1 JjeEfFfrFeRy@EYsh Sin. bSrHotIfNirBmR.cOomT, ESQ. (SBN 155486) 2 JEFFREY S. SHINBROT, APLC 15260 Ventura Blvd., Suite 1200 3 Sherman Oaks, CA 91403 Telephone: (310) 659-5444 Fax: (310) 878-8304 4 Counsel for NANCY COHEN 5

UNITED STATES DISTRICT COURT

6

CENTRAL DISTRICT OF CALIFORNIA - CENTRAL DIVISION

7

8 NANCY COHEN, individual Case No. 2:23-10330-MWF-ADS 9 Plaintiff, 10 STIPULATED PROTECTIVE

ORDER

11 v.

12 JPMORGAN CHASE BANK, N.A., a Trial Date: March 18, 2025 13 national association

14 Defendant.

15

16 17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may 21 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 22 enter the following Stipulated Protective Order. The parties acknowledge that this 23 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 25 only to the limited information or items that are entitled to confidential treatment 26 under the applicable legal principles. 27 28 1 B. GOOD CAUSE STATEMENT 2 This action is likely to involve trade secrets, customer and pricing lists and 3 other valuable research, development, commercial, financial, technical and/or 4 proprietary information for which special protection from public disclosure and 5 from use for any purpose other than prosecution of this action is warranted. Such 6 confidential and proprietary materials and information consist of, among other 7 things, confidential business or financial information, information regarding 8 confidential business practices, or other confidential research, development, or 9 commercial information (including information implicating privacy rights of third 10 parties), information otherwise generally unavailable to the public, or which may be 11 privileged or otherwise protected from disclosure under state or federal statutes, 12 court rules, case decisions, or common law. 13 Accordingly, to expedite the flow of information, to facilitate the prompt 14 resolution of disputes over confidentiality of discovery materials, to adequately 15 protect information the parties are entitled to keep confidential, to ensure that the 16 parties are permitted reasonable necessary uses of such material in preparation for 17 and in the conduct of trial, to address their handling at the end of the litigation, and 18 serve the ends of justice, a protective order for such information is justified in this 19 matter. It is the intent of the parties that information will not be designated as 20 confidential for tactical reasons and that nothing be so designated without a good 21 faith belief that it has been maintained in a confidential, non-public manner, and 22 there is good cause why it should not be part of the public record of this case. 23 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 24 The parties further acknowledge, as set forth in Section 12.3, below, that this 25 Stipulated Protective Order does not entitle them to file confidential information 26 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 27 and the standards that will be applied when a party seeks permission from the court 28 to file material under seal. 1 There is a strong presumption that the public has a right of access to judicial 2 proceedings and records in civil cases. In connection with non-dispositive motions, 3 good cause must be shown to support a filing under seal. See Kamakana v. City and 4 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 5 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 6 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 7 require good cause showing), and a specific showing of good cause or compelling 8 reasons with proper evidentiary support and legal justification, must be made with 9 respect to Protected Material that a party seeks to file under seal. The parties’ mere 10 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 11 without the submission of competent evidence by declaration, establishing that the 12 material sought to be filed under seal qualifies as confidential, privileged, or 13 otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, 15 then compelling reasons, not only good cause, for the sealing must be shown, and 16 the relief sought shall be narrowly tailored to serve the specific interest to be 17 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 18 2010). For each item or type of information, document, or thing sought to be filed 19 or introduced under seal in connection with a dispositive motion or trial, the party 20 seeking protection must articulate compelling reasons, supported by specific facts 21 and legal justification, for the requested sealing order. Again, competent evidence 22 supporting the application to file documents under seal must be provided by 23 declaration. 24 Any document that is not confidential, privileged, or otherwise protectable in 25 its entirety will not be filed under seal if the confidential portions can be redacted. 26 If documents can be redacted, then a redacted version for public viewing, omitting 27 only the confidential, privileged, or otherwise protectable portions of the document, 28 shall be filed. Any application that seeks to file documents under seal in their 1 entirety should include an explanation of why redaction is not feasible. 2 2. DEFINITIONS 3 2.1 Action: Cohen v. JPMorgan Chase Bank, N.A., Case No. 2:23-10330- 4 MWF-ADS (C.D. Cal.) 5 2.2 Challenging Party: a Party or Non-Party that challenges the 6 designation of information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced 19 or generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 28 2.10 Outside Counsel of Record: attorneys who are not employees of a 1 party to this Action but are retained to represent or advise a party to this Action and 2 have appeared in this Action on behalf of that party or are affiliated with a law firm 3 that has appeared on behalf of that party, and includes support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record (and their 6 support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation 10 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 and their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery 16 Material from a Producing Party. 