Jennifer Pae v. Fox Restaurant Concepts, LLC et al

Filing 42

PROTECTIVE ORDER by Magistrate Judge Frederick F. Mumm re Stipulation for Protective Order #35 (see attached) (jm)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JENNIFER PAE, individually and on
behalf of all others similarly situated,
vs.

Plaintiff,

FOX RESTAURANT CONCEPTS,
LLC d/b/a TRUE FOOD
KITCHEN; a Arizona limited
liability company; et al.,
Defendants.

Case No.: 2:16-CV-06965-DSF-FFM
[CLASS ACTION]
[DISCOVERY MATTER]
Assigned to Hon. Dale S. Fischer
[PROPOSED] STIPULATED
PROTECTIVE ORDER
Action Filed:
July 22, 2016
Date of Removal: September 16, 2016
Trial Date:
January 17, 2018

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Plaintiff Jennifer Pae, on behalf of the putative class (“Plaintiff”), and

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Defendants Fox Restaurant Concepts LLC, FRC True Food SMP LLC, FRC True

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Food SDFV LLC and FRC True Food NBFI LLC (“True Food Kitchen” or

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“Defendants”) (collectively, the “Parties”) through their respective counsel, hereby

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stipulate to and petition the Court to enter the following Stipulated Protective Order

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(“Protective Order”). Discovery in this action is likely to involve production of

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confidential, proprietary, or private information for which special protection from
[PROPOSED] STIPULATED PROTECTIVE ORDER

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public disclosure and from use for any purpose other than prosecuting this litigation

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may be warranted. The Parties acknowledge and understand that this Protective

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Order does not confer blanket protection on all disclosures or responses to

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discovery, that the protection it affords from public disclosures and use extends only

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to limited information or items that are entitled to confidential treatment under the

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applicable legal principles. The parties further acknowledge, as set forth in Section

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II, Paragraph 20, below, that this Protective Order does not entitle them to file

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confidential information under seal; Civil Local Rule 79-5 sets forth the procedures

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that must be followed and the standards that will be applied when a party seeks

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permission from the court to file material under seal.

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I.

STATEMENT OF GOOD CAUSE

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In this putative class action lawsuit, Plaintiff, on behalf of herself and others

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similarly situated, alleges that Defendants violated the law by failing to pay for all

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hours worked and not providing legally compliant meal and rest periods. Plaintiff

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also alleges a host of other Labor Code violations stemming, in large part, from

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Defendants failure to pay for all hours worked and said meal and rest period

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violations. In connection with discovery in this lawsuit, Plaintiff has sought certain

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documents, written discovery responses, deposition testimony, and other items

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containing confidential information, including third-party information protected by

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privacy laws such as personal contact information of current and former non-

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exempt, hourly restaurant workers for Defendants, the personnel records, payroll

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records and/or timekeeping records of current and former putative class members of

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Defendants, and employee-initiated complaints that are subject to confidentiality

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provisions. The Parties recognize that employers such as Defendants are obligated

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to maintain the right to privacy guaranteed by the California Constitution, which

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protects putative class members’ files from improper disclosure to third parties. See

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Board of Trustees v. Superior Courts, 119 Cal. App. 3d 516, 174 Cal. Rptr. 160

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(1981). The Parties also recognize that certain documents may also involve or be
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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the subject of confidentiality provisions, for which Defendants desire to maintain

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pursuant to agreements unrelated to this lawsuit. Accordingly, to expedite the flow

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of information, to facilitate the prompt resolution of disputes over confidentiality of

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discovery materials, to adequately protect information the parties are entitled to keep

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confidential, to ensure that the parties are permitted reasonable necessary uses of

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such material in preparation for and in the conduct of trial, to address their handling

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at the end of the litigation, and serve the ends of justice, a protective order for such

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information is justified in this matter. It is the intent of the parties that information

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will not be designated as confidential for tactical reasons and that nothing be so

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designated without a good faith belief that it has been maintained in a confidential,

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non-public manner, and there is good cause why it should not be part of the public

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record of this case.

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II.

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TERMS OF PROTECTIVE ORDER
1.

In this Protective Order, the words set forth below shall have the

following meanings:
(a)

"Action" means the above-entitled case (Case No. 2:16-CV-

06965-DSF-FFM).
(b)

“Challenging Party” means a Party or Non-Party that challenges

the designation of information or items under this Protective Order.
(c)

"‘Confidential’ Information or Items" means information

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(regardless of how it is generated, stored or maintained) or tangible things that

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qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified

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above in the Statement of Good Cause.

