Case 8:22-cv-00296-JVS-JDE Document 55 Filed 07/01/22 Page 1 of 15 Page ID #:889

1 2 3

UNITED STATES DISTRICT COURT

4

CENTRAL DISTRICT OF CALIFORNIA

5

SOUTHERN DIVISION

6 PALM COMMUNITIES, f/k/a PALM Case No. 8:22-CV-00296-JVS-JDE 7 DESERT DEVELOPMENT COMPANY, a California corporation; and 8 HOUSING CORPORATION OF STIPULATED PROTECTIVE AMERICA, a Utah non-profit corporation, ORDER 9 Plaintiffs, 10 v. 11

CENTERLINE HOUSING

12 PARTNERSHIP I, L.P. – SERIES 2, f/k/a

RELATED CAPITAL HOUSING

13 PARTNERSHIP I, L.P. – SERIES 2, a Delaware limited partnership; RCHP SLP I 14 L.P. – SERIES 2, a Delaware limited partnership; ALDEN TORCH FINANCIAL 15 LLC, Delaware limited liability company; and MACATAWA HOLDINGS LLC, a 16 Delaware limited liability company,

17 Defendants,

18 and

19 CENTERLINE HOUSING PARTNERSHIP I, L.P. – SERIES 2, f/k/a 20 RELATED CAPITAL HOUSING PARTNERSHIP I, L.P. – SERIES 2, a 21 Delaware limited partnership; and RCHP SLP I L.P. – SERIES 2, a Delaware limited 22 partnership,

23 Counterclaimants,

24 v.

25 PALM COMMUNITIES, f/k/a PALM DESERT DEVELOPMENT COMPANY, a 26 California corporation,

27 Counter-Defendant.

28

STIPULATED PROTECTIVE ORDER

Case 8:22-cv-00296-JVS-JDE Document 55 Filed 07/01/22 Page 2 of 15 Page ID #:890

1 Pursuant to the Parties Stipulation, the Court finds and orders as follows. 2 1. PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public disclosure 5 and from use for any purpose other than pursuing this litigation may be warranted. 6 Accordingly, the Parties hereby stipulate and petition the Court to enter the following 7 Stipulated Protective Order. The Parties acknowledge that this Order does not confer 8 blanket 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 items 10 that are entitled to confidential treatment under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve confidential valuation, commercial, financial, and 13 business information for which special protection from public disclosure and from use 14 for any purpose other than prosecution of this action is warranted. Accordingly, to 15 expedite the flow of information, to facilitate the prompt resolution of disputes over 16 confidentiality of discovery materials, to adequately protect information the Parties are 17 entitled to keep confidential, to ensure that the Parties are permitted reasonable 18 necessary uses of such material in preparation for and in the conduct of trial, to address 19 their handling at the end of the litigation, and to serve the ends of justice, a protective 20 order for such information is justified in this matter. It is the intent of the Parties that 21 information will not be designated as confidential for tactical reasons and that nothing 22 will be so designated without a good faith belief that it has been maintained in a 23 confidential, non-public manner, and there is good cause why it should not be part of 24 the public record of this case. 25 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 26 The Parties further acknowledge, as set forth in Section 14.3 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 -

STIPULATED PROTECTIVE ORDER

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1 standards that will be applied when a party seeks permission from the court to file 2 material under seal. There is a strong presumption that the public has a right of access 3 to judicial proceedings and records in civil cases. In connection with non-dispositive 4 motions, good cause must be shown to support a filing under seal. See Kamakana v. 5 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 6 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 7 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 8 require good cause showing), and a specific showing of good cause or compelling 9 reasons with proper evidentiary support and legal justification, must be made with 10 respect to Protected Material that a party seeks to file under seal. The Parties’ mere 11 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 12 without the submission of competent evidence by declaration, establishing that the 13 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 14 protectable—constitute good cause. 15 Further, if a Party requests sealing related to a dispositive motion or trial, then 16 compelling reasons, not only good cause, for the sealing must be shown, and the relief 17 sought shall be narrowly tailored to serve the specific interest to be protected. See 18 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 19 or type of information, document, or thing sought to be filed or introduced under seal, 20 the party seeking protection must articulate compelling reasons, supported by specific 21 facts 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 its 25 entirety will not be filed under seal if the confidential portions can be redacted. If 26 documents can be redacted, then a redacted version for public viewing, omitting only 27 the confidential, privileged, or otherwise protectable portions of the document, shall be 28 - 2 -

STIPULATED PROTECTIVE ORDER

Case 8:22-cv-00296-JVS-JDE Document 55 Filed 07/01/22 Page 4 of 15 Page ID #:892

1 filed. Any application that seeks to file documents under seal in their entirety should 2 include an explanation of why redaction is not feasible. 3 4. DEFINITIONS 4 4.1 Action: this pending federal lawsuit. 5 4.2 Challenging Party: a Party or Non-Party that challenges the designation of 6 information or items under this Order. 7 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how 8 it is generated, stored or maintained) or tangible things that qualify for protection under 9 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 10 Statement. 11 4.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as 12 their support staff). 13 4.5 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 4.6 Disclosure or Discovery Material: all items or information, regardless of 17 the medium or manner in which it is generated, stored, or maintained (including, among 18 other things, testimony, transcripts, and tangible things), that are produced or generated 19 in disclosures or responses to discovery. 20 4.7 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 an 22 expert witness or as a consultant in this Action. 23 4.8 In-House Counsel: attorneys who are employees of a Party to this Action. 24 In-House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 4.9 Non-Party: any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 28 - 3 -