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 4. DURATION 26 Once a case proceeds to trial, information that was designated as 27 CONFIDENTIAL or maintained pursuant to this protective order used or 28 introduced as an exhibit at trial becomes public and will be presumptively available 1 to all members of the public, including the press, unless compelling reasons 2 supported by specific factual findings to proceed otherwise are made to the trial 3 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 4 “good cause” showing for sealing documents produced in discovery from 5 “compelling reasons” standard when merits-related documents are part of court 6 record). Accordingly, the terms of this protective order do not extend beyond the 7 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 11 under this Order must take care to limit any such designation to specific material 12 that qualifies under the appropriate standards. The Designating Party must 13 designate for protection only those parts of material, documents, items or oral or 14 written communications that qualify so that other portions of the material, 15 documents, items or communications for which protection is not warranted are not 16 swept unjustifiably within the ambit of this Order. Mass, indiscriminate or routinized designations are prohibited. 17 Designations that are shown to be clearly unjustified or that have been made for 18 an improper purpose (e.g., to unnecessarily encumber the case development process 19 or to impose unnecessary expenses and burdens on other parties) may expose 20 the Designating Party to sanctions. 21 If it comes to a Designating Party’s attention that information or items that 22 it designated for protection do not qualify for protection, that Designating Party 23 must promptly notify all other Parties that it is withdrawing the inapplicable 24 designation. 25 5.2 Manner and Timing of Designations. Except as otherwise provided 26 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as 27 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 28 1 protection under this Order must be clearly so designated before the material is 2 disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or 5 electronic documents, but excluding transcripts of depositions or other 6 pretrial or trial proceedings), that the Producing Party affix at a minimum, the 7 legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each 8 page that contains protected material. If only a portion of the material on a page 9 qualifies for protection, the Producing Party also must clearly identify the 10 protected portion(s) (e.g., by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents available for 12 inspection need not designate them for protection until after the inspecting Party 13 has indicated which documents it would like copied and produced. During the 14 inspection and before the designation, all of the material made available for 15 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the Producing Party must 17 determine which documents, or portions thereof, qualify for protection under 18 this Order. Then, before producing the specified documents, the Producing 19 Party must affix the “CONFIDENTIAL legend” to each page that contains 20 Protected Material. If only a portion of the material on a page qualifies for 21 protection, the Producing Party also must clearly identify the protected portion(s) 22 (e.g., by making appropriate markings in the margins). 23 (b) for testimony given in depositions that the Designating Party 24 identifies the Disclosure or Discovery Material on the record, before the 25 close of the deposition all protected testimony. 26 (c) for information produced in some form other than 27 documentary and for any other tangible items, that the Producing Party affix in a 28 prominent place on the exterior of the container or containers in which the 1 information is stored the legend “CONFIDENTIAL.” If only a portion or 2 portions of the information warrants protection, the Producing Party, to the 3 extent practicable, shall identify the protected portion(s). 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 failure to designate qualified information or items does not, standing alone, waive 5 the Designating Party’s right to secure protection under this Order for such 6 material. Upon timely correction of a designation, the Receiving Party must make 7 reasonable efforts to assure that the material is treated in accordance with the 8 provisions of this 9 Order. 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may 12 challenge a designation of confidentiality at any time that is consistent with 13 the Court’s Scheduling Order. 14 15 6.2 Meet and Confer. The Challenging Party shall initiate the 16 dispute resolution process under Local Rule 37-1 et seq. 17 6.3 Joint Stipulation. Any challenge submitted to the Court shall be 18 via a joint stipulation pursuant to Local Rule 37-2. 19 6.4 The burden of persuasion in any such challenge proceeding 20 shall be on the Designating Party. Frivolous challenges, and those made for 21 an improper purpose (e.g., to harass or impose unnecessary expenses and 22 burdens on other parties) may expose the Challenging Party to sanctions. Unless 23 the Designating Party has waived or withdrawn the confidentiality designation, 24 all parties shall continue to afford the material in question the level of protection 25 to which it is entitled under the Producing Party’s designation until the Court 26 rules on the challenge. 27 28 /// 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material 3 that is disclosed or produced by another Party or by a Non-Party in connection 4 with this Action only for prosecuting, defending or attempting to settle this 5 Action. Such Protected Material may be disclosed only to the categories of persons 6 and under the conditions described in this Order. When the Action has been 7 terminated, a Receiving Party must comply with the provisions of section 13 8 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at 10 a location and in a secure manner that ensures that access is limited to the 11 persons authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 13 Unless otherwise ordered by the court or permitted in writing by the Designating 14 Party, a Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, 17 as well as employees of said Outside Counsel of Record to whom it is 18 reasonably necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (g) the author or recipient of a document containing the information or 2 a custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in 4 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 5 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any confidential information unless they sign the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 7 agreed by the Designating Party or ordered by the court. Pages of transcribed 8 deposition testimony or exhibits to depositions that reveal Protected Material may 9 be separately bound by the court reporter and may not be disclosed to anyone except 10 as permitted under this Stipulated Protective Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, 12 mutually agreed upon by any of the parties engaged in settlement discussions. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14

