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8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 12 ALISHA MALDONADO, individually CASE NO. 8:19-cv-00883-JLS (JDEx) and as successor in interest to ANDRU 13 MALDONADO, deceased, Assigned for General Purposes to: Hon. Josephine L. Staton 14 Courtroom 10A

15 Plaintiff, Assigned for Discovery Purposes to: United States Magistrate Judge 16 Hon. John D. Early Courtroom 6A 17 vs.

STIPULATED PROTECTIVE

18 ORDER COUNTY OF ORANGE and DOES 1- 19 10, inclusive,

20 Complaint Filed: May 10, 2019

21 Defendant.

22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 1 I. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 II. GOOD CAUSE STATEMENT 12 Defendant the County of Orange (“Defendant”) may be producing documents 13 concerning confidential internal policies of the Orange County Sheriff’s Department 14 (“OCSD”) or of Orange County, among other documents, which documents are 15 generally unavailable to the public. The disclosure of such information may 16 jeopardize the security of the OCSD or Orange County’s operations, or may 17 jeopardize the safety of certain individuals, including other defendants herein, other 18 Sheriff’s Deputies, Plaintiff(s), or unrelated third parties. Defendant may also be 19 producing documentation containing confidential information. Defendants may also 20 be producing video, audio, and still photo images related to incidents at issue in 21 Plaintiff’s First Amended Complaint, and/or any thereafter filed pleading which 22 videos are not generally available to the public. Defendant may likewise be producing 23 investigative reports generally unavailable to the public, the disclosure of which could 24 violate others’ privacy rights under substantive law or the California or United States 25 Constitution. Likewise, Defendant may be producing information on particular 26 Deputies that is confidential, subject to privacy and other protective laws that is not 27 generally available to the public and may represent a privacy and/or safety concern 1 produced by third parties pursuant to requests or subpoenas by Defendant. 2 Defendants DOE DEPUTIES likewise have a privacy interest in some of the 3 documentation likely to be produced in the discovery phase of this matter, and the 4 documentation is not generally available to the public. 5 Plaintiff ALISHA MALDONADO, individually and as successor in interest to 6 ANDRU MALDONADO, deceased (“Plaintiff”) may be producing documents 7 concerning confidential, private, or embarrassing documentation concerning Plaintiff, 8 and/or of decedent ANDRU MALDONADO (“Decedent”) health, criminal history, 9 criminal acts, or health related conditions. Similar documentation may also be 10 produced by third parties pursuant to subpoena. Such information is private to 11 Plaintiff, unavailable to the general public, and disclosure of said documentation may 12 cause embarrassment to Plaintiff or to Decedent’s memory. 13 As such, information produced by either party, or third parties, may be 14 privileged or otherwise protected from disclosure under state or federal statutes, court 15 rules, case decisions, or common law. 16 Accordingly, to expedite the flow of information, to facilitate the prompt 17 resolution of disputes over confidentiality of discovery materials, to adequately 18 protect information the parties are entitled to keep confidential, to ensure that the 19 parties are permitted reasonable necessary uses of such material in preparation for and 20 in the conduct of trial, to address their handling at the end of the litigation, and serve 21 the ends of justice, a protective order for such information is justified in this matter. 22 It is the intent of the parties that information will not be designated as confidential for 23 tactical reasons and that nothing be so designated without a good faith belief that it 24 has been maintained in a confidential, non-public manner, and there is good cause 25 why it should not be part of the public record of this case. 26 / / / 27 / / / 1 III. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 2 SEAL 3 The parties further acknowledge, as set forth in Section 14.3, below, that this 4 Stipulated Protective Order does not entitle them to file confidential information 5 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 6 the standards that will be applied when a party seeks permission from the court to file 7 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 motions, 10 good cause must be shown to support a filing under seal. See Kamakana v. City and 11 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 12 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 13 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 14 cause showing), and a specific showing of good cause or compelling reasons with 15 proper evidentiary support and legal justification, must be made with respect to 16 Protected Material that a party seeks to file under seal. The parties’ mere designation 17 of Disclosure or Discovery Material as CONFIDENTIAL does not, without the 18 submission of competent evidence by declaration, establishing that the material 19 sought to be filed under seal qualifies as confidential, privileged, or otherwise 20 protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, then 22 compelling reasons, not only good cause, for the sealing must be shown, and the relief 23 sought shall be narrowly tailored to serve the specific interest to be protected. See 24 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each 25 item or type of information, document, or thing sought to be filed or introduced under 26 seal in connection with a dispositive motion or trial, the party seeking protection must 27 articulate compelling reasons, supported by specific facts and legal justification, for 1 file documents under seal must be provided by declaration. 2 Any document that is not confidential, privileged, or otherwise protectable in 3 its entirety will not be filed under seal if the confidential portions can be redacted. If 4 documents can be redacted, then a redacted version for public viewing, omitting only 5 the confidential, privileged, or otherwise protectable portions of the document, shall 6 be filed. Any application that seeks to file documents under seal in their entirety 7 should include an explanation of why redaction is not feasible. 8 IV. DEFINITIONS 9 4.1 Action: Alisha Maldonado v. County of Orange, et al. CASE 10 NO. 8:19-cv-00883-JLS (JDEx). 