Paulette Smith v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: February 13, 2020
• Docket: 2:19-cv-05370
• Status: Unknown

Opinion

MICHAEL N. FEUER, city Attomey ! || KATHLEEN A. KENEALY, Chief Assistant City Attomey (SBN 212289) SCOTT MARCUS, Chief, Civil Litigation Branch (SBN 184980) 2 || CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453) 3 GEOFFREY PLOWDEN, Deputy City Attorney (SBN146602) 200 No. Main Street, 6th Floor City Hall East A Los Angeles, California 90012. Email: geoffrey.plowden@lacity.or 5 || Phone: (213) 978-7038 Fax No: O13) 978-8785 6 || Attorneys for Defendant CITY OF LOS ANGELES 7 || THE COCHRAN FIRM DISCOVERY MATTER BRIAN DUNN (SBN 176502) 8 ||4929 Wilshire Blvd. #1010 Los Angeles, California 9010 9 || Phone Number: (323) 435-8205 Fax Number: (323) 282-5280 10 || Email: Bdunn @cochranfirm.com 11 || Attorneys for Plaintiff PAULETTE SMITH 12 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 16 PAULETTE SMITH, individually and as CASE NO. Successor in Interest to ALBERT DORSEY,| 2:19-cv—05370-—CAS—JCx 17 || deceased; 18 Plaintiff, STIPULATION FOR PROPOSED 19 PROTECTIVE ORDER V. 20 U.S. MAGISTRATE CITY OF LOS ANGELES, a municipal JACQUELINE CHOOLJIAN 21 || entity, OFFICER EDWARD AGDEPPA, an 09 individual, and DOES 1 through 10 inclusive, 23 Defendants. 24 25 6 || 1- A. PURPOSES AND LIMITATIONS 7 Discovery in this action is likely to involve production of confidential, 4g proprietary or private information for which special protection from public disclosure

1 and from use for any purpose other than prosecuting this litigation may be warranted. 2 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 3 Stipulated Protective Order. The parties acknowledge that this Order does not confer 4 blanket protections on all disclosures or responses to discovery and that the protection 5 it affords from public disclosure and use extends only to the limited information or 6 items that are entitled to confidential treatment under the applicable legal principles. 7 B. GOOD CAUSE STATEMENT 8 This action is likely to involve third party privacy, HIPPA information, peace 9 officer personnel and official information for which special protection from public 10 disclosure and from use for any purpose other than prosecution of this action is 11 warranted. Such confidential and proprietary materials and information consist of, 12 among other things, (including information implicating privacy rights of third parties), 13 information otherwise generally unavailable to the public, or which may be privileged 14 or otherwise protected from disclosure under state or federal statutes, court rules, case 15 decisions, or common law. Accordingly, to expedite the flow of information, to 16 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 17 to adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in preparation 19 for and in the conduct of trial, to address their handling at the end of the litigation, and 20 serve the ends of justice, a protective order for such information is justified in this 21 matter. It is the intent of the parties that information will not be designated as 22 confidential for tactical reasons and that nothing be so designated without a good faith 23 belief that it has been maintained in a confidential, non-public manner, and there is good 24 cause why it should not be part of the public record of this case. 25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information under 28 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 1 standards that will be applied when a party seeks permission from the court to file 2 material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 proceedings and records in civil cases. In connection with non-dispositive motions, 5 good cause must be shown to support a filing under seal. See Kamakana v. City and 6 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 7 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 8 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 9 cause showing), and a specific showing of good cause or compelling reasons with 10 proper evidentiary support and legal justification, must be made with respect to 11 Protected Material that a party seeks to file under seal. The parties’ mere designation 12 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 13 submission of competent evidence by declaration, establishing that the material sought 14 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 15 constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 compelling reasons, not only good cause, for the sealing must be shown, and the relief 18 sought shall be narrowly tailored to serve the specific interest to be protected. See 19 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 20 or type of information, document, or thing sought to be filed or introduced under seal 21 in connection with a dispositive motion or trial, the party seeking protection must 22 articulate compelling reasons, supported by specific facts and legal justification, for the 23 requested sealing order. Again, competent evidence supporting the application to file 24 documents under seal must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in its 26 entirety will not be filed under seal if the confidential portions can be redacted. If 27 documents can be redacted, then a redacted version for public viewing, omitting only 28 1 the confidential, privileged, or otherwise protectable portions of the document, shall be 2 filed. Any application that seeks to file documents under seal in their entirety should 3 include an explanation of why redaction is not feasible. 4 2. DEFINITIONS 5 2.1 Action: this pending federal lawsuit. 6 2.2 Challenging Party: a Party or Non-Party that challenges the designation 7 of information or items under this Order. 8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 9 it is generated, stored or maintained) or tangible things that qualify for protection under 10 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 11 Statement. 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 13 support staff). 14 2.5 Designating Party: a Party or Non-Party that designates information or 15 items that it produces in disclosures or in responses to discovery as 16 “CONFIDENTIAL.” 