John Martinez v. Trojan Battery Company, LLC
John Martinez v. Trojan Battery Company, LLC
Trial Court Opinion
1 | ANTHONY K. MCCLAREN, Bar No. 232515 akm@ mlegal.law 2 || TAR 6 I. BOULAD, Bar No. 330965 tib@pmiegal law 3 || PERLEBERG MCCLAREN LLP 3415 South Sepulveda Blvd., Suite 1100 4 || Los Angeles, California 90034 Telephone: 323.741.6500 5 || Facsimile: 323.426.2405 6 || Attorneys for Plaintiff 7 JOHN MARTINEZ
8 || JON C. YONEMITSU, Bar No. 199026 {ygnemitsu@ hitler com 9 ARA ADELLE RITTER COLE, Bar No. 306515 [email protected] 10 | LITTCER MENDELSON, P.C. 501 W. Broadway, Suite 900 Il || San Diego, CA 92101.3577 Telephone: 619.232.0441 12 || Facsimile: 619.232.4302 13 || Attorneys for Defendant 14 TROJAN BATTERY COMPANY, LLC
15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17 WESTERN DIVISION 18 || JOHN MARTINEZ, an individual, Case No. 2:21-CV-00436-DSF (ASx) 19 Plaintiff, PROTECTIVE ORDER 20 || y. 21 || TROJAN BATTERY COMPANY, 9 || LLC, a Delaware Limited Liability Company, and DOES 1-25, inclusive, 23 Defendant. 24 25 26 27 28 1.
1 || 1. INTRODUCTION 2 A. 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 prosecuting this litigation may be warranted. 6 || Accordingly, the parties hereby stipulate to 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 9 || it 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. The 11 || parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 12 || Protective Order does not entitle them to file confidential information under seal; Civil 13 || Local Rule 79-5 sets forth the procedures that must be followed and the standards that 14 || will be applied when a party seeks permission from the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 This action involves whistleblower retaliation and wrongful termination claims 17 || arising from workplace safety policies, regulations and operations, including those 18 || surrounding the COVID-19 pandemic and is therefore likely to involve trade secrets, 19 || customer and pricing lists and other valuable research, development, commercial, 20 || financial, technical and/or proprietary information for which special protection from 21 || public disclosure and from use for any purpose other than prosecution of this action 22 || is warranted. Such confidential and proprietary materials and information is anticipated 23 || to include, among other things, potential discovery and disclosure of confidential 24 || personal, medical and/or employment information associated with exposure and/or 25 || infection rate(s) as well as confidential communications with regulatory agencies 26 || regarding safety protocols and implementation of preventative measures contingent on 27 || proprietary business operations and practices. 28° /// 2.
Such confidential and private information is otherwise generally unavailable to 2 || the public and/or is privileged or otherwise protected from disclosure under state or 3 || federal statutes, court rules, case decisions, or common law. Disclosure of the foregoing 4 || confidential information to the public without proper protection will result in serious 5 || violation of privacy of third parties and may lead to misuse of such information. 6 || Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 7 || disputes over confidentiality of discovery materials, to adequately protect information 8 || the parties are entitled to keep confidential, to ensure that the parties are permitted 9 || reasonable necessary uses of such material in preparation for and in the conduct of trial, 10 || to address their handling at the end of the litigation, and serve the ends of justice, a 11 || protective order for such information is justified in this matter. It is the intent of the 12 || parties that information will not be designated as confidential for tactical reasons and 13 || that nothing be so designated without a good faith belief that it has been maintained in 14 || aconfidential, non-public manner, and there is good cause why it should not be part of 15 || the public record of this case. 16 |] 2. DEFINITIONS 17 2.1. Action: John Martinez v. Trojan Battery Company, LLC, Case No. 2:21- 18 || CV-00436-DSF-AS. 19 2.2. Challenging Party: a Party or Non-Party that challenges the designation 20 || of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 22 || itis generated, stored or maintained) or tangible things that qualify for protection under 23 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 24 || Statement 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 26 || support staff). 27 | /// 28° /// 3.
1 2.5 Designating Party: a Party or Non-Party that designates information or 2 | items that it produces in disclosures or in responses to discovery as 3 || “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless of 5 || the medium or manner in which it is generated, stored, or maintained (including, among 6 || other things, testimony, transcripts, and tangible things), that are produced or generated 7 || in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 10 || expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 || House Counsel does not include Outside Counsel of Record or any other outside 13 || counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association, or 15 || other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 17 || this Action but are retained to represent or advise a party to this Action and have 18 || appeared in this Action on behalf of that party or are affiliated with a law firm which 19 || has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 || employees, consultants, retained experts, and Outside Counsel of Record (and their 22 || support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 || Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation support 26 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and 28 © their employees and subcontractors. 4.
