John Kostikyan v. USAA Federal Savings Bank

1 Abraham J. Colman (SBN 146933)

Zachary C. Frampton (SBN 303225)

2 HOLLAND & KNIGHT LLP

400 South Hope Street, 8th Floor

3 Los Angeles, CA 90071

Tel.: 213.896.2400

4 Fax: 213.896.2450

E-mail: zac.frampton@hklaw.com

5 E-mail: abe.colman@hklaw.com

6 Attorneys for Defendant

USAA Federal Savings Bank

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 JOHN KOSTIKYAN, Case No.: 2:22-cv-08768-SVW-

(AFMx)

12 Plaintiff;

STIPULATED PROTECTIVE

13 v. ORDER1

14 USAA FEDERAL SAVINGS BANK,

ET AL.

15

Defendants.

16

17

18 Plaintiff John Kostikyan (“Plaintiff”) and defendant USAA Federal Savings

19 Bank (“Defendant”) hereby jointly submit for the Court’s approval in the above-

20 captioned action this proposed Stipulated Protective Order:

21

22 1. A. 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 disclosure

25 and from use for any purpose other than prosecuting this litigation may be warranted.

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

27

1 This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge

1 Stipulated Protective Order. The parties acknowledge that this Order does not confer

2 blanket protections on all disclosures or responses to discovery and that the protection

3 it affords from public disclosure and use extends only to the limited information or

4 items that are entitled to confidential treatment under the applicable legal principles.

5 B. GOOD CAUSE STATEMENT:

6 This action is likely to involve trade secrets, customer information, and other

7 valuable research, development, commercial, financial, technical and/or proprietary

8 information for which special protection from public disclosure and from use for any

9 purpose other than prosecution of this action is warranted. Such confidential and

10 proprietary materials and information consist of, among other things, confidential

11 business or financial information, non-public personal information, personal identifying

12 information and/or private financial information, information regarding confidential

13 business practices, or other confidential research, development, or commercial

14 information (including information implicating privacy rights of third parties),

15 information otherwise generally unavailable to the public, or which may be privileged

16 or otherwise protected from disclosure under state or federal statutes, court rules, case

17 decisions, or common law. Accordingly, to expedite the flow of information, to

18 facilitate the prompt resolution of disputes over confidentiality of discovery materials,

19 to adequately protect information the parties are entitled to keep confidential, to ensure

20 that the parties are permitted reasonable necessary uses of such material in preparation

21 for and in the conduct of trial, to address their handling at the end of the litigation, and

22 serve the ends of justice, a protective order for such information is justified in this

23 matter. It is the intent of the parties that information will not be designated as

24 confidential for tactical reasons and that nothing be so designated without a good faith

25 belief that it has been maintained in a confidential, non-public manner, and there is

26 good cause why it should not be part of the public record of this case.

27

1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

2 SEAL

3 The parties further acknowledge, as set forth in Section 12.3, below, that this

4 Stipulated Protective Order does not entitle them to file confidential information under

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

6 standards that will be applied when a party seeks permission from the court to file

7 material under seal. There is a strong presumption that the public has a right of access

8 to judicial proceedings and records in civil cases. In connection with non-dispositive

9 motions, good cause must be shown to support a filing under seal. See Kamakana v.

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

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

12 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

13 require good cause showing), and a specific showing of good cause or compelling

14 reasons with proper evidentiary support and legal justification, must be made with

15 respect to Protected Material that a party seeks to file under seal. The parties’ mere

16 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

17 without the submission of competent evidence by declaration, establishing that the

18 material sought to be filed under seal qualifies as confidential, privileged, or otherwise

19 protectable—constitute good cause. Further, if a party requests sealing related to a

20 dispositive motion or trial, then compelling reasons, not only good cause, for the

21 sealing must be shown, and the relief sought shall be narrowly tailored to serve the

22 specific interest to be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665,

23 677-79 (9th Cir. 2010). For each item or type of information, document, or thing sought

24 to be filed or introduced under seal in connection with a dispositive motion or trial, the

25 party seeking protection must articulate compelling reasons, supported by specific facts

26 and legal justification, for the requested sealing order. Again, competent evidence

27 supporting the application to file documents under seal must be provided by

declaration. Any document that is not confidential, privileged, or otherwise protectable

1 in its entirety will not be filed under seal if the confidential portions can be redacted.

2 If documents can be redacted, then a redacted version for public viewing, omitting only

3 the confidential, privileged, or otherwise protectable portions of the document, shall be

4 filed. Any application that seeks to file documents under seal in their entirety should

5 include an explanation of why redaction is not feasible.

6

7 2. DEFINITIONS

8 2.1 Action: [this pending federal lawsuit]. [*Option: consolidated or related

9 actions.]

