Garcia et al v. HM Islamic, Inc. et al

Filing 15

STIPULATED PROTECTIVE ORDER FOR STANDARD LITIGATION re 14 STIPULATION WITH PROPOSED ORDER STIPULATED PROTECTIVE ORDER filed by Shih-Kewi Chen, HM Islamic, Inc. Signed by Judge Paul S. Grewal on April 25, 2012. (psglc1, COURT STAFF) (Filed on 4/25/2012)

1
2
3
4

TOMAS E. MARGAIN, Bar No. 193555
DAL BON & MARGAIN, APC
28 NORTH 1ST SUITE 700
SAN JOSE, CA 95113
TEL [phone]
FAX [phone]
[e-mail]

5
Attorneys for Plaintiffs
6
7
UNITED STATES DISTRICT COURT

8

NORTHERN DISTRICT OF CALIFORNIA

9
10
11

CELESTINO GARCIA and SAUL L.
ALTAMIRANO

12
Plaintiffs

Case No. C 11-04944 PSG
STIPULATED PROTECTIVE ORDER FOR
STANDARD LITIGATION

13
14
15

v.
HM ISLAMIC, INC. SHIH-KWEI CHEN aka
SAM CHEN

16

Defendants

17
18

1.

PURPOSES AND LIMITATIONS

19

Disclosure and discovery activity in this action are likely to involve production of confidential,

20

proprietary, or private information for which special protection from public disclosure and from use for

21

any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby

22

stipulate to and petition the court to enter the following Stipulated Protective Order. The parties

23

acknowledge that this Order does not confer blanket protections on all disclosures or responses to

24

discovery and that the protection it affords from public disclosure and use extends only to the limited

25

information or items that are entitled to confidential treatment under the applicable legal principles. The

26

parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does

27

not entitle them to file confidential information under seal; Civil Local Rule 79-5 and General Order 62 set

28

1

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

2

permission from the court to file material under seal.

3

2.

4
5

DEFINITIONS
2.1

Challenging Party: a Party or Non-Party that challenges the designation of information or

items under this Order.

6

2.2

“CONFIDENTIAL” Information or Items: information (regardless of how it is generated,

7

stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure

8

26(c).

9

2.3

10

their support staff).

11

2.4

12
13

Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as

Designating Party: a Party or Non-Party that designates information or items that it

produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
2.5

Disclosure or Discovery Material: all items or information, regardless of the medium or

14

manner in which it is generated, stored, or maintained (including, among other things, testimony,

15

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

16

this matter.

17

2.6

Expert: a person with specialized knowledge or experience in a matter pertinent to the

18

litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in

19

this action.

20

2.7

21
22
23
24

House Counsel: attorneys who are employees of a party to this action. House Counsel

does not include Outside Counsel of Record or any other outside counsel.
2.8

Non-Party: any natural person, partnership, corporation, association, or other legal entity

not named as a Party to this action.
2.9

Outside Counsel of Record: attorneys who are not employees of a party to this action but

25

are retained to represent or advise a party to this action and have appeared in this action on behalf of that

26

party or are affiliated with a law firm which has appeared on behalf of that party.

27
28

2.10

Party: any party to this action, including all of its officers, directors, employees,

consultants, retained experts, and Outside Counsel of Record (and their support staffs).

2

1
2

2.11

Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in

this action.

3

2.12

Professional Vendors: persons or entities that provide litigation support services (e.g.,

4

photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or

5

retrieving data in any form or medium) and their employees and subcontractors.

6

2.13

7

“CONFIDENTIAL.”

8

2.14

Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing

2.15

Worker Contact Information:

9

Protected Material: any Disclosure or Discovery Material that is designated as

Party.

10

any documents or other information produced

11

containing the name, telephone number, and/or address of any worker, employee and/or

12

independent contractor of any party hereto may be designated as “Confidential.”

13
14

3.

SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material (as

15
16

defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies,

17

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

18

presentations by Parties or their Counsel that might reveal Protected Material. However, the protections

19

conferred by this Stipulation and Order do not cover the following information: (a) any information that is

20

in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain

21

after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order,

22

including becoming part of the public record through trial or otherwise; and (b) any information known to

23

the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a

24

source who obtained the information lawfully and under no obligation of confidentiality to the Designating

25

Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.

