Opinion

1 KkeEllLyL.gYra Rf@. GdeRnAtoFn s(.ScBomN 301325)

2 NATALIE LIMBER (SBN 304252)

natalie.limber@dentons.com

3 SAMANTHA FAHR (SBN 299409)

samantha.fahr@dentons.com

4 KATYA KEKLIKIAN (SBN 359564)

katya.keklikian@dentons.com

5 DENTONS US LLP

601 South Figueroa Street, Suite 2500

6 Los Angeles, CA 90017

Telephone: 213 623 9300

7 Facsimile: 213 623 9924

8 Attorneys for Defendant

NATIONWIDE MUTUAL

9 INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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TONY GREER AND MAYRA Case No. 2:25-cv-09046-JLS-PD

13 GREER,

Judge: Hon. Josephine Staton

14 Plaintiffs,

Magistrate Judge: Hon. Patricia

15 vs. Donahue

16 NATIONWIDE MUTUAL STIPULATION AND

INSURANCE COMPANY, a mutual PROTECTIVE ORDER

17 company based in Ohio; DOES 1

through 10, inclusive, Action Filed: August 15, 2025

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Defendants.

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21 1. PURPOSES AND LIMITATIONS

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

23 proprietary or private information for which special protection from public

24 disclosure and from use for any purpose other than pursuing this litigation may be

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

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

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

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

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

2 under the applicable legal principles.

3 2. GOOD CAUSE STATEMENT

4 This action is likely to involve private, commercial, financial, personal

5 medical, technical and/or proprietary information for which special protection from

6 public disclosure and from use for any purpose other than prosecution of this action

7 is warranted. Such confidential and proprietary materials and information consist

8 of, among other things, confidential business or financial information, information

9 regarding confidential business practices, or other confidential research,

10 development, or commercial information (including information implicating

11 privacy rights of third parties), information otherwise generally unavailable to the

12 public, or which may be privileged or otherwise protected from disclosure under

13 state or federal statutes, court rules, case decisions, or common law. Accordingly, to

14 expedite the flow of information, to facilitate the prompt resolution of disputes over

15 confidentiality of discovery materials, to adequately protect information the parties

16 are entitled to keep confidential, to ensure that the parties are permitted reasonably

17 necessary uses of such material in preparation for and in the conduct of trial, to

18 address their handling at the end of the litigation, and serve the ends of justice, a

19 protective order for such information is justified in this matter. It is the intent of the

20 parties that information will not be designated as confidential for tactical reasons

21 and that nothing be so designated without a good faith belief that it has been

22 maintained in a confidential, non-public manner, and there is good cause why it

23 should not be part of the public record of this case.

24 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE

25 The parties further acknowledge, as set forth in Section 14.3, below, that this

26 Stipulated Protective Order does not entitle them to file confidential information

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

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

1 to file material under seal. There is a strong presumption that the public has a right

2 of access to judicial proceedings and records in civil cases. In connection with non-

3 dispositive motions, good cause must be shown to support a filing under seal. See

4 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),

5 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-

6 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even

7 stipulated protective orders require good cause showing), and a specific showing of

8 good cause or compelling reasons with proper evidentiary support and legal

9 justification must be made with respect to Protected Material that a party seeks to

10 file under seal. The parties’ mere designation of Disclosure or Discovery Material

11 as CONFIDENTIAL does not—without the submission of competent evidence by

12 declaration, establishing that the material sought to be filed under seal qualifies as

13 confidential, privileged, or otherwise protectable—constitute good cause. Further, if

14 a party requests sealing related to a dispositive motion or trial, then compelling

15 reasons, not only good cause, for the sealing must be shown, and the relief sought

16 shall be narrowly tailored to serve the specific interest to be protected. See Pintos v.

