Opinion

Mendoza

Court
District Court, E.D. California
Filed
Aug 11, 2026
Cited by
0 cases

The opinion

1 Carolyn Hunt Cottrell (SBN 166977)

Esther L. Bylsma (SBN 264208)

2 Sandra Acosta Tello (SBN 315616)

Caroline L. Hill (SBN 349176)

3 SCHNEIDER WALLACE

COTTRELL KIM LLP

4 2000 Powell Street, Suite 1400

Emeryville, California 94608

5 Tel: (415) 421-7100; Fax: (415) 421-7105

ccottrell@schneiderwallace.com

6 ebylsma@schneiderwallace.com

sacostatello@schneiderwallace.com

7 chill@schneiderwallace.com

Attorneys for Plaintiff

8

9 UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA

10

SACRAMENTO DIVISION

11

BENTURA MENDOZA, Case No.: 2:24−CV−03371−DAD−CSK

12

Plaintiff,

13

PROTECTIVE ORDER

V.

14

15 MOVEMENT MORTGAGE, LLC,

16 Defendant.

17

18 1. PURPOSES AND LIMITATIONS

19 Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary,

20 or private information for which special protection from public disclosure and from use for any purpose other than

21 prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to

22 enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket

23 protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and

24 use extends only to the limited information or items that are entitled to confidential treatment under the applicable

25 legal principles. "[B]lanket orders are inherently subject to challenge and modification, as the party resisting

26 disclosure generally has not made a particularized showing of good cause with respect to any individual

27 document."(See San Jose Mercury News, Inc. v. U.S. Dist. Court--N. Dist. (San Jose), 187 F.3d 1096, 1103 (9th Cir.

1 According to the requirements of Local Rule 141.1(c), protective orders must contain "(1) A description of

2 the types of information eligible for protection under the order, with the description provided in general terms

3 sufficient to reveal the nature of the information (e.g., customer list, formula for soda, diary of a troubled child."

4 Pursuant to Local Rule 141.1(c), the parties identify the following categories of information, described in general

5 terms, that are eligible for designation as “CONFIDENTIAL” under this Order, together with the particularized need

6 for protection of each such category. Just because certain categories of information are identified below does not

7 mean that the Parties agree to disclose or exchange such information.

8 (a) Documents that refer, reflect, or relate to Plaintiff’s personal private information, including but not

9 limited to compensation, financial information, medical and health information. These documents

10 contain sensitive business information and third-party information. The nature of this employment

11 litigation makes it likely that Protected Material will need to be shared with experts, consultants, and

12 other individuals beyond the parties and their counsel, and a court order is required to impose binding

13 confidentiality obligations on such persons.

14 (b) Documents that refer, reflect, or relate to company and/or confidential or proprietary information,

15 including financial information, as well as documents and information related to Defendant’s other

16 personnel. These documents contain sensitive business information and private third-party information.

17 The nature of this employment litigation makes it likely that Protected Material will need to be shared

18 with experts, consultants, and other individuals beyond the parties and their counsel, and a court order

19 is required to impose binding confidentiality obligations on such persons.

20 Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated

21 Protective Order. The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

22 Order does not entitle them to file confidential information under seal; Civil Local Rules 140, 141 and 141.1 set

23 forth the procedures that must be followed and the standards that will be applied when a party seeks permission from

24 the court to file material under seal.

25 The parties further acknowledge that the Court’s Local Rules indicate that once an action is closed, it “will

26 not retain jurisdiction over enforcement of the terms of any protective order filed in that action.” L.R. 141.1(f); see

27 Bylin Heating Sys., Inc. v. Thermal Techs., Inc., 2012 WL 13237584, at *2 (E.D. Cal. Oct. 29, 2012) (noting that

1 case). Thus, the Court will not retain jurisdiction over this protective order once the case is closed.

2 2. DEFINITIONS

3 2.1. Challenging Party: a Party or Non-Party that challenges the designation of information or items

4 under this Order.

5 2.2. “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, stored

6 or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c).

7 2.3. Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their

8 support staff).

9 2.4. Designating Party: a Party or Non-Party that designates information or items that it produces in

10 disclosures or in responses to discovery as “CONFIDENTIAL.”

11 2.5. Disclosure or Discovery Material: all items or information, regardless of the medium or manner in

12 which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible

13 things), that are produced or generated in disclosures or responses to discovery in this matter.

14 2.6. Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation

15 who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.

16 2.7. House Counsel: attorneys who are employees of a party to this action. House Counsel does not

17 include Outside Counsel of Record or any other outside counsel.

18 2.8. Non-Party: any natural person, partnership, corporation, association, or other legal entity not

19 named as a Party to this action.

20 2.9. Outside Counsel of Record: attorneys who are not employees of a party to this action but are

21 retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are

22 affiliated with a law firm which has appeared on behalf of that party.

23 2.10. Party: any party to this action, including all of its officers, directors, employees, consultants,

24 retained experts, and Outside Counsel of Record (and their support staffs).

25 2.11. Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this

26 action.

27 2.12. Professional Vendors: persons or entities that provide litigation support services (e.g.,

1 data in any form or medium) and their employees and subcontractors.

2 2.13. Protected Material: any Disclosure or Discovery Material that is designated as

3 “CONFIDENTIAL.”

4 2.14. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

5 3. SCOPE

6 The protections conferred by this Stipulation and Order cover not only Protected Material (as defined

7 above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts,

8 summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties

9 or their Counsel that might reveal Protected Material. However, the protections conferred by this Stipulation and

10 Order do not cover the following information: (a) any information that is in the public domain at the time of

11 disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a

12 result of publication not involving a violation of this Order, including becoming part of the public record through

13 trial or otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained by the

14 Receiving Party after the disclosure from a source who obtained the information lawfully and under no obligation of

15 confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a separate

16 agreement or order.

17 4. DURATION

18 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order shall

19 remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise directs. Final

20 disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this action, with or without

21 prejudice; and (2) final judgment herein after the completion and exhaustion of all appeals, rehearings, remands,

22 trials, or reviews of this action, including the time limits for filing any motions or applications for extension of time

23 pursuant to applicable law.

24 5. DESIGNATING PROTECTED MATERIAL

25 5.1. Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party

26 that designates information or items for protection under this Order must take care to limit any such designation to

27 specific material that qualifies under the appropriate standards. The Designating Party must designate for protection

1 portions of the material, documents, items, or communications for which protection is not warranted are not swept

2 unjustifiably within the ambit of this Order.

3 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly

4 unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or retard the case

5 development process or to impose unnecessary expenses and burdens on other parties) expose the Designating Party

6 to sanctions.

7 If it comes to a Designating Party’s attention that information or items that it designated for protection do

8 not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the

9 mistaken designation.

10 5.2. Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g., second

11 paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that

12 qualifies for protection under this Order must be clearly so designated before the material is disclosed or produced.

13 Designation in conformity with this Order requires:

14 (a) for information in documentary form (e.g., paper or electronic documents, but excluding transcripts of

15 depositions or other pretrial or trial proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to

16 each page that contains protected material. If only a portion or portions of the material on a page qualifies for

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

18 markings in the margins). A Party or Non-Party that makes original documents or materials available for inspection

19 need not designate them for protection until after the inspecting Party has indicated which material it would like

20 copied and produced. During the inspection and before the designation, all of the material made available for

21 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

22 copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for

23 protection under this Order. Then, before producing the specified documents, the Producing Party must affix the

24 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a portion or portions of the

25 material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s)

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

27 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the Designating Party

1 (c) for information produced in some form other than documentary and for any other tangible items, that

2 the Producing Party affix in a prominent place on the exterior of the container or containers in which the information

3 or item is stored the legend “CONFIDENTIAL.” If only a portion or portions of the information or item warrant

4 protection, the Producing Party, to the extent practicable, shall identify the protected portion(s).

5 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified

6 information or items does not, standing alone, waive the Designating Party’s right to secure protection under this

7 Order for such material. Upon timely correction of a designation, the Receiving Party must make reasonable efforts

8 to assure that the material is treated in accordance with the provisions of this Order.

9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

10 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation of confidentiality at

11 any time. Unless a prompt challenge to a Designating Party’s confidentiality designation is necessary to avoid

12 foreseeable, substantial unfairness, unnecessary economic burdens, or a significant disruption or delay of the

13 litigation, a Party does not waive its right to challenge a confidentiality designation by electing not to mount a

14 challenge promptly after the original designation is disclosed.

15 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution process by providing

16 written notice of each designation it is challenging and describing the basis for each challenge. To avoid ambiguity

17 as to whether a challenge has been made, the written notice must recite that the challenge to confidentiality is being

18 made in accordance with this specific paragraph of the Protective Order. The parties shall attempt to resolve each

19 challenge in good faith and must begin the process by conferring directly (in voice to voice dialogue; other forms of

20 communication are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging

21 Party must explain the basis for its belief that the confidentiality designation was not proper and must give the

22 Designating Party an opportunity to review the designated material, to reconsider the circumstances, and, if no

23 change in designation is offered, to explain the basis for the chosen designation. A Challenging Party may proceed

24 to the next stage of the challenge process only if it has engaged in this meet and confer process first or establishes

25 that the Designating Party is unwilling to participate in the meet and confer process in a timely manner.

26 6.3. Judicial Intervention. If the Parties cannot resolve a challenge without court intervention, the

27 Designating Party shall file and serve a motion to retain confidentiality under Civil Local Rules 140, 141, and 141.1

1 within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute, whichever is

2 earlier. Each such motion must be accompanied by a competent declaration affirming that the movant has complied

3 with the meet and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to

4 make such a motion including the required declaration within 21 days (or14 days, if applicable) shall automatically

5 waive the confidentiality designation for each challenged designation. In addition, the Challenging Party may file a

6 motion challenging a confidentiality designation at any time if there is good cause for doing so, including a

7 challenge to the designation of a deposition transcript or any portions thereof. Any motion brought pursuant to this

8 provision must be accompanied by a competent declaration affirming that the movant has complied with the meet

9 and confer requirements imposed by the preceding paragraph.

10 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous

11 challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

12 other parties) may expose the Challenging Party to sanctions. Unless the Designating Party has waived the

13 confidentiality designation by failing to file a motion to retain confidentiality as described above, all parties shall

14 continue to afford the material in question the level of protection to which it is entitled under the Producing Party’s

15 designation until the court rules on the challenge.

16 7. ACCESS TO AND USE OF PROTECTED MATERIAL

17 7.1. Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by

18 another Party or by a Non-Party in connection with this case only for prosecuting, defending, or attempting to settle

19 this litigation. Such Protected Material may be disclosed only to the categories of persons and under the conditions

20 described in this Order. When the litigation has been terminated, a Receiving Party must comply with the provisions

21 of section 13 below (FINAL DISPOSITION).

22 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner

23 that ensures that access is limited to the persons authorized under this Order.

24 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or

25 permitted in writing by the Designating Party, a Receiving Party may disclose any information or item

26 designated “CONFIDENTIAL” only to:

27 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees of said

1 have signed the “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A;

2 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to

3 whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and

4 Agreement to Be Bound” (Exhibit A);

5 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably

6 necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

7 (d) the court and its personnel;

8 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and

9 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the

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

11 (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary

12 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by

13 the Designating Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions

14 that reveal Protected Material must be separately bound by the court reporter and may not be disclosed to anyone

15 except as permitted under this Stipulated Protective Order.

16 (g) the author or recipient of a document containing the information or a custodian or other person

17 who otherwise possessed or knew the information.

18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any

20 information or items designated in this action as “CONFIDENTIAL,” that Party must:

21 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the

22 subpoena or court order;

23 (b) promptly notify in writing the party who caused the subpoena or order to issue in the other

24 litigation that some or all of the material covered by the subpoena or order is subject to this Protective Order. Such

25 notification shall include a copy of this Stipulated Protective Order; and

26 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating

27 Party whose Protected Material may be affected.

1 shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the

2 court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission.

3 The Designating Party shall bear the burden and expense of seeking protection in that court of its confidential

4 material –

5 and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to

6 disobey a lawful directive from another court.

7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION

8 (a) The terms of this Order are applicable to information produced by a Non-Party in this action

9 and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation

10 is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as

11 prohibiting a Non-Party from seeking additional protections.

12 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s

13 confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to

14 produce the Non-Party’s confidential information, then the Party shall:

15 (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of

16 the information requested is subject to a confidentiality agreement with a Non-Party;

17 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in this

18 litigation, the relevant discovery request(s), and a reasonably specific description of the

19 information requested; and

20 (3) make the information requested available for inspection by the Non-Party.

21 (c) If the Non-Party fails to object or seek a protective order from this court within 14 days of

22 receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential

23 information responsive to the discovery request. If the Non-Party timely seeks a protective order, the Receiving

24 Party shall not produce any information in its possession or control that is subject to the confidentiality agreement

25 with the Non-Party before a determination by the court. Absent a court order to the contrary, the Non-Party shall

26 bear the burden and expense of seeking protection in this court of its Protected Material.

27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

1 person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving Party must

2 immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to

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

4 disclosures were made of all the terms of this Order, and (d) request such person or persons to execute the

5 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.

6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL

7 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is

8 subject to a claim of privilege or other protection, the obligations of the Receiving Parties are those set forth in

9 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be

10 established in an e-discovery order that provides for production without prior privilege review. Pursuant to Federal

11 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a

12 communication or information covered by the attorney-client privilege or work product protection, the parties may

13 incorporate their agreement in the stipulated protective order submitted to the court.

14 12. MISCELLANEOUS

15 12.1. Right to Further Relief. Nothing in this Order abridges the right of any person to seek its

16 modification by the court in the future.

17 12.2. Right to Assert Other Objections. By stipulating to the entry of this Protective Order no Party

18 waives any right it otherwise would have to object to disclosing or producing any information or item on any ground

19 not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to object on any ground to use

20 in evidence of any of the material covered by this Protective Order.

21 12.3. Filing Protected Material. Without the written permission of the designating party or a court order

22 a Party may not file in the public record in this action any Protected Material. A Party that seeks to file under seal

23 any Protected Material must comply with Civil Local Rules 140, 141 and 141.1. Protected Material may only be

24 filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a

25 Receiving Party’s request to file Protected Material under seal pursuant to Civil Local Rules 140, 141 and 141.1 is

26 denied by the court, then the Receiving Party may file the information in the public record pursuant to Civil Local

27 Rules 140, 141 and 141.1, unless otherwise instructed by the court.

1 13. FINAL DISPOSITION

2 Within 60 days after the final disposition of this action, as defined in paragraph 4, each Receiving Party

3 must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all

4 Protected Material” includes all copies, abstracts, compilations, summaries, and any other format reproducing or

5 capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving

6 Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the

7 Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected

8 Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies,

9 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material.

10 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial,

11 deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports,

12 attorney work product, and consultant and expert work product, even if such materials contain Protected Material.

13 Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order as set

14 forth in Section 4 (DURATION).

15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

16 ECF CERTIFICATION

17 I, Caroline L. Hill, certify that the content of this document (Stipulated Protective Order) is acceptable to

18 the undersigned counsel of record to affix my electronic signature hereto.

19 /s/ Caroline L. Hill

20 Caroline L. Hill

21

22 ECF CERTIFICATION

23 I, Kevin Quan, certify that the content of this document (Stipulated Protective Order) is acceptable to the

24 undersigned counsel of record to affix my electronic signature hereto.

25

/s/ Kevin Quan

26 Kevin Quan

27

1

2

EXHIBIT A

3

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4

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

5

________________________________________________________________________ [print or type full

6

address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective

7

Order that was issued by the United States District Court for the Eastern District of California on __________ [date]

8

in the case of Mendoza v. Movement Mortgage., LLC, United States District Court Eastern District of California

9

Case No. 2:24-cv-03371-DAD-CSK. I agree to comply with and to be bound by all the terms of this Stipulated

10

Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and

11 punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or

12 item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the

13 provisions of this Order.

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

15 California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement

16 proceedings occur after termination of this action.

17 I hereby appoint ___________________________________________________ [print or type full name]

18 of ________________________________________________________________________ [print or type full

19 address and telephone number] as my California agent for service of process in connection with this action or any

20 proceedings related to enforcement of this Stipulated Protective Order.

Date: __________________________________________

21

Printed name: ____________________________________

22

23

Signature: _______________________________________

24

City and State where sworn and signed: ______________________________________________________

25

26

27

eee EOI I REE IED! IEEE IE EEE ESE ESE! IE EEE eee eee

1

2

{PROPOSED} ORDER

3

4

PURSUANT TO STIPULATION, IT IS SO ORDERED.

5

° || DATED: August 11. 2026 Cin Spe I

’ United States Magistrate Judge Chi Soo Kim

8

9

10

8, mend.3371.24

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

PROTECTIVE ORDER - 13

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.