1 || Eugene P. Ramirez (State Bar No. 134865) eugene.ramirez@manningkass.com Yury A. Kolesnikov (State Bar No. 271173) 3 yury.kolesnikov@manningkass.com Kayleigh Andersen (State Bar No. 306442) 4 kayleigh.andersen@manningkass.com 5||MANNING & KASS 6 ELLROD, RAMIREZ, TRESTER LLP 801 S. Figueroa St, 15th Floor 7 || Los Angeles, California 90017-3012 8 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 9 10 Attorneys for Defendant Deputy CORRIN

CASSIDY

STIPULATED PROTECTIVE

16 Plaintiffs, | ORDER i V Complaint Filed: | December 20, 2023 18 Trial Date: Not Yet Set 19 || VICTORVILLE POLICE 20 DEPARTMENT, a public entity, e¢ al., 21 Defendants. 22 °3/1. A, PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 || proprietary, or private information for which special protection from public disclosure 26 || and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the 28 following Stipulated Protective Order. The parties acknowledge that this Order does

1 ||not confer blanket protections on all disclosures or responses to discovery and that 2 ||the protection it affords from public disclosure and use extends only to the limited 3 information or items that are entitled to confidential treatment under the applicable 4 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 5||that this Stipulated Protective Order does not entitle them to file confidential 6 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 7 || followed and the standards that will be applied when a party seeks permission from 8 || the court to file material under seal. 9 B. GOOD CAUSE STATEMENT ”n 10 This action is expected to involve the disclosure of highly sensitive and 2 11 || confidential information, including both (1) medical and personal records and (2) law = 12 || enforcement personnel records and related materials. The parties agree that special 13 || protection from public disclosure—and from use for any purpose other than the S 14 || prosecution of this case—is warranted. 15 1.1. Medical and Personal Confidential Information 16 This case may involve the production of private medical and mental health 17 || records, autopsy reports, and other sensitive documents related to the death at issue. 18||These records include, but are not limited to, HIPAA-protected health care 19 || information, as well as confidential information concerning third parties and non- 20 || parties. The parties further anticipate the disclosure of personal identifying 21 |jinformation, background investigation materials, and other documents generally 22 |) unavailable to the public or protected by law. 23 The parties agree that such materials are protected under federal and state 24 || privacy laws, including the Health Insurance Portability and Accountability Act 25 || (HIPAA), and should not be disclosed outside the litigation. The need to preserve the 26 || confidentiality of this information, particularly with respect to individuals not party 27 || to the action, supports the entry of a protective order. 28 1.2. Law Enforcement Personnel Records and Privileged Law Enforcement

1 Materials 2 Separately, Defendants contend that good cause exists for a protective order to 3 || prevent the disclosure of peace officer personnel records and associated investigative 4 || materials. These records include internal police procedures, investigative analyses, 5 ||and legal communications, the release of which could harm public safety, impair law 6 || enforcement functions, and intrude on officers’ privacy. 7 First, Defendants assert that peace officers have a reasonable expectation of 8 || privacy in their personnel records, a protection recognized under both federal law and 9 || California’s Pitchess statutes. See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027, ”n 10 || 1033-34 (9th Cir. 1990); Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665, 2 11 || at *2—3, *12—13 (E.D. Cal. 2012); Soto v. City of Concord, 162 F.R.D. 603, 613 n.4, 12 ||616 (N.D. Cal. 1995); cf. Cal. Penal Code §§ 832.7, 832.8; Cal. Evid. Code §§ 1040- 13 || 1047. They argue that unrestricted disclosure of these materials could endanger 14 || officers, non-party witnesses, and their families or associates. 15 Second, Defendants assert that these records are protected by several federal || privileges, including the deliberative process privilege, the official information privilege, the law enforcement privilege, and the attorney-client privilege (and 18 attorney work product doctrine). These privileges apply especially to materials 19 || involving internal evaluations, critical self-analysis, or legal advice, such as Internal 20 || Affairs reports, supervisory assessments, and documents prepared at the direction of 21 |)counsel. See Kelly v. City of San Jose, 114 F.R.D. 654, 668-71 (N.D. Cal. 1987); 22 || Maricopa Audubon Soc’y v. U.S. Forest Serv., 108 F.3d 1089, 1092-95 (9th Cir. 23 || 1997); Tuite v. Henry, 181 F.R.D. 175, 176-77 (D.D.C. 1998); Admiral Ins. Co. v. 24 || U.S. Dist. Ct., 881 F.2d 1486, 1492, 1495 (9th Cir. 1988). Defendants contend that 25 || disclosure would undermine law enforcement’s ability to obtain candid input from 26 || witnesses, conduct effective investigations, and implement necessary reforms. 27 Third, Defendants note that peace officers may be compelled to provide 28 || statements in connection with internal investigations, unlike private citizens. They