10 2.2 Challenging Party: a Party or Non-Party that challenges the designation

11 of information or items under this Order.

12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

15 Statement.

16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

17 support staff).

18 2.5 Designating Party: a Party or Non-Party that designates information or

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

20 “CONFIDENTIAL.”

21 2.6 Disclosure or Discovery Material: all items or information, regardless of

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

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

24 in disclosures or responses to discovery in this matter.

25 2.7 Expert: a person with specialized knowledge or experience in a matter

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

27 expert witness or as a consultant in this Action.

1 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

3 counsel.

4 2.9 Non-Party: any natural person, partnership, corporation, association or

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

6 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

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

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

10 2.11 Party: any party to this Action, including all of its officers, directors,

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

12 support staffs).

13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

14 Discovery Material in this Action.

15 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

18 their employees and subcontractors.

19 2.14 Protected Material: any Disclosure or Discovery Material that is

20 designated as “CONFIDENTIAL.”

21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

22 from a Producing Party.

23 ///

24 ///

25 ///

26 ///

27 ///

///

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 extracted

4 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

5 Protected Material; and (3) any testimony, conversations, or presentations by Parties

6 or their Counsel that might reveal Protected Material.

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

8 judge. This Order does not govern the use of Protected Material at trial.

9

10 4. DURATION

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

12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

13 as an exhibit at trial becomes public and will be presumptively available to all members

14 of the public, including the press, unless compelling reasons supported by specific

15 factual findings to proceed otherwise are made to the trial judge in advance of the trial.

16 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing

17 documents produced in discovery from “compelling reasons” standard when merits-

18 related documents are part of court record). Accordingly, the terms of this protective

19 order do not extend beyond the commencement of the trial.

20

21 5. DESIGNATING PROTECTED MATERIAL

22 5.1 Exercise of Restraint and Care in Designating Material for

23 Protection. Each Party or Non-Party that designates information or items for protection

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

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

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

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

or communications for which protection is not warranted are not swept unjustifiably

1 within the ambit of this Order.

2 Mass, indiscriminate or routinized designations are prohibited. Designations that

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

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

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

6 to sanctions.

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

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

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

10 5.2 Manner and Timing of Designations. Except as otherwise provided in this

11 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

12 or ordered, Disclosure or Discovery Material that qualifies for protection under this

13 Order must be clearly so designated before the material is disclosed or produced.

14 Designation in conformity with this Order requires:

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

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

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

18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

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

20 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

21 by making appropriate markings in the margins).

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

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

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

25 the designation, all of the material made available for inspection shall be deemed

26 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

27 copied and produced, the Producing Party must determine which documents, or

portions thereof, qualify for protection under this Order. Then, before producing the

1 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”

2 to each page that contains Protected Material. If only a portion of the material on a

3 page qualifies for protection, the Producing Party also must clearly identify the

4 protected portion(s) (e.g., by making appropriate markings in the margins). (b) for

5 testimony given in depositions that the Designating Party identifies the Disclosure or

6 Discovery Material on the record, before the close of the deposition all protected

7 testimony. (c) for information produced in some form other than documentary and for

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

9 exterior of the container or containers in which the information is stored the legend

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

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

12 portion(s).

13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

16 timely correction of a designation, the Receiving Party must make reasonable efforts

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

18

19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

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

23 process under Local Rule 37-1 et seq.

24 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via

25 a joint stipulation pursuant to Local Rule 37-2. 6.4 The burden of persuasion in any

26 such challenge proceeding shall be on the Designating Party. Frivolous challenges, and

27 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

1 the Designating Party has waived or withdrawn the confidentiality designation, all

2 parties shall continue to afford the material in question the level of protection to which

3 it is entitled under the Producing Party’s designation until the Court rules on the

4 challenge.

5

6 7. ACCESS TO AND USE OF PROTECTED MATERIAL

7 7.1 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. Such

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

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

12 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

15 authorized under this Order.

16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

18 Receiving Party may disclose any information or item designated “CONFIDENTIAL”

19 only to:

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

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

22 necessary to disclose the information for this Action;

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

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

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

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

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

(d) the court and its personnel;

1 (e) court reporters and their staff;

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

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

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

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

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

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

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

9 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

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

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

12 by the Designating Party or ordered by the court. Pages of transcribed deposition

13 testimony or exhibits to depositions that reveal Protected Material may be separately

14 bound by the court reporter and may not be disclosed to anyone except as permitted

15 under this Stipulated Protective Order; and

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

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

18

19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

20 PRODUCED IN OTHER LITIGATION

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

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

23 as “CONFIDENTIAL,” that Party must:

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

25 shall include a copy of the subpoena or court order;

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

27 to issue in the other litigation that some or all of the material covered by the subpoena

1 or order is subject to this Protective Order. Such notification shall include a copy of

2 this Stipulated Protective Order; and

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

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

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

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

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

8 or order issued, unless the Party has obtained the Designating Party’s permission. The

9 Designating Party shall bear the burden and expense of seeking protection in that court

10 of its confidential material and nothing in these provisions should be construed as

11 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

12 directive from another court.

