Christopher Clark, Esq. Bar No. 346464 2

MORDAUNT, ROUNDY, REIHL & JIMERSON

3 A Professional Law Corporation 2800 W. March Lane, Suite 300 4 Stockton, CA 95219 Telephone: (209) 473-8732 5 Facsimile: (209) 957-9165 6 lreihl@mrrjlaw.com; cclark@mrrjlaw.com service@mrrjlaw.com 7 8 Attorneys for Defendants

COUNTY OF SANTA BARBARA, SANTA BARBARA

9 COUNTY SHERIFF'S OFFICE, SERGEANT RICHARD

SOTO, DEPUTY JOHN HEIL; DEPUTY MICHAEL REYNOSO,

10 DEPUTY DAVID VANDERPOL, SERGEANT JEFFREY KOELLER, DEPUTY IAN UR, and DEPUTY JOSE ALEJO 11

12

UNITED STATES DISTRICT COURT

13

CENTRAL DISTRICT OF CALIFORNIA

14 TAWNY GONZALEZ, an individual, ) Case No. 2:24-cv-01926-AB-MAR 15 SANDRA ESCOBEDO, as Guardian ad ) Litem for J.L.G., a minor, and T.J.G., a ) STIPULATED PROTECTIVE 16 minor ) ORDER ) 17 Plaintiff(s), ) vs. ) 18 )

COUNTY OF SANTA BARBARA, )

19 SANTA BARBARA COUNTY SHERIFF’S )

OFFICE, SANTA BARBARA COUNTY )

20 SHERIFF’S SERGEANT RICHARD )

SOTO, SANTA BARBARA COUNTY )

21 SHERIFF’S DEPUTY JOHN HEIL; )

SANTA BARBARA COUNTY SHERIFF’S )

22 DEPUTY MICHAEL REYNOSO, SANTA )

BARBARA COUNTY SHERIFF’S )

23 DEPUTY DAVID VANDERPOL, SANTA )

BARBARA COUNTY SHERIFF’S )

24 CUSTODY SERGEANT JEFFREY )

KOELLER, SANTA BARBARA COUNTY )

25 SHERIFF’S CUSTODY DEPUTY IAN )

UR, SANTA BARBARA COUNTY )