STIPULATED PROTECTIVE ORDER

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1 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 2 this Action but are retained to represent a party to this Action and have appeared in this 3 Action on behalf of that Party or are affiliated with a law firm that has appeared on 4 behalf of that Party (as well as their support staff). 5 4.11 Party: any party to this Action, including all of its officers, directors, 6 employees, representatives, consultants, retained experts, and Outside Counsel of 7 Record (and their support staffs). 8 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 9 Discovery Material in this Action. 10 4.13 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 4.14 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL.” 16 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 5. 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 and other applicable authorities. This Order does not govern the use of Protected 26 Material at trial. 27 / / / 28 / / / - 4 -

STIPULATED PROTECTIVE ORDER

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1 6. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order used or 4 introduced as an exhibit at trial becomes public and will be presumptively available to 5 all members of the public, including the press, unless compelling reasons supported by 6 specific factual findings to proceed otherwise are made to the trial judge in advance of 7 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing 8 for sealing documents produced in discovery from “compelling reasons” standard when 9 merits-related documents are part of court record). 10 7. DESIGNATING PROTECTED MATERIAL 11 7.1 Exercise of Restraint and Care in Designating Material for Protection. 12 Each Party or Non-Party that designates information or items for protection 13 under this Order must take care to limit any such designation to specific material that 14 qualifies under the appropriate standards. The Designating Party must designate for 15 protection only those parts of material, documents, items or oral or written 16 communications that qualify so that other portions of the material, documents, items or 17 communications for which protection is not warranted are not swept unjustifiably 18 within the ambit of this Order. 19 Mass, indiscriminate or routinized designations are prohibited. Designations that 20 are shown to be clearly unjustified or that have been made for an improper purpose 21 (e.g., to unnecessarily encumber the case development process or to impose 22 unnecessary expenses and burdens on other Parties) may expose the Designating Party 23 to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party must 26 promptly notify all other Parties that it is withdrawing the inapplicable designation. 27 7.2 Manner and Timing of Designations. Except as otherwise provided in this 28 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that - 5 -

STIPULATED PROTECTIVE ORDER

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1 qualifies for protection under this Order must be clearly so designated before the 2 material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic 5 documents, but excluding transcripts of depositions or other pretrial or trial 6 proceedings), that the Producing Party affix at a minimum, the legend 7 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 8 contains protected material. If only a portion of the material on a page qualifies for 9 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 10 by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents available for inspection 12 need not designate them for protection until after the inspecting Party has indicated 13 which documents it would like copied and produced. During the inspection and before 14 the designation, all of the material made available for inspection shall be deemed 15 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 16 copied and produced, the Producing Party must determine which documents, or 17 portions thereof, qualify for protection under this Order. Then, before producing the 18 specified documents, the Producing Party must affix the CONFIDENTIAL legend to 19 each page that contains Protected Material. If only a portion of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). 22 (b) for testimony given in depositions, that the Designating Party either (i) 23 identifies on the record, before the close of the deposition, as “CONFIDENTIAL” by 24 specifying all portions of the testimony that qualify as “CONFIDENTIAL”; or (ii) 25 designate the entirety of the testimony at the deposition as “CONFIDENTIAL” (before 26 the deposition is concluded) with the right to identify more specific portions of the 27 testimony as to which protection is sought within 30 days following receipt of the 28 deposition transcript. In circumstances where portions of the deposition testimony are - 6 -

STIPULATED PROTECTIVE ORDER

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1 designated for protection, the transcript pages containing “CONFIDENTIAL” 2 information shall be separately bound by the court reporter, who must affix to the top of 3 each page the legend “CONFIDENTIAL,” as instructed by the Designating Party. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent place on the 6 exterior of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information warrants 8 protection, the Producing Party, to the extent practicable, shall identify the protected 9 portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 Designating Party’s right to secure protection under this Order for such material. Upon 13 timely correction of a designation, the Receiving Party must make reasonable efforts to 14 assure that the material is treated in accordance with the provisions of this Order. 15 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 17 designation of confidentiality at any time that is consistent with the Court’s Scheduling 18 Order. 19 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 20 resolution process under Local Rule 37-1 et seq. 21 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 22 stipulation pursuant to Local Rule 37-2. 23 8.4 The burden of persuasion in any such challenge proceeding shall be on the 24 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 25 to harass or impose unnecessary expenses and burdens on other Parties) may expose the 26 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 27 the confidentiality designation, all Parties shall continue to afford the material in 28 - 7 -

