1 RODNEY S. DIGGS, Esq. (SBN 274459) RDiggs@imwlaw.com 2 KAELIN S. DAVIS, Esq. (SBN 3 KDavis@imwlaw.com IVIE McNEILL WYATT PURCELL & DIGGS 4 A Professional Law Corporation 5 444 South Flower Street, Suite 1800 Los Angeles, California 90071 6 Telephone: (213) 489-0028 7 Facsimile: (213) 489-0552 Attorneys for Plaintiff, CAREY COCO 8 9 DAWN MCINTOSH, City Attorney NICHOLAS J. MASERO, Deputy City Attorney 10 State Bar No. 302989 11 411 W. Ocean Boulevard, 9th Floor Long Beach, California 90802-4664 12 Telephone: (562) 570-2200 13 Facsimile: (562) 436-1579 Attorneys for Defendant 14

CITY OF LONG BEACH

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

17 18 CAREY COCO, an individual, CASE NO.: 2:22-cv-08591-RGK- Plaintiff, (JEMx) 19 vs. 20 CITY OF LONG BEACH; and STIPULATED PROTECTIVE 21 DOES 1 through 10, inclusive. ORDER 22 Defendants. 23 24 25 26 27

A. PURPOSES AND LIMITATIONS

1 Discovery in this action is likely to involve production of confidential, 2 proprietary, or private information for which special protection from public 3 disclosure and from use for any purpose other than prosecuting this litigation may 4 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 5 enter the following Stipulated Protective Order. The parties acknowledge that this 6 Order does not confer blanket protections on all disclosures or responses to 7 discovery and that the protection it affords from public disclosure and use extends 8 only to the limited information or items that are entitled to confidential treatment 9 under the applicable legal principles. 10

B. GOOD CAUSE STATEMENT

11 This case involves the wrongful detention and arrest of Plaintiff Carey 12 Coco. Discovery in this action is likely to involve the production of sensitive, 13 confidential documents pertaining to and contained in the private employment 14 personnel file of City of Long Beach Department officers and of the City of Los 15 Angeles Department officers, which include Plaintiff Carey Coco, (collectively 16 “the parties”) production and disclosure of these confidential personnel file 17 documents without this protective order will subject the parties to unwarranted 18 and unnecessary embarrassment, harassment, and/or violation of the parties’ rights 19 20 of privacy. 21 Accordingly, to expedite the flow of information, to facilitate the prompt 22 resolution of disputes over confidentiality of discovery materials, to adequately 23 protect information the parties are entitled to keep confidential, to ensure that the 24 parties are permitted reasonable necessary uses of such material in preparation for 25 and in the conduct of trial, to address their handling at the end of the litigation, 26 and serve the ends of justice, a protective order for such information is justified in 27 this matter. It is the intent of the parties that information will not be designated good faith belief that it has been maintained in a confidential, non-public manner, 1 and there is good cause why it should not be part of the public record of this case. 2