IN OTHER LITIGATION

15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this Action 17 as “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such 19 notification shall include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena 21 or order to issue in the other litigation that some or all of the material covered 22 by the subpoena or order is subject to this Protective Order. Such notification shall 23 include a copy of this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought 25 to be pursued by the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with 27 the subpoena or court order shall not produce any information designated in 28 1 this action as “CONFIDENTIAL” before a determination by the court from which 2 the subpoena or order issued, unless the Party has obtained the Designating 3 Party’s permission. The Designating Party shall bear the burden and expense of 4 seeking protection in that court of its confidential material and nothing in these 5 provisions should be construed as authorizing or encouraging a Receiving Party in 6 this Action to disobey a lawful directive from another court. 7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced 10 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 11 information produced by Non-Parties in connection with this litigation is 12 protected by the remedies and relief provided by this Order. Nothing in these 13 provisions should be construed as prohibiting a Non-Party from seeking additional 14 protections. 15 (b) In the event that a Party is required, by a valid discovery 16 request, to produce a Non-Party’s confidential information in its possession, and 17 the Party is subject to an agreement with the Non-Party not to produce the 18 Non-Party’s confidential information, then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the 20 Non-Party that some or all of the information requested is subject to a 21 confidentiality agreement with a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the 23 Stipulated Protective Order in this Action, the relevant discovery request(s), and 24 a reasonably specific description of the information requested; and 25 (3) make the information requested available for inspection 26 by the Non-Party, if requested. 27 28 1 (c) If the Non-Party fails to seek a protective order from this court 2 within 14 days of receiving the notice and accompanying information, the 3 Receiving Party may produce the Non-Party’s confidential information responsive 4 to the discovery request. If the Non-Party timely seeks a protective order, the 5 Receiving Party shall not produce any information in its possession or control 6 that is subject to the confidentiality agreement with the Non-Party before a 7 determination by the court. Absent a court order to the contrary, the Non-Party 8 shall bear the burden and expense of seeking protection in this court of its 9 Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under 13 this Stipulated Protective Order, the Receiving Party must immediately (a) 14 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 15 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 16 the person or persons to whom unauthorized disclosures were made of all the terms 17 of this Order, and (d) request such person or persons to execute the 18 “Acknowledgment and 19 Agreement to Be Bound” that is attached hereto as Exhibit A. 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 26 procedure may be established in an e-discovery order that provides for production 27 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) 28 and (e), insofar as the parties reach an agreement on the effect of disclosure 1 of a communication or information covered by the attorney-client privilege or 2 work product protection, the parties may incorporate their agreement in the 3 stipulated protective order submitted to the court. 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of 6 any person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of 8 this Protective Order, no Party waives any right it otherwise would have to 9 object to disclosing or producing any information or item on any ground not 10 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 11 to object on any ground to use in evidence of any of the material covered by this 12 Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal 14 any Protected Material must comply with Local Civil Rule 79-5. Protected 15 Material may only be filed under seal pursuant to a court order authorizing the 16 sealing of the specific Protected Material at issue. If a Party’s request to file 17 Protected Material under seal is denied by the court, then the Receiving Party may 18 file the information 19 in the public record unless otherwise instructed by the court. 20 13. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 4, within 22 60 days of a written request by the Designating Party, each Receiving Party must 23 return all Protected Material to the Producing Party or destroy such material. As 24 used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any 26 of the Protected Material. Whether the Protected Material is returned or 27 destroyed, the Receiving Party must submit a written certification to the Producing 28 1 Party (and, if not the same person or entity, to the Designating Party) by the 60 2 day deadline that (1) identifies (by category, where appropriate) all the Protected 3 Material that was returned or destroyed and (2) affirms that the Receiving 4 Party has not retained any copies, abstracts, compilations, summaries or any other 5 format reproducing or capturing any of the Protected Material. Notwithstanding 6 this provision, Counsel are entitled to retain an archival copy of all pleadings, 7 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 8 correspondence, deposition and trial exhibits, expert reports, attorney work 9 product, and consultant and expert work product, even if such materials contain 10 Protected Material. Any such archival copies that contain or constitute 11 Protected Material remain subject to this Protective Order as set forth in 12 Section 4 (DURATION). 13 14. VIOLATION 14 Any violation of this Order may be punished by appropriate measures 15 including, without limitation, contempt proceedings and/or monetary sanctions. 16 /// /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 // 26 /// 27