STIPULATED PROTECTIVE ORDER

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1 question the level of protection to which it is entitled under the Producing Party’s 2 designation until the Court rules on the challenge. 3 9. ACCESS TO AND USE OF PROTECTED MATERIAL 4 9.1 Basic Principles. A Receiving Party may use Protected Material that is 5 disclosed or produced by another Party or by a Non-Party in connection with this 6 Action only for prosecuting, defending, or attempting to settle this Action. Such 7 Protected Material may be disclosed only to the categories of persons and under the 8 conditions described in this Order. When the Action has been terminated, a Receiving 9 Party must comply with the provisions of Section 15 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 14 ordered by the Court or permitted in writing by the Designating Party, a Receiving 15 Party may disclose any information or item designated “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 18 disclose the information for this Action; 19 (b) the officers, directors, and employees (including In-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); - 8 -

STIPULATED PROTECTIVE ORDER

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1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions in the Action, witnesses and attorneys for 4 witnesses to whom disclosure is reasonably necessary provided: (1) the witness signs 5 the form attached as Exhibit A hereto; and (2) the witness and attorneys for the witness 6 will not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 8 by the Designating Party or ordered by the Court; and 9 (i) any mediators or settlement officers and their supporting personnel, 10 mutually agreed upon by any of the Parties engaged in settlement discussions. 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 11

PRODUCED IN OTHER LITIGATION

12 If a Party is served with a subpoena or a court order issued in other litigation that 13 compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification 16 shall include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order 18 to issue in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to this Stipulated Protective Order. Such notification shall include a 20 copy of this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be 22 pursued by the Designating Party whose Protected Material may be affected. If the 23 Designating Party timely seeks a protective order, the Party served with the subpoena or 24 court order shall not produce any information designated in this action as 25 “CONFIDENTIAL” before a determination by the court from which the subpoena or 26 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 - 9 -

STIPULATED PROTECTIVE ORDER

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1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 11. A NON PARTY’S PROTECTED MATERIAL SOUGHT TO BE 3

PRODUCED IN THIS LITIGATION

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

STIPULATED PROTECTIVE ORDER

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1 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) 8 request such person or persons to execute the “Acknowledgment an Agreement to Be 9 Bound” attached hereto as Exhibit A. 10 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, the 14 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Inadvertent production by any Party of material containing privileged 18 attorney-client or other privileged communications, attorney work product, or other 19 information not subject to discovery, shall not constitute a waiver of any privilege, 20 immunity or other right not to produce such material. 21 14. MISCELLANEOUS 22 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 23 person to seek its modification by the Court in the future. 24 14.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order, no Party waives any right it otherwise would have to object to 26 disclosing or producing any information or item on any ground not addressed in this 27 Stipulated Protective Order. Similarly, no Party waives any right to object on any 28 ground to use in evidence of any of the material covered by this Order. - 11 -

STIPULATED PROTECTIVE ORDER

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1 14.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 3 only be filed under seal pursuant to a court order authorizing the sealing of the specific 4 Protected Material. If a Party’s request to file Protected Material under seal is denied 5 by the Court, then the Receiving Party may file the information in the public record 6 unless otherwise instructed by the Court. 7 15. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraphs 4.1 and 9.1, 9 within 60 days of a written request by the Designating Party, each Receiving Party must 10 return all Protected Material to the Producing Party or destroy such material. As used 11 in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 14 must submit a written certification to the Producing Party (and, if not the same person 15 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 16 category, where appropriate) all the Protected Material that was returned or destroyed 17 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 18 compilations, summaries or any other format reproducing or capturing any of the 19 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 20 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 21 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 22 work product, and consultant and expert work product, even if such materials contain 23 Protected Material. Any such archival copies that contain or constitute Protected 24 Material remain subject to this Stipulated Protective Order. 25 / / / 26 / / / 27 / / / 28 / / / - 12 -

STIPULATED PROTECTIVE ORDER

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1 16. VIOLATION 2 Any violation of this Order may be punished by appropriate measures including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 5 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 7 || DATED: July 01, 2022 8 if Le 9 Lihue ; AG 10 J D. EARLY 4 hited States Magistrate Judge

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

_13-

STIPULATED PROTECTIVE ORDER

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1 EXHIBIT “A” 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND BY 3 STIPULATED PROTECTIVE ORDER 4 5 This is to certify that I, the undersigned, have read and am fully familiar with the 6 provisions of the Stipulated Protective Order filed and entered in the case Palm 7 Communities, et al. v. Centerline Housing Partnership I, L.P. – Series 2, et al., Case 8 No. 8:22-CV-00296-JVS-JDE (C.D. Cal.) (hereinafter referred to as “Stipulated 9 Protective Order”). 10 As a condition precedent to the disclosure to me of any Confidential Information 11 pursuant to the Stipulated Protective Order, or my obtaining any information contained 12 in said material, I hereby agree that the Stipulated Protective Order is binding upon me, 13 and I further agree to keep all such material and information in strictest confidence and 14 otherwise to observe, comply with, and be bound by the provisions of the Stipulated 15 Protective Order. 16 I declare under penalty of perjury under the laws of the United States of America 17 that the foregoing is true and correct. 18 Signature: 19 Name: Address: 20

21 Telephone: 22

23 24 25 26 27 28 - 14 -

STIPULATED PROTECTIVE ORDER