The opinion
1 BLANK ROME LLP
Caroline P. Donelan (SBN 268762)
2
Caroline.Donelan@blankrome.com
3 Howard M. Knee (SBN 55048)
Howard.Knee@blankrome.com
4
Gabrielle Weiss (admitted pro hac vice)
5 Gabrielle.Weiss@blankrome.com
2029 Century Park East, 6th Floor
6
Los Angeles, CA 90067
7 Telephone: 424.239.3400
Facsimile: 424.239.3434
8
9 Attorneys for Defendants, CENCORA, INC. and
AMERISOURCEBERGEN DRUG CORPORATION
10
11 UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA
13
14 JONATHON SAINZ, an individual, Case No.: 5:24-cv-02230-JGB-DTB
15 Plaintiff,
v. STIPULATION AND PROPOSED
16 PROTECTIVE ORDER
CENCORA, INC., a Delaware Stock
17 Corporation; AMERISOURCEBERGEN
DRUG CORPORATION; a Delaware
18 Stock Corporation; and DOES 1 through Complaint Filed: September 17, 2024
30, inclusive,
19
Defendants.
20
21
22 1. PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 proprietary or private information for which special protection from public
25 disclosure and from use for any purpose other than pursuing this litigation may be
26 warranted. Accordingly, the parties hereby stipulate to and petition the Court to
27 enter the following Stipulated Protective Order. The parties acknowledge that this
28 Order does not confer blanket protections on all disclosures or responses to
1 discovery and that the protection it affords from public disclosure and use extends
2 only to the limited information or items that are entitled to confidential treatment
3 under the applicable legal principles.
4 2. GOOD CAUSE STATEMENT
5 This action is likely to involve trade secrets, customer and pricing lists and
6 other valuable research, development, commercial, financial, technical and/or
7 proprietary information for which special protection from public disclosure and
8 from use for any purpose other than prosecution of this action is warranted. Such
9 confidential and proprietary materials and information consist of, among other
10 things, confidential business or financial information, information regarding
11 confidential business practices, or other confidential research, development, or
12 commercial information (including information implicating privacy rights of third
13 parties), information otherwise generally unavailable to the public, or which may be
14 privileged or otherwise protected from disclosure under state or federal statutes,
15 court rules, case decisions, or common law. Accordingly, to expedite the flow of
16 information, to facilitate the prompt resolution of disputes over confidentiality of
17 discovery materials, to adequately protect information the parties are entitled to
18 keep confidential, to ensure that the parties are permitted reasonable necessary uses
19 of such material in preparation for and in the conduct of trial, to address their
20 handling at the end of the litigation, and serve the ends of justice, a protective order
21 for such information is justified in this matter. It is the intent of the parties that
22 information will not be designated as confidential for tactical reasons and that
23 nothing be so designated without a good faith belief that it has been maintained in a
24 confidential, non-public manner, and there is good cause why it should not be part
25 of the public record of this case.
26 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
27 The parties further acknowledge, as set forth in Section 14.3, below, that this
28 Stipulated Protective Order does not entitle them to file confidential information
1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
2 and the standards that will be applied when a party seeks permission from the court
3 to file material under seal. There is a strong presumption that the public has a right
4 of access to judicial proceedings and records in civil cases. In connection with non-
5 dispositive motions, good cause must be shown to support a filing under seal. See
6 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
7 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
8 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
9 stipulated protective orders require good cause showing), and a specific showing of
10 good cause or compelling reasons with proper evidentiary support and legal
11 justification, must be made with respect to Protected Material that a party seeks to
12 file under seal. The parties’ mere designation of Disclosure or Discovery Material
13 as CONFIDENTIAL does not— without the submission of competent evidence by
14 declaration, establishing that the material sought to be filed under seal qualifies as
15 confidential, privileged, or otherwise protectable—constitute good cause.
