even stipulated protective orders 22 require good cause showing
How later courts described this case
- even stipulated protective orders 22 require good cause showing
Written by the judges who cited it.
The opinion
Yakub Hazzard (SBN 150242) Travis A. Corder (SBN: 237575)
1
Rebecca Benyamin (SBN 334130) CORDER LAW OFFICE
2 MITCHELL SILBERBERG & KNUPP 11355 w. Olympic Blvd., Suite 200
LLP Los Angeles, CA 90064
3
2049 Century Park East, 18th Floor Telephone: (310) 775-5762
4 Los Angeles, CA 90067 Email: travisacorder@gmail.com
Telephone: (310) 312-2000
5
Email: yxh@msk.com Averil K. Andrews (SBN 315843)
6 Email: r1e@msk.com Patrick D. Vellone (pro hac vice)
7
ALLEN VELLONE WOLF HELFRICH &
Matthew Jones (pro hac vice) FACTOR P.C.
8 JONES & ADAMS, PA 1600 Stout Street, Suite 900
999 Ponce De Leon, Suite 925 Denver, CO 80202
9
Coral Gables, FL 33134 Telephone: (303) 534-4499
10 Telephone: (305) 270-8858 Email: aandrews@allen-vellone.com
Email: matthew@jones-
11
adams.com Attorneys for Petitioner
12 Email: steven@jones-adams.com
13
Attorneys for Respondents
14
15 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
16
WESTERN DIVISION
17
18 In The Matter Of The Arbitration Case No. 2:17-cv-01292-RGK
Between TRADEWINDS LTD., d/b/a
19
TRADEWINDS CONSULTING, LTD., RAO
20
Petitioner, STIPULATED
21 PROTECTIVE ORDER
22 v.
23
GRUPO DOLPHIN DISCOVERY and
24 CONTROLADORA DOLPHIN S.A. de
25 C.V.,
Respondents.
26
27
1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this judgment enforcement action may involve production of
3 confidential information of disinterested third parties for which special protection
4 from public disclosure and from use for any purpose other than enforcing the
5 judgment may be warranted. Accordingly, the parties hereby stipulate to and
6 petition the Court to enter the following Stipulated Protective Order. The judgment
7 debtors acknowledge that discovery in a judgment enforcement is distinct from a
8 pre-judgment action. Post judgment discovery favors “full discovery of any matter
9 arguably related to [the creditor’s] efforts to trace [the debtor’s] assets and
10 otherwise enforce its judgment.” A&F Bahamas, LLC, World Venture Group, Inc.,
11 CV 17-8523, 2018 WL 5961297 at *2 (C.D. Cal. 2018). Therefore, this Order is
12 narrowly tailored to protect the confidential information of disinterested third
13 parties. It does not confer protections to the financial information and business
14 information of the debtors. Not does it provide blanket protections on all
15 disclosures or responses to discovery. The protection this order affords from public
16 disclosure and use extends only to the limited information or items that are entitled
17 to confidential treatment under the applicable legal principles and pursuant to this
18 order.
19 B. GOOD CAUSE STATEMENT
20 The judgment debtors have requested entry of this protective order to
21 maintain the confidentiality of contracts with third parties that contain valid
22 confidentiality clauses. Plaintiff also agrees not to use the information or documents
23 acquired in discovery (that Plaintiff would not have had access to otherwise) for
24 competitive or commercial purposes. Plaintiff further agrees not to disseminate or
25 post information or documents acquired from Defendants in discovery (that
26 Plaintiff would not have had access to otherwise) on social media platforms. This
27 protective order is limited to these purposes. Accordingly, to expedite the flow
1 of discovery materials, to adequately protect information that third parties are
2 entitled to keep confidential, to ensure that the judgment creditor is permitted
3 reasonable necessary uses of such material to enforce the judgment, to address their
4 handling at the end of the litigation, and serve the ends of justice, a protective order
5 for such information is justified in this matter. It is the intent of the parties that
6 information will not be designated as confidential for tactical reasons and that
7 nothing be so designated without a good faith belief that it has been maintained in
8 a confidential, non-public manner, and there is good cause why it should not be part
9 of the public record of this case.
10 D. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER
11 SEAL
The parties further acknowledge, as set forth in Section 12.3, below, that this
12
Stipulated Protective Order does not entitle them to file confidential information
13
under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
14
and the standards that will be applied when a party seeks permission from the court
15
to file material under seal.