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(d)

“Counsel” means Outside Counsel of Record and House Counsel

(as well as their support staff).
(e)

"Designating Party" means a Party or Non-Party that designates

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

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“CONFIDENTIAL.”
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[PROPOSED] STIPULATED PROTECTIVE ORDER

(f)

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"Disclose" or "Disclosed" or "Disclosure" means to reveal,

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divulge, give, or make available Materials, or any part thereof, or any information

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contained therein.
(g)

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“Disclosure or Discovery Material” means all items or

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information, regardless of the medium or manner in which it is generated, stored, or

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maintained (including, among other things, testimony, transcripts, and tangible

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things), that are produced or generated in disclosures or responses to discovery in

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this matter.
(h)

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“Expert” means a person with specialized knowledge or

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experience in a matter pertinent to the litigation who has been retained by a Party or

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its counsel to serve as an expert witness or as a consultant in this Action.
(i)

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“House Counsel” means attorneys who are employees of a party

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to this Action. House Counsel does not include Outside Counsel of Record or any

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other outside counsel.
(j)

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“Non-Party” means any natural person, partnership, corporation,

association, or other legal entity not named as a Party to this action.
(k)

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“Outside Counsel of Record” means attorneys who are not

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employees of a party to this Action but are retained to represent or advise a party to

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this Action and have appeared in this Action on behalf of that party or are affiliated

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with a law firm which has appeared on behalf of that party, and includes support

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staff.

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(l)

"Party" means any party to this Action, including all of its

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officers, directors, employees, consultants, retained experts, and Outside Counsel of

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Record (and their support staffs).

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(m)

“Producing Party” means a Party or Non-Party that produces

Disclosure or Discovery Material in this Action.
(n)

“Professional Vendors” mean persons or entities that provide

litigation support services (e.g., photocopying, videotaping, translating, preparing
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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exhibits or demonstrations, and organizing, storing, or retrieving data in any form or

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medium) and their employees and subcontractors.
(o)

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Material that is designated as “CONFIDENTIAL.”
(p)

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“Protected Material” means any Disclosure or Discovery

“Receiving Party” means a Party that receives Disclosure or

Discovery Material from a Producing Party.
2.

The protections conferred by this Protective Order cover not only

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

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

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

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

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

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

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3.

Even after final disposition of this litigation, the confidentiality

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obligations imposed by this Protective Order shall remain in effect until a

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

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Final disposition shall be deemed to be the later of (1) dismissal of all claims and

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defenses in this Action, with or without prejudice; and (2) final judgment herein

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after the completion and exhaustion of all appeals, rehearings, remands, trials, or

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reviews of this Action, including the time limits for filing any motions or

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applications for extension of time pursuant to applicable law.

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4.

The Designating Party shall have the right to designate as

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"Confidential" any Disclosure or Discovery Material that the Designating Party in

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good faith believes to contain non-public information that is entitled to confidential

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treatment under applicable law.

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information or items for protection under this Order must take care to limit any such

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designation to specific material that qualifies under the appropriate standards. The

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Designating Party must designate for protection only those parts of material,

Each Party or Non-Party that designates

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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documents, items, or oral or written communications that qualify so that other

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portions of the material, documents, items, or communications for which protection

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is not warranted are not swept unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Party to sanctions.

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

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

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promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.

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The entry of this Protective Order does not alter, waive, modify, or

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abridge any right, privilege or protection otherwise available to any Party with

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respect to the discovery of matters, including but not limited to any Party's right to

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assert the attorney-client privilege, the attorney work-product doctrine, or other

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privileges, or any Party's right to contest any such assertion,
6.

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Except as otherwise provided in this Protective Order, or as otherwise

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stipulated or ordered, any Disclosure or Discovery Material that qualifies for

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protection under this Protective Order must be clearly so designated before the

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material is disclosed or produced. The designation should not obscure or interfere

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with the legibility of the designated Disclosure or Discovery Material. Designation

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in conformity with this Protective Order requires:
(a)

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

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

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

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

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contains protected material. If only a portion or portions of the material on a page

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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qualifies for protection, the Producing Party also must clearly identify the protected

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

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

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

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

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

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deemed “CONFIDENTIAL.” After the inspecting Party has identified the

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

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documents, or portions thereof, qualify for protection under this Order. Then, before

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producing the specified documents, the Producing Party must affix the

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

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

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

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markings in the margins).

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

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

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deposition all protected testimony.

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

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

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

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

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warrants protection, the Producing Party, to the extent practicable, shall identify the

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protected portion(s).
7.

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If corrected within fifteen (15) calendar days of any disclosure, an

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inadvertent failure to designate qualified information or items does not, standing

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alone, waive the Designating Party’s right to secure protection under this Order for

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such material. Upon timely correction, within fifteen (15) calendar days of any

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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disclosure, of a designation, the Receiving Party must make reasonable efforts to

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

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Any Party or Non-Party may challenge a designation of confidentiality

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at any time that is consistent with the Court’s Scheduling Order. The Challenging

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Party shall notify the Designating Party of its challenge and shall initiate the dispute

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resolution process under Local Rule 37.1 et seq. In the event a Receiving Party

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challenges any designation of confidentiality hereunder, counsel for such Party shall

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advise counsel for the Designating Party, in writing, of such objections and the

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specific Confidential Information or Items to which each objection pertains, and the

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specific reasons and support for such objections (the “Designation Objections”).

