 Wilshire Blvd., Suite 2010
Los Angeles, CA 90024
3
(424) 325-3112
4 (424) 325-6311 fax
Alex@Farzanlaw.com
5
Attorney for Plaintiff,
6
SWAN STEGEMANN
7

8 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
9
SOUTHERN DIVISION
10

11 SWAN STEGEMANN,
Case No.: 8:25-cv-01357-DOC-ADS
12
Plaintiff,
13
v. STIPULATED PROTECTIVE
14 ORDER
JOHNSON & JOHNSON, MENTOR
15
WORLDWIDE LLC; and DOES 1
through 100, inclusive,
16

17 Defendants.

18

19

20
21
22

23

24
1
I. PURPOSES AND LIMITATIONS
2 A. 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 be warranted. Accordingly, the parties hereby stipulate to
5
and petition the Court to enter the following Stipulated Protective Order.
6
The parties acknowledge that this Order does not confer blanket protections
7
on all disclosures or responses to discovery and that the protection it affords
8
from public disclosure and use extends only to the limited information or
9 items that are entitled to confidential treatment under the applicable legal
10 principles. The parties further acknowledge, as set forth in Section XIII(C),
11 below, that this Stipulated Protective Order does not entitle them to file
confidential information under seal; Civil Local Rule 79-5 sets forth the
12
procedures that must be followed and the standards that will be applied
13
when a party seeks permission from the Court to file material under seal.
14
II. GOOD CAUSE STATEMENT
15
A. This action is likely to involve sensitive personal information
16
regarding Swan Stegemann, as well as trade secrets, customer and pricing
17 lists and other valuable research, development, commercial, financial,
18 technical and/or proprietary information for which special protection from
19 public disclosure and from use for any purpose other than prosecution of
this action is warranted. Such confidential and proprietary materials and
20
information consist of, among other things, confidential business or
21
financial information, information regarding confidential business practices,
22
or other confidential research, development, or commercial information
23
(including information implicating privacy rights of third parties),
24 information otherwise generally unavailable to the public, or which may be
1
privileged or otherwise protected from disclosure under state or federal
2 statutes, court rules, case decisions, or common law. Accordingly, to
3 expedite the flow of information, to facilitate the prompt resolution of
4 disputes over confidentiality of discovery materials, to adequately protect
information the parties are entitled to keep confidential, to ensure that the
5
parties are permitted reasonable necessary uses of such material in
6
preparation for and in the conduct of trial, to address their handling at the
7
end of the litigation, and serve the ends of justice, a protective order for
8
such information is justified in this matter. It is the intent of the parties that
9 information will not be designated as confidential for tactical reasons and
10 that nothing be so designated without a good faith belief that it has been
11 maintained in a confidential, non-public manner, and there is good cause
why it should not be part of the public record of this case.
12
III. DEFINITIONS
13
A. Action: This pending federal law suit.
14
B. Challenging Party: A Party or Non-Party that challenges the
15
designation of information or items under this Order.
16
C. “CONFIDENTIAL” Information or Items: Information (regardless
17 of how it is generated, stored or maintained) or tangible things that qualify
18 for protection under Federal Rule of Civil Procedure 26(c) and 26(c)(1)(g),
19 and as specified above in the Good Cause Statement.
D. Counsel: Outside Counsel of Record and House Counsel (as well as
20
their support staff).
21
E. Designating Party: A Party or Non-Party that designates information
22
or items that it produces in disclosures or in responses to discovery as
23
“CONFIDENTIAL.”
24
1
F. Disclosure or Discovery Material: All items or information,
2 regardless of the medium or manner in which it is generated, stored, or
3 maintained (including, among other things, testimony, transcripts, and
4 tangible things), that are produced or generated in disclosures or responses
to discovery in this matter.
5
G. Expert: A person with specialized knowledge or experience in a
6
matter pertinent to the litigation who has been retained by a Party or its
7
counsel to serve as an expert witness or as a consultant in this Action.
8
H. House Counsel: Attorneys who are employees of a party to this
9 Action. House Counsel does not include Outside Counsel of Record or any
10 other outside counsel.
11 I. Non-Party: Any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
12
J. Outside Counsel of Record: Attorneys who are not employees of a
13
party to this Action but are retained to represent or advise a party to this
14
Action and have appeared in this Action on behalf of that party or are
15
affiliated with a law firm which has appeared on behalf of that party, and
16
includes support staff.
17 K. Party: Any party to this Action, including all of its officers,
18 directors, employees, consultants, retained experts, and Outside Counsel of