16
There is a strong presumption that the public has a right of access to judicial
17
proceedings and records in civil cases. In connection with non-dispositive motions,
18
good cause must be shown to support a filing under seal. See Kamakana v. City and
19
County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
20
Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
21
Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
22
require good cause showing), and a specific showing of good cause or compelling
23
reasons with proper evidentiary support and legal justification, must be made with
24
respect to Protected Material that a party seeks to file under seal. The parties’ mere
25
designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
26
without the submission of competent evidence by declaration, establishing that the
27
1 material sought to be filed under seal qualifies as confidential, privileged, or
2 otherwise protectable—constitute good cause.
3 Further, if a party requests sealing related to a motion, then compelling
4 reasons, not only good cause, for the sealing must be shown, and the relief sought
5 shall be narrowly tailored to serve the specific interest to be protected. See Pintos
6 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or
7 type of information, document, or thing sought to be filed or introduced under seal
8 in connection with a motion, the party seeking protection must articulate
9 compelling reasons, supported by specific facts and legal justification, for the
10 requested sealing order. Again, competent evidence supporting the application to
11 file documents under seal must be provided by declaration.
12 Any document that is not confidential, privileged, or otherwise protectable
13 in its entirety will not be filed under seal if the confidential portions can be redacted.
14 If documents can be redacted, then a redacted version for public viewing, omitting
15 only the confidential, privileged, or otherwise protectable portions of the document
16 shall be filed. Any application that seeks to file documents under seal in their
17 entirety should include an explanation of why redaction is not feasible.
18
2. DEFINITIONS
19
2.1 Action: this federal lawsuit.
20
2.2 Challenging Party: a Party or Non-Party that challenges the
21
designation of information or items under this Order.
22
2.3 “CONFIDENTIAL” Information or Items: information (regardless of
23
how it is generated, stored or maintained) or tangible things that qualify for
24
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
25
the Good Cause Statement.
26
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
27
their support staff).
1 2.5 Designating Party: a Party or Non-Party that designates information
2 or items that it produces in disclosures or in responses to discovery as
3 “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information, regardless
5 of the medium or manner in which it is generated, stored, or maintained (including,
6 among other things, testimony, transcripts, and tangible things) that are produced
7 or generated in disclosures or responses to discovery in this matter.
8 2.7 Expert: a person with specialized knowledge or experience in a matter
9 pertinent to the litigation who has been retained by a Party or its counsel to serve
10 as an expert witness or as a consultant in this Action.
11 2.8 House Counsel: attorneys who are employees of a party to this Action.
12 House Counsel does not include Outside Counsel of Record or any other outside
13 counsel.
14 2.9 Non-Party: any natural person, partnership, corporation, association or
15 other legal entity not named as a Party to this action.
16 2.10 Outside Counsel of Record: attorneys who are not employees of a
17 party to this Action but are retained to represent or advise a party to this Action and
18 have appeared in this Action on behalf of that party or are affiliated with a law firm
19 that has appeared on behalf of that party, and includes support staff.
20 2.11 Party: any party to this Action, including all of its officers, directors,
21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
24 Discovery Material in this Action.
25 2.13 Professional Vendors: persons or entities that provide litigation
26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium)
1 2.14 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 2.15 Receiving Party: a Party that receives Disclosure or Discovery
4 Material from a Producing Party.
5 3. SCOPE
6 The protections conferred by this Stipulation and Order cover not only
7 Protected Material (as defined above), but also (1) any information copied or
8 extracted from Protected Material; (2) all copies, excerpts, summaries, or
9 compilations of Protected Material; and (3) any testimony, conversations, or
10 presentations by Parties or their Counsel that might reveal Protected Material.
11 Any use of Protected Material in judgment enforcement proceedings shall be
12 governed by the orders of Court. This Order does not govern the use of Protected
13 Material at evidentiary hearings.
14 4. DURATION
15 If this case proceeds to a trial or evidentiary hearing, information that was
16 designated as CONFIDENTIAL or maintained pursuant to this protective order
17 used or introduced as an exhibit at any evidentiary hearing becomes public and will
18 be presumptively available to all members of the public, including the press, unless
19 compelling reasons supported by specific factual findings to proceed otherwise are
20 made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81
21 (distinguishing “good cause” showing for sealing documents produced in discovery
22 from “compelling reasons” standard when merits-related documents are part of
23 court record). Accordingly, the terms of this protective order do not extend beyond
24 the commencement of the trial or evidentiary hearing.
25 5. DESIGNATING PROTECTED MATERIAL
26 5.1 Exercise of Restraint and Care in Designating Material for Protection.
27 Each Party or Non-Party that designates information or items for protection under
1 qualifies under the appropriate standards. The Designating Party must designate for
2 protection only those parts of material, documents, items or oral or written
3 communications that qualify so that other portions of the material, documents,
4 items or communications for which protection is not warranted are not swept
5 unjustifiably within the ambit of this Order.