16 Further, if a party requests sealing related to a dispositive motion or trial,
17 then compelling reasons, not only good cause, for the sealing must be shown, and
18 the relief sought shall be narrowly tailored to serve the specific interest to be
19 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
20 2010). For each item or type of information, document, or thing sought to be filed
21 or introduced under seal, the party seeking protection must articulate compelling
22 reasons, supported by specific facts and legal justification, for the requested sealing
23 order. Again, competent evidence supporting the application to file documents
24 under seal must be provided by declaration.
25 Any document that is not confidential, privileged, or otherwise protectable in
26 its entirety will not be filed under seal if the confidential portions can be redacted.
27 If documents can be redacted, then a redacted version for public viewing, omitting
28 only the confidential, privileged, or otherwise protectable portions of the document,
1 shall be filed. Any application that seeks to file documents under seal in their
2 entirety should include an explanation of why redaction is not feasible.
3 4. DEFINITIONS
4 4.1 Action: Jonathon Sainz v. Cencora, Inc. et al., United States District
5 Court for the Central District of California, Case No. 2:25-cv- 02230-JGB-DTB.
6 4.2 Challenging Party: a Party or Non-Party that challenges the designation
7 of information or items under this Order.
8 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
9 how it is generated, stored or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
11 the Good Cause Statement.
12 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
13 support staff).
14 4.5 Designating Party: a Party or Non-Party that designates information or
15 items that it produces in disclosures or in responses to discovery as
16 “CONFIDENTIAL.”
17 4.6 Disclosure or Discovery Material: all items or information, regardless of
18 the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced
20 or generated in disclosures or responses to discovery.
21 4.7 Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24 4.8 House Counsel: attorneys who are employees of a party to this Action.
25 House Counsel does not include Outside Counsel of Record or any other outside
26 counsel.
27 4.9 Non-Party: any natural person, partnership, corporation, association or
28 other legal entity not named as a Party to this action.
1 4.10 Outside Counsel of Record: attorneys who are not employees of a party
2 to this Action but are retained to represent a party to this Action and have appeared
3 in this Action on behalf of that party or are affiliated with a law firm that has
4 appeared on behalf of that party, and includes support staff.
5 4.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 4.13 Professional Vendors: persons or entities that provide litigation support
11 services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 4.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as “CONFIDENTIAL.”
16 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
17 from a Producing Party.
18 5. SCOPE
19 The protections conferred by this Stipulation and Order cover not only Protected
20 Material (as defined above), but also (1) any information copied or extracted from
21 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
22 Material; and (3) any testimony, conversations, or presentations by Parties or their
23 Counsel that might reveal Protected Material.
24 Any use of Protected Material at trial shall be governed by the orders of the
25 trial judge and other applicable authorities. This Order does not govern the use of
26 Protected Material at trial.
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1 6. DURATION
2 Once a case proceeds to trial, information that was designated as
3 CONFIDENTIAL or maintained pursuant to this protective order used or
4 introduced as an exhibit at trial becomes public and will be presumptively available
5 to all members of the public, including the press, unless compelling reasons
6 supported by specific factual findings to proceed otherwise are made to the trial
7 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
8 “good cause” showing for sealing documents produced in discovery from
9 “compelling reasons” standard when merits-related documents are part of court
10 record). Accordingly, the terms of this protective order do not extend beyond the
11 commencement of the trial.
12 7. DESIGNATING PROTECTED MATERIAL
13 7.1 Exercise of Restraint and Care in Designating Material for
14 Protection.
15 Each Party or Non-Party that designates information or items for protection
16 under this Order must take care to limit any such designation to specific material
17 that qualifies under the appropriate standards. The designating party shall not
18 designate materials as confidential unless it reasonably believes the material
19 qualifies under Rule 26(c).“Routine business records, policies, or materials already
20 publicly available may not be designated confidential.” The Designating Party must
21 designate for protection only those parts of material, documents, items or oral or
22 written communications that qualify so that other portions of the material,
23 documents, items or communications for which protection is not warranted are not
24 swept unjustifiably within the ambit of this Order.