13

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

15 PRODUCED IN THIS LITIGATION

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

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

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

19 and relief provided by this Order. Nothing in these provisions should be construed as

20 prohibiting a Non-Party from seeking additional protections.

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

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

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

24 information, then the Party shall:

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

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

27 agreement with a Non-Party;

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

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

3 specific description of the information requested; and

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

5 Non-Party, if requested.

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

7 14 days of receiving the notice and accompanying information, the Receiving Party

8 may produce the Non-Party’s confidential information responsive to the discovery

9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not

10 produce any information in its possession or control that is subject to the confidentiality

11 agreement with the Non-Party before a determination by the court. Absent a court order

12 to the contrary, the Non-Party shall bear the burden and expense of seeking protection

13 in this court of its Protected Material.

14

15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

19 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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

21 whom unauthorized disclosures were made of all the terms of this Order, and (d)

22 request such person or persons to execute the “Acknowledgment and Agreement to Be

23 Bound” that is attached hereto as Exhibit A.

24

25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

26 PROTECTED MATERIAL

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

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

1 the obligations of the Receiving Parties are those set forth in Federal Rule of

2 Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever

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

4 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e),

5 insofar as the parties reach an agreement on the effect of disclosure of a communication

6 or information covered by the attorney-client privilege or work product protection, the

7 parties may incorporate their agreement in the stipulated protective order submitted to

8 the court.

9

10 12. MISCELLANEOUS

11 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

13 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

15 disclosing or producing any information or item on any ground not addressed in this

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

17 ground to use in evidence of any of the material covered by this Protective Order.

18 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

21 Protected Material at issue. If a Party’s request to file Protected Material under seal is

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

23 record unless otherwise instructed by the court.

24 ///

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1 13. FINAL DISPOSITION

2 After the final disposition of this Action, as defined in paragraph 4, within 60

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

4 all Protected Material to the Producing Party or destroy such material. As used in this

5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

6 summaries, and any other format reproducing or capturing any of the Protected

7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party

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

9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by

10 category, where appropriate) all the Protected Material that was returned or destroyed

11 and (2) affirms that the Receiving Party has not retained any copies, abstracts,

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

13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

15 legal memoranda, correspondence, deposition and trial exhibits, expert reports,

16 attorney work product, and consultant and expert work product, even if such materials

17 contain Protected Material. Any such archival copies that contain or constitute

18 Protected Material remain subject to this Protective Order as set forth in Section 4

19 (DURATION).

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1 || 14. VIOLATION

2 Any violation of this Order may be punished by appropriate measures includir

3 || without limitation, contempt proceedings and/or monetary sanctions.

4

5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

6

7 || Dated: March 30, 2023 HOLLAND & KNIGHT LLP

8 By: _ /s/ Zachary C. Frampton

9 Zachary C. Frampton (SBN 303225)

10 Attorneys for Defendant

USAA FEDERAL SAVINGS BANK

1]

D Dated: March 30, 2023 MCCARTHY LAW PLC

By: __/s/ Robert F. Brennan

S 14 Robert F. Brennan (SBN 132449)

= 15 Attorneys for Plaintiff

JOHN KOSTIKYAN

16

17

L.R. 5-4.3.4(a) CERTIFICATION

18

Pursuant to L.R. 5-4.3.4(a)(2), I, Zachary C. Frampton, hereby attest that

19

other signatories listed, and on whose behalf the filing is submitted, concur in t

20

filing’s content and have authorized the filing.

21

22 /s/ Zachary C. Frampton

Zachary C. Frampton

23

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

DATED: __ 3/29/2023

— Chey Me

27|| HON. ALEXANDER F. MacKINNON

28 || United States Magistrate Judge

-15-

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 that

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

7 by the United States District Court for the Central District of California on

8 [date] in the case of John Kostikyan, V. USAA Federal Savings

9 Bank, Et Al., Case No.: 2:22-cv-08768-MRW. I agree to comply with and to be bound

10 by all the terms of this Stipulated Protective Order and I understand and acknowledge

11 that failure to so comply could expose me to sanctions and punishment in the nature of

12 contempt. I solemnly promise that I will not disclose in any manner any information

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

14 in strict compliance with the provisions of this Order. I further agree to submit to the

15 jurisdiction of the United States District Court for the Central District of California for

16 enforcing the terms of this Stipulated Protective Order, even if such enforcement

17 proceedings occur after termination of this action. I hereby appoint

18 __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

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

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25 Printed name: _______________________________

26 Signature: __________________________________

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