17 2.6 Disclosure or Discovery Material: all items or information, regardless of 18 the medium or manner in which it is generated, stored, or maintained (including, among 19 other things, testimony, transcripts, and tangible things), that are produced or generated 20 in disclosures or responses to discovery in this matter. 21 2.7 Expert: a person with specialized knowledge or experience in a matter 22 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 23 expert witness or as a consultant in this Action. 24 2.8 House Counsel: attorneys who are employees of a party to this Action. 25 House Counsel does not include Outside Counsel of Record or any other outside 26 counsel. 27 2.9 Non-Party: any natural person, partnership, corporation, association or 28 other legal entity not named as a Party to this action. 1 2.10 Outside Counsel of Record: attorneys who are not employees of a party 2 to this Action but are retained to represent or advise a party to this Action and have 3 appeared in this Action on behalf of that party or are affiliated with a law firm that has 4 appeared on behalf of that party, and includes support staff. 5 2.11 Party: any party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 9 Discovery Material in this Action. 10 2.13 Professional Vendors: persons or entities that provide litigation support 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 13 their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL.” A watermark may be affixed to the documents. 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only Protected 20 Material (as defined above), but also (1) any information copied or extracted from 21 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 22 Material; and (3) any testimony, conversations, or presentations by Parties or their 23 Counsel that might reveal Protected Material. 24 Any use of Protected Material at trial shall be governed by the orders of the trial 25 judge. This Order does not govern the use of Protected Material at trial. 26 4. DURATION 27 Once a case proceeds to trial, information that was designated as 28 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 1 an exhibit at trial becomes public and will be presumptively available to all members 2 of the public, including the press, unless compelling reasons supported by specific 3 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 4 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 5 documents produced in discovery from “compelling reasons” standard when merits- 6 related documents are part of court record). Accordingly, the terms of this protective 7 order do not extend beyond the commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection under this 11 Order must take care to limit any such designation to specific material that qualifies 12 under the appropriate standards. The Designating Party must designate for protection 13 only those parts of material, documents, items or oral or written communications that 14 qualify so that other portions of the material, documents, items or communications for 15 which protection is not warranted are not swept unjustifiably within the ambit of this 16 Order. 17 Mass, indiscriminate or routinized designations are prohibited. Designations that 18 are shown to be clearly unjustified or that have been made for an improper purpose 19 (e.g., to unnecessarily encumber the case development process or to impose 20 unnecessary expenses and burdens on other parties) may expose the Designating Party 21 to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 designated for protection do not qualify for protection, that Designating Party must 24 promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 5.2 Manner and Timing of Designations. Except as otherwise provided in this 26 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 27 or ordered, Disclosure or Discovery Material that qualifies for protection under this 28 Order must be clearly so designated before the material is disclosed or produced. 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 6 portion of the material on a page qualifies for protection, the Producing Party also must 7 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 8 margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and before 12 the designation, all of the material made available for inspection shall be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 14 copied and produced, the Producing Party must determine which documents, or 15 portions thereof, qualify for protection under this Order. Then, before producing the 16 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 17 each page that contains Protected Material. If only a portion of the material on a page 18 qualifies for protection, the Producing Party also must clearly identify the protected 19 portion(s) (e.g., by making appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 the Disclosure or Discovery Material on the record, before the close of the deposition 22 all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 protection, the Producing Party, to the extent practicable, shall identify the protected 28 portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. Upon 4 timely correction of a designation, the Receiving Party must make reasonable efforts to 5 assure that the material is treated in accordance with the provisions of this Order. 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 designation of confidentiality at any time that is consistent with the Court’s Scheduling 9 Order. 