26 SHERIFF’S CUSTODY DEPUTY JOSE ) ALEJO, and DOES 1 TO 20 ) 27 ) Mordaunt, Roundy, Defendant(s) ) 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 ) Suite 300 Stockton, CA 95219 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, proprietary, or 4 private information for which special protection from public disclosure and from use 5 for any purpose other than prosecuting this litigation may be warranted. Accordingly, 6 the parties hereby stipulate to and petition the Court to enter the following Stipulated 7 Protective Order. The parties acknowledge that this Order does not confer blanket 8 protections on all disclosures or responses to discovery and that the protection it 9 affords from public disclosure and use extends only to the limited information or 10 items that are entitled to confidential treatment under the applicable legal principles. 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and 14 the standards that will be applied when a party seeks permission from the court to file 15 material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 The parties jointly ask the Court to enter the stipulated protective order 18 because good cause exists under Federal Rule of Civil Procedure 26(c). This action 19 concerns a death that occurred while the decedent was in county jail custody, and 20 discovery will necessarily encompass sensitive materials that would otherwise 21 remain confidential, including surveillance video, autopsy photographs, medical and 22 mental health records, internal affairs reports, and facility security protocols. Public 23 disclosure of those materials would invade the privacy of the decedent’s family, other 24 inmates, and correctional staff, reveal security measures and investigative techniques, 25 interfere with related administrative or criminal reviews. The proposed order 26 narrowly tailors its restrictions by allowing use of the designated material solely for 27 this litigation, by requiring secure storage and controlled access, and by directing that Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 the material be returned or destroyed when the case concludes, thus balancing the Suite 300 Stockton, CA 95219 2 order will protect those interests, facilitate efficient and complete discovery, and 3 promote the just resolution of this case. 4 5 2. DEFINITIONS 6 2.1 Action: Tawny Gonzalez, et. al. v. County of Santa Barbara, et. al. Case 7 No. 2:24-cv-01926-AB-MAR 8 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 9 information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 11 it is generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 13 Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 15 support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless of 20 the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced or 22 generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.8 House Counsel: attorneys who are employees of a party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 counsel. Suite 300 Stockton, CA 95219 2 other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 4 this Action but are retained to represent or advise a party to this Action and have 5 appeared in this Action on behalf of that party or are affiliated with a law firm which 6 has appeared on behalf of that party, and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 from a Producing Party. 20 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial will be governed by the orders of the Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 trial judge. This Order does not govern the use of Protected Material at trial. Suite 300 Stockton, CA 95219 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will 4 be presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are 6 made to the trial judge in advance of the trial. See Kamakana v. City and County of 7 Honolulu, 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial. 11 However, this does not waive the right of the designating party to seek an 12 order that any information that was designated as confidential or maintained pursuant 13 to this protective order continue to be maintained under the terms of the order at the 14 time of trial. The designating party shall have the burden to seek the order as to each 15 item of protected material, separately, which the designating party seeks to maintain 16 under the terms of the protective order. 17 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection under 21 this Order must take care to limit any such designation to specific material that 22 qualifies 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, items, 25 or communications for which protection is not warranted are not swept unjustifiably 26 within the ambit of this Order. 27 Mass, indiscriminate, or routinized designations are prohibited. Designations Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 that are shown to be clearly unjustified or that have been made for an improper Suite 300 Stockton, CA 95219 2 unnecessary expenses and burdens on other parties) may expose the Designating 3 Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 designated for protection do not qualify for protection, that Designating Party must 6 promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 5.2 Manner and Timing of Designations. Except as otherwise provided in this 8 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 9 or ordered, Disclosure or Discovery Material that qualifies for protection under this 10 Order must be clearly so designated before the material is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic documents, 13 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 14 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 15 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 16 portion or portions of the material on a page qualifies for protection, the Producing 17 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 18 markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection will be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 24 it wants copied and produced, the Producing Party must determine which documents, 25 or portions thereof, qualify for protection under this Order. Then, before producing 26 the specified documents, the Producing Party must affix the “CONFIDENTIAL 27 legend” to each page that contains Protected Material. If only a portion or portions of Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 the material on a page qualifies for protection, the Producing Party also must clearly Suite 300 Stockton, CA 95219 2 margins). 3 (b) for testimony given in depositions that the Designating Party identify the 4 Disclosure or Discovery Material on the record, before the close of the deposition all 5 protected testimony. 6 (c) for information produced in some form other than documentary and for any 7 other tangible items, that the Producing Party affix in a prominent place on the 8 exterior of the container or containers in which the information is stored the legend 9 “CONFIDENTIAL.” If only a portion or portions of the information warrants 10 protection, the Producing Party, to the extent practicable, will identify the protected 11 portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive the 14 Designating Party’s right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make reasonable 16 efforts to assure that the material is treated in accordance with the provisions of this 17 Order. 18 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party will initiate the dispute resolution 24 process under Local Rule 37.1 et seq. 25 6.3 The burden of persuasion in any such challenge proceeding will be on the 26 Designating Party. Frivolous challenges, and those made for an improper purpose 27 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 expose the Challenging Party to sanctions. Unless the Designating Party has waived Suite 300 Stockton, CA 95219 2 material in question the level of protection to which it is entitled under the Producing 3 Party’s designation until the Court rules on the challenge. 4 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 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 17 ordered by the court or permitted in writing by the Designating Party, a Receiving 18 Party may disclose any information or item designated “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 20 employees of said Outside Counsel of Record to whom it is reasonably necessary to 21 disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of the 23 Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the Court and its personnel; Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 (e) court reporters and their staff; Suite 300 Stockton, CA 95219 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 9 not be permitted to keep any confidential information unless they sign the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 agreed by the Designating Party or ordered by the court. Pages of transcribed 12 deposition testimony or exhibits to depositions that reveal Protected Material may be 13 separately bound by the court reporter and may not be disclosed to anyone except as 14 permitted under this Stipulated Protective Order; and (i) any mediator or settlement 15 officer, and their supporting personnel, mutually agreed upon by any of the parties 16 engaged in settlement discussions. 17 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 19 OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification will 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena 27 or order is subject to this Protective Order. Such notification will include a copy of Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 this Stipulated Protective Order; and Suite 300 Stockton, CA 95219 2 the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with 4 the subpoena or court order will not produce any information designated in this 5 action as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party will bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action to 10 disobey a lawful directive from another court. 11 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 13 IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a Non- 15 Party in this Action and designated as “CONFIDENTIAL.” Such information 16 produced by Non-Parties in connection with this litigation is protected by the 17 remedies and relief provided by this Order. Nothing in these provisions should be 18 construed as prohibiting a Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 20 produce a Non-Party’s confidential information in its possession, and the Party is 21 subject to an agreement with the Non-Party not to produce the Non-Party’s 22 confidential information, then the Party will: 23 (1) promptly notify in writing the Requesting Party and the Non-Party 24 that some or all of the information requested is subject to a confidentiality 25 agreement with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 Protective Order in this Action, the relevant discovery request(s), and a Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 reasonably specific description of the information requested; and Suite 300 Stockton, CA 95219 2 Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 4 days of receiving the notice and accompanying information, the Receiving Party may 5 produce the Non-Party’s confidential information responsive to the discovery 6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 7 not produce any information in its possession or control that is subject to the 8 confidentiality agreement with the Non-Party before a determination by the court. 9 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 10 of seeking protection in this court of its Protected Material. 11 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of this Order, 19 and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 may be established in an e-discovery order that provides for production without prior Suite 300 Stockton, CA 95219 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted 5 to the court. 6 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party’s request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information 20 in the public record unless otherwise instructed by the court. 21 22 13. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 60 24 days of a written request by the Designating Party, each Receiving Party must return 25 all Protected Material to the Producing Party or destroy such material. As used in this 26 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the Protected Mordaunt, Roundy, 28 R 00 ei h W l . & M J a im rc e h r s L o a n n e, 28 Material. Whether the Protected Material is returned or destroyed, the Receiving Suite 300 Stockton, CA 95219 2 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 3 (by category, where appropriate) all the Protected Material that was returned or 4 destroyed and (2) affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any 6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 7 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 8 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 9 reports, attorney work product, and consultant and expert work product, even if such 10 materials contain Protected Material. Any such archival copies that contain or 11 constitute Protected Material remain subject to this Protective Order as set forth in 12 Section 4 (DURATION). 13 14 14. Any willful violation of this Order may be punished by civil or criminal contempt 15 proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, 16 or other appropriate action at the discretion of the Court. 17 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 19 Dated: 9/18/2025 LAW OFFICES OF ERIN DARLING 20