1 |/argue that the involuntary nature of such disclosures makes public release 2 || fundamentally unfair. See Lybarger v. City of Los Angeles, 40 Cal. 3d 822, 828-30 3 || (1985); cf. U.S. Const. amend. V. 4 2. DEFINITIONS 5 2.1. Action: this pending federal law suit. 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 9 || how it is generated, stored or maintained) or tangible things that qualify for protection ”n 10 ||under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 2 11 || Cause 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 18 || of the medium or manner in which it is generated, stored, or maintained (including, 19 among other things, testimony, transcripts, and tangible things), that are produced or 20 || generated 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 23 ||an 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.

l 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 which 4 || has 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. ”n 10 2.13 Professional Vendors: persons or entities that provide litigation support 2 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or = 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 || and their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is 15 || designated as “CONFIDENTIAL.” 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 17 || from a Producing Party. "13. SCOPE 19 Once a case proceeds to trial, all of the information that was designated as 20 confidential or maintained pursuant to this protective order used or introduced as I an exhibit at trial becomes public and will be presumptively available to all member 22 of the public, including the press, unless compelling reasons supported by specific 23 factual findings to proceed otherwise are made to the trial judge in advance of the 24 trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 □□□ 25 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in 26 discovery from “compelling reasons” standard when merits-related documents are 27 part of court record). Accordingly, the terms of this protective order do not extend 28

1 || beyond the commencement of the trial except as outlined in this Section. 2 || 4. DURATION 3 Even after final disposition of this litigation, the confidentiality obligations 4|/imposed by this Order shall remain in effect until a Designating Party agrees 5 || otherwise in writing or a court order otherwise directs. Final disposition shall be 6 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 7\|or without prejudice; and (2) final judgment herein after the completion and 8 ||exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 9 || including the time limits for filing any motions or applications for extension of time ”n 10 || pursuant to applicable law. 2 1/5. DESIGNATING PROTECTED MATERIAL = 12 5.1 Exercise of Restraint and Care in Designating Material for 13 Protection. 14 Each Party or Non-Party that designates information or items for protection 15 || under this Order must take care to limit any such designation to specific material that 16 || qualifies under the appropriate standards. The Designating Party must designate for 17 || protection only those parts of material, documents, items, or oral or written 18 || communications that qualify so that other portions of the material, documents, items, 19 || or communications for which protection is not warranted are not swept unjustifiably 20 || within the ambit of this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 ||that are shown to be clearly unjustified or that have been made for an improper 23 || purpose (e.g., to unnecessarily encumber the case development process or to impose 24 || unnecessary expenses and burdens on other parties) may expose the Designating Party 25 || to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 || designated for protection do not qualify for protection, that Designating Party must 28 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

l 5.2. Manner and Timing of Designations. 2 Except as otherwise provided in this Order (see, e.g., second paragraph of 3 || section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 4 || Material that qualifies for protection under this Order must be clearly so designated 5 || before the material is disclosed or produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic documents, 8 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the 9 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter ”n 10 || “CONFIDENTIAL legend”), to each page that contains protected material. If only a 2 11 || portion or portions of the material on a page qualifies for protection, the Producing = 12 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate 13 || markings in the margins). S 14 A Party or Non-Party that makes original documents available for inspection 15 ||need not designate them for protection until after the inspecting Party has indicated 16 || which documents it would like copied and produced. During the inspection and before 17||the designation, all of the material made available for inspection shall be deemed 18 || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants || copied and produced, the Producing Party must determine which documents, or 20 || portions thereof, qualify for protection under this Order. Then, before producing the 21 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 22 ||to each page that contains Protected Material. If only a portion or portions of the 23 ||material on a page qualifies for protection, the Producing Party also must clearly 24 |jidentify the protected portion(s) (e.g., by making appropriate markings in the 25 || margins). 26 (b) for testimony given in depositions that the Designating Party identify the 27 || Disclosure or Discovery Material on the record, before the close of the deposition all 28 || protected testimony.

