The opinion
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 1 of 15 Page ID #:104
LAW OFFICES OF DALE K. GALIPO
1
Dale K. Galipo, Esq. (SBN 144074)
2 dalekgalipo@yahoo.com
Marcel F. Sincich, Esq. (SBN 319508)
3 msincich@galipolaw.com
21800 Burbank Boulevard, Suite 310
4
Woodland Hills, CA 91367
5 Tel: (818) 347-3333
Fax: (818) 347-4118
6
LAW OFFICES OF GRECH & PACKER
7 Trenton C. Packer (SBN 241057)
tpacker@grechpackerlaw.com
8
7095 Indiana Ave Ste 200
9 Riverside, CA 92506
Tel: (951) 682-9311
10
Attorneys for Plaintiffs
11
12 Roger A. Colvin, Esq. (SBN 068773)
Araceli Almazan, Esq. (SBN 284225)
13 Attorneys at Law
13181 Crossroads Parkway North
14 Suite 400 – West Tower
City of Industry, CA 91746
15
Tel: (562) 699-5500 – Fax (562) 692-2244
16 rcolvin@agclawfirm.com
17 Attorneys for Defendants
18 UNITED STATES DISTRICT COURT
19 CENTRAL DISTRICT OF CALIFORNIA
20
HECTOR BARBA, SR, et al. CASE NO. 2:22-cv-08987-FMO (JEMx)
21
[Honorable Fernando M. Olguin]
22 Plaintiffs, Magistrate Judge John E. McDermott
23 v.
24 STIPULATED PROTECTIVE
CITY OF HUNTINGTON PARK, et
ORDER
25 al.,
26 Defendant(s).
27
28
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 2 of 15 Page ID #:105
1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary, or private information for which special protection from public
4 disclosure and from use for any purpose other than prosecuting this litigation may
5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
6 enter the following Stipulated Protective Order. The parties acknowledge that this
7 Stipulated Protective Order does not confer blanket protections on all disclosures or
8 responses to discovery and that the protection it affords from public disclosure and
9 use extends only to the limited information or items that are entitled to confidential
10 treatment under the applicable legal principles. The parties further acknowledge, as
11 set forth in Section 12.3 below, that this Stipulated Protective Order does not entitle
12 them to file confidential information under seal; Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a
14 party seeks permission from the Court to file material under seal. Discovery in this
15 action is likely to involve production of confidential, proprietary, or private
16 information for which special protection from public disclosure and from use for
17 any purpose other than prosecuting this litigation may be warranted.
18
19 1. GOOD CAUSE STATEMENT
20 This action is likely to involve confidential, proprietary, or private
21 information for which special protection from public disclosure and from use for
22 any purpose other than prosecution of this action is warranted. Such confidential
23 and proprietary materials and information consist of, among other things,
24 confidential business or financial information, information regarding confidential
25 business practices, or other confidential information (including information
26 implicating privacy rights of third parties), information otherwise generally
27 unavailable to the public, or which may be privileged or otherwise protected from
28 disclosure under state or federal statutes, court rules, case decisions, or common
2
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 3 of 15 Page ID #:106
1 law. Accordingly, to expedite the flow of information, to facilitate the prompt
2 resolution of disputes over confidentiality of discovery materials, to adequately
3 protect information the parties are entitled to keep confidential, to ensure that the
4 parties are permitted reasonable necessary uses of such material in preparation for
5 and in the conduct of trial, to address their handling at the end of the litigation, and
6 to serve the ends of justice, a protective order for such information is justified in
7 this matter. It is the intent of the parties that information will not be designated as
8 confidential for tactical reasons and that nothing be so designated without a good
9 faith belief that it has been maintained in a confidential, non-public manner, and
10 there is good cause why it should not be part of the public record of this case.
11
12 2. DEFINITIONS
13 2.1. Action: This pending federal lawsuit; Barba, et al. v. City of
14 Huntington Park, et al., Case No. 2:22-cv-08987-FMO (JEMx).
15 2.2. Challenging Party: A Party or Nonparty that challenges the
16 designation of information or items under this Order.
17 2.3. “CONFIDENTIAL” Information or Items: Information (regardless of
18 how it is generated, stored or maintained) or tangible things that qualify for
19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
20 the Good Cause Statement.
21 2.4. Counsel: Outside Counsel of Record and In-House Counsel (as well
22 as their support staff).
23 2.5. Designating Party: A Party or Nonparty that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 “CONFIDENTIAL.”
26 2.6. Disclosure or Discovery Material: All items or information, regardless
27 of the medium or manner in which it is generated, stored, or maintained (including,
28 among other things, testimony, transcripts, and tangible things), that is produced or
3
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 4 of 15 Page ID #:107
1 generated in disclosures or responses to discovery in this matter.