26

4.

27
28

DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this Order

shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise

3

1

directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this

2

action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all

3

appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any

4

motions or applications for extension of time pursuant to applicable law.

5

5.

6

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-

7

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

8

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

9

designate for protection only those parts of material, documents, items, or oral or written communications

10

that qualify – so that other portions of the material, documents, items, or communications for which

11

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

12

Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be

13

clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or

14

retard the case development process or to impose unnecessary expenses and burdens on other parties)

15

expose the Designating Party to sanctions.

16

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

17

protection do not qualify for protection, that Designating Party must promptly notify all other Parties that

18

it is withdrawing the mistaken designation.

19

5.2

Manner and Timing of Designations. Except as otherwise provided in this Order (see,

20

e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or

21

Discovery Material that qualifies for protection under this Order must be clearly so designated before the

22

material is disclosed or produced.

23
24

Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic documents, but

25

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix

26

the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion or portions

27

of the material on a page qualifies for protection, the Producing Party also must clearly identify the

28

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

4

1

A Party or Non-Party that makes original documents or materials available for inspection need not

2

designate them for protection until after the inspecting Party has indicated which material it would like

3

copied and produced. During the inspection and before the designation, all of the material made available

4

for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the

5

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

6

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

7

the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains Protected

8

Material. If only a portion or portions of the material on a page qualifies for protection, the Producing

9

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

10

margins).

11

(b) for testimony given in deposition or in other pretrial or trial proceedings, that

12

the Party or non-party offering or sponsoring the testimony identify on the record, before the

13

close of the deposition, hearing, or other proceeding, all protected testimony, and further specify

14

any portions of the testimony that qualify as “CONFIDENTIAL” When it is impractical to

15

identify separately each portion of testimony that is entitled to protection, and when it appears

16

that substantial portions of the testimony may qualify for protection, the Party or non-party that

17

sponsors, offers, or gives the testimony may invoke on the record (before the deposition or

18

proceeding is concluded) a right to have up to 20 days to identify the specific portions of the

19

testimony as to which protection is sought.

20

appropriately designated for protection within the 20 days shall be covered by the provisions of

21

this Stipulated Protective Order.

Only those portions of the testimony that are

22

Transcript pages containing Protected Material must be separately bound by the court

23

reporter, who must affix to the top of each such page the legend “CONFIDENTIAL” as instructed

24

by the Party or nonparty offering or sponsoring the witness or presenting the testimony.

25
26

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

27

tangible items, that the Producing Party affix in a prominent place on the exterior of the container or

28

containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a portion or

5

1

portions of the information or item warrant protection, the Producing Party, to the extent practicable, shall

2

identify the protected portion(s).

3

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

4

designate qualified information or items does not, standing alone, waive the Designating Party’s

5

right to secure protection under this Order for such material. . If material is appropriately

6

designated as “Confidential” after the material was initially produced, the Receiving Party, on

7

timely notification of the designation, must make reasonable efforts to assure that the material is

8

treated in accordance with the provisions of this Order.

9
10
11

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

12

confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality designation

13

is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant

14

disruption or delay of the litigation, a Party does not waive its right to challenge a confidentiality

15

designation by electing not to mount a challenge promptly after the original designation is disclosed.

16

6.2

Meet and Confer. A Party that elects to initiate a challenge to a Designating Party’s

17

confidentiality designation must do so in good faith and must begin the process by conferring directly (in

18

voice to voice dialogue; other forms of communication are not sufficient) with counsel for the Designating

19

Party. In conferring, the challenging Party must explain the basis for its belief that the confidentiality

20

designation was not proper and must give the Designating Party an opportunity to review the designated

21

material, to reconsider the circumstances, and, if no change in designation is offered, to explain the basis

22

for the chosen designation. A challenging Party may proceed to the next stage of the challenge process

23

only if it has engaged in this meet and confer process first.