1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 || designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 4 || from a Producing Party. 5 |} 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only Protected 7 || Material (as defined above), but also (1) any information copied or extracted from 8 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 9 || Material; and (3) any testimony, conversations, or presentations by Parties or their 10 || Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial will be governed by the orders of the trial 12 || judge. This Order does not govern the use of Protected Material at trial. 4. DURATION 14 Once a case proceeds to trial, all of the information admitted or used during a 15 || public trial that was designated as confidential or maintained pursuant to this protective 16 || order becomes public and will be presumptively available to all members of the public, 17 || including the press, unless compelling reasons supported by specific factual findings to 18 || proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 19 || City and County of Honolulu,
447 F.3d 1172, 1180-81(9th Cir. 2006) (distinguishing 20 || “good cause” showing for sealing documents produced in discovery from “compelling 21 || reasons” standard when merits-related documents are part of court record). 22 || Accordingly, to the extent any material is subsequently used for or admitted during a 23 || public trial of this matter, the terms of this protective order do not extend beyond the 24 || commencement of such trial. 25 If the Action resolves prior to a public trial, even after final disposition of this 26 || litigation, the confidentiality obligations imposed by this Order will remain in effect 27 || until a Designating Party agrees otherwise in writing or a court order otherwise directs. 28 © Final disposition will be deemed to be the later of (1) dismissal of all claims and 5.
1 || defenses in this Action, with or without prejudice; and (2) final judgment herein after 2 || the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 3 || this Action, including the time limits for filing any motions or applications for extension 4 || of time pursuant to applicable law. 5 || 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 || Each Party or Non-Party that designates information or items for protection under this 8 || Order must take care to limit any such designation to specific material that qualifies 9 || under the appropriate standards. The Designating Party must designate for protection 10 || only those parts of material, documents, items, or oral or written communications that 11 || qualify so that other portions of the material, documents, items, or communications for 12 || which protection is not warranted are not swept unjustifiably within the ambit of this 13 || Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 || that are shown to be clearly unjustified or that have been made for an improper purpose 16 || (e.g., to unnecessarily encumber the case development process or to impose 17 || unnecessary expenses and burdens on other parties) may expose the Designating Party 18 || to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 || designated for protection do not qualify for protection, that Designating Party must 21 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2. Manner and Timing of Designations. Except as otherwise provided in this 23 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 24 || or ordered, Disclosure or Discovery Material that qualifies for protection under this 25 || Order must be clearly so designated before the material is disclosed or produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 © documents, but excluding transcripts of depositions or other pretrial or trial 6.
1 || proceedings), that the Producing Party affix at a minimum, the legend 2 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each page that 3 || contains protected material. If only a portion or portions of the material on a page 4 || qualifies for protection, the Producing Party also must clearly identify the protected 5 || portion(s) (e.g., by making appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 || need not designate them for protection until after the inspecting Party has indicated 8 || which documents it would like copied and produced. During the inspection and before 9 || the designation, all of the material made available for inspection will be deemed 10 || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 11 || copied and produced, the Producing Party must determine which documents, or portions 12 || thereof, qualify for protection under this Order. Then, before producing the specified 13 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 14 || that contains Protected Material. If only a portion or portions of the material on a page 15 || qualifies for protection, the Producing Party also must clearly identify the protected 16 || portion(s) (e.g., by making appropriate markings in the margins). 17 (b) for testimony given in depositions that the Designating Party identify 18 || the Disclosure or Discovery Material on the record, before the close of the deposition 19 || all protected testimony. 20 (c) for information produced in some form other than documentary and 21 || for any other tangible items, that the Producing Party affix in a prominent place on the 22 || exterior of the container or containers in which the information is stored the legend 23 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 24 || protection, the Producing Party, to the extent practicable, will identify the protected 25 || portion(s). 26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 || failure to designate qualified information or items does not, standing alone, waive the 28 Designating Party’s right to secure protection under this Order for such material. Upon 7.
1 || timely correction of a designation, the Receiving Party must make reasonable efforts to 2 || assure that the material is treated in accordance with the provisions of this Order. 3 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 || designation of confidentiality at any time that is consistent with the Court’s Scheduling 6 || Order. 7 6.2 Meetand Confer. The Challenging Party shall initiate the informal dispute 8 || resolution process set forth in the Court's Procedures and Schedules. see 9 || http://www.cacd.uscourts.gov/honorable-alka-sagar 10 6.3. The burden of persuasion in any such challenge proceeding will be on the 11 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 12 || to harass or impose unnecessary expenses and burdens on other parties) may expose the 13 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 14 || the confidentiality designation, all parties will continue to afford the material in question 15 || the level of protection to which it is entitled under the Producing Party’s designation 16 || until the Court rules on the challenge. 17 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1. Basic Principles. A Receiving Party may use Protected Material that is 19 || disclosed or produced by another Party or by a Non-Party in connection with this Action 20 || only for prosecuting, defending, or attempting to settle this Action. Such Protected 21 || Material may be disclosed only to the categories of persons and under the conditions 22 || described in this Order. When the Action has been terminated, a Receiving Party must 23 || comply with the provisions of section 13 below (FINAL DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 || location and in a secure manner that ensures that access is limited to the persons 26 || authorized under this Order. 27 | /// 28° /// 8.