25 Mass, indiscriminate or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to
28
1 impose unnecessary expenses and burdens on other parties) may expose the
2 Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 7.2 Manner and Timing of Designations. Except as otherwise provided in
7 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
8 that qualifies for protection under this Order must be clearly so designated before
9 the material is disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electronic documents,
12 but excluding transcripts of depositions or other pretrial or trial proceedings), that
13 the Producing Party affix at a minimum, the legend “CONFIDENTIAL”
14 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected
15 material. If only a portion of the material on a page qualifies for protection, the
16 Producing Party also must clearly identify the protected portion(s) (e.g., by making
17 appropriate markings in the margins).
18 A Party or Non-Party that makes original documents available for inspection
19 need not designate them for protection until after the inspecting Party has indicated
20 which documents it would like copied and produced. During the inspection and
21 before the designation, all of the material made available for inspection shall be
22 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
23 documents it wants copied and produced, the Producing Party must determine
24 which documents, or portions thereof, qualify for protection under this Order. Then,
25 before producing the specified documents, the Producing Party must affix the
26 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
27 portion of the material on a page qualifies for protection, the Producing Party also
28
1 must clearly identify the protected portion(s) (e.g., by making appropriate markings
2 in the margins).
3 (b) for testimony given in depositions that the Designating Party identifies
4 the Disclosure or Discovery Material on the record, before the close of the
5 deposition all protected testimony.
6 (c) for information produced in some form other than documentary and for
7 any other tangible items, that the Producing Party affix in a prominent place on the
8 exterior of the container or containers in which the information is stored the legend
9 “CONFIDENTIAL.” If only a portion or portions of the information warrants
10 protection, the Producing Party, to the extent practicable, shall identify the
11 protected portion(s).
12 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13 failure to designate qualified information or items does not, standing alone, waive
14 the Designating Party’s right to secure protection under this Order for such
15 material. Upon timely correction of a designation, the Receiving Party must make
16 reasonable efforts to assure that the material is treated in accordance with the
17 provisions of this Order.
18 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37-1 et seq.
24 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
25 joint stipulation pursuant to Local Rule 37-2.
26 8.4 The burden of persuasion in any such challenge proceeding shall be on
27 the Designating Party. Frivolous challenges, and those made for an improper
28 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
1 parties) may expose the Challenging Party to sanctions. Unless the Designating
2 Party has waived or withdrawn the confidentiality designation, all parties shall
3 continue to afford the material in question the level of protection to which it is
4 entitled under the Producing Party’s designation until the Court rules on the
5 challenge.
6 9. ACCESS TO AND USE OF PROTECTED MATERIAL
7 9.1 Basic Principles. A Receiving Party may use Protected Material that is
8 disclosed or produced by another Party or by a Non-Party in connection with this
9 Action only for prosecuting, defending or attempting to settle this Action or any
10 pending actions by Plaintiff against Defendants. Such Protected Material may be
11 disclosed only to the categories of persons and under the conditions described in
12 this Order. When the Action has been terminated, a Receiving Party must comply
13 with the provisions of section 15 below (FINAL DISPOSITION).
14 Protected Material must be stored and maintained by a Receiving Party at a
15 location and in a secure manner that ensures that access is limited to the persons
16 authorized under this Order.