24

6.3

Judicial Intervention. If the Parties cannot resolve a challenge without court intervention,

25

the Designating Party shall file and serve a motion to retain confidentiality under Civil Local Rule 7 (and

26

in compliance with Civil Local Rule 79-5 and General Order 62, if applicable) within 21 days of the initial

27

notice of challenge or within 14 days of the parties agreeing that the meet and confer process will not

28

resolve their dispute, whichever is earlier. Each such motion must be accompanied by a competent

6

1

declaration affirming that the movant has complied with the meet and confer requirements imposed in the

2

preceding paragraph. Failure by the Designating Party to make such a motion including the required

3

declaration within 21 days (or 14 days, if applicable) shall automatically waive the confidentiality

4

designation for each challenged designation. In addition, the Challenging Party may file a motion

5

challenging a confidentiality designation at any time if there is good cause for doing so, including a

6

challenge to the designation of a deposition transcript or any portions thereof. Any motion brought

7

pursuant to this provision must be accompanied by a competent declaration affirming that the movant has

8

complied with the meet and confer requirements imposed by the preceding paragraph.

9

The burden of persuasion in any such challenge proceeding shall be on the Designating Party.

10

Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary

11

expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the

12

Designating Party has waived the confidentiality designation by failing to file a motion to retain

13

confidentiality as described above, all parties shall continue to afford the material in question the level of

14

protection to which it is entitled under the Producing Party’s designation until the court rules on the

15

challenge.

16

7.

17

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is disclosed or

18

produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending,

19

or attempting to settle this litigation. Such Protected Material may be disclosed only to the categories of

20

persons and under the conditions described in this Order. When the litigation has been terminated, a

21

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

22
23
24

Protected Material must be stored and maintained by a Receiving Party at a location and in a
secure manner that ensures that access is limited to the persons authorized under this Order.
7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the

25

court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or

26

item designated “CONFIDENTIAL” only to:

27

(a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees

28

of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this

7

1

litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is attached hereto

2

as Exhibit A;

3

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

4

Party to whom disclosure is reasonably necessary for this litigation and who have signed the

5

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

6

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

7

reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be

8

Bound” (Exhibit A);

9

(d) the court and its personnel;

10

(e) court reporters and their staff, professional jury or trial consultants, mock jurors, and

11

Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have signed

12

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

13

(f) during their depositions, witnesses in the action to whom disclosure is reasonably

14

necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

15

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

16

testimony or exhibits to depositions that reveal Protected Material must be separately bound by the court

17

reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order.

18

(g) the author of the document or the original source of the information.

19

7.3

Disclosure

of

Worker

Contact

Information

designated

20

“CONFIDENTIAL”:

21

Unless otherwise ordered by the court or agreed to in writing by the parties, a Receiving

22

Party may use Worker Contact Information (as defined in paragraph 2.15) only to investigate,

23

prosecute, or defend this litigation. This also includes information regarding any former or

24

current employer of Plaintiffs. Furthermore, Counsel for the Receiving Party who uses Worker

25

Contact Information to contact any individual, must:

26
27
28

(a) inform the individual that they have the right not to talk to any party and/or their
counsel,
(b) terminate contact with any individuals who elect not to talk to a party or their counsel,
8

1

(c) keep a list of those individuals who are contacted,

2

(d) ensure that the contact information is not used for any purpose outside of this

3

litigation, and

4

(e) agree not to solicit in violation of California Law or California Rule of Professional

5

Conduct 1-400 any individual for the purpose of bringing a claim, complaint, charge, and/or

6

demand against any party to this ligation.

7
8

8.

9

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

10
11

disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall include a

12
13

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
LITIGATION

copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order to issue in the

14
15

other litigation that some or all of the material covered by the subpoena or order is subject to this

16

Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by the

17
18

Designating Party whose Protected Material may be affected.

19

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

20

court order shall not produce any information designated in this action as “CONFIDENTIAL” before a

21

determination by the court from which the subpoena or order issued, unless the Party has obtained the

22

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

23

protection in that court of its confidential material – and nothing in these provisions should be construed as

24

authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from another

25

court.

26

The purpose of imposing these duties is to alert the interested parties to the existence of

27

this Protective Order and to afford the Designating Party in this case an opportunity to try to

28

protect its confidentiality interests in the court from which the subpoena or order issued.

9

1
2

9.

3
4

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION
(a)

The terms of this Order are applicable to information produced by a Non-Party in

5

this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in

6

connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in

7

these provisions should be construed as prohibiting a Non-Party from seeking additional protections.

8
9
10

(b)

In the event that a Party is required, by a valid discovery request, to produce a

Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the
Non-Party not to produce the Non-Party’s confidential information, then the Party shall:

11
12

promptly notify in writing the Requesting Party and the Non-Party that
some or all of the information requested is subject to a confidentiality agreement with a Non-Party;

13

promptly provide the Non-Party with a copy of the Stipulated Protective

14

Order in this litigation, the relevant discovery request(s), and a reasonably specific description of the

15

information requested; and

16

make the information requested available for inspection by the Non-Party.

17

(c)

If the Non-Party fails to object or seek a protective order from this court within 14

18

days of receiving the notice and accompanying information, the Receiving Party may produce the Non-

19

Party’s confidential information responsive to the discovery request. If the Non-Party timely seeks a

20

protective order, the Receiving Party shall not produce any information in its possession or control that is

21

subject to the confidentiality agreement with the Non-Party before a determination by the court.1 Absent a

22

court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this

23

court of its Protected Material.

24

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

25

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

26

to any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving

27
28

10

1

Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use

2

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

3

persons to whom unauthorized disclosures were made of all the terms of this Order, and (d) request such

4

person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto

5

as Exhibit A.

6

11.

7

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

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
MATERIAL

Material to any person or in any circumstance not authorized under this Stipulated Protective
Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
unauthorized disclosures, (b) use its best efforts to retrieve all copies of the Protected Material, (c)
inform the person or persons to whom unauthorized disclosures were made of all the terms of this
Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
Be Bound” that is attached hereto as Exhibit A.
12.

MISCELLANOUS
12.1

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

modification by the court in the future.
12.2

Right to Assert Other Objections. By stipulating to the entry of this Protective Order no

Party waives any right it otherwise would have to object to disclosing or producing any information or
item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right
to object on any ground to use in evidence of any of the material covered by this Protective Order.
12.3

Filing Protected Material. Without written permission from the Designating Party or a

court order secured after appropriate notice to all interested persons, a Party may not file in the public
record in this action any Protected Material. A Party that seeks to file under seal any Protected Material
must comply with Civil Local Rule 79-5 and General Order 62. Protected Material may only be filed
under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue.
Pursuant to Civil Local Rule 79-5 and General Order 62, a sealing order will issue only upon a request
establishing that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise

11

1

entitled to protection under the law. If a Receiving Party's request to file Protected Material under seal

2

pursuant to Civil Local Rule 79-5(d) and General Order 62 is denied by the court, then the Receiving Party

3

may file the information in the public record pursuant to Civil Local Rule 79-5(e) unless otherwise

4

instructed by the court.

5

13.

6

FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph 4, each Receiving

7

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

8

subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and any other

9

format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned

10

or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the

11

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

12

where appropriate) all the Protected Material that was returned or destroyed and (2)affirms that the

13

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

14

reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are

15

entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

16

legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and

17

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

18

copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in

19

Section 4 (DURATION).

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

12

1

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2
3
4
5

DATED: April 24, 2012________________ ___/s/ Tomas E. Margain______________________
Tomas E. Margain
Attorneys for Plaintiff

6
7
8

DATED: April 24, 2012_______________

/s/ Lee Sheldon__________________________________
Lee Sheldon
Attorneys for Defendant

9
10

PURSUANT TO STIPULATION, IT IS SO ORDERED.

11
12
13

4/25/2012
DATED: ________________________ _____________________________________
Hon. Paul S. Grewal
United States Magistrate Judge

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

13

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, _____________________________ [print or type full name], of _________________

4

[print or type full address], declare under penalty of perjury that I have read in its entirety and understand

5

the Stipulated Protective Order that was issued by the United States District Court for the Northern District

6

of California on

7

agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand

8

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

9

contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject

10

to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions

11

of this Order.

in the case of Garcia v. HM Islamic NDCA Case No. 11-04944 PSG. I

12

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

13

Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order,

14

even if such enforcement proceedings occur after termination of this action.

15

I hereby appoint __________________________ [print or type full name] of

16

_______________________________________ [print or type full address and telephone number] as my

17

California agent for service of process in connection with this action or any proceedings related to

18

enforcement of this Stipulated Protective Order.

19
20

Date: _________________________________

21

City and State where sworn and signed: _________________________________

22
23
24

Printed name: ______________________________
[printed name]
Signature: __________________________________
[signature]

25
26
27
28

14