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party 3 || may disclose any information or item designated “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 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 20 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 21 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 22 || not be permitted to keep any confidential information unless they sign the 23 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 24 || by the Designating Party or ordered by the court. Pages of transcribed deposition 25 || testimony or exhibits to depositions that reveal Protected Material may be separately 26 || bound by the court reporter and may not be disclosed to anyone except as permitted 27 || under this Stipulated Protective Order; and 28° /// 9.
(i) any mediator or settlement officer, and their supporting personnel, 2 || mutually agreed upon by any of the parties engaged in settlement discussions. 3 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 4 OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation that 6 || compels disclosure of any information or items designated in this Action as 7 || “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification will 9 || include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order 11 || to issue in the other litigation that some or all of the material covered by the subpoena 12 || or order is subject to this Protective Order. Such notification will include a copy of this 13 || Stipulated Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be 15 || pursued by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with the 17 || subpoena or court order will not produce any information designated in this action as 18 || “CONFIDENTIAL” before a determination by the court from which the subpoena or 19 || order issued, unless the Party has obtained the Designating Party’s permission. The 20 || Designating Party will bear the burden and expense of seeking protection in that court 21 || of its confidential material and nothing in these provisions should be construed as 22 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 23 || from another court. 24 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 25 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 28 © produced by Non-Parties in connection with this litigation is protected by the remedies 10.
1 || and relief provided by this Order. Nothing in these provisions should be construed as 2 || prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 || produce a Non-Party’s confidential information in its possession, and the Party is 5 || subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 6 || information, then the Party will: 7 (1) promptly notify in writing the Requesting Party and the Non- 8 || Party that some or all of the information requested is subject to a confidentiality 9 || agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 || specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 || Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 || 14 days of receiving the notice and accompanying information, the Receiving Party may 17 || produce the Non-Party’s confidential information responsive to the discovery request. 18 || If the Non-Party timely seeks a protective order, the Receiving Party will not produce 19 || any information in its possession or control that is subject to the confidentiality 20 || agreement with the Non-Party before a determination by the court. Absent a court 21 || order to the contrary, the Non-Party will bear the burden and expense of seeking 22 || protection in this court of its Protected Material. 23 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 || Protected Material to any person or in any circumstance not authorized under this 26 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 27 || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 28 all unauthorized copies of the Protected Material, (c) inform the person or persons to 11.
1 || whom unauthorized disclosures were made of all the terms of this Order, and (d) request 2 || such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 3 || that is attached hereto as Exhibit 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 protection, 8 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 9 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 || may be established in an e-discovery order that provides for production without prior 11 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 || parties reach an agreement on the effect of disclosure of a communication or 13 || information covered by the attorney-client privilege or work product protection, the 14 || parties may incorporate their agreement in the stipulated protective order submitted to 15 || the court. 16 |} 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 18 || person to seek its modification by the Court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 || Protective Order no Party waives any right it otherwise would have to object to 21 || disclosing or producing any information or item on any ground not addressed in this 22 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 23 || ground to use in evidence of any of the material covered by this Protective Order. 24 12.3 Filing Protected Material. A Party that seeks to file under seal any 25 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 26 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 27 || Protected Material at issue. If a Party's request to file Protected Material under seal is 28° /// 12.
1 || denied by the court, then the Receiving Party may file the information in the public 2 || 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 60 5 || days of a written request by the Designating Party, each Receiving Party must return all 6 || Protected Material to the Producing Party or destroy such material. As used in this 7 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 8 || summaries, and any other format reproducing or capturing any of the Protected 9 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party 10 || must submit a written certification to the Producing Party (and, if not the same person 11 || or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 12 || category, where appropriate) all the Protected Material that was returned or destroyed 13 || and (2) affirms that the Receiving Party has not retained any copies, abstracts, 14 || compilations, summaries or any other format reproducing or capturing any of the 15 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 16 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 17 || legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 18 || work product, and consultant and expert work product, even if such materials contain 19 || Protected Material. Any such archival copies that contain or constitute Protected 20 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 21 || 14. Any willful violation of this Order may be punished by any and all appropriate 22 || measures including, without limitation, contempt proceedings and/or monetary 23 | /// 24 | /// 25 | /// 26 | /// 27 | /// /// 13.
1 || sanctions, evidentiary sanctions, reference to disciplinary authorities, or other 2 || appropriate action at the discretion of the Court. 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 5 || Dated: June 15, 2021 6 /s/ Anthony K. McClaren Anthony K. McClaren 7 Tariq I. Boulad PERLEBERG MCