Hemphill v. County of San Bernardino et al

Filing 18

PROTECTIVE ORDER by Magistrate Judge David T. Bristow re Stipulation for Protective Order 17 . (see document for details) (hr)

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1 7 Paul B. Beach, Esq. [State Bar No. 166265] E-mail: pbeach@lbaclaw.com Aamir Raza, Esq. [State Bar No. 223530] E-mail: araza@lbaclaw.com LAWRENCE BEACH ALLEN & CHOI, PC E-mail: LBACOCstaff@lbaclaw.com 959 South Coast Drive, Suite 260 Costa Mesa, California 92626 Telephone No.: (714) 479-0180 8 Attorneys for Defendant, CITY OF SAN BERNARDINO 2 3 4 5 6 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 13 14 15 16 17 18 19 20 DEJON HEMPHILL, ) ) Plaintiff, ) ) vs. ) ) COUNTY OF SAN BERNARDINO; ) CITY OF SAN BERNARDINO; and ) DOES 1-10, inclusive, ) ) Defendants. ) _________________________) Case No.: 5:24-cv-00825-KK-DTB [DISCOVERY MATTER] STIPULATED PROTECTIVE ORDER Matter For Determination Before The Honorable Kenly Kiya Kato TO THE HONORABLE COURT, COME NOW ALL THE PARTIES 21 22 AND JOINTLY STIPULATE AS FOLLOWS: 23 1. 24 A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public 26 disclosure and from use for any purpose other than prosecuting this litigation may 27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 enter the following Stipulated Protective Order. The parties acknowledge that this 1 STIPULATED PROTECTIVE ORDER 1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 under the applicable legal principles. The parties further acknowledge, as set forth in 5 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 6 file confidential information under seal; Civil Local Rule 79-5 sets forth the 7 procedures that must be followed and the standards that will be applied when a party 8 seeks permission from the court to file material under seal. 9 10 B. GOOD CAUSE STATEMENT This action pertains to sensitive and confidential inter-agency documents 11 related to the incident that involved Plaintiff DEJON HEMPHILL (“Plaintiff) and 12 Defendants City of San Bernardino, et.al. (“Defendants,” collectively). This action 13 is likely to involve materials and information that were acquired in confidence by 14 public employees in the course of their duties and have not been officially disclosed 15 or made open or available to the public. Such confidential materials and information 16 consist of, among other things: (1) confidential police personnel files and 17 accompanying materials maintained by the City of San Bernardino Police 18 Department; (2) law enforcement investigative reports and records which may 19 contain personal contact information of third party witnesses; and (3) information 20 otherwise generally unavailable to the public, or which may be privileged or 21 otherwise protected from disclosure under state or federal statues, court rules, case 22 decisions, or common law. City Defendants contend that individual officers have an 23 interest in protecting their own privacy rights relating to information in their 24 personnel files and other related information including but not limited to internal 25 affairs investigations. Public divulgence of identities of the various law-enforcement 26 officers and civilian witnesses contained therein would violate the aforementioned 27 individual’s rights of privacy and subject them to potential harm, harassment, 28 intimidation or other unwarranted retribution. Further, the administrative 2 STIPULATED PROTECTIVE ORDER 1 investigations as to the underlying alleged incidents are incomplete, ongoing and 2 continuing. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately 5 protect information the parties are entitled to keep confidential, to ensure that the 6 parties are permitted reasonable necessary uses of such material in preparation for 7 and in the conduct of trial, to address their handling at the end of the litigation, and 8 serve the ends of justice, a protective order for such information is justified in this 9 matter. It is the intent of the parties that information will not be designated as 10 confidential for tactical reasons and that nothing be so designated without a good 11 faith belief that it has been maintained in a confidential, non-public manner, and 12 there is good cause why it should not be part of the public record of this case. 13 2. DEFINITIONS 14 2.1 Action: This pending federal lawsuit in DEJON HEMPHILL, an individual, 15 v. County of San Bernardino, et.al. Case No.5:24-cv-00825-KK-DTBx. 16 2.2 17 information or items under this Order. 18 2.3 19 is generated, stored or maintained) or tangible things that qualify for protection 20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 21 Cause Statement. 22 2.4 23 support staff). 24 2.5 25 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 26 2.6 Challenging Party: a Party or Non-Party that challenges the designation of “CONFIDENTIAL” Information or Items: information (regardless of how it Counsel: Outside Counsel of Record and House Counsel (as well as their Designating Party: a Party or Non-Party that designates information or items Disclosure or Discovery Material: all items or information, regardless of the 27 28 3 STIPULATED PROTECTIVE ORDER 1 medium or manner in which it is generated, stored, or maintained (including, among 2 other things, testimony, transcripts, and tangible things), that are produced or 3 generated in disclosures or responses to discovery in this matter. 4 2.7 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as 6 an expert witness or as a consultant in this Action. 7 2.8 8 Counsel does not include Outside Counsel of Record or any other outside counsel. 9 2.9 Expert: a person with specialized knowledge or experience in a matter House Counsel: attorneys who are employees of a party to this Action. House Non-Party: any natural person, partnership, corporation, association, or other 10 legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 12 Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 19 Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 25 “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 27 a Producing Party. 28 4 STIPULATED PROTECTIVE ORDER 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. Any 7 use of Protected Material at trial shall be governed by the orders of the trial judge. 8 This Order does not govern the use of Protected Material at trial. 9 4. 10 DURATION Even after final disposition of this litigation, the confidentiality obligations 11 imposed by this Order shall remain in effect until a Designating Party agrees 12 otherwise in writing or a court order otherwise directs. Final disposition shall be 13 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 14 or without prejudice; and (2) final judgment herein after the completion and 15 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 16 including the time limits for filing any motions or applications for extension of time 17 pursuant to applicable law. 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 20 Party or Non-Party that designates information or items for protection under this 21 Order must take care to limit any such designation to specific material that qualifies 22 under the appropriate standards. The Designating Party must designate for 23 protection only those parts of material, documents, items, or oral or written 24 communications that qualify so that other portions of the material, documents, 25 items, or communications for which protection is not warranted are not swept 26 unjustifiably within the ambit of this Order. 27 /// 28 5 STIPULATED PROTECTIVE ORDER 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating 5 Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in this 10 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) For information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 19 contains protected material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine which 28 documents, or portions thereof, qualify for protection under this Order. Then, 6 STIPULATED PROTECTIVE ORDER 1 before producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 3 portion or portions of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 5 markings in the margins). 6 (b) For testimony given in depositions that the Designating Party identify 7 the Disclosure or Discovery Material on the record, before the close of the 8 deposition all protected testimony. 9 (c) For information produced in some form other than documentary and for 10 any other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, shall identify the protected 14 portion(s). 15 5.3 16 designate qualified information or items does not, standing alone, waive the 17 Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 23 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 24 6.2 25 process under Local Rule 37.1 et seq. 26 6.3 27 Designating Party. Frivolous challenges, and those made for an improper purpose 28 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to Meet and Confer. The Challenging Party shall initiate the dispute resolution The burden of persuasion in any such challenge proceeding shall be on the 7 STIPULATED PROTECTIVE ORDER 1 expose the Challenging Party to sanctions. Unless the Designating Party has waived 2 or withdrawn the confidentiality designation, all parties shall continue to afford the 3 material in question the level of protection to which it is entitled under the 4 Producing Party’s designation until the Court rules on the challenge. 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 Basic Principles. A Receiving Party may use Protected Material that is 7 disclosed or produced by another Party or by a Non-Party in connection with this 8 Action only for prosecuting, defending, or attempting to settle this Action. Such 9 Protected Material may be disclosed only to the categories of persons and under the 10 conditions described in this Order. When the Action has been terminated, a 11 Receiving Party must comply with the provisions of section 13 below (FINAL 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 Disclosure of “CONFIDENTIAL” Information or Items. Unless (a) The Receiving Party’s Outside Counsel of Record in this Action, as 21 well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 24 25 (b) The officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 (d) The court and its personnel; 8 STIPULATED PROTECTIVE ORDER 1 (e) Court reporters and their staff; 2 (f) Professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 6 (g) The author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 7 (h) During their depositions, witnesses, and attorneys for witnesses, in the 8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 9 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 10 not be permitted to keep any confidential information unless they sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 12 agreed by the Designating Party or ordered by the court. Pages of transcribed 13 deposition testimony or exhibits to depositions that reveal Protected Material may 14 be separately bound by the court reporter and may not be disclosed to anyone except 15 as permitted under this Stipulated Protective Order; and 16 17 (i) Any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 18 Notwithstanding the aforementioned specified categories of persons and 19 circumstances, all documents designated CONFIDENTIAL and their contents, 20 including and especially, but not limited to, documents and depositions under seal 21 containing the identities of witnesses, employees/personnel and consultants shall 22 expressly be deemed “Attorneys Eyes Only,” meaning its disclosure shall be limited 23 only to counsel for the parties in addition to the aforementioned specified categories 24 of persons and circumstances. However, documents that do not contain the 25 identities of percipient witnesses, such as the autopsy report, shall not be deemed 26 “attorneys eyes only.” 27 /// 28 /// 9 STIPULATED PROTECTIVE ORDER 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 7 (a) shall include a copy of the subpoena or court order; 8 9 Promptly notify in writing the Designating Party. Such notification (b) Promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and 12 (c) Cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. If the 14 Designating Party timely seeks a protective order, the Party served with the 15 subpoena or court order shall not produce any information designated in this action 16 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 25 Non-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 28 construed as prohibiting a Non-Party from seeking additional protections. 10 STIPULATED PROTECTIVE ORDER 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 that 6 some or all of the information requested is subject to a confidentiality agreement 7 with a Non-Party; 8 9 10 (2) Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 11 12 Promptly provide the Non-Party with a copy of the Stipulated (3) Make the information requested available for inspection by the 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. 22 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 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 or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 28 11 STIPULATED PROTECTIVE ORDER 1 and (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 4 OTHERWISE 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 protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without 10 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 11 as the parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work product protection, the 13 parties may incorporate their agreement in the stipulated protective order submitted 14 to the court. 15 12. 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 17 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 Protective 19 Order no Party waives any right it otherwise would have to object to disclosing or 20 producing any information or item on any ground not addressed in this Stipulated 21 Protective Order. Similarly, no Party waives any right to object on any ground to use 22 in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 24 Material must comply with Civil Local Rule 79-5. Protected Material may only be 25 filed under seal pursuant to a court order authorizing the sealing of the specific 26 Protected Material at issue. If a Party's request to file Protected Material under seal 27 is denied by the court, then the Receiving Party may file the information in the 28 public record unless otherwise instructed by the court. MISCELLANEOUS 12 STIPULATED PROTECTIVE ORDER 1 13. 2 FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 14. 21 measures including, without limitation, contempt proceedings and/or monetary 22 sanctions. Any violation of this Order may be punished by any and all appropriate IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 23 24 /// 25 /// 26 /// 27 /// 28 /// 13 STIPULATED PROTECTIVE ORDER 1 Respectfully submitted, 2 LAWRENCE BEACH ALLEN & CHOI, PC 3 4 Dated: June 5, 2024 By 5 6 7 8 /s/ Aamir Raza PAUL B. BEACH AAMIR RAZA1 Attorneys for Defendant CITY OF SAN BERNARDINO LAW OFFICE OF DALE K. GALIPO 9 10 Dated: June 5, 2024 11 12 13 By /s/ Hang D. Le DALE K. GALIPO HANG D. LE Attorneys for Plaintiff DEJON HEMPHILL 14 15 16 17 18 OO RDERED. FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. Dated: -XQH 19 _______________________________ __________________________ HONORABLE DAVID T.. B BRISTOW ORABL LE DA AVID T RISTOW UNITED ED STATES MAGISTRATE MAG GISTRATE JUDGE JUD 20 21 22 23 24 25 26 27 28 1 I, Aamir Raza, hereby attest that all the signatories listed, and on whose behalf the filing is submitted, concur in the content of this Stipulation and have authorized its filing. 14 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _______________________________ 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 DEJON HEMPHILL, an individual, v. County of San 8 Bernardino, et.al. Case No.5:24-cv-00825-KK-DTBx. I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and [print or type full name], of 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. I 14 further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 Termination of this action. I hereby appoint __________________________ [print 18 or type full name] of __________________________________________ [print or 19 type full address and telephone number] as my California agent for service of 20 process in connection with this action or any proceedings related to enforcement of 21 this Stipulated Protective Order. 22 Date: ____________________________ 23 City and State where sworn and signed: ________________________ 24 Printed name: _____________________________ 25 Signature: _______________________________ 26 27 28 15 STIPULATED PROTECTIVE ORDER

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