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

3 The parties further acknowledge, as set forth in Section 12.3, below, that 4 this Stipulated Protective Order does not entitle them to file confidential 5 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 6 be followed and the standards that will be applied when a party seeks permission 7 from the court to file material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive 10 motions, good cause must be shown to support a filing under seal. See Kamakana 11 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 12 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 13 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of good 15 cause or compelling reasons with proper evidentiary support and legal 16 justification, must be made with respect to Protected Material that a party seeks to 17 file under seal. The parties’ mere designation of Disclosure or Discovery Material 18 as CONFIDENTIAL does not—without the submission of competent evidence by 19 20 declaration, establishing that the material sought to be filed under seal qualifies as 21 confidential, privileged, or otherwise protectable—constitute good cause. 22 Further, if a party request sealing related to a dispositive motion or trial, 23 then compelling reasons, not only good cause, for the sealing must be shown, and 24 the relief sought shall be narrowly tailored to serve the specific interest to be 25 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 26 2010). For each item or type of information, document, or thing sought to be filed 27 or introduced under seal in connection with a dispositive motion or trial, the party and legal justification, for the requested sealing order. Again, competent evidence 1 supporting the application to file documents under seal must be provided by 2 declaration. 3 Any document that is not confidential, privileged, or otherwise protectable 4 in its entirety will not be filed under seal if the confidential portions can be 5 redacted. If documents can be redacted, then a redacted version for public 6 viewing, omitting only the confidential, privileged, or otherwise protectable 7 portions of the document, shall be filed. Any application that seeks to file 8 documents under seal in their entirety should include an explanation of why 9 redaction is not feasible. 10 2. DEFINITIONS 11 2.1 Action: This pending federal lawsuit. 12 2.2 Challenging Party: A Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 20 their support staff). 21 2.5 Designating Party: A Party or Non-Party that designates information 22 or items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: All items or information, 25 regardless of the medium or manner in which it is generated, stored, or maintained 26 (including, among other things, testimony, transcripts, and tangible things), that 27 are produced or generated in disclosures or responses to discovery in this matter. 2.7 Expert: A person with specialized knowledge or experience in a 1 matter pertinent to the litigation who has been retained by a Party or its counsel to 2 serve as an expert witness or as a consultant in this Action. 3 2.8 House Counsel: Attorneys who are employees of a party to this 4 Action. House Counsel does not include Outside Counsel of Record or any other 5 outside counsel. 6 2.9 Non-Party: Any natural person, partnership, corporation, association, 7 or other legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: Attorneys who are not employees of a 9 party to this Action but are retained to represent or advise a party to this Action 10 and have appeared in this Action on behalf of that party or are affiliated with a law 11 firm which has appeared on behalf of that party, and includes support staff. 12 2.11 Party: Any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and 14 their support staffs). 15 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 16 Discovery Material in this Action. 17 2.13 Professional Vendors: Persons or entities that provide litigation 18 support services (e.g., photocopying, videotaping, translating, preparing exhibits 19 20 or demonstrations, and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 22 2.14 Protected Material: Any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only extracted from Protected Material; (2) all copies, excerpts, summaries, or 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 trial judge. This Order does not govern the use of Protected Material at trial. 5 4. DURATION 6 FINAL DISPOSITION of the action is defined as the conclusion of any 7 appellate proceedings, or, if no appeal is taken, when the time for filing of an 8 appeal has run. Except as set forth below, the terms of this protective order apply 9 through FINAL DISPOSITION of the action. The parties may stipulate that they 10 will be contractually bound by the terms of this agreement beyond FINAL 11 DISPOSITION, but will have to file a separate action for enforcement of the 12 agreement once all proceedings in this case are complete. 13