l (c) for information produced in some form other than documentary and for any 2 || other tangible items, that the Producing Party affix in a prominent place on the exterior 3 ||of the container or containers in which the information is stored the legend 4||“CONFIDENTIAL.” If only a portion or portions of the information warrants 5 || protection, the Producing Party, to the extent practicable, shall identify the protected 6 || portion(s). 7 5.3. Inadvertent Failures to Designate. 8 If timely corrected, an inadvertent failure to designate qualified information or 9 |/items does not, standing alone, waive the Designating Party’s right to secure ”n 10 || protection under this Order for such material. Upon timely correction of a designation, 2 11 || the Receiving Party must make reasonable efforts to assure that the material is treated 12 || in accordance with the provisions of this Order. 13 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 15 || designation of confidentiality at any time that is consistent with the Court’s 16 || Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 || resolution process under Local Rule 37.1 et seq. 19 6.3. The burden of persuasion in any such challenge proceeding shall be on 20 || the Designating Party. Frivolous challenges, and those made for an improper purpose 21 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 ||or withdrawn the confidentiality designation, all parties shall continue to afford the 24 || material in question the level of protection to which it is entitled under the Producing 25 || Party’s designation until the Court rules on the challenge. 26 ||7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1. Basic Principles. A Receiving Party may use Protected Material that is 28 || disclosed or produced by another Party or by a Non-Party in connection with this

1 || Action only for prosecuting, defending, or attempting to settle this Action. Such 2 || Protected Material may be disclosed only to the categories of persons and under the 3 || conditions described in this Order. When the Action has been terminated, a Receiving 4 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 5 || Protected Material must be stored and maintained by a Receiving Party at a location 6 || and in a secure manner that ensures that access is limited to the persons authorized 7 || under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 || otherwise ordered by the court or permitted in writing by the Designating Party, a ”n 10||Receiving Party may disclose any information or item designated 2 11 || “CONFIDENTIAL” only to: = 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 13 ||}employees of said Outside Counsel of Record to whom it is reasonably necessary to 14 || disclose the information for this Action; 15 (b) the officers, directors, and employees (including House Counsel) of the 16 || Receiving Party to whom disclosure is reasonably necessary for this Action; 17 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 18 || is reasonably necessary for this Action and who have signed the “Acknowledgment 19 ||and Agreement to Be Bound” (Exhibit A); 20 (d) the court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 23 ||to whom disclosure is reasonably necessary for this Action and who have signed the 24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) the author or recipient of a document containing the information or a 26 || custodian or other person who otherwise possessed or knew the information; 27 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 28 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party

1 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 2||not be permitted to keep any confidential information unless they sign the 3 ||“‘Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 4||agreed by the Designating Party or ordered by the court. Pages of transcribed 5 || deposition testimony or exhibits to depositions that reveal Protected Material may be 6 || separately bound by the court reporter and may not be disclosed to anyone except as 7 || permitted under this Stipulated Protective Order; and 8 (1) any mediator or settlement officer, and their supporting personnel, mutually 9 || agreed upon by any of the parties engaged in settlement discussions. ”n 10 ||8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 11 |} OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 ||that compels disclosure of any information or items designated in this Action as S 14 || “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification shall 16 || include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to 18 || issue in the other litigation that some or all of the material covered by the subpoena 19 || or order is subject to this Protective Order. Such notification shall include a copy of 20 || this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be pursued by 22 || the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with 24 || the subpoena or court order shall not produce any information designated in this action 25 |}as “CONFIDENTIAL” before a determination by the court from which the subpoena 26 || or order issued, unless the Party has obtained the Designating Party’s permission. The 27 || Designating Party shall bear the burden and expense of seeking protection in that court 28 || of its confidential material and nothing in these provisions should be construed as

1 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 || directive from another court.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

4 || PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a Non- 6||Party in this Action and designated as “CONFIDENTIAL.” Such information 7||produced by Non-Parties in connection with this litigation is protected by the 8 ||remedies and relief provided by this Order. Nothing in these provisions should be 9 || construed as prohibiting a Non-Party from seeking additional protections. ”n 10 (b) In the event that a Party is required, by a valid discovery request, to 2 11 || produce a Non-Party’s confidential information in its possession, and the Party is = 12||subject to an agreement with the Non-Party not to produce the Non-Party’s 13 || confidential information, then the Party shall: S 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 || that some or all of the information requested is subject to a confidentiality agreement 16 || with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 || specific description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 || Party, if requested. 22 (c) Ifthe Non-Party fails to seek a protective order from this court within 14 23 || days of receiving the notice and accompanying information, the Receiving Party may 24 || produce the Non-Party’s confidential information responsive to the discovery request. 25 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 26 ||any information in its possession or control that is subject to the confidentiality 27 ||agreement with the Non-Party before a determination by the court. Absent a court 28 || order to the contrary, the Non-Party shall bear the burden and expense of seeking

