Opinion

Court: District Court, C.D. California
Filed: Aug 4, 2026
Cited by: 0 cases

The opinion

Bradley Arant Boult Cummings LLP

Robert J. McGahan

3 California Bar No.: 196568

BRADLEY ARANT BOULT

CUMMINGS LLP

5 1900 K Street, Suite 800

Washington, D.C. 20006

Phone: (202) 719-8298

7 Fax: (202) 347-1684

bmcgahan@bradley.com

Attorney for Defendant SoFi Bank N.A.

IN THE UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

ANTHONY MICHAEL VALDEZ, )

12 Case No. 2:25-cv-11851-FMO-SSC

)

13 Plaintiff, )

STIPULATED PROTECTIVE

)

14 ORDER1

v. )

15 )

BANK OF AMERICA N.A.; )

GOLDMAN SACHS GROUP, INC.; )

17 and SOFI BANK, N.A., )

Defendants. )

Plaintiff Anthony Michael Valdez (“Plaintiff”) and Defendant SoFi Bank, N.A.

(“SoFi”) stipulate to the entry of this Protective Order (the “Order”) and agree that it

shall control the dissemination of all documents, materials, and other information,

including the substance, content, copies, and summaries thereof, by any party in the

above-captioned litigation and any appeals thereto.

Therefore, the Parties request that the Court enter this Protective Order.

1 This Stipulated Protective Order is substantially based on the model protective

order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of

1 For good cause shown, IT IS HEREBY ORDERED:

2 1. INTRODUCTION

3 1.1 Purposes and Limitations. Discovery in this action is likely to involve

4 production of confidential, proprietary, or private information for which special

5 protection from public disclosure and from use for any purpose other than prosecuting

6 this litigation may be warranted. Accordingly, the parties hereby stipulate to and

7 petition the court to enter the following Stipulated Protective Order. The parties

8 acknowledge that this Order does not confer blanket protections on all disclosures or

9 responses to discovery and that the protection it affords from public disclosure and

10 use extends only to the limited information or items that are entitled to confidential

11 treatment under the applicable legal principles.

12 1.2 Good Cause Statement. This action is likely to involve trade secrets, and

13 development, commercial, financial, technical and/or proprietary information for

14 which special protection from public disclosure and from use for any purpose other

15 than prosecution of this action is warranted. Such confidential and proprietary

16 materials and information consist of, among other things, confidential business or

17 financial information, information regarding confidential business practices, or other

18 confidential development, or commercial information (including information

19 implicating privacy rights of third parties), information otherwise generally

20 unavailable to the public, or which may be privileged or otherwise protected from

21 disclosure under state or federal statutes, court rules, case decisions, or common law.

22 Accordingly, to expedite the flow of information, to facilitate the prompt resolution

23 of disputes over confidentiality of discovery materials, to adequately protect

24 information the parties are entitled to keep confidential, to ensure that the parties are

25 permitted reasonable necessary uses of such material in preparation for and in the

26 conduct of trial, to address their handling at the end of the litigation, and serve the

27 ends of justice, a protective order for such information is justified in this matter. It is

1 the intent of the parties that information will not be designated as confidential for

2 tactical reasons and that nothing be so designated without a good faith belief that it

3 has been maintained in a confidential, non-public manner, and there is good cause

4 why it should not be part of the public record of this case.

5 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties

6 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

7 Order does not entitle them to file confidential information under seal; Local Rule 79-

8 5 sets forth the procedures that must be followed and the standards that will be applied

9 when a party seeks permission from the court to file material under seal.

10 There is a strong presumption that the public has a right of access to judicial

11 proceedings and records in civil cases. In connection with non-dispositive motions,

12 good cause must be shown to support a filing under seal. See Kamakana v. City and

13 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd

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

15 Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective

16 orders require good cause showing), and a specific showing of good cause or

17 compelling reasons with proper evidentiary support and legal justification, must be

18 made with respect to Protected Material that a party seeks to file under seal. The

19 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL

20 does not—without the submission of competent evidence by declaration,

21 establishing that the material sought to be filed under seal qualifies as confidential,

22 privileged, or otherwise protectable—constitute good cause.

23 Further, if a party requests sealing related to a dispositive motion or trial, then

24 compelling reasons, not only good cause, for the sealing must be shown, and the

25 relief sought shall be narrowly tailored to serve the specific interest to be protected.

26 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each

27 item or type of information, document, or thing sought to be filed or introduced under

1 seal in connection with a dispositive motion or trial, the party seeking protection

2 must articulate compelling reasons, supported by specific facts and legal

3 justification, for the requested sealing order. Again, competent evidence supporting

4 the application to 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.

7 If 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 entirety

10 should include an explanation of why redaction is not feasible.

11 2. DEFINITIONS

2.1 Action: This pending federal lawsuit.

2.2 Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

the Good Cause Statement.

2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

support staff).

2.5 Designating Party: a Party or Non-Party that designates information or

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

“CONFIDENTIAL.”

2.6 Disclosure or Discovery Material: all items or information, regardless of

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

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

generated in disclosures or responses to discovery in this matter.

1 2.7 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 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in

5 this Action, with or without prejudice; and (2) final judgment herein after the

6 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of

7 this Action, including the time limits for filing any motions or applications for

8 extension of time pursuant to applicable law.

9 2.9 In-House Counsel: attorneys who are employees of a party to this Action.

10 In-House Counsel does not include Outside Counsel of Record or any other outside

11 counsel.

12 2.10 Non-Party: any natural person, partnership, corporation, association, or

13 other legal entity not named as a Party to this action.

14 2.11 Outside Counsel of Record: attorneys who are not employees of a party

15 to this Action but are retained to represent or advise a party to this Action and have

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

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

18 2.12 Party: any party to this Action, including all of its officers, directors,

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

20 support staff).

21 2.13 Producing Party: a Party or Non-Party that produces Disclosure or

22 Discovery Material in this Action.

23 2.14 Professional Vendors: persons or entities that provide litigation- support

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

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

26 and their employees and subcontractors.

27 2.15 Protected Material: any Disclosure or Discovery Material that is

1 designated as “CONFIDENTIAL.”

2 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material

3 from a Producing Party.

4 3. SCOPE

The protections conferred by this Stipulation and Order cover not only

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

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

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

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

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

trial judge. This Stipulated Protective Order does not govern the use of Protected

Material at trial.

4. TRIAL AND DURATION

The terms of this Stipulated Protective Order apply through Final Disposition

of the Action.

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

CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and

used or introduced as an exhibit at trial becomes public and will be presumptively

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

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

in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

cause” showing for sealing documents produced in discovery from “compelling

reasons” standard when merits-related documents are part of court record).

Accordingly, for such materials, the terms of this Stipulated Protective Order do not

extend beyond the commencement of the trial.

Even after Final Disposition of this litigation, the confidentiality obligations

1 Party agrees otherwise in writing or a court order otherwise directs.

2 5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

under the appropriate standards. The Designating Party must designate for protection

only those parts of material, documents, items, or oral or written communications that

qualify so that other portions of the material, documents, items, or communications

for which protection is not warranted are not swept unjustifiably within the ambit of

this Order.

Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

unnecessary expenses and burdens on other parties) may expose the Designating

Party to sanctions.

If it comes to a Designating Party’s attention that information or items that it

designated for protection do not qualify for protection, that Designating Party must

promptly notify all other Parties that it is withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise provided in

this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below),

or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies

for protection under this Stipulated Protective Order must be clearly so designated

before the material is disclosed or produced.

Designation in conformity with this Stipulated Protective Order requires:

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

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

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

1 “CONFIDENTIAL” to each page that contains protected material. If only a portion

2 or portions of the material on a page qualifies for protection, the Producing Party

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

4 markings in the margins).

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

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

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

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

9 deemed CONFIDENTIAL. After the inspecting Party has identified the documents

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

11 or portions thereof, qualify for protection under this Stipulated Protective Order.

12 Then, before producing the specified documents, the Producing Party must affix the

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

14 portion or portions of the material on a page qualifies for protection, the Producing

15 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

16 markings in the margins).

17 (b) for testimony given in depositions that the Designating Party identify

18 the Disclosure or Discovery Material on the record, before the close of the deposition

19 all protected testimony.

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

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

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

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

24 protection, the Producing Party, to the extent practicable, shall identify the protected

25 portion(s).

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

1 Designating Party’s right to secure protection under this Order for such material.

2 Upon timely correction of a designation, the Receiving Party must make reasonable

3 efforts to assure that the material is treated in accordance with the provisions of this

4 Stipulated Protective Order.

5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

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

Scheduling Order.

6.2 Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge

Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2

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

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

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

may expose the Challenging Party to sanctions. Unless the Designating Party has

waived or withdrawn the confidentiality designation, all parties shall continue to

afford the material in question the level of protection to which it is entitled under the

Producing Party’s designation until the court rules on the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

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

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

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

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

conditions described in this Order. When the Action reaches a Final Disposition, a

Receiving Party must comply with the provisions of section 13 below.

2 Judge Christensen’s Procedures are available at

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

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

3 authorized under this Stipulated Protective Order.

4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

6 Receiving Party may disclose any information or item designated

7 “CONFIDENTIAL” only:

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

9 well as employees of said Outside Counsel of Record to whom it is reasonably

10 necessary to disclose the information for this Action;

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

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

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

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

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

16 (d) to the court and its personnel;

17 (e) to court reporters and their staff;

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

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

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

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

22 custodian or other person who otherwise possessed or knew the information;

23 (h) during their depositions, to witnesses, and attorneys for witnesses, in the

24 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party

25 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”

26 (Exhibit A); and (2) the witness will not be permitted to keep any confidential

27 information unless they sign the “Acknowledgment and Agreement to Be Bound”

1 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the

2 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal

3 Protected Material may be separately bound by the court reporter and may not be

4 disclosed to anyone except as permitted under this Stipulated Protective Order; and

5 (i) to any mediator or settlement officer, and their supporting personnel,

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

7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

8 PRODUCED IN OTHER LITIGATION

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

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

“CONFIDENTIAL,” that Party must:

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

include a copy of the subpoena or court order;

(b) promptly notify in writing the party who caused the subpoena 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. Such notification shall include a copy of

this Stipulated Protective Order; and

by the Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served

with the subpoena or court order shall not produce any information designated in this

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

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

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

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

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

to disobey a lawful directive from another court.

1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

2 PRODUCED IN THIS LITIGATION

3 9.1 Application. The terms of this Stipulated Protective Order are applicable

4 to information produced by a Non-Party in this Action and designated as

5 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with

6 this litigation is protected by the remedies and relief provided by this Order. Nothing

7 in these provisions should be construed as prohibiting a Non-Party from seeking

8 additional protections.

9 9.2 Notification. In the event that a Party is required, by a valid discovery

10 request, to produce a Non-Party’s confidential information in its possession, and the

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

12 confidential information, then the Party shall:

13 (a) promptly notify in writing the Requesting Party and the Non-Party that

14 some or all of the information requested is subject to a confidentiality agreement with

15 a Non-Party;

16 (b) make the information requested available for inspection by the Non-

17 Party, if requested.

18 9.3 Conditions of Production. If the Non-Party fails to seek a protective

19 order from this court within 14 days of receiving the notice and accompanying

20 information, the Receiving Party may produce the Non-Party’s confidential

21 information responsive to the discovery request. If the Non-Party timely seeks a

22 protective order, the Receiving Party shall not produce any information in its

23 possession or control that is subject to the confidentiality agreement with the Non-

24 Party before a determination by the court. Absent a court order to the contrary, the

25 Non-Party shall bear the burden and expense of seeking protection in this court of its

26 Protected Material.

27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

5 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

6 persons to whom unauthorized disclosures were made of all the terms of this Order,

7 and (d) request such person or persons to execute the “Acknowledgment and

8 Agreement to Be Bound” (Exhibit A).

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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

the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the

Federal Rules of Civil Procedure. This provision is not intended to modify whatever

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

without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules

of Evidence, insofar as the parties reach an agreement on the effect of disclosure of

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

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

protective order submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Stipulated Protective Order

abridges the right of any person to seek its modification by the court in the future.

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

Stipulated Protective Order no Party waives any right it otherwise would have to

object to disclosing or producing any information or item on any ground not

1 to object on any ground to use in evidence of any of the material covered by this

2 Stipulated Protective Order.

3 12.3 Filing Protected Material. A Party that seeks to file under seal any

4 Protected Material must comply with Local Rule 79-5. Protected Material may only

5 be filed under seal pursuant to a court order authorizing the sealing of the specific

6 Protected Material at issue. If a Party's request to file Protected Material under seal

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

8 record unless otherwise instructed by the court.

9 13. FINAL DISPOSITION

After the Final Disposition of this Action, as defined in paragraph 4, within

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

that contain or constitute Protected Material remain subject to this Protective Order

as set forth in Section 4.

1 14. VIOLATION

2 Any violation of this Stipulated Protective Order may be punished by any and

3 all appropriate measures including, without limitation, contempt proceedings and/or

4 monetary sanctions.

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

3 DATED: August 3, 2026 _/s/ Charles B. Cummins__________

Matthew M. Loker, Esq. (279939)

Charles B. Cummins, Esq. (354861)

5 Loker Law, APC

132 Bridge Street

Arroyo Grande, CA 93420

7 (805) 994-0177

Matt.loker@loker.law

Charles.cummins@loker.law

9 Attorneys for Plaintiff

DATED: August 3, 2026 _/s/ Robert J. McGahan

12 Robert J. McGahan

California Bar No.: 196568

BRADLEY ARANT BOULT

14 CUMMINGS LLP

15 1615 L Street NW, Suite 1350

Washington, D.C. 20036

16 Phone: (202) 719-8298

17 Fax: (202) 347-1684

bmcgahan@bradley.com

18 Attorney for Defendant SoFi Bank N.A.

21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

August 4, 2026

23 DATED:_____________ _________________________________

24 STEPHANIE S. CHRISTENSEN

United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under penalty of perjury

that I have read in its entirety and understand the Stipulated Protective Order that

was issued by the United States District Court for the Central District of California

in the case of Anthony Michael Valdez v. Bank of America, N.A. et al, 2:25-cv-

11851-FMO-SSC. I agree to comply with and to be bound by all the terms of this

Stipulated Protective Order 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 will not disclose in any manner any information or item

that is subject to this Stipulated Protective Order to any person or entity except in

strict compliance with the provisions of this Order.

I further agree to submit to the jurisdiction of the United States District Court

for the Central District of California for the purpose of enforcing the terms of this

Stipulated Protective Order, even if such enforcement proceedings occur after

termination of this action. I hereby appoint ________________________ [print

or type full name] of _________ [print or type full address and telephone

number] as my California agent for service of process in connection with this

action or any proceedings related to enforcement of this Stipulated Protective Order.

Date: ___________________________

City and State where sworn and signed:

24 ___________________________

Printed name: ___________________________

Signature: ___________________________

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