11 4.2 Challenging Party: a Party or Non-Party that challenges the 12 designation of information or items under this Order. 13 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 14 how it is generated, stored or maintained) or tangible things that qualify for protection 15 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 16 Cause Statement. 17 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 18 their support staff). 19 4.5 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL.” 22 4.6 Disclosure or Discovery Material: all items or information, regardless 23 of the medium or manner in which it is generated, stored, or maintained (including, 24 among other things, testimony, transcripts, and tangible things), that are produced or 25 generated in disclosures or responses to discovery in this matter. 26 4.7 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as 1 4.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 4.9 Non-Party: any natural person, partnership, corporation, association or 5 other legal entity not named as a Party to this action. 6 4.10 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm that 9 has appeared on behalf of that party, and includes support staff. 10 4.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 4.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 4.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 V. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or extracted 26 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 27 Protected Material; and (3) any testimony, conversations, or presentations by Parties 1 Any use of Protected Material at trial shall be governed by the orders of the 2 trial judge. This Order does not govern the use of Protected Material at trial. 3 VI. DURATION 4 Once a case proceeds to trial, information that was designated as 5 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 6 as an exhibit at trial becomes public and will be presumptively available to all 7 members of the public, including the press, unless compelling reasons supported by 8 specific factual findings to proceed otherwise are made to the trial judge in advance 9 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 10 showing for sealing documents produced in discovery from “compelling reasons” 11 standard when merits-related documents are part of court record). Accordingly, the 12 terms of this protective order do not extend beyond the commencement of the 13 trial. 14 VII. DESIGNATING PROTECTED MATERIAL 15 7.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection under this 17 Order must take care to limit any such designation to specific material that qualifies 18 under the appropriate standards. The Designating Party must designate for protection 19 only those parts of material, documents, items or oral or written communications that 20 qualify so that other portions of the material, documents, items or communications 21 for which protection is not warranted are not swept unjustifiably within the ambit of 22 this Order. 23 Mass, indiscriminate or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper 25 purpose (e.g., to unnecessarily encumber the case development process or to impose 26 unnecessary expenses and burdens on other parties) may expose the Designating Party 27 to sanctions. 1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 7.2 Manner and Timing of Designations. Except as otherwise provided in 4 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 5 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 6 under this Order must be clearly so designated before the material is disclosed or 7 produced. 8 Designation in conformity with this Order requires: 9 (a) for information in documentary form (e.g., paper or electronic 10 documents, but excluding transcripts of depositions or other pretrial or trial 11 proceedings), that the Producing Party affix at a minimum, the legend 12 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 13 that contains protected material. If only a portion of the material on a page 14 qualifies for protection, the Producing Party also must clearly identify the 15 protected portion(s) (e.g., by making appropriate markings in the margins). 16 A Party or Non-Party that makes original documents available for 17 inspection need not designate them for protection until after the inspecting 18 Party has indicated which documents it would like copied and produced. 19 During the inspection and before the designation, all of the material made 20 available for inspection shall be deemed “CONFIDENTIAL.” After the 21 inspecting Party has identified the documents it wants copied and produced, 22 the Producing Party must determine which documents, or portions thereof, 23 qualify for protection under this Order. Then, before producing the specified 24 documents, the Producing Party must affix the “CONFIDENTIAL legend” 25 to each page that contains Protected Material. If only a portion of the 26 material on a page qualifies for protection, the Producing Party also must 27 clearly identify the protected portion(s) (e.g., by making appropriate 1 (b) for testimony given in depositions that the Designating Party 2 identifies the Disclosure or Discovery Material on the record, before the 3 close of the deposition all protected testimony. 4 (c) for information produced in some form other than documentary 5 and for any other tangible items, that the Producing Party affix in a 6 prominent place on the exterior of the container or containers in which the 7 information is stored the legend “CONFIDENTIAL.” If only a portion or 8 portions of the information warrants protection, the Producing Party, to the 9 extent practicable, shall identify the protected 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. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 VIII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 8.1 Timing of Challenges. Any Party or Non-Party may challenge 18 a designation of confidentiality at any time that is consistent with the 19 Court’s Scheduling Order. 20 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37-1 et seq. 22 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 23 joint stipulation pursuant to Local Rule 37-2. 24 8.4 The burden of persuasion in any such challenge proceeding shall be on 25 the Designating Party. Frivolous challenges, and those made for an improper 26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 27 parties) may expose the Challenging Party to sanctions. Unless the Designating 1 continue to afford the material in question the level of protection to which it is 2 entitled under the Producing Party’s designation until the Court rules on the 3 challenge. 