Gengcai Tian v. Bank of America, N.A. et al

Filing 27

PROTECTIVE ORDER by Magistrate Judge Patricia Donahue re Stipulation for Protective Order 26 . See document for details. (es)

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1 AUSTIN B. KENNEY (State Bar No. 242277) 2 STEPHEN D. BRITT (State Bar No. 279793) 3 SEVERSON & WERSON A Professional Corporation 4 The Atrium 19100 Von Karman Avenue, Suite 700 5 Irvine, California 92612 Telephone: (949) 442-7110 6 Facsimile: (949) 442-7118 7 Attorneys for Defendant BANK OF AMERICA, N.A. 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 13 14 15 GENGCAI TIAN, Case No. 2:24-cv-00602-MCS (PDx) Plaintiff, Assigned for All Purposes To: Hon. Mark C. Scarsi United States District Court Judge 350 1st Street, Ctrm 7C vs. 16 BANK OF AMERICA, N.A., and DOES 1 through 10, inclusive , 17 Defendants. 18 Hon. Patricia Donahue United States Magistrate Judge PROTECTIVE ORDER 19 20 21 22 1. INTRODUCTION 1.1 PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation may 25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 enter the following Stipulated Protective Order. The parties acknowledge that this 27 Order does not confer blanket protections on all disclosures or responses to 28 discovery and that the protection it affords from public disclosure and use extends 70001.0828/16793564.1 [PROPOSED] PROTECTIVE ORDER 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. The parties further acknowledge, as set forth 3 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 4 file confidential information under seal; Civil Local Rule 79-5 sets forth the 5 procedures that must be followed and the standards that will be applied when a party 6 seeks permission from the court to file material under seal. 7 1.2 GOOD CAUSE STATEMENT 8 This action is likely to involve the disclosure and discovery of personal 9 financial information and other private personal identifying information of plaintiff, 10 Gengcai Tian, including but not limited to bank account records, telephone records 11 and social security numbers, as well as defendant Bank of America, N.A.’s 12 (“BofA”) trade secrets, valuable research, development, commercial, financial, 13 technical and/or proprietary information for which special protection from public 14 disclosure and from use for any purpose other than prosecution of this action is 15 warranted. Such confidential and proprietary materials and information consist of, 16 among other things, confidential business or financial information, information 17 regarding confidential business practices, or other confidential research, 18 development, or commercial information (including information implicating privacy 19 rights of third parties), information otherwise generally unavailable to the public, or 20 which may be privileged or otherwise protected from disclosure under state or 21 federal statutes, court rules, case decisions, or common law, as well as any 22 information copied or extracted therefrom, plus testimony, conversations, or 23 presentations by Parties or counsel to or in court or in other settings that might 24 reveal information, the disclosure of which would, in the good faith judgment of the 25 Producing Party (defined below) be detrimental to that Party and/or to the conduct 26 of that Party’s business or the business of any of that Party’s customers or clients. 27 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 28 of disputes over confidentiality of discovery materials, to adequately protect 70001.0828/16793564.1 2 PROTECTIVE ORDER 1 information the parties are entitled to keep confidential, to ensure that the parties are 2 permitted reasonable necessary uses of such material in preparation for and in the 3 conduct of trial, to address their handling at the end of the litigation, and serve the 4 ends of justice, a protective order for such information is justified in this matter. It is 5 the intent of the parties that information will not be designated as confidential for 6 tactical reasons and that nothing be so designated without a good faith belief that 7 it has been maintained in a confidential, non-public manner, and there is good cause 8 why it should not be part of the public record of this case. 9 10 2. DEFINITIONS 11 2.1 Action: This pending lawsuit. 12 2.2 Challenging Party: a Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 2.7 Expert: a person with specialized knowledge or experience in a matter 28 pertinent to the litigation who has been retained by a Party or its counsel to serve as 70001.0828/16793564.1 3 PROTECTIVE ORDER 1 an expert witness or as a consultant in this Action. 2 2.8 House Counsel: attorneys who are employees of a party to this Action. 3 House Counsel does not include Outside Counsel of Record or any other outside 4 counsel. 5 2.9 Non-Party: any natural person, partnership, corporation, association, or 6 other legal entity not named as a Party to this action. 7 2.10 Outside Counsel of Record: attorneys who are not employees of a 8 party to this Action but are retained to represent or advise a party to this Action and 9 have appeared in this Action on behalf of that party or are affiliated with a law firm 10 which has appeared on behalf of that party, and includes support staff. 11 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 15 Discovery Material in this Action. 16 2.13 Professional Vendors: persons or entities that provide litigation 17 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) 19 and their employees and subcontractors. 20 2.14 Protected Material: any Disclosure or Discovery Material that is 21 designated as “CONFIDENTIAL.” 22 2.15 Receiving Party: a Party that receives Disclosure or Discovery 23 Material from a Producing Party. 24 25 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 Protected Material (as defined above), but also (1) any information copied or 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 70001.0828/16793564.1 4 PROTECTIVE ORDER 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial will be governed by the orders of the 4 trial judge. This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION Even after final disposition of this litigation, the confidentiality 7 8 obligations imposed by this Order will remain in effect until a Designating Party 9 agrees otherwise in writing or a court order otherwise directs. Final disposition will 10 be deemed to be the later of (1) dismissal of all claims and defenses in this Action, 11 with or without prejudice; and (2) final judgment herein after the completion and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection under 19 this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items, or oral or written 22 communications that qualify so that other portions of the material, documents, 23 items, or communications for which protection is not warranted are not swept 24 unjustifiably within the ambit of this Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 unnecessary expenses and burdens on other parties) may expose the Designating 70001.0828/16793564.1 5 PROTECTIVE ORDER 1 Party to sanctions. If it comes to a Designating Party’s attention that information or items 2 3 that it designated for protection do not qualify for protection, that Designating Party 4 must promptly notify all other Parties that it is withdrawing the inapplicable 5 designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic documents, 13 but excluding transcripts of depositions or other pretrial or trial proceedings), that 14 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 15 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 16 portion or portions of the material on a page qualifies for protection, the Producing 17 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 18 markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection will be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine which 25 documents, or portions thereof, qualify for protection under this Order. Then, before 26 producing the specified documents, the Producing Party must affix the 27 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 28 portion or portions of the material on a page qualifies for protection, the Producing 70001.0828/16793564.1 6 PROTECTIVE ORDER 1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 2 markings in the margins). 3 (b) for testimony given in depositions that the Designating Party identify the 4 Disclosure or Discovery Material on the record, before the close of the deposition all 5 protected testimony. 6 (c) for information produced in some form other than documentary and for 7 any other tangible items, that the Producing Party affix in a prominent place on the 8 exterior of the container or containers in which the information is stored the legend 9 “CONFIDENTIAL.” If only a portion or portions of the information warrants 10 protection, the Producing Party, to the extent practicable, will identify the protected 11 portion(s). 12 5.3 Inadvertent Failures to Designate Discovery Materials as Confidential 13 Information. The unintentional failure by a Producing Party to designate Discovery 14 Material with the correct “CONFIDENTIAL” designation shall not waive any such 15 designation. If the Producing Party notifies all Receiving Parties of an unintentional 16 failure to designate materials as “CONFIDENTIAL,” the Producing Party shall 17 reproduce the Discovery Material with the correct “CONFIDENTIAL” designation 18 within ten (10) business days of the Producing Party’s notification to the Receiving 19 Party. Upon receiving the Discovery Material with the correct “CONFIDENTIAL” 20 designation, the Receiving Parties shall destroy all Discovery Material that was 21 identified as incorrectly designated. A Receiving Party shall not be in breach of this 22 Stipulation and Order for any use of such unintentionally non-designated or 23 inadvertently mis-designated Discovery Material before the Receiving Party 24 receives notice of the inadvertent failure to designate. Once a Receiving Party has 25 received notice of the unintentional failure to designate pursuant to this provision, 26 the Receiving Party shall treat such Discovery Material at the appropriately 27 designated level pursuant to the terms of this Stipulation and Order. 28 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 70001.0828/16793564.1 7 PROTECTIVE ORDER 1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 designation of confidentiality at any time that is consistent with the Court’s 3 Scheduling Order. 6.2 4 Meet and Confer. The Challenging Party will initiate the dispute 5 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 6 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding will be on 8 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 will 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 is 18 disclosed or produced by another Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending, or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Order. When the Action has been terminated, a 22 Receiving Party must comply with the provisions of section 13 below (FINAL 23 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 28 otherwise ordered by the court or permitted in writing by the Designating Party, a 70001.0828/16793564.1 8 PROTECTIVE ORDER 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 and the jury; 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, 28 mutually agreed upon by any of the parties engaged in settlement discussions. 