6 Mass, indiscriminate or routinized designations are prohibited. Designations
7 that are shown to be clearly unjustified or that have been made for an improper
8 purpose (e.g., to unnecessarily encumber the case development process or to
9 impose unnecessary expenses and burdens on other parties) may expose the
10 Designating Party to sanctions.
11 If it comes to a Designating Party’s attention that information or items that it
12 designated for protection do not qualify for protection, that Designating Party must
13 promptly notify all other Parties that it is withdrawing the inapplicable designation.
14 5.2 Manner and Timing of Designations. Except as otherwise provided in
15 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
17 under this Order must be clearly so designated before the material is disclosed or
18 produced.
19 Designation in conformity with this Order requires:
20 (a) for information in documentary form (e.g., paper or electronic
21 documents, but excluding transcripts of depositions or other pretrial or trial
22 proceedings), that the Producing Party affix at a minimum, the legend
23 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
24 contains protected material. If only a portion of the material on a page qualifies
25 for protection, the Producing Party also must clearly identify the protected
26 portion(s) (e.g., by making appropriate markings in the margins). The
27 producing party must also include a log that states the basis for each
1 nondisclosure agreement that requires the producing party to maintain that
2 document as confidential.)
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and
6 before the designation, all of the material made available for inspection shall be
7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
8 documents it wants copied and produced, the Producing Party must determine
9 which documents, or portions thereof, qualify for protection under this Order. Then,
10 before producing the specified documents, the Producing Party must affix the
11 “CONFIDENTIAL legend” to each page that contains Protected Material. If only
12 a portion of the material on a page qualifies for protection, the Producing Party also
13 must clearly identify the protected portion(s) (e.g., by making appropriate markings
14 in the margins).
15 (b) for testimony given in depositions that the Designating Party identifies
16 the Disclosure or Discovery Material on the record, before the close of the
17 deposition all protected testimony.
18 (c) for information produced in some form other than documentary and for
19 any other tangible items, that the Producing Party affix in a prominent place on the
20 exterior of the container or containers in which the information is stored the legend
21 “CONFIDENTIAL.” If only a portion or portions of the information warrants
22 protection, the Producing Party, to the extent practicable, shall identify the
23 protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such
27 material. Upon timely correction of a designation, the Receiving Party must make
1 provisions of this Order.
2
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
3
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
4
designation of confidentiality at any time.
5
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
6
resolution process under Local Rule 37.1 et seq.
7
6.3 The burden of persuasion in any such challenge proceeding shall be
8
on the Designating Party. Frivolous challenges, and those made for an improper
9
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
10
parties) may expose the Challenging Party to sanctions. Unless the Designating
11
Party has waived or withdrawn the confidentiality designation, all parties shall
12
continue to afford the material in question the level of protection to which it is
13
entitled under the Producing Party’s designation until the Court rules on the
14
challenge.
15
16 7. ACCESS TO AND USE OF PROTECTED MATERIAL
17 7.1 Basic Principles. A Receiving Party may use Protected Material that
18 is disclosed or produced by another Party or by a Non-Party in connection with this
19 Action only for enforcing the Judgement entered in this Action. Such Protected
20 Material may be disclosed only to the categories of persons and under the
21 conditions described in this Order. When the judgment has been satisfied or
22 discharged, a Receiving Party must comply with the provisions of section 13 below
23 (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
4 as employees of said Outside Counsel of Record to whom it is reasonably necessary
5 to disclose the information for this Action;
6 (b) the officers, directors, and employees (including House Counsel) of the
7 Receiving Party to whom disclosure is reasonably necessary for this Action;
8 (c) Experts (as defined in this Order) of the Receiving Party to whom
9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (d) the court and its personnel;
12 (e) court reporters and their staff;
13 (f) professional jury or trial consultants, mock jurors, and Professional
14 Vendors to whom disclosure is reasonably necessary for this Action and who have
15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (g) the author or recipient of a document containing the information or a
17 custodian or other person who otherwise possessed or knew the information;
18 (h) during their depositions, witnesses, and attorneys for witnesses, in the
19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
20 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
21 will not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may
25 be separately bound by the court reporter and may not be disclosed to anyone except
26 as permitted under this Stipulated Protective Order; and
27 (i) any mediator or settlement officer, and their supporting personnel,
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 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 shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to
9 issue in the other litigation that some or all of the material covered by the subpoena
10 or order is subject to this Protective Order. Such notification shall include a copy
11 of this Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued
13 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 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
23 PRODUCED IN THIS LITIGATION
24 (a) The terms of this Order are applicable to information produced by a Non-
25 Party in this Action and designated as “CONFIDENTIAL.” Such information
26 produced by Non-Parties in connection with this litigation is protected by the
27 remedies and relief provided by this Order. Nothing in these provisions should be
1 (b) In the event that a Party is required, by a valid discovery request, to
2 produce a Non-Party’s confidential information in its possession, and the Party is
3 subject to an agreement with the Non-Party not to produce the Non-Party’s
4 confidential information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the Non-Party
6 that some or all of the information requested is subject to a confidentiality
7 agreement with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the Stipulated
9 Protective Order in this Action, the relevant discovery request(s), and a reasonably
10 specific description of the information requested; and
11 (3) make the information requested available for inspection by the
12 Non-Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this court within 14
14 days of receiving the notice and accompanying information, the Receiving Party
15 may produce the Non-Party’s confidential information responsive to the discovery
16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
17 not produce any information in its possession or control that is subject to the
18 confidentiality agreement with the Non-Party before a determination by the court.