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Counsel for the Designating Party shall have thirty (30) days from receipt of the

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written Designation Objections to either (a) agree in writing to withdraw the

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“Confidential” designation as to the Confidential Information or Items pursuant to

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any or all of the Designation Objections and/or (b) file a motion with the Court

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seeking to uphold any or all designations addressed by the Designation Objections

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(the “Designation Motion”). The burden of persuasion in any such Designation

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Motion shall be on the Designating Party. Frivolous challenges, and those made for

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an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

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other parties) may expose the Challenging Party to sanctions. Unless the

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Designating Party has waived or withdrawn the confidentiality designation or unless

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the Court has ordered, on any motion duly made pursuant to this paragraph

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challenging any designation, that such designation shall be withdrawn, all parties

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shall continue to afford the material in question the level of protection to which it is

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

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challenge.

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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9.

Unless otherwise ordered by the court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any information or item

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designated “CONFIDENTIAL” only to:

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(a)

the court and its personnel;

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(b)

the Receiving Party’s Outside Counsel of Record in this Action,

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

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necessary to disclose the information for this Action;

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(c)

the officers, directors, and employees (including House Counsel)

of the Receiving Party to whom disclosure is reasonably necessary for this Action;
(d)

the author or recipient of a document containing the information

or a custodian or other person who otherwise possessed or knew the information;
(e)

those officers, directors, partners, members, employees and

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agents of all non-designating Parties that counsel for such Parties deems necessary

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to aid counsel in the prosecution and defense of this Action; provided, however, that

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prior to the Disclosure of Confidential Materials to any such officer, director,

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partner, member, employee or agent, counsel for the Party making the Disclosure

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shall deliver a copy of this Protective Order to such person, shall explain that such

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person is bound to follow the terms of such Order, and shall secure the signature of

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such person on a statement in the form attached hereto as Exhibit A;

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(f)

court reporters and their staff;

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(g)

any deposition, trial or hearing witness in the Action who

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previously has had access to the Confidential Materials, or who is currently or was

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previously an officer, director, partner, member, employee or agent of an entity that

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has had access to the Confidential Materials;

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(h)

during their depositions, witnesses, and attorneys for witnesses,

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

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

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they will not be permitted to keep any confidential information unless they sign the
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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

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agreed by the Designating Party or ordered by the court. Pages of transcribed

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deposition testimony or exhibits to depositions that reveal Protected Material may

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be separately bound by the court reporter and may not be disclosed to anyone except

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as permitted under this Stipulated Protective Order; and
(i)

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professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for this Action

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and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

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A);
(j)

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

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

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

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any other person that the Designating Party agrees to in writing;

(l)

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any mediator or settlement officer, and their supporting

and

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personnel, mutually agreed upon by any of the parties engaged in settlement

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discussions.
11.

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A Receiving Party may use Protected Material that is disclosed or

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produced by another Party or by a Non-Party in connection with this Action only for

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prosecuting, defending, or attempting to settle this Action. Such Protected Material

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may be disclosed only to the categories of persons and under the conditions

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described in this Protective Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of Section II, Paragraph 21,

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

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

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authorized under this Protective Order. This Protective Order is expressly intended

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to comply with Rule 1-500(A) of the California Rules of Professional Conduct.

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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12.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

PRODUCED IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification

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shall include a copy of the subpoena or court order;

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

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

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subpoena or order is subject to this Protective Order. Such notification shall include

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a copy of this Stipulated Protective Order; and
(c)

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cooperate with respect to all reasonable procedures sought to be

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

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

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

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

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

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

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

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

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to disobey a lawful directive from another court.

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13.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

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

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

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

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remedies and relief provided by this Order. Nothing in these provisions should be

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construed as prohibiting a Non-Party from seeking additional protections.
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[PROPOSED] STIPULATED PROTECTIVE ORDER

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

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

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

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confidential information, then the Party shall:

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

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

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agreement with a Non-Party;

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

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

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specific description of the information requested; and
(3) make the information requested available for inspection by the

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Non-Party, if requested.

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

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

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

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request. If the Non-Party timely seeks a protective order, the Receiving Party shall

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not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Non-Party before a determination by the court.

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Absent a court order to the contrary, the Non-Party shall bear the burden and

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expense of seeking protection in this court of its Protected Material.

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14.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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15.