17 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
18 otherwise ordered by the court or permitted in writing by the Designating Party, a
19 Receiving Party may disclose any information or item designated
20 “CONFIDENTIAL” only to:
21 (a) the Receiving Party’s Outside Counsel of Record in this Action,
22 as well as employees of said Outside Counsel of Record to whom it is
23 reasonably necessary to disclose the information for this Action;
24 (b) the officers, directors, and employees (including House
25 Counsel) of the Receiving Party to whom disclosure is reasonably necessary
26 for litigation decisions in this Action or any pending action by Plaintiff
27 against Defendants;
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1 (c) Experts (as defined in this Order) of the Receiving Party to
2 whom disclosure is reasonably necessary for this Action and who have
3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and
7 Professional Vendors to whom disclosure is reasonably necessary for this
8 Action and who have signed the “Acknowledgment and Agreement to Be
9 Bound” (Exhibit A);
10 (g) the author or recipient of a document containing the information
11 or a custodian or other person who otherwise possessed or knew
12 the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, in
14 the Action to whom disclosure is reasonably necessary provided: (1) the
15 deposing party requests that the witness sign the form attached as Exhibit A
16 hereto; and (2) they will not be permitted to keep any confidential
17 information unless they sign the “Acknowledgment and Agreement to Be
18 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
19 ordered by the court. Pages of transcribed deposition testimony or exhibits to
20 depositions that reveal Protected Material may be separately bound by the
21 court reporter and may not be disclosed to anyone except as permitted under
22 this Stipulated Protective Order; and
23 (i) any mediators or settlement officers and their supporting
24 personnel, mutually agreed upon by any of the parties engaged in settlement
25 discussions.
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1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification
7 shall include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or
9 order to issue in the other litigation that some or all of the material covered
10 by the subpoena or order is subject to this Protective Order. Such notification
11 shall include a copy of this Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be
13 pursued by the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with
15 the subpoena or court order shall not produce any information designated in
16 this action as “CONFIDENTIAL” before a determination by the court from
17 which the subpoena or order issued, unless the Party has obtained the
18 Designating Party’s permission. The Designating Party shall bear the burden
19 and expense of seeking protection in that court of its confidential material
20 and nothing in these provisions should be construed as authorizing or
21 encouraging a Receiving Party in this Action to disobey a lawful directive
22 from another court.
23 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
24 PRODUCED IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced
26 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
27 information produced by Non-Parties in connection with this litigation is
28 protected by the remedies and relief provided by this Order. Nothing in these
1 provisions should be construed as prohibiting a Non-Party from seeking
2 additional protections.
3 (b) In the event that a Party is required, by a valid discovery
4 request, to produce a Non-Party’s confidential information in its possession,
5 and the Party is subject to an agreement with the Non-Party not to produce
6 the Non-Party’s confidential information, then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-
8 Party that some or all of the information requested is subject to a
9 confidentiality agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the
11 Stipulated Protective Order in this Action, the relevant discovery
12 request(s), and a reasonably specific description of the information
13 requested; and
14 (3) make the information requested available for inspection by
15 the Non-Party, if requested.
16 (c) If the Non-Party fails to seek a protective order from this court
17 within 14 days of receiving the notice and accompanying information, the
18 Receiving Party may produce the Non-Party’s confidential information
19 responsive to the discovery request. If the Non-Party timely seeks a
20 protective order, the Receiving Party shall not produce any information in its
21 possession or control that is subject to the confidentiality agreement with the
22 Non-Party before a determination by the court. Absent a court order to the
23 contrary, the Non-Party shall bear the burden and expense of seeking
24 protection in this court of its Protected Material.
25 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27 Protected Material to any person or in any circumstance not authorized under this
28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
1 writing the Designating Party of the unauthorized disclosures, (b) use its best
2 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
3 person or persons to whom unauthorized disclosures were made of all the terms of
4 this Order, and (d) request such person or persons to execute the “Acknowledgment
5 an Agreement to Be Bound” attached hereto as Exhibit A.
6 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7 PROTECTED MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain
9 inadvertently produced material is subject to a claim of privilege or other
10 protection, the obligations of the Receiving Parties are those set forth in Federal
11 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify
12 whatever procedure may be established in an e-discovery order that provides for
13 production without prior privilege review. Pursuant to Federal Rule of Evidence
14 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
15 of a communication or information covered by the attorney-client privilege or work
16 product protection, the parties may incorporate their agreement in the stipulated
17 protective order submitted to the court.
18 14. MISCELLANEOUS
19 14.1 Right to Further Relief. Nothing in this Order abridges the right
20 of any person to seek its modification by the Court in the future.