ONCE A CASE PROCEEDS TO TRIAL, INFORMATION THAT WAS

DESIGNATED AS CONFIDENTIAL OR MAINTAINED PURSUANT TO

THIS PROTECTIVE ORDER USED OR INTRODUCED AS AN EXHIBIT AT

TRIAL BECOMES PUBLIC AND WILL BE PRESUMPTIVELY AVAILABLE

TO ALL MEMBERS OF THE PUBLIC, INCLUDING THE PRESS, UNLESS

COMPELLING REASONS SUPPORTED BY SPECIFIC FACTUAL

19 20 FINDINGS TO PROCEED OTHERWISE ARE MADE TO THE TRIAL JUDGE 21 IN ADVANCE OF THE TRIAL. SEE KAMAKANA, 447 F.3D AT 1180-81 22 (DISTINGUISHING “GOOD CAUSE” SHOWING FOR SEALING 23 DOCUMENTS PRODUCED IN DISCOVERY FROM “COMPELLING 24 REASONS” STANDARD WHEN MERITS-RELATED DOCUMENTS ARE 25 PART OF COURT RECORD). ACCORDINGLY, FOR SUCH MATERIALS, 26 THE TERMS OF THIS PROTECTIVE ORDER DO NOT EXTEND BEYOND 27 THE COMMENCEMENT OF THE TRIAL. 5.1 Exercise of Restraint and Care in Designating Material for 1 Protection. Each Party or Non-Party that designates information or items for 2 protection under this Order must take care to limit any such designation to specific 3 material that qualifies under the appropriate standards. The Designating Party 4 must designate for protection only those parts of material, documents, items, or 5 oral or written communications that qualify so that other portions of the material, 6 documents, items, or communications for which protection is not warranted are 7 not swept unjustifiably within the ambit of this Order. 8 Mass, indiscriminate, or routinized designations are prohibited. 9 Designations that are shown to be clearly unjustified or that have been made for 10 an improper purpose (e.g., to unnecessarily encumber the case development 11 process or to impose unnecessary expenses and burdens on other parties) may 12 expose the Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that 14 it designated for protection do not qualify for protection, that Designating Party 15 must promptly notify all other Parties that it is withdrawing the inapplicable 16 designation. 17 5.2 Manner and Timing of Designations. Except as otherwise provided in 18 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 19 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for 21 protection under this Order must be clearly so designated before the material is 22 disclosed or produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that qualifies for protection, the Producing Party also must clearly identify the 1 protected portion(s) (e.g., by making appropriate markings in the margins). 2 A Party or Non-Party that makes original documents available for 3 inspection need not designate them for protection until after the inspecting Party 4 has indicated which documents it would like copied and produced. During the 5 inspection and before the designation, all of the material made available for 6 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 7 identified the documents that it wants copied and produced, the Producing Party 8 must determine which documents, or portions thereof, qualify for protection under 9 this Order. Then, before producing the specified documents, the Producing Party 10 must affix the “CONFIDENTIAL legend” to each page that contains Protected 11 Material. If only a portion or portions of the material on a page qualifies for 12 protection, the Producing Party also must clearly identify the protected portion(s) 13 (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party identify 15 the Disclosure or Discovery Material on the record, before the close of the 16 deposition all protected testimony. 17 (c) for information produced in some form other than documentary and 18 for any other tangible items, that the Producing Party affix in a prominent place on 19 20the exterior of the container or containers in which the information is stored the 21legend “CONFIDENTIAL.” If only a portion or portions of the information 22warrants protection, the Producing Party, to the extent practicable, shall identify 23the protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 25 failure to designate qualified information or items does not, standing alone, waive 26 the Designating Party’s right to secure protection under this Order for such 27 material. Upon timely correction of a designation, the Receiving Party must make reasonable efforts to assure that the material is treated in accordance with the 1 provisions of this Order. 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 4 designation of confidentiality at any time that is consistent with the Court’s 5 Scheduling Order. 6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 7 resolution process under Local Rule 37.1 et seq. 8 6.3 The burden of persuasion in any such challenge proceeding shall be 9 on the Designating Party. Frivolous challenges, and those made for an improper 10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 parties) may expose the Challenging Party to sanctions. Unless the Designating 12 Party has waived or withdrawn the confidentiality designation, all parties shall 13 continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the Court rules on the 15 challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that 18 is disclosed or produced by another Party or by a Non-Party in connection with 19 20 this Action only for prosecuting, defending, or attempting to settle this Action. 21 Such Protected Material may be disclosed only to the categories of persons and 22 under the conditions described in this Order. When the Action has been 23 terminated, a Receiving Party must comply with the provisions of section 13 24 below (FINAL DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 5 well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of 8 the Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) the court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 20 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing 22 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 23 they will not be permitted to keep any confidential information unless they sign 24 the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 25 otherwise agreed by the Designating Party or ordered by the court. Pages of 26 transcribed deposition testimony or exhibits to depositions that reveal Protected 27 Material may be separately bound by the court reporter and may not be disclosed (i) any mediator or settlement officer, and their supporting personnel, 1 mutually agreed upon by any of the parties engaged in settlement discussions. 2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 3

IN OTHER LITIGATION

4 If a Party is served with a subpoena or a court order issued in other 5 litigation that compels disclosure of any information or items designated in this 6 Action as “CONFIDENTIAL,” that Party must: 7 (a) promptly notify in writing the Designating Party. Such notification 8 shall include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or 10 order to issue in the other litigation that some or all of the material covered by the 11 subpoena or order is subject to this Protective Order. Such notification shall 12 include a copy of this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be 14 pursued by the Designating Party whose Protected Material may be affected. 15 (d) If the Designating Party timely seeks a protective order, the Party 16 served with the subpoena or court order shall not produce any information 17 designated in this action as “CONFIDENTIAL” before a determination by the 18 court from which the subpoena or order issued, unless the Party has obtained the 19 20 Designating Party’s permission. The Designating Party shall bear the burden and 21 expense of seeking protection in that court of its confidential material and nothing 22 in these provisions should be construed as authorizing or encouraging a Receiving 23 Party in this Action to disobey a lawful directive from another court. 24 9. NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a 27 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information remedies and relief provided by this Order. Nothing in these provisions should be 1 construed as prohibiting a Non-Party from seeking additionalprotections. 2 (b) In the event that a Party is required, by a valid discovery request, to 3 produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non- 7 Party that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated 10 Protective Order in this Action, the relevant discovery request(s), and a reasonably 11 specific description of the information requested; and 12 (3) make the information requested available for inspection by the 13 Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court within 15 14 days of receiving the notice and accompanying information, the Receiving 16 Party may produce the Non-Party’s confidential information responsive to the 17 discovery request. If the Non-Party timely seeks a protective order, the Receiving 18 Party shall not produce any information in its possession or control that is subject 19 20 to the confidentiality agreement with the Non-Party before a determination by the 21 court. Absent a court order to the contrary, the Non-Party shall bear the burden 22 and expense of seeking protection in this court of its ProtectedMaterial. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has 25 disclosed Protected Material to any person or in any circumstance not authorized 26 under this Stipulated Protective Order, the Receiving Party must immediately (a) 27 notify in writing the Designating Party of the unauthorized disclosures, (b) use its inform the person or persons to whom unauthorized disclosures were made of all 1 the terms of this Order, and (d) request such person or persons to execute the 2 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 3 A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5

PROTECTED MATERIAL

6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other 8 protection, the obligations of the Receiving Parties are those set forth in Federal 9 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 10 whatever procedure may be established in an e-discovery order that provides for 11 production without prior privilege review. Pursuant to Federal Rule of Evidence 12 502(d) and (e), insofar as the parties reach an agreement on the effect of 13 disclosure of a communication or information covered by the attorney-client 14 privilege or work product protection, the parties may incorporate their agreement 15 in the stipulated protective order submitted to the court. 16 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Order abridges the right of 18 any person to seek its modification by the Court in the future. 19 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 Protective Order no Party waives any right it otherwise would have to object to 22 disclosing or producing any information or item on any ground not addressed in 23 this Stipulated Protective Order. Similarly, no Party waives any right to object on 24 any ground to use in evidence of any of the material covered by this Protective 25 Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Civil Local Rule 79-5. Protected Material the specific Protected Material at issue. If a Party's request to file Protected 1 Material under seal is denied by the court, then the Receiving Party may file the 2 information in the public record unless otherwise instructed by the court. 3 13. FINAL DISPOSITION 4 After the final disposition of this Action, as defined in paragraph 4, within 5 60 days of a written request by the Designating Party, each Receiving Party must 6 return all Protected Material to the Producing Party or destroy such material. As 7 used in this subdivision, “all Protected Material” includes all copies, abstracts, 8 compilations, summaries, and any other format reproducing or capturing any of 9 the Protected Material. Whether the Protected Material is returned or destroyed, 10 the Receiving Party must submit a written certification to the Producing Party 11 (and, if not the same person or entity, to the Designating Party) by the 60 day 12 deadline that (1) identifies (by category, where appropriate) all the Protected 13 Material that was returned or destroyed and (2)affirms that the Receiving Party 14 has not retained any copies, abstracts, compilations, summaries or any other 15 format reproducing or capturing any of the Protected Material. Notwithstanding 16 this provision, Counsel is entitled to retain an archival copy of all pleadings, 17 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 18 correspondence, deposition and trial exhibits, expert reports, attorney work 19 20 product, and consultant and expert work product, even if such materials contain 21 Protected Material. Any such archival copies that contain or constitute Protected 22 Material remain subject to this Protective Order as set forth in Section 4 23 (DURATION). 24 14. Any violation of this Order may be punished by any and all appropriate 25 measures including, without limitation, contempt proceedings and/or monetary 26 sanctions. 27 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. ] DATED: April 24, 2023 IVIE McNEILL WYATT PURCELL &

DIGGS

3 4 By: /s/ Rodney S. Diggs

RODNEY S. DIGGS

5 KAELIN S. DAVIS 6 Attorneys for Plaintiff, CAREY COCO 7 8 9 . DATED: April 28, 2023 DAWN NTOSH, City Attorney 10

3 12 By: { 13 NICHOLAS J. MASERO 2 Deputy City Attorney 14 Attorneys for Defendant, £15 CITY OF LONG BEACH 16 217 ig OR GOOD CAUSE SHOWN, IT IS SO ORDERED.

19 FE WedDems | Hon. John E. McDermott 71 United States Magistrate Judge 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name], of ________________ 4 [print or type full address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on [date] in 7 the case of CAREY COCO, an individual, Plaintiff, vs. THE CITY OF LONG 8 BEACH, and DOES 1 through 10, inclusive, Defendants, Case No.: 2:22-cv- 9 08591-RGK-(JEMx), I agree to comply with and to be bound by all the terms of 10 this Stipulated Protective Order and I understand and acknowledge that failure to 11 so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. I 15 further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ________________________ [print 19 or type full name] of _________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Dated: __________________________ 24 City and State where sworn and signed: _____________________________ 25 Printedname: ____________________________________ 26 Signature: ________________________________ 27