19 Absent a court order to the contrary, the Non-Party shall bear the burden and
20 expense of seeking protection in this court of its Protected Material.
21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
27 or persons to whom unauthorized disclosures were made of all the terms of this
1 (d) request such person or persons to execute the “Acknowledgment and
2 Agreement to Be Bound” that is attached hereto as Exhibit A.
3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
4 PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other
7 protection, the obligations of the Receiving Parties are those set forth in Federal
8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
9 whatever procedure may be established in an e-discovery order that provides for
10 production without prior privilege review. Pursuant to Federal Rule of Evidence
11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
12 of a communication or information covered by the attorney-client privilege or work
13 product protection, the parties may incorporate their agreement in the stipulated
14 protective order submitted to the court.
15 12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
17 person to seek its modification by the Court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of this
19 Protective Order, no Party waives any right it otherwise would have to object to
20 disclosing or producing any information or item on any ground not addressed in
21 this Stipulated Protective Order. Similarly, no Party waives any right to object on
22 any ground to use in evidence of any of the material covered by this Protective
23 Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Civil Rule 79-5. Protected Material
26 may only be filed under seal pursuant to a court order authorizing the sealing of the
27 specific Protected Material at issue. If a Party’s request to file Protected Material
1 in the public record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the judgment (and any amendments thereto) in this Action, as defined
4 in paragraph 4, is completely satisfied, within 60 days of a written request by the
5 Designating Party, each Receiving Party must return all Protected Material to the
6 Producing Party or destroy such material. As used in this subdivision, “all Protected
7 Material” includes all copies, abstracts, compilations, summaries, and any other
8 format reproducing or capturing any of the Protected Material. Whether the
9 Protected Material is returned or destroyed, the Receiving Party must submit a
10 written certification to the Producing Party (and, if not the same person or entity,
11 to the Designating Party) by the 60 day deadline that (1) identifies (by category,
12 where appropriate) all the Protected Material that was returned or destroyed and (2)
13 affirms that the Receiving Party has not retained any copies, abstracts,
14 compilations, summaries or any other format reproducing or capturing any of the
15 Protected Material. Notwithstanding this provision, Counsel are entitled to retain
16 an archival copy of all pleadings, motion papers, trial, deposition, and hearing
17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
18 reports, attorney work product, and consultant and expert work product, even if
19 such materials contain Protected Material. Any such archival copies that contain or
20 constitute Protected Material remain subject to this Protective Order as set forth in
21 Section 4 (DURATION).
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
1 || 14. VIOLATION
2 Any violation of this Order may be punished by appropriate measures
3 |) including, without limitation, contempt proceedings and monetary sanctions.
4
5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 || DATED May 19, 2023
8
9 || /s/Averil K. Andrews
10 Attorneys for Petitioner
11
12 || DATED: May 19, 2023
13
14 || /s/ Matthew L. Jones
3 Attorneys for Respondent
16
17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
19 || DATED: May 24, 2023
20 .
21 _Rapeb ln Qa. Qe
22 || United States Magistrate ludge
23
24
25
26
27
28
1c
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of ___________ [insert formal name of the case and the
8 number and initials assigned to it by the court]. I agree to comply with and to
9 be bound by all the terms of this Stipulated Protective Order and I understand and
10 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
12 in any manner any information or item that is subject to this Stipulated Protective
13 Order to any person or entity except in strict compliance with the provisions of this
14 Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of
18 this action. I hereby appoint __________________________ [print or type full
19 name] of _______________________________________ [print or type full
20 address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27