4 IX. ACCESS AND USE TO PROTECTED MATERIAL 5 9.1 Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a Receiving 10 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at a 12 location and in a secure manner that ensures that access is limited to the persons 13 authorized under this Order. 14 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 15 otherwise ordered by the court or permitted in writing by the Designating Party, a 16 Receiving Party may disclose any information or item designated 17 “CONFIDENTIAL” only to: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 19 as employees of said Outside Counsel of Record to whom it is reasonably 20 necessary to disclose the information for this Action; 21 (b) the officers, directors, and employees (including House Counsel) of the 22 Receiving Party to whom disclosure is reasonably necessary for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the court and its personnel; 27 (e) court reporters and their staff; 1 Vendors to whom disclosure is reasonably necessary for this Action and who 2 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (g) the author or recipient of a document containing the information or a 4 custodian or other person who otherwise possessed or knew the information; 5 (h) during their depositions, witnesses, and attorneys for witnesses, in the 6 Action to whom disclosure is reasonably necessary provided: (1) the deposing 7 party requests that the witness sign the form attached as Exhibit 1 hereto; and 8 (2) they will not be permitted to keep any confidential information unless they 9 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 10 otherwise agreed by the Designating Party or ordered by the court. Pages of 11 transcribed deposition testimony or exhibits to depositions that reveal Protected 12 Material may be separately bound by the court reporter and may not be 13 disclosed to anyone except as permitted under this Stipulated Protective Order; 14 and 15 (i) any mediator or settlement officer, and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions 17 X. PROTECTED MATERIAL SUBPOENAED OR ORDERED 18 PRODUCED IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that compels disclosure of any information or items designated in this Action as 21 “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification 23 shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order 25 to issue in the other litigation that some or all of the material covered by the subpoena 26 or order is subject to this Protective Order. Such notification shall include a copy of 27 this Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. 3 4 If the Designating Party timely seeks a protective order, the Party served with 5 the subpoena or court order shall not produce any information designated in this action 6 as “CONFIDENTIAL” before a determination by the court from which the subpoena 7 or order issued, unless the Party has obtained the Designating Party’s permission. The 8 Designating Party shall bear the burden and expense of seeking protection in that court 9 of its confidential material and nothing in these provisions should be construed as 10 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 11 directive from another court. 12 XI. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a 15 Non-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 shall: 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 agreement 25 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 reasonably 1 (3) make the information requested available for inspection by the 2 Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 4 14 days of receiving the notice and accompanying information, the Receiving Party 5 may 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 XII. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and 19 Agreement to Be Bound” that is attached hereto as Exhibit A. 20 XIII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIALS 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 26 may be established in an e-discovery order that provides for production without prior 27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 1 information covered by the attorney-client privilege or work product protection, the 2 parties may incorporate their agreement in the stipulated protective order submitted 3 to the court. 4 XIV. MISCELLANEOUS 5 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the Court in the future. 7 14.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order, no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in this 10 Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 ground to use in evidence of any of the material covered by this Protective Order. 12 14.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 14 only be filed under seal pursuant to a court order authorizing the sealing of the specific 15 Protected Material at issue. If a Party’s request to file Protected Material under seal is 16 denied by the court, then the Receiving Party may file the information in the public 17 record unless otherwise instructed by the court. 18 XV. FINAL DISPOSITION 19 After the final disposition of this Action, as defined herein, within sixty (60) 20 days of a written request by the Designating Party, each Receiving Party must destroy 21 such material. As used in this subdivision, “all Protected Material” includes all copies, 22 abstracts, compilations, summaries, and any other format reproducing or capturing 23 any of the Protected Material. Receiving Party must submit a written certification to 24 the Producing Party (and, if not the same person or entity, to the Designating Party) 25 by the 60 day deadline that confirms in writing the destruction of all Protected 26 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 27 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 1 work product, and consultant and expert work product, even if such materials contain 2 Protected Material. Any such archival copies that contain or constitute Protected 3 Material remain subject to this Protective Order as set forth herein. 4 XVI. VIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 including, without limitation, contempt proceedings and/or monetary sanctions. 7 IT IS SO STIPULATED. 8 9 DATED: November 14, 2019 LYNBERG & WATKINS 10 A Professional Corporation

11

12 By: /s/ Jonathan C. Bond

NORMAN J. WATKINS

13 S. FRANK HARRELL

JONATHAN C. BOND

14 Attorneys for Defendant

COUNTY OF ORANGE

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16 DATED: November 14, 2019 LAW OFFICES OF DALE K. GALIPO 17

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By: /s/ Renee V. Masongsong 20 Attorneys for Plaintiff ALISHA MALDONADO, individually 21 and as successor in interest to ANDRU

MALDONADO

22

23 [ ORDER ON FOLLOWING PAGE ] 24 / / / 25 / / / 26 / / / 27 / / /

FOR GOOD CAUSE APPEARING, THE FOREGOING STIPULATION IS

2||SO ORDERED. pate 5 || Dated: November 19, 2019 6 JOHN D. EARLY United States Magistrate Judge 7 Central District of California 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________________, with the address of 4 _____________________________________________ declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective Order 6 that was issued by the United States District Court for the Central District of California 7 November 19, 2019 in the case of Alisha Maldonado v. County of Orange, et al. Case 8 No. 8:19-cv-00883-JLS (JDEx). I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that failure 10 to so comply could expose me to sanctions and punishment in the nature of contempt. 11 I solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint ____________________________ with address 19 ___________________________________ and telephone number 20 _____________________ as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Dated: _____________________ City/State: ___________________________ 24 Name: ________________________________ 25 Signature: ___________________________________ 26 27