17 Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or

18 type of information, document, or thing sought to be filed or introduced under seal,

19 the party seeking protection must articulate compelling reasons, supported by

20 specific facts and legal justification, for the requested sealing order. Again,

21 competent evidence supporting the application to file documents under seal must be

22 provided by declaration. Any document that is not confidential, privileged, or

23 otherwise protectable in its entirety will not be filed under seal if the confidential

24 portions can be redacted. If documents can be redacted, then a redacted version for

25 public viewing, omitting only the confidential, privileged, or otherwise protectable

26 portions of the document, shall be filed. Any application that seeks to file

27 documents under seal in their entirety should include an explanation of why

28 redaction is not feasible.

1 4. DEFINITIONS

2 4.1 Action: this pending federal lawsuit.

3 4.2 Challenging Party: a Party or Non-Party that challenges the

4 designation of information or items under this Order.

5 4.3 “CONFIDENTIAL” Information or Items: information (regardless of

6 how it is generated, stored or maintained) or tangible things that qualify for

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

8 the Good Cause Statement.

9 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as

10 their support staff).

11 4.5 Designating Party: a Party or Non-Party that designates information or

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

13 “CONFIDENTIAL.”

14 4.6 Disclosure or Discovery Material: all items or information, regardless

15 of the medium or manner in which it is generated, stored, or maintained (including,

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

17 or generated in disclosures or responses to discovery.

18 4.7 Expert: a person with specialized knowledge or experience in a matter

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

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

21 4.8 House Counsel: attorneys who are employees of a party to this Action.

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

23 counsel.

24 4.9 Non-Party: any natural person, partnership, corporation, association or

25 other legal entity not named as a Party to this Action.

26 4.10 Outside Counsel of Record: attorneys who are not employees of a

27 party to this Action but are retained to represent a party to this Action and have

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

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

3 4.11 Party: any party to this Action, including all of its officers, directors,

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

5 support staffs).

6 4.12 Producing Party: a Party or Non-Party that produces Disclosure or

7 Discovery Material in this Action.

8 4.13 Professional Vendors: persons or entities that provide litigation

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

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

11 and their employees and subcontractors.

12 4.14 Protected Material: any Disclosure or Discovery Material that is

13 designated as “CONFIDENTIAL.”

14 4.15 Receiving Party: a Party that receives Disclosure or Discovery

15 Material from a Producing Party.

16 5. SCOPE

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

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

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

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

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

22 use of Protected Material at trial shall be governed by the orders of the trial judge

23 and other applicable authorities. This Order does not govern the use of Protected

24 Material at trial.

25 6. DURATION

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

27 CONFIDENTIAL or maintained pursuant to this protective order and used or

28 introduced as an exhibit at trial becomes public and will be presumptively available

1 to all members of the public, including the press, unless compelling reasons

2 supported by specific factual findings to proceed otherwise are made to the trial

3 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing

4 “good cause” showing for sealing documents produced in discovery from

5 “compelling reasons” standard when merits-related documents are part of court

6 record). Accordingly, the terms of this protective order do not extend beyond the

7 commencement of the trial.

8 7. DESIGNATING PROTECTED MATERIAL

9 7.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

14 communications that qualify so that other portions of the material, documents,

15 items or communications for which protection is not warranted are not swept

16 unjustifiably within the ambit of this Order.

17 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

20 impose unnecessary expenses and burdens on other parties) may expose the

21 Designating Party to sanctions. If it comes to a Designating Party’s attention that

22 information or items that it designated for protection do not qualify for protection,

23 that Designating Party must promptly notify all other Parties that it is withdrawing

24 the inapplicable designation.

25 7.2 Manner and Timing of Designations. Except as otherwise provided in

26 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material

27 that qualifies for protection under this Order must be clearly so designated before

28 the material is disclosed or produced.

1 Designation in conformity with this Order requires:

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

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

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

5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL” legend) to each page that

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

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

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

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

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

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

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

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

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

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

16 before producing the specified documents, the Producing Party must affix the

17 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a

18 portion of the material on a page qualifies for protection, the Producing Party also

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

20 in the margins).

21 (b) for testimony given in depositions, that the Designating Party

22 identifies on the record, before the close of the deposition, that all or some portion

23 of the deposition is Protected Material. The Designating Party shall have 14 days

24 from the close of the deposition to notify the Receiving Party that either the entire

25 deposition is being designated as “CONFIDENTIAL” or, if only a portion of the

26 deposition qualifies for protection, the specific page and line designations

27 containing “CONFIDENTIAL” information or items.