2 2.7. Expert: A person with specialized knowledge or experience in a
3 matter pertinent to the litigation who has been retained by a Party or its counsel to
4 serve as an expert witness or as a consultant in this Action.
5 2.8. House Counsel: Attorneys who are employees of a party to this
6 Action. House Counsel does not include Outside Counsel of Record or any other
7 outside counsel.
8 2.9. Non-party: Any natural person, partnership, corporation, association,
9 or other legal entity not named as a Party to this action.
10 2.10. Outside Counsel of Record: Attorneys who are not employees of a
11 party to this Action but are retained to represent or advise a party to this Action and
12 have appeared in this Action on behalf of that party or are affiliated with a law firm
13 which has appeared on behalf of that party, and includes support staff.
14 3.11. Party: Any party to this Action, including all of its officers, directors,
15 employees, consultants, retained experts, and Outside Counsel of Record (and their
16 support staffs).
17 3.12. Producing Party: A Party or Nonparty that produces Disclosure or
18 Discovery Material in this Action.
19 3.13. Professional Vendors: Persons or entities that provide litigation
20 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
21 demonstrations, and organizing, storing, or retrieving data in any form or medium)
22 and their employees and subcontractors.
23 3.14. Protected Material: Any Disclosure or Discovery Material that is
24 designated as “CONFIDENTIAL.”
25 3.15. Receiving Party: A Party that receives Disclosure or Discovery
26 Material from a Producing Party.
27
28 / / /
4
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 5 of 15 Page ID #:108
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge. This Order does not govern the use of Protected Material at trial.
9
10 4. DURATION
11 Once a case proceeds to trial, all of the information that was designated as
12 confidential or maintained pursuant to this Stipulated Protective Order becomes
13 public and presumptively will be available to all members of the public, including
14 the press, unless compelling reasons supported by specific factual findings to
15 proceed otherwise are made to the trial judge in advance of the trial. See
16 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006)
17 (distinguishing “good cause” showing for sealing documents produced in discovery
18 from “compelling reasons” standard when merits-related documents are part of
19 court record). Accordingly, the terms of this Stipulated Protective Order do not
20 extend beyond the commencement of the trial.
21
22 5. DESIGNATING PROTECTED MATERIAL
23 5.1. Exercise of Restraint and Care in Designating Material for Protection.
24 Each Party or Non-Party that designates information or items for protection under
25 this Order must take care to limit any such designation to specific material that
26 qualifies under the appropriate standards. The Designating Party must designate for
27 protection only those parts of material, documents, items, or oral or written
28 communications that qualify so that other portions of the material, documents,
5
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 6 of 15 Page ID #:109
1 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
4 that are shown to be clearly unjustified or that have been made for an improper
5 purpose (e.g., to unnecessarily encumber the case development process or to
6 impose unnecessary expenses and burdens on other parties) may expose the
7 Designating Party to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 5.2. Manner and Timing of Designations. Except as otherwise provided in
12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
14 under this Order must be clearly so designated before the material is disclosed or
15 produced.
16 Designation in conformity with this Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 documents, but excluding transcripts of depositions or other pretrial or trial
19 proceedings), that the Producing Party affix at a minimum, the legend
20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
21 contains protected material. If only a portion or portions of the material on a page
22 qualifies for protection, the Producing Party also must clearly identify the protected
23 portion(s) (e.g., by making appropriate markings in the margins).
24 A Party or Non-Party that makes original documents available for inspection
25 need not designate them for protection until after the inspecting Party has indicated
26 which documents it would like copied and produced. During the inspection and
27 before the designation, all of the material made available for inspection shall be
28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
6
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 7 of 15 Page ID #:110
1 documents it wants copied and produced, the Producing Party must determine
2 which documents, or portions thereof, qualify for protection under this Order. Then,
3 before producing the specified documents, the Producing Party must affix the
4 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
5 portion or portions of the material on a page qualifies for protection, the Producing
6 Party also must clearly identify the protected portion(s) (e.g., by making
7 appropriate markings in the margins).
8 (b) for testimony given in depositions that the Designating Party identify
9 the Disclosure or Discovery Material on the record, before the close of the
10 deposition all protected testimony.
11 (c) for information produced in some form other than documentary and
12 for any other tangible items, that the Producing Party affix in a prominent place on
13 the exterior of the container or containers in which the information is stored the
14 legend “CONFIDENTIAL.” If only a portion or portions of the information
15 warrants protection, the Producing Party, to the extent practicable, shall identify the
16 protected portion(s).
17 5.3. Inadvertent Failure to Designate. If timely corrected, an inadvertent
18 failure to designate qualified information or items does not, standing alone, waive
19 the Designating Party’s right to secure protection under this Order for such
20 material. Upon timely correction of a designation, the Receiving Party must make
21 reasonable efforts to assure that the material is treated in accordance with the
22 provisions of this Order.
23
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1. Timing of Challenges. Any Party or Nonparty may challenge a
26 designation of confidentiality at any time that is consistent with the Court’s
27 Scheduling Order.
28 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
7
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 8 of 15 Page ID #:111
1 resolution process, which shall comply with Local Rule 37.1 et seq.
2 6.3. The burden of persuasion in any such challenge proceeding shall be on
3 the Designating Party. Frivolous challenges, and those made for an improper
4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
5 parties) may expose the Challenging Party to sanctions. Unless the Designating
6 Party has waived or withdrawn the confidentiality designation, all parties shall
7 continue to afford the material in question the level of protection to which it is
8 entitled under the Producing Party’s designation until the Court rules on the
9 challenge.
10 7. ACCESS TO AND USE OF PROTECTED MATERIALS
11 7.1. Basic Principles. A Receiving Party may use Protected Material that is
12 disclosed or produced by another Party or by a Non-Party in connection with this
13 Action only for prosecuting, defending, or attempting to settle this Action. Such
14 Protected Material may be disclosed only to the categories of persons and under the
15 conditions described in this Order. When the Action has been terminated, a
16 Receiving Party must comply with the provisions of section 13 below (FINAL
17 DISPOSITION).
18 Protected Material must be stored and maintained by a Receiving Party at a
19 location and in a secure manner that ensures that access is limited to the persons
20 authorized under this Order.
21 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
22 otherwise ordered by the court or permitted in writing by the Designating Party, a
23 Receiving Party may disclose any information or item designated
24 “CONFIDENTIAL” only to:
25 (a) the Receiving Party’s Outside Counsel of Record in this Action,
26 as well as employees of said Outside Counsel of Record to whom it is reasonably
27 necessary to disclose the information for this Action;
28 (b) the officers, directors, and employees (including House
8
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 9 of 15 Page ID #:112
1 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this
2 Action;
3 (c) Experts (as defined in this Order) of the Receiving Party to
4 whom disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and
9 Professional Vendors to whom disclosure is reasonably necessary for this Action
10 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
11 A);
12 (g) the author or recipient of a document containing the information
13 or a custodian or other person who otherwise possessed or knew the information;
14 (h) during their depositions, witnesses ,and attorneys for witnesses,
15 in the Action to whom disclosure is reasonably necessary provided: (1) the
16 deposing party requests that the witness sign the form attached as Exhibit 1 hereto;
17 and (2) they will not be permitted to keep any confidential information unless they
18 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
19 otherwise agreed by the Designating Party or ordered by the court. Pages of
20 transcribed deposition testimony or exhibits to depositions that reveal Protected
21 Material may be separately bound by the court reporter and may not be disclosed to
22 anyone except as permitted under this Stipulated Protective Order; and
23 (i) any mediator or settlement officer, and their supporting
24 personnel, mutually agreed upon by any of the parties engaged in settlement
25 discussions.
26
27 / / /
28 / / /
9
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 10 of 15 Page ID #:113
1 8. 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 order
9 to issue in the other litigation that some or all of the material covered by the
10 subpoena or order is subject to this Protective Order. Such notification shall include
11 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 this
16 action as “CONFIDENTIAL” before a determination by the court from which the
17 subpoena or order issued, unless the Party has obtained the Designating Party’s
18 permission. The Designating Party shall bear the burden and expense of seeking
19 protection in that court of its confidential material and nothing in these provisions
20 should be construed as authorizing or encouraging a Receiving Party in this Action
21 to disobey a lawful directive from another court.
22
23 9. 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 by a
26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
27 produced by Non-Parties in connection with this litigation is protected by the
28 remedies and relief provided by this Order. Nothing in these provisions should be
10
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 11 of 15 Page ID #:114
1 construed as prohibiting a Non-Party from seeking additional protections.
2 (b) In the event that a Party is required, by a valid discovery request, to
3 produce a Non-Party’s confidential information in its possession, and the Party is
4 subject to an agreement with the Non-Party not to produce the Non-Party’s
5 confidential information, then the Party shall:
6 (1) promptly notify in writing the Requesting Party and the Non-
7 Party that some or all of the information requested is subject to a confidentiality
8 agreement with a Non-Party;
9 (2) promptly provide the Non-Party with a copy of the Stipulated
10 Protective Order in this Action, the relevant discovery request(s), and a reasonably
11 specific description of the information requested; and
12 (3) make the information requested available for inspection by the
13 Non-Party, if requested.
14 (c) If the Non-Party fails to seek a protective order from this court within
15 14 days of receiving the notice and accompanying information, the Receiving Party
16 may produce the Non-Party’s confidential information responsive to the discovery
17 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
18 not produce any information in its possession or control that is subject to the
19 confidentiality agreement with the Non-Party before a determination by the court.
20 Absent a court order to the contrary, the Non-Party shall bear the burden and
21 expense of seeking protection in this court of its Protected Material.
22
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party immediately must (1) notify in
27 writing the Designating Party of the unauthorized disclosures, (2) use its best
28 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the
11
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 12 of 15 Page ID #:115
1 person or persons to whom unauthorized disclosures were made of all the terms of
2 this Stipulated Protective Order, and (4) request such person or persons to execute
3 the “Acknowledgment and Agreement to be Bound” (Exhibit A).
4
5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
6 PROTECTED MATERIAL
7 When a Producing Party gives notice to Receiving Parties that certain
8 inadvertently produced material is subject to a claim of privilege or other
9 protection, the obligations of the Receiving Parties are those set forth in Federal
10 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
11 whatever procedure may be established in an e-discovery order that provides for
12 production without prior privilege review. Pursuant to Federal Rule of Evidence
13 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
14 of a communication or information covered by the attorney-client privilege or work
15 product protection, the parties may incorporate their agreement in the stipulated
16 protective order submitted to the court.
17
18 12. MISCELLANEOUS
19 12.1. Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 12.2. Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order no Party waives any right it otherwise would have to object to
23 disclosing or producing any information or item on any ground not addressed in
24 this Stipulated Protective Order. Similarly, no Party waives any right to object on
25 any ground to use in evidence of any of the material covered by this Protective
26 Order.
27 12.3. Filing Protected Material. A Party that seeks to file under seal any
28 Protected Material must comply with Civil Local Rule 79-5. Protected Material
12
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 13 of 15 Page ID #:116
1 may only be filed under seal pursuant to a court order authorizing the sealing of the
2 specific Protected Material at issue. If a Party's request to file Protected Material
3 under seal is denied by the court, then the Receiving Party may file the information
4 in the public record unless otherwise instructed by the court.
5
6 13. FINAL DISPOSITION
7 After the final disposition of this Action, as defined in paragraph 4, within 60
8 days of a written request by the Designating Party, each Receiving Party must
9 return all Protected Material to the Producing Party or destroy such material. As
10 used in this subdivision, “all Protected Material” includes all copies, abstracts,
11 compilations, summaries, and any other format reproducing or capturing any of the
12 Protected Material. Whether the Protected Material is returned or destroyed, the
13 Receiving Party must submit a written certification to the Producing Party (and, if
14 not the same person or entity, to the Designating Party) by the 60 day deadline that
15 (1) 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 4 (DURATION).
25 / / /
26 / / /
27 / / /
28 / / /
13
Case 2:22-cv-08987-FMO-JEM Document16 Filed 03/23/23 Page140f15 Page ID#:117
14. Any violation of this Order may be punished by any and all
2 || appropriate measures including, without limitation, contempt proceedings and/or
3 || monetary sanctions.
5 | ISSO STIPULATED, THROUGH COUNSEL OF RECORD.
7 || DATED: March 23, 2023 LAW OFFICES OF DALE K. GALIPO
LAW OFFICES OF GRECH & PACKER
By: /s/ Marcel F. Sincich
10 Dale K. Galipo, Esq.
11 Marcel F. Sincich, Esq.
Trenton C. Packer, Esq.
12 Attorneys for Plaintiffs
13
14 DATED: March 23, 2023 ALVEREZ-GLASMAN & COLVIN
15
By: /s/ Roger A. Colvin
16 Roger A. Colvin, Esq.
17 Araceli Almazan, Esq.
ig Attorneys for Defendants
19 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20
21 ph EWeDeral
Dated: 3/23/2023
22 John E. McDermott
23 United States Magistrate Judge
24
25
26
27
28
14
Case 2:22-cv-08987-FMO-JEM Document 16 Filed 03/23/23 Page 15 of 15 Page ID #:118
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [full name], of
4 [address], declare under penalty of perjury that I have read in its
5 entirety and understand the Stipulated Protective Order that was issued by the
6 United States District Court for the Central District of California on
7 [date] in the case of Barba, et al. v. City of Huntington Park, et al., Case No. 2:22-
8 cv-08987-FMO (JEMx). I agree to comply with and to be bound by all the terms of
9 this Stipulated Protective Order, and I understand and acknowledge that failure to
10 so comply could expose me to sanctions and punishment in the nature of contempt.
11 I solemnly promise that I will not disclose in any manner any information or item
12 that is subject to this Stipulated Protective Order to any person or entity except in
13 strict compliance with the provisions of this Stipulated Protective Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint [full name]
18 of [address and telephone number]
19 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.
21
22 Signature:
23 Printed Name:
24 Date:
25 City and State Where Sworn and Signed:
26
27
28
15