21 14.2 Right to Assert Other Objections. By stipulating to the entry of
22 this Protective Order, no Party waives any right it otherwise would have to
23 object to disclosing or producing any information or item on any ground not
24 addressed in this Stipulated Protective Order. Similarly, no Party waives any
25 right to object on any ground to use in evidence of any of the material
26 covered by this Protective Order.
27 14.3 Filing Protected Material. A Party that seeks to file under seal
28 any Protected Material must comply with Local Civil Rule 79-5. Protected
1 Material may only be filed under seal pursuant to a court order authorizing
2 the sealing of the specific Protected Material. If a Party’s request to file
3 Protected Material under seal is denied by the court, then the Receiving Party
4 may file the information in the public record unless otherwise instructed by
5 the court.
6 15. FINAL DISPOSITION
7 After the final disposition of this Action, as defined in paragraph 6, within 60 days
8 of a written request by the Designating Party, each Receiving Party must return all
9 Protected Material to the Producing Party or destroy such material. As used in this
10 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
11 summaries, and any other format reproducing or capturing any of the Protected
12 Material. Whether the Protected Material is returned or destroyed, the Receiving
13 Party must submit a written certification to the Producing Party (and, if not the
14 same person or entity, to the Designating Party) by the 60-day deadline that (1)
15 identifies (by category, where appropriate) all the Protected Material that was
16 returned or destroyed and (2) affirms that the Receiving Party has not retained any
17 copies, abstracts, compilations, summaries or any other format reproducing or
18 capturing any of the Protected Material. Notwithstanding this provision, Counsel
19 are entitled to retain an archival copy of all pleadings, motion papers, trial,
20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
21 and trial exhibits, expert reports, attorney work product, and consultant and expert
22 work product, even if such materials contain Protected Material. Any such archival
23 copies that contain or constitute Protected Material remain subject to this Protective
24 Order as set forth in Section 6 (DURATION).
25 16. VIOLATION
26 Any violation of this Order may be punished by appropriate measures including,
27 without limitation, contempt proceedings and/or monetary sanctions.
28 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
1
DATED: March 13, 2026 BOKHOUR LAW GROUP, P.C.
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3 By: /s/ Mehrdad Bokhour
Mehrdad Bokhour
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5 DATED: March 13, 2026 FALAKASSA LAW, P.C.
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By: /s/ Joshua S. Falakassa
7 Joshua S. Falakassa
Attorneys for Plaintiff,
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JONATHON SAINZ
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DATED: March 13, 2026 BLANK ROME LLP
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By: /s/ Howard M. Knee
13 Caroline P. Donelan
Howard M. Knee
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Gabrielle I. Weiss
15 Attorneys for Defendants,
CENCORA, INC. and
16
AMERISOURCEBERGEN
17 DRUG CORPORATION
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1 || FOR GOOD CAUSE SHOWN, IT IS ORDERED.
3 DATED: March 16, 2026
bp (pe
tt fo
7 HON. DAVID T. BRISTOW
United States Magistrate Judge
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16
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 Jonathon Sainz v. Cencora, Inc. et al., United
9 States District Court for the Central District of California, Case No. 2:25-cv-
10 02230-JGB-DTB. I agree to comply with and to be bound by all the terms of this
11 Stipulated Protective Order and I understand and acknowledge that failure to so
12 comply could expose me to sanctions and punishment in the nature of contempt. I
13 solemnly promise that I will not disclose in any manner any information or item
14 that is subject to this Stipulated Protective Order to any person or entity except in
15 strict compliance with the provisions of this Order.
16 I further agree to submit to the jurisdiction of the United States District Court for
17 the Central District of California for enforcing the terms of this Stipulated
18 Protective Order, even if such enforcement proceedings occur after termination of
19 this action. I hereby appoint __________________________ [print or type full
20 name] of _______________________________________ [print or type full
21 address and telephone number] as my California agent for service of process in
22 connection with this action or any proceedings related to enforcement of this
23 Stipulated Protective Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26 Printed name: _______________________________
27 Signature: _________________________________
28