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

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

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

3 legend “CONFIDENTIAL.” If only a portion or portions of the information

4 warrants protection, the Producing Party, to the extent practicable, shall identify the

5 protected portion(s).

6 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

8 the Designating Party’s right to secure protection under this Order for such

9 material. Upon timely correction of a designation, the Receiving Party must make

10 reasonable efforts to assure that the material is treated in accordance with the

11 provisions of this Order.

12 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

13 8.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

15 Scheduling Order.

16 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

17 resolution process under Local Rule 37-1 et seq.

18 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

19 joint stipulation pursuant to Local Rule 37-2.

20 8.4 The burden of persuasion in any such challenge proceeding shall be on

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

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

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

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

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

26 entitled under the Producing Party’s designation until the Court rules on the

27 challenge.

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1 9. ACCESS TO AND USE OF PROTECTED MATERIAL

2 9.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

7 Receiving Party must comply with the provisions of section 15 below (FINAL

8 DISPOSITION).

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

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

11 authorized under this Order.

12 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

14 Receiving Party may disclose any information or item designated

15 “CONFIDENTIAL” only to:

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

17 well as employees of said Outside Counsel of Record to whom disclosure is

18 reasonably necessary to disclose the information for this Action;

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

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

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

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

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

24 (d) the Court and its personnel;

25 (e) court reporters and their staff;

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

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

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

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

2 a custodian or other person who otherwise possessed or knew the information;

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

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

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

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

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

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

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

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

11 except as permitted under this Stipulated Protective Order; and

12 (i) any mediators or settlement officers and their supporting personnel,

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

14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

15 PRODUCED IN OTHER LITIGATION

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

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

18 “CONFIDENTIAL,” that Party must:

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

20 notification shall include a copy of the subpoena or court order;

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

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

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

24 a copy of this Stipulated Protective Order; and

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

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

27 Designating Party timely seeks a protective order, the Party served with the

28 subpoena or court order shall not produce any information designated in this action

1 as “CONFIDENTIAL” before a determination by the court from which the

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

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

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

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

6 to disobey a lawful directive from another court.

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

8 PRODUCED IN THIS LITIGATION

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

10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

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

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

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

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

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

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

17 confidential information, then the Party shall:

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

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

20 agreement with a Non-Party;

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

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

23 specific description of the information requested; and

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

25 Non-Party, if requested.

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

27 within 14 days of receiving the notice and accompanying information, the

28 Receiving Party may produce the Non-Party’s confidential information responsive

1 to the discovery request. If the Non-Party timely seeks a protective order, the

2 Receiving Party shall not produce any information in its possession or control that

3 is subject to the confidentiality agreement with the Non-Party before a

4 determination by the court. Absent a court order to the contrary, the Non-Party shall

5 bear the burden and expense of seeking protection in this court of its Protected

6 Material.

7 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

12 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the

13 person or persons to whom unauthorized disclosures were made of all the terms of

14 this Order, and (d) request such person or persons to execute the “Acknowledgment

15 an Agreement to Be Bound” attached hereto as Exhibit A.

16 13. INADVERTENT PRODUCTION OF PRIVILEGED OR

17 OTHERWISE PROTECTED MATERIAL

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

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

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

21 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify

22 whatever procedure may be established in an e-discovery order that provides for

23 production without prior privilege review. Pursuant to Federal Rule of Evidence

24 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

25 of a communication or information covered by the attorney-client privilege or work

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

27 protective order submitted to the court.

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1 14. MISCELLANEOUS

2 14.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

4 14.2 Right to Assert Other Objections. By stipulating to the entry of this

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

6 disclosing or producing any information or item on any ground not addressed in

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

8 any ground to use in evidence of any of the material covered by this Protective

9 Order.

10 14.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

13 specific Protected Material. If a Party’s request to file Protected Material under seal

14 is denied by the court, then the Receiving Party may file the information in the

15 public record unless otherwise instructed by the court.

16 15. FINAL DISPOSITION

17 After the final disposition of this Action, as defined in paragraph 6, within 60

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

19 return all Protected Material to the Producing Party or destroy such material. As

20 used in this subdivision, “all Protected Material” includes all copies, abstracts,

21 compilations, summaries, and any other format reproducing or capturing any of the

22 Protected Material. Whether the Protected Material is returned or destroyed, the

23 Receiving Party must submit a written certification to the Producing Party (and, if

24 not the same person or entity, to the Designating Party) by the 60-day deadline that

25 (1) identifies (by category, where appropriate) all the Protected Material that was

26 returned or destroyed and (2) affirms that the Receiving Party has not retained any

27 copies, abstracts, compilations, summaries or any other format reproducing or

28 capturing any of the Protected Material. Notwithstanding this provision, Counsel

1 are entitled to retain an archival copy of all pleadings, motion papers, trial,

2 deposition, and hearing transcripts, legal memoranda, correspondence, deposition

3 and trial exhibits, expert reports, attorney work product, and consultant and expert

4 work product, even if such materials contain Protected Material. Any such archival

5 copies that contain or constitute Protected Material remain subject to this Protective

6 Order as set forth in Section 6 (DURATION).

7 16. VIOLATION

8 Any violation of this Order may be punished by appropriate measures

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

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11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: January 22, 2026 SINGLETON SCHREIBER, LLP

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By: /s/ Jordan Goulet

15 Jordan Goulet

16 Attorneys For Plaintiffs

TONY GREER AND MAYRA GREER

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Dated: January 22, 2026 DENTONS US LLP

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By: /s/ Samantha Fahr

20 Samantha Fahr

21 Attorneys for Defendant

NATIONWIDE MUTUAL INSURANCE

22 COMPANY

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1 SIGNATURE ATTESTATION

2 Pursuant to Local Rule 5-4.3.4, I hereby attest that the other signatories

3 listed, on whose behalf the filing is submitted, concur in the filing’s content and

4 have authorized the filing.

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Dated: January 22, 2026 DENTONS US LLP

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By: /s/ Samantha Fahr

8 Samantha Fahr

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

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DATED: January 28, 2026

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□□ obicie Lena koe_

PATRICIA DONAHUE

6 United States Magistrate Judge

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Case No. 2:25-cy-9046-T1.S-PD STIPULATION AND PROPOSED

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I hereby acknowledge that I, _______________________________[NAME],

4 _______________________________________ [POSITION AND EMPLOYER],

5 am about to receive Protected Materials supplied in connection with the Action,

6 (Case No. 2:25-cv-09046-JLS-PD). I certify that I understand that the Protected

7 Materials are provided to me subject to the terms and restrictions of the Stipulation

8 and Protective Order filed in this Action. I have been given a copy of the

9 Stipulation and Protective Order; I have read it, and I agree to be bound by its

10 terms. I understand that Protected Materials, as defined in the Stipulation and

11 Protective Order, including any notes or other records that may be made regarding

12 any such materials, shall not be disclosed to anyone except as expressly permitted

13 by the Stipulation and Protective Order. I will not copy or use, except solely for the

14 purposes of this Action, any Protected Materials obtained pursuant to this

15 Protective Order, except as provided therein or otherwise ordered by the Court in

16 the Action. I further understand that I am to retain all copies of all Confidential

17 Information or Items provided to me in the Action in a secure manner, and that all

18 copies of such Confidential Information or Items are to remain in my personal

19 custody until termination of my participation in this Action, whereupon the copies

20 of such Confidential Information or Items will be returned to counsel who provided

21 me with such Confidential Information or Items. I declare under penalty of perjury,

22 under the laws of the State of California, that the foregoing is true and correct.

23 Executed this _____ day of ______, 202__, at __________________.

24 BY: ___________________________ _________________________________

Signature Address

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______________________________ _________________________________

26 Title City, State, Zip

27 _________________________________

Telephone Number

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