21 By: __/s/ Erin Darling_________________________ 22 Erin Darling, Esq. Attorneys for Plaintiffs 23 TAWNY GONZALEZ, SANDRA ESCOBEDO,

AS GUARDIAN AD LITEM FOR J.L.G., A

24 MINOR, AND T.J.G., A MINOR

25 Dated: 9/19/2025 MORDAUNT, ROUNDY, REIHL & JIMERSON 26

27 By: __/s/ Christopher Clark_____________________ M R o e r i d h a l u & n t J , i R m o e u rs n o d n y , Christopher J. Clark, Esq. 2800 W. March Lane, 28 Suite 300 Stockton, CA 95219 Attorney for Defendants | COUNTY OF SANTA BARBARA, SANTA > BARBARA COUNTY SHERIFF'S OFFICE,

SERGEANT RICHARD SOTO, DEPUTY

3 JOHN HEIL; DEPUTY MICHAEL REYNOS

DEPUTY DAVID VANDERPOL, SERGEAN

4 JEFFREY KOELLER, DEPUTY JAN UR,

AND DEPUTY JOSE ALEJO

° | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: 9/23/2025 a3 — 9 Margo A’ Rocconi 10 UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Round 27

14

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 was issued by the United States District Court for the Central District of 5 California on _________ [date] in the case of Tawny Gonzalez, et. al. v. County of 6 Santa Barbara, et. al. Case No. 2:24-cv-01926-AB-MAR. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and 7 acknowledge that failure to so comply could expose me to sanctions and punishment 8 in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any 9 person or entity except in strict compliance with the provisions of this Order. 10 I further agree to submit to the jurisdiction of the United States District Court for the 11 Central District of California for the purpose of enforcing the terms of this Stipulated 12 Protective Order, even if such enforcement proceedings occur after termination of this action 13

14 Date: ______________________________________ City and State where signed: _________________________________ 15 Printed name: _______________________________ 16 Signature: __________________________________

17

18 19 20 21 22 23 24 25 26 27 Mordaunt, Roundy, Reihl & Jimerson 2800 W. March Lane, 28 Suite 300 Stockton, CA 95219