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 11 resolution process under Local Rule 37.1 et seq. 12 6.3 The burden of persuasion in any such challenge proceeding shall be on the 13 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 14 to harass or impose unnecessary expenses and burdens on other parties) may expose the 15 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 16 the confidentiality designation, all parties shall continue to afford the material in 17 question the level of protection to which it is entitled under the Producing Party’s 18 designation until the Court rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this Action 22 only for prosecuting, defending or attempting to settle this Action. Such Protected 23 Material may be disclosed only to the categories of persons and under the conditions 24 described in this Order. When the Action has been terminated, a Receiving Party must 25 comply with the provisions of section 13 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 location and in a secure manner that ensures that access is limited to the persons 28 authorized under this Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 4 only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 6 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 7 disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or a 19 custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses, and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 23 not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 25 by the Designating Party or ordered by the court. Pages of transcribed deposition 26 testimony or exhibits to depositions that reveal Protected Material may be separately 27 bound by the court reporter and may not be disclosed to anyone except as permitted 28 under this Stipulated Protective Order; and 1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 4 OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation that 6 compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification shall 9 include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to 11 issue in the other litigation that some or all of the material covered by the subpoena or 12 order is subject to this Protective Order. Such notification shall include a copy of this 13 Stipulated Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be pursued 15 by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with the 17 subpoena or court order shall not produce any information designated in this action as 18 “CONFIDENTIAL” before a determination by the court from which the subpoena or 19 order issued, unless the Party has obtained the Designating Party’s permission. The 20 Designating Party shall bear the burden and expense of seeking protection in that court 21 of its confidential material and nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 23 directive from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 25 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 produced 28 by Non-Parties in connection with this litigation is protected by the remedies and relief 1 provided by this Order. Nothing in these provisions should be construed as prohibiting 2 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 confidential 6 information, then the Party shall: 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 with 9 a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific 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 may 17 produce the Non-Party’s confidential information responsive to the discovery request. 18 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 19 any information in its possession or control that is subject to the confidentiality 20 agreement with the Non-Party before a determination by the court. Absent a court order 21 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 22 in this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 28 all unauthorized copies of the Protected Material, (c) inform the person or persons to 1 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 2 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 3 that is attached hereto as Exhibit A. 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other 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 prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 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 to 14 the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order, no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use 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 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 25 only be 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 is 27 denied by the court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 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 all 4 Protected Material to the Producing Party or destroy such material. As used in this 5 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 Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 16 work product, and consultant and expert work product, even if such materials contain 17 Protected Material. Any such archival copies that contain or constitute Protected 18 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 19 /// 20 /// 21 22 /// 23 /// 24 25 /// 26 /// 27 /// 28 14. VIOLATION 1 Any violation of this Order may be punished by appropriate measures including, 2 without limitation, contempt proceedings and/or monetary sanctions. 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 5 Dated: January 24, 2020 THE COHRAN FIRM 6 7 By: /s/ Brian Dunn BRIAN DUNN 8 Attorney for Plaintiffs PAULETTE SMITH, 9 10 11 Dated: January 24, 2020 MICHAEL N. FEUER, City Attorney KATHLEEN A. KENEALY, Chief Asst. City Atty 12 SCOTT MARCUS, Chief, Civil Litigation Branch CORY M. BRENTE, Senior Asst. City Atty. 13 14 By: /s/ Geoffrey Plowden__________ 15 GEOFFREY PLOWDEN 16 Attorneys for Defendant CITY OF LOS ANGELES 17 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 DATED: February 13, 2020 21 22 ____________/s/___________________ 23 HON. JACQUELINE CHOOLJIAN United States Magistrate Judge 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that 6 I have read in its entirety and understand the Stipulated Protective Order that was issued 7 by the United States District Court for the Central District of California on February 8 13, 2020 in the case of Paulette Smith v. City of Los Angeles, et al., 2:19-cv-05370- 9 CAS-JC. I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 12 that I will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. I further agree to submit to the jurisdiction of the United States 15 District Court for the Central District of California for 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 or 18 type full name] of _______________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this Stipulated 21 Protective Order. 22 Date: ______________________________________ 23 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 Signature: __________________________________ 28