1 || protection in this court of its Protected Material. 2 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 4 || Protected Material to any person or in any circumstance not authorized under this 5 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 6 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 7 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 8 || persons to whom unauthorized disclosures were made of all the terms of this Order, 9|/and (d) request such person or persons to execute the “Acknowledgment and ”n 10 || Agreement to Be Bound” that is attached hereto as Exhibit A. 2 11]}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 12 PROTECTED MATERIAL 13 When a Producing Party gives notice to Receiving Parties that certain 14 || inadvertently produced material is subject to a claim of privilege or other protection, 15 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 16 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 17 || may be established in an e-discovery order that provides for production without prior 18 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 19 || parties reach an agreement on the effect of disclosure of a communication or 20 || information covered by the attorney-client privilege or work product protection, the 21 || parties may incorporate their agreement in the stipulated protective order submitted 22 || to the court. 23 |} 12. MISCELLANEOUS 24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 25 || person to seek its modification by the Court in the future. 26 12.2 Right to Assert Other Objections. By stipulating to the entry of this 27 || Protective Order no Party waives any right it otherwise would have to object to 28 || disclosing or producing any information or item on any ground not addressed in this

1 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 || ground to use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 5 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 6 || Protected Material at issue. If a Party's request to file Protected Material under seal is 7 || denied by the court, then the Receiving Party may file the information in the public 8 || record unless otherwise instructed by the court. 9 ||13. FINAL DISPOSITION ”n 10 After the final disposition of this Action, as defined in paragraph 4, within 60 2 11 || days of a written request by the Designating Party, each Receiving Party must return = 12 || all Protected Material to the Producing Party or destroy such material. As used in this 13 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, S 14||summaries, and any other format reproducing or capturing any of the Protected 15 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party 16 || must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 18 || category, where appropriate) all the Protected Material that was returned or destroyed 19 ||and (2)affirms that the Receiving Party has not retained any copies, abstracts, 20 || compilations, summaries or any other format reproducing or capturing any of the 21 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 22 ||archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 24 || reports, attorney work product, and consultant and expert work product, even if such 25 ||materials contain Protected Material. Any such archival copies that contain or 26 || constitute Protected Material remain subject to this Protective Order as set forth in 27 || Section 4 (DURATION). 28/14. VIOLATIONS

l Any violation of this Order may be punished by any and all appropriate 2||measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 4 5 IT IS SO STIPULATED THROUGH COUNSEL OF RECORD. 6 DATED: September 22, 2025 Respectfully submitted, 8 MANNING & KASS 9 ELLROD, RAMIREZ, TRESTER LLP 10 By: /s/ Kayleigh Andersen 2 11 Eugene P. Ramirez x 2 Kayleigh Andersen oO Attorneys for Defendant, Deputy CORRIN z 13 CASSIDY 4

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 DATED: October 3, 2025 4

PRR

4 United States Magistrate Judge 8 9 ”n 10 < 11 — 12 2;

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 || Stipulated Protective Order that was issued by the United States District Court for the 7||Central District of California on [date] in the case of 8 || ESTATE OF GLENN MCCRARY, et al, v. COUNTY OF SAN BERNARDINO, 9 || et al, Case No. 5:23-cv-02602 SSS (SPx). I agree to comply with and to be bound by ”n 10 || all the terms of this Stipulated Protective Order and I understand and acknowledge 2 11 || that failure to so comply could expose me to sanctions and punishment in the nature = 12 || of contempt. I solemnly promise that I will not disclose in any manner any information 13 || or item that is subject to this Stipulated Protective Order to any person or entity except S 14 || in strict compliance with the provisions of this Order. I further agree to submit to the 15 || jurisdiction of the United States District Court for the Central District of California 16 || for the purpose of enforcing the terms of this Stipulated Protective Order, even if such 17 enforcement proceedings occur after termination of this action. I hereby appoint 18 [print or type full name] of 19 [print or type full address and telephone 20 || number] as my California agent for service of process in connection with this action 21 || or any proceedings related to enforcement of this Stipulated Protective Order. 22 || Date: 23 || City and State where sworn and signed: 24 25 || Printed name: 26 27 || Signature: 28