19 Record (and their support staffs).
L. Producing Party: A Party or Non-Party that produces Disclosure or
20
Discovery Material in this Action.
21
M. Professional Vendors: Persons or entities that provide litigation
22
support services (e.g., photocopying, videotaping, translating, preparing
23
exhibits or demonstrations, and organizing, storing, or retrieving data in any
24 form or medium) and their employees and subcontractors.
1
N. Protected Material: Any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 O. Receiving Party: A Party that receives Disclosure or Discovery
4 Material from a Producing Party.
IV. SCOPE
5
A. The protections conferred by this Stipulation and Order cover not
6
only Protected Material (as defined above), but also (1) any information
7
copied or extracted from Protected Material; (2) all copies, excerpts,
8
summaries, or compilations of Protected Material; and (3) any testimony,
9 conversations, or presentations by Parties or their Counsel that might reveal
10 Protected Material.
11 B. Any use of Protected Material at trial shall be governed by the orders
of the trial judge. This Order does not govern the use of Protected Material at
12
trial.
13
V. DURATION
14
A. Once a case proceeds to trial, information that was designated as
15
confidential and produced as an exhibit during trial may become public and
16
will be presumptively available to all members of the public, including the
17 press, unless compelling reasons supported by specific factual findings to
18 proceed otherwise are made to the trial judge in advance of the trial. See
19 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th
Cir. 2006) (distinguishing “good cause” showing for sealing documents
20
produced in discovery from “compelling reasons” standard when merits-
21
related documents are part of court record). Accordingly, the terms of this
22
Protective Order do not extend beyond the commencement of the trial.
23
VI. DESIGNATING PROTECTED MATERIAL
24 A. Exercise of Restraint and Care in Designating Material for Protection
1
1. Each Party or Non-Party that designates information or items
2 for protection under this Order must take care to limit any such
3 designation to specific material that qualifies under the appropriate
4 standards. The Designating Party must designate for protection only
those parts of material, documents, items, or oral or written
5
communications that qualify so that other portions of the material,
6
documents, items, or communications for which protection is not
7
warranted are not swept unjustifiably within the ambit of this Order.
8
2. Mass, indiscriminate, or routinized designations are prohibited.
9 Designations that are shown to be clearly unjustified or that have
10 been made for an improper purpose (e.g., to unnecessarily encumber
11 the case development process or to impose unnecessary expenses and
burdens on other parties) may expose the Designating Party to
12
sanctions.
13
3. If it comes to a Designating Party’s attention that information
14
or items that it designated for protection do not qualify for protection,
15
that Designating Party must promptly notify all other Parties that it is
16
withdrawing the inapplicable designation.
17 B. Manner and Timing of Designations
18 1. Except as otherwise provided in this Order (see, e.g., Section
19 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or
Discovery Material that qualifies for protection under this Order must
20
be clearly so designated before the material is disclosed or produced.
21
2. Designation in conformity with this Order requires the
22
following:
23
a. For information in documentary form (e.g., paper or
24 electronic documents, but excluding transcripts of depositions
1
or other pretrial or trial proceedings), that the Producing Party
2 affix at a minimum, the legend “CONFIDENTIAL”
3 (hereinafter “CONFIDENTIAL legend”), to each page that
4 contains protected material.
b. A Party or Non-Party that makes original documents
5
available for inspection need not designate them for protection
6
until after the inspecting Party has indicated which documents
7
it would like copied and produced. During the inspection and
8
before the designation, all of the material made available for
9 inspection shall be deemed “CONFIDENTIAL.” After the
10 inspecting Party has identified the documents it wants copied
11 and produced, the Producing Party must determine which
documents, or portions thereof, qualify for protection under
12
this Order. Then, before producing the specified documents,
13
the Producing Party must affix the “CONFIDENTIAL legend”
14
to each page that contains Protected Material. If only a portion
15
or portions of the material on a page qualifies for protection,
16
the Producing Party also must clearly identify the protected
17 portion(s) (e.g., by making appropriate markings in the
18 margins).
19 c. For testimony given in depositions, that the Designating
Party identify the Disclosure or Discovery Material on the
20
record, before the close of the deposition all protected
21
testimony.
22
d. For information produced in form other than document