INADVERTENT

PRODUCTION

OF

PRIVILEGED

OR

OTHERWISE PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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may be established in an e-discovery order that provides for production without

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prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar

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

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

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parties may incorporate their agreement in the stipulated protective order submitted

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to the court.

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16.

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

person to seek its modification by the Court in the future.
17.

Entering into, agreeing to, and/or complying with the terms of this

Protective Order shall not:
(a)

operate as an admission by any person that any particular

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Disclosure or Discovery Material marked "Confidential" contains or reflects trade

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secrets, proprietary, confidential or competitively sensitive business, commercial,

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financial or personal information; or

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(b)

prejudice in any way the right of any Party (or any other person

subject to the terms of this Protective Order):
(i)

to seek a determination by the Court of whether any

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particular Protected Material should be subject to protection as

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"Confidential” under the terms of this Protective Order; or

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[PROPOSED] STIPULATED PROTECTIVE ORDER

(ii)

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to seek relief from the court on appropriate notice to all

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other Parties to the Action from any provision(s) of this Protective

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Order, either generally or as to any particular Disclosure or Discovery

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Material.

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(c)

act as a Party’s waiver of any right it otherwise would have to

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

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addressed in this Stipulated Protective Order. Similarly, no Party waives any right to

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

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Protective Order

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18.

Nothing in this Protective Order shall be construed to preclude any

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Party or Non-Party from asserting in good faith that certain Confidential

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Information or Materials require additional protection. The Parties or Non-Parties

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shall meet and confer to agree upon the terms of such additional protection.

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19.

If, after execution of this Protective Order, any Protected Materials

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submitted by a Designating Party under the terms of this Protective Order are

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Disclosed by a non-Designating Party to any person other than in the manner

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authorized by this Protective Order, the non-Designating Party responsible for the

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Disclosure shall bring all pertinent facts relating to the Disclosure of such Protected

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Materials to the immediate attention of the Designating Party.

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20.

A Party that seeks to file under seal any Protected Material must

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comply with Civil Local Rule 79-5. Protected Material may only be filed under seal

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pursuant to a court order authorizing the sealing of the specific Protected Material at

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issue. If a Party's request to file Protected Material under seal is denied by the court,

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then the Receiving Party may file the information in the public record unless

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otherwise instructed by the court.

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21.

After the final disposition of this Action, as defined in Section II,

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Paragraph 1(a), within 60 days of a written request by the Designating Party, each

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Receiving Party must return all Protected Material to the Producing Party or destroy
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[PROPOSED] STIPULATED PROTECTIVE ORDER

1

such material. As used in this subdivision, “all Protected Material” includes all

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

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capturing any of the Protected Material. Whether the Protected Material is returned

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or destroyed, the Receiving Party must submit a written certification to the

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Producing Party (and, if not the same person or entity, to the Designating Party) by

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the 60 day deadline that (1) identifies (by category, where appropriate) all the

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Protected Material that was returned or destroyed and (2)affirms that the Receiving

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Party has not retained any copies, abstracts, compilations, summaries or any other

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format reproducing or capturing any of the Protected Material. Notwithstanding this

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provision, Counsel are entitled to retain an archival copy of all pleadings, motion

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

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

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and expert work product, even if such materials contain Protected Material. Any

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such archival copies that contain or constitute Protected Material remain subject to

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this Protective Order as set forth in Section II, Paragraph 3.

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Any violation of this Order may be punished by any and all appropriate

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measures including, without limitation, contempt proceedings, monetary sanctions

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and/or any other appropriate relief.

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This Protective Order may be executed in counterparts.

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PURSUANT TO THE PARTIES’ STIPULATION, AND FOR GOOD CAUSE
SHOWN, IT IS SO ORDERED.

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DATED: May 1, 2017

/S/ FREDERICK F. MUMM
THE HON. FREDERICK F. MUMM
United States Magistrate Judge
for the Central District of California

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

_____________________________

[print

or

type

full

name],

of

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

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

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

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___________ [date] in the case of Pae v. Fox Restaurant Concepts, LLC d/b/a True

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Food Kitchen, et al., Case No. 2:16-CV-06965-DSF-FFM. I agree to comply with

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and to be bound by all the terms of this Protective Order and I understand and

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acknowledge that failure to so comply could expose me to sanctions and punishment

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in the nature of contempt. I solemnly promise that I will not disclose in any manner

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any information or item that is subject to this Protective Order to any person or

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entity except in strict compliance with the provisions of this Protective Order.

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

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

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Protective Order, even if such enforcement proceedings occur after termination of

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this action. I hereby appoint __________________________ [print or type full

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name] of _______________________________________ [print or type full address

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

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

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Date: ______________________________________

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City and State where sworn and signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________

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[PROPOSED] STIPULATED PROTECTIVE ORDER