70001.0828/16793564.1 9 PROTECTIVE ORDER 1 2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 3 PRODUCED IN OTHER LITIGATION 4 If a Party is served with a subpoena or a court order issued in other litigation 5 that compels disclosure of any information or items designated in this Action as 6 “CONFIDENTIAL,” that Party must: 7 (a) promptly notify in writing the Designating Party. Such notification will 8 include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or order to 10 issue in the other litigation that some or all of the material covered by the subpoena 11 or order is subject to this Protective Order. Such notification will include a copy of 12 this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be pursued 14 by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with 16 the subpoena or court order will not produce any information designated in this 17 action as “CONFIDENTIAL” before a determination by the court from which the 18 subpoena or order issued, unless the Party has obtained the Designating Party’s 19 permission. The Designating Party will bear the burden and expense of seeking 20 protection in that court of its confidential material and nothing in these provisions 21 should be construed as authorizing or encouraging a Receiving Party in this Action 22 to disobey a lawful directive from another court. 23 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a Non- 27 Party in this Action and designated as “CONFIDENTIAL.” Such information 28 produced by Non-Parties in connection with this litigation is protected by the 70001.0828/16793564.1 10 PROTECTIVE ORDER 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party will: 7 (1) promptly notify in writing the Requesting Party and the Non-Party that 8 some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 11 Order in this Action, the relevant discovery request(s), and a reasonably specific 12 description of the information requested; and 13 (3) make the information requested available for inspection by the Non- 14 Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 16 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party will 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party will bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 70001.0828/16793564.1 11 PROTECTIVE ORDER 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 7 OTHERWISE PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 14 (e), insofar as the parties reach an agreement on the effect of disclosure of a 15 communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated 17 protective order submitted to the court. 18 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order no Party waives any right it otherwise would have to object to 24 disclosing or producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 70001.0828/16793564.1 12 PROTECTIVE ORDER 1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party's request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 6 13. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return 9 all Protected Material to the Producing Party or destroy such material. As used in 10 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 summaries, and any other format reproducing or capturing any of the Protected 12 Material. Whether the Protected Material is returned or destroyed, the Receiving 13 Party must submit a written certification to the Producing Party (and, if not the same 14 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 15 (by category, where appropriate) all the Protected Material that was returned or 16 destroyed and (2) affirms that the Receiving Party has not retained any copies, 17 abstracts, compilations, summaries or any other format reproducing or capturing any 18 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 19 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 21 reports, attorney work product, and consultant and expert work product, even if such 22 materials contain Protected Material. Any such archival copies that contain or 23 constitute Protected Material remain subject to this Protective Order as set forth in 24 Section 4 (DURATION). 25 26 14. Any willful violation of this Order may be punished by civil or criminal 27 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 28 authorities, or other appropriate action at the discretion of the Court. 70001.0828/16793564.1 13 PROTECTIVE ORDER 1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 4 DATED: June 4, 2024 GOLDEN & CARDONA-LOYA, LLP 5 6 By: 7 /s/ Jeremy S. Golden JEREMY S. GOLDEN 8 Attorneys for Plaintiff GENGCAI TIAN 9 10 DATED: June 4, 2024 11 SEVERSON & WERSON A Professional Corporation 12 By: 13 /s/ Austin B. Kenney AUSTIN B. KENNEY 14 Attorneys for Defendant BANK OF AMERICA, N.A. 15 16 STATEMENT OF ATTESTATION 17 18 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I hereby attest that all other 19 signatories listed, and on whose behalf the filing is submitted, concur in the filing’s 20 content and have authorized the filing. By: 21 /s/ Austin B. Kenney AUSTIN B. KENNEY 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 DATED: June 05, 2024 __________________________________ 26 HON. PATRICIA DONAHUE 27 United States Magistrate Judge 28 70001.0828/16793564.1 14 PROTECTIVE ORDER 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 I, ________________________ [print or type full name], of _________________ [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the United States District Court for the Central District of California on __________________ in the case of GENGCAI TIAN v. BANK OF AMERICA, N.A., Case No. 2:24-cv-00602-MCS-PD. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for the Central District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint ________________________ [print or type full name] of _________ ______________________[print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. 23 24 25 26 27 28 70001.0828/16793564.1 15 PROTECTIVE ORDER 1 2 3 4 5 Date: __________________________ City and State where sworn and signed: _____________________________ Printed name: ____________________________________ 6 Signature: ________________________________ 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 70001.0828/16793564.1 16 PROTECTIVE ORDER

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