23
and for any other tangible items, that the Producing Party affix
24 in a prominent place on the exterior of the container or
1
containers in which the information is stored the legend
2 “CONFIDENTIAL.”
3 C. Inadvertent Failure to Designate
4 1. If timely corrected, an inadvertent failure to designate qualified
information or items does not, standing alone, waive the Designating
5
Party’s right to secure protection under this Order for such material.
6
Upon timely correction of a designation, the Receiving Party must
7
make reasonable efforts to assure that the material is treated in
8
accordance with the provisions of this Order.
9 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
10 A. Timing of Challenges
11 1. Any party or Non-Party may challenge a designation of
confidentiality at any time that is consistent with the Court’s
12
Scheduling Order.
13
B. Meet and Confer
14
1. The Challenging Party shall initiate the dispute resolution
15
process under Local Rule 37.1 et seq.
16
C. The burden of persuasion in any such challenge proceeding shall be
17 on the Designating Party. Frivolous challenges, and those made for an
18 improper purpose (e.g., to harass or impose unnecessary expenses and
19 burdens on other parties) may expose the Challenging Party to sanctions.
Unless the Designating Party has waived or withdrawn the confidentiality
20
designation, all parties shall continue to afford the material in question the
21
level of protection to which it is entitled under the Producing Party’s
22
designation until the Court rules on the challenge.
23
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
24 A. Basic Principles
1
1. A Receiving Party may use Protected Material that is disclosed
2 or produced by another Party or by a Non-Party in connection with
3 this Action only for prosecuting, defending, or attempting to settle
4 this Action. Such Protected Material may be disclosed only to the
categories of persons and under the conditions described in this
5
Order. When the Action has been terminated, a Receiving Party must
6
comply with the provisions of Section XIV below.
7
2. Protected Material must be stored and maintained by a
8
Receiving Party at a location and in a secure manner that ensures that
9 access is limited to the persons authorized under this Order. Materials
10 must be kept following industry-standard data-security practices
11 including encryption, access controls and malware protection.
B. Disclosure of “CONFIDENTIAL” Information or Items
12
1. Unless otherwise ordered by the Court or permitted in writing
13
by the Designating Party, a Receiving Party may disclose any
14
information or item designated “CONFIDENTIAL” only to:
15
a. The Receiving Party’s Outside Counsel of Record in this
16
Action, as well as employees of said Outside Counsel of
17 Record to whom it is reasonably necessary to disclose the
18 information for this Action;
19 b. The officers, directors, and employees (including House
Counsel) of the Receiving Party to whom disclosure is
20
reasonably necessary for this Action;
21
c. Experts (as defined in this Order) of the Receiving Party
22
to whom disclosure is reasonably necessary for this Action and
23
who have signed the “Acknowledgment and Agreement to Be
24 Bound” (Exhibit A);
1
d. The Court and its personnel;
2 e. Court reporters and their staff;
3 f. Professional jury or trial consultants, mock jurors, and
4 Professional Vendors (collectively “Consultants”) to whom
disclosure is reasonably necessary for this Action only if 1)
5
the Consultant has signed the “Acknowledgment and
6
Agreement to be Bound” attached as Exhibit A hereto, 2) the
7
Consultant is not a Competitor of the Designating Party, and 3)
8
Counsel for the party retaining the Consultant, after duly
9 diligent inquiry, does not know of any instance in which they
10 have been found to be in violation of the terms of a protective
11 order in any legal proceeding;
i. As used in this Order, “Competitor” means any
12
manufacturer of, or entity involved in the sale of breast
13
implants and/or breast tissue expanders who, upon
14
reasonable and good faith inquiry, could be determined
15
to be employed by, to be a consultant doing research for,
16
or otherwise to be retained by any manufacturer of, or
17 entity involved in the sale of breast implants and/or
18 breast tissue expanders.
19 g. The author or recipient of a document containing the
information or a custodian or other person who otherwise
20
possessed or knew the information;
21
h. During their depositions, witnesses, and attorneys for
22
witnesses, in the Action to whom disclosure is reasonably
23
necessary provided: (i) the deposing party requests that the
24 witness sign the “Acknowledgment and Agreement to Be
1
Bound;” and (ii) they will not be permitted to keep any
2 confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound,” unless
4 otherwise agreed by the Designating Party or ordered by the
Court. Pages of transcribed deposition testimony or exhibits to
5
depositions that reveal Protected Material may be separately
6
bound by the court reporter and may not be disclosed to
7