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

28 1 Dated: August 27, 2024 JEFFREY S. SHINBROT, APLC 2 3 By:/s/Jeffrey S. Shinbrot

JEFFREY S. SHINBROT, ESQ.

4 Counsel to Plaintiff Nancy Cohen

5

6 Dated: August 27, 2024 GREENBERG TRAURIG, LLP 7 8 By /s/ Layal L. Bishara Layal L. Bishara 9 Attorneys for Defendant

JPMORGAN CHASE BANK, N.A.

10

11

SIGNATURE ATTESTATION

12 Pursuant to Local Rule 5-4.3.4(a)(2), I hereby attest that all signatories listed above, 13 and on whose behalf this filing is submitted, concur in the filings’ content and have 14 authorized the filing. 15

16 Dated: August 27, 2024 JEFFREY S. SHINBROT, APLC 17 18 By:/s/Jeffrey S. Shinbrot

JEFFREY S. SHINBROT, ESQ.

19 Counsel to Plaintiff Nancy Cohen 20 /// /// 21 /// 22 /// 23 /// 24 /// /// 25 /// 26 /// 27 /// 28 /// 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 Dated: 08/28/2024 3 4 By /s/ Autumn D. Spaeth ___ 5 HON. AUTUMN D. SPAETH United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I,___________________________ of ______________, declare under penalty of 4 perjury that I have read in its entirety and understand the Stipulated Protective Order that 5 was issued by the United States District Court for the Central District of California 6 on ______in the case of NANCY COHEN v. JPMORGAN CHASE BANK, N.A., 7 Case No. 2:23-10330-MWF-ADS. I agree to comply with and to be bound by all 8 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 9 contempt. I solemnly promise that I will not disclose in any manner any 10 information or item that is subject to this Stipulated Protective Order to any person 11 or entity except in strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court 13 for the Central District of California for enforcing the terms of this Stipulated 14 Protective 15 Order, even if such enforcement proceedings occur after termination of this 16 action. 17 I hereby appoint ________________ [print or type full name] of 18 _________________ as my California agent for service of process in connection 19 with this action or any proceedings related to enforcement of this Stipulated 20 Protective Order. 21 Date: ______________________________________ 22

23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28