anyone except as permitted under this Stipulated Protective
8
Order; and
9 i. Any mediator or settlement officer, and their supporting
10 personnel, mutually agreed upon by any of the parties engaged
11 in settlement discussions.
IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED
12
PRODUCED IN OTHER LITIGATION
13
A. If a Party is served with a subpoena or a court order issued in other
14
litigation that compels disclosure of any information or items designated in
15
this Action as “CONFIDENTIAL,” that Party must:
16
1. Promptly notify in writing the Designating Party. Such
17 notification shall include a copy of the subpoena or court order;
18 2. Promptly notify in writing the party who caused the subpoena
19 or order to issue in the other litigation that some or all of the material
covered by the subpoena or order is subject to this Protective Order.
20
Such notification shall include a copy of this Stipulated Protective
21
Order; and
22
3. Cooperate with respect to all reasonable procedures sought to
23
be pursued by the Designating Party whose Protected Material may
24 be affected.
1
B. If the Designating Party timely seeks a protective order, the Party
2 served with the subpoena or court order shall not produce any information
3 designated in this action as “CONFIDENTIAL” before a determination by
4 the Court from which the subpoena or order issued, unless the Party has
obtained the Designating Party’s permission. The Designating Party shall
5
bear the burden and expense of seeking protection in that court of its
6
confidential material and nothing in these provisions should be construed as
7
authorizing or encouraging a Receiving Party in this Action to disobey a
8
lawful directive from another court.
9 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
10 PRODUCED IN THIS LITIGATION
11 A. The terms of this Order are applicable to information produced by a
Non-Party in this Action and designated as “CONFIDENTIAL.” Such
12
information produced by Non-Parties in connection with this litigation is
13
protected by the remedies and relief provided by this Order. Nothing in
14
these provisions should be construed as prohibiting a Non-Party from
15
seeking additional protections.
16
B. In the event that a Party is required, by a valid discovery request, to
17 produce a Non-Party’s confidential information in its possession, and the
18 Party is subject to an agreement with the Non-Party not to produce the Non-
19 Party’s confidential information, then the Party shall:
1. Promptly notify in writing the Requesting Party and the Non-
20
Party that some or all of the information requested is subject to a
21
confidentiality agreement with a Non-Party;
22
2. Promptly provide the Non-Party with a copy of the Stipulated
23
Protective Order in this Action, the relevant discovery request(s), and
24 a reasonably specific description of the information requested; and
1
3. Make the information requested available for inspection by the
2 Non-Party, if requested.
3 C. If the Non-Party fails to seek a protective order from this court within
4 14 days of receiving the notice and accompanying information, the
Receiving Party may produce the Non-Party’s confidential information
5
responsive to the discovery request. If the Non-Party timely seeks a
6
protective order, the Receiving Party shall not produce any information in
7
its possession or control that is subject to the confidentiality agreement with
8
the Non-Party before a determination by the court. Absent a court order to
9 the contrary, the Non-Party shall bear the burden and expense of seeking
10 protection in this court of its Protected Material.
11 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
A. If a Receiving Party learns that, by inadvertence or otherwise, it has
12
disclosed Protected Material to any person or in any circumstance not
13
authorized under this Stipulated Protective Order, the Receiving Party must
14
immediately (1) notify in writing the Designating Party of the unauthorized
15
disclosures, (2) use its best efforts to retrieve all unauthorized copies of the
16
Protected Material, (3) inform the person or persons to whom unauthorized
17 disclosures were made of all the terms of this Order, and (4) request such
18 person or persons to execute the “Acknowledgment and Agreement to be
19 Bound” that is attached hereto as Exhibit A.
XII. INADVERTENT PRODUCTION OF PRIVILEGED OR
20
OTHERWISE PROTECTED MATERIAL
21
A. When a Producing Party gives notice to Receiving Parties that certain
22
inadvertently produced material is subject to a claim of privilege or other
23
protection, the obligations of the Receiving Parties are those set forth in
24 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended
1
to modify whatever procedure may be established in an e-discovery order
2 that provides for production without prior privilege review. Pursuant to
3 Federal Rule of Evidence 502(d), insofar as the parties reach an agreement
4 on the effect of disclosure of a communication or information covered by
the attorney-client privilege or work product protection, the parties may
5
incorporate their agreement in the Stipulated Protective Order submitted to
6
the Court.
7
XIII. MISCELLANEOUS
8
A. Right to Further Relief
9 1. Nothing in this Order abridges the right of any person to seek
10 its modification by the Court in the future.
11 B. Right to Assert Other Objections
1. By stipulating to the entry of this Protective Order, no Party
12
waives any right it otherwise would have to object to disclosing or
13
producing any information or item on any ground not addressed in
14
this Stipulated Protective Order. Similarly, no Party waives any right
15
to object on any ground to use in evidence of any of the material
16
covered by this Protective Order.
17 C. Filing Protected Material
18 1. A Party that seeks to file under seal any Protected Material
19 must comply with Civil Local Rule 79-5. Protected Material may
only be filed under seal pursuant to a court order authorizing the
20
sealing of the specific Protected Material at issue. If a Party's request
21
to file Protected Material under seal is denied by the Court, then the
22
Receiving Party may file the information in the public record unless
23
otherwise instructed by the Court.
24
1
D. Use of AI
2 1. The Parties agree that the receiving party shall not use any
3 documents, electronically stored information (“ESI”), or other materials
4 produced or exchanged in the course of this litigation, including but not
limited to those designated as “Confidential”, in whole or in part, for
5
prompts (inputs), completion (outputs), or embeddings that are used to train
6
improve, re-train, or otherwise develop any artificial intelligence,
7
foundation model, or large language model (collectively “AI Models”).
8
This prohibition applies regardless of whether the AI Models are
9 proprietary, open-source, or provided by a third party, and regardless of
10 whether the use is for commercial, research, or any other purpose. The
11 Parties further agree to take reasonable steps to ensure that their employees,
counsel, agents, consultants, contractors, and any other persons or entities
12
who may have access to such materials comply with this prohibition. Any
13
violation of this provision may be addressed by the Court through
14
appropriate remedies, including but not limited to, sanctions.
15
E. Third-Party Litigation Funding
16
1. Funders of litigation are unauthorized parties and shall be
17 prohibited access to, and denied copies of, any confidential, proprietary,
18 and sensitive commercial information produced in this action through
19 litigation discovery. The term “funders or litigation” shall be applied
broadly an include any entity or individual engaged in the business of
20
litigation funding, their employees, counsel, consultants, and other agents,
21
whether foreign or domestic. Parties will comply with the Department of
22
Justice, National Security Division’s Foreign Agents Registration Act,
23
and/or the Data Security Program as may be applicable.
24
1
F. Prior to any discovery-related disclosure or production, the Producing
2 Party may redact information or material that is protected from disclosure
3 by applicable privilege or immunity, that is governed by any applicable
4 privacy law or regulation, that contains commercial sensitive or proprietary
non-responsive in, or that any Order entered in this Action allows to be
5
redacted. The Producing Party may also withhold entire non-responsive
6
attachments in a document family and may produce slipsheets in their
7
place.
8
XIV. FINAL DISPOSITION
9 A. After the final disposition of this Action, as defined in Section V,
10 within sixty (60) days of a written request by the Designating Party, each
11 Receiving Party must return all Protected Material to the Producing Party or
destroy such material. As used in this subdivision, “all Protected Material”
12
includes all copies, abstracts, compilations, summaries, and any other
13
format reproducing or capturing any of the Protected Material. Whether the
14
Protected Material is returned or destroyed, the Receiving Party must
15
submit a written certification to the Producing Party (and, if not the same
16
person or entity, to the Designating Party) by the 60 day deadline that (1)
17 identifies (by category, where appropriate) all the Protected Material that
18 was returned or destroyed and (2) affirms that the Receiving Party has not
19 retained any copies, abstracts, compilations, summaries or any other format
reproducing or capturing any of the Protected Material. Notwithstanding
20
this provision, Counsel are entitled to retain an archival copy of all
21
pleadings, motion papers, trial, deposition, and hearing transcripts, legal
22
memoranda, correspondence, deposition and trial exhibits, expert reports,
23
attorney work product, and consultant and expert work product, even if
24 such materials contain Protected Material. Any such archival copies that
1
contain or constitute Protected Material remain subject to this Protective
2 Order as set forth in Section V.
3 B. Any violation of this Order may be punished by any and all
4 appropriate measures including, without limitation, contempt proceedings
and/or monetary sanctions.
5
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6

7
Dated: September 30, 2025 LAW OFFICE OF ALEX FARZAN
8

9 By: /s/ Alex Farzan
Alex Farzan
10 Attorney for Plaintiff
SWAN STEGEMANN
11

12 DATED: October 16, 2025 NELSON MULLINS RILEY &
SCARBOROUGH LLP
13

14 By: /s/ Monee Takla Hanna
Dustin B. Rawlin (pro hac vice)
15 Monee Takla Hanna
Attorneys for Defendants
16
MENTOR WORLDWIDE LLC and
17 JOHNSON & JOHNSON

18
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
19

20

21
Dated: 10/16/2025 /s/ Autumn D. Spaeth
22 HONORABLE AUTUMN D. SPAETH
23 United States Magistrate Judge
24
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 issue by the United States District Court for the Central District of California
8
on [DATE] in the case of [insert formal name of
9 the case and the number and initials assigned to it by the Court]. I agree to
10 comply with and to be bound by all the terms of this Stipulated Protective Order
11 and I understand and acknowledge that failure to so comply could expose me to
sanctions and punishment in the nature of contempt. I solemnly promise that I
12
will not disclose in any manner any information or item that is subject to this
13
Stipulated Protective Order to any person or entity except in strict compliance
14
with the provisions of this Order.
15
I further agree to submit to the jurisdiction of the United States District
16
Court for the Central District of California for the purpose of enforcing the terms
17 of this Stipulated Protective Order, even if such enforcement proceedings occur
18 after termination of this action. I hereby appoint
19 [print or type full name] of [print or type full
address and telephone number] as my California agent for service of process in
20
connection with this action or any proceedings related to enforcement of this
21
Stipulated Protective Order.
22
Date:
23
City and State where sworn and signed:
24 Printed Name:
1
Signature:
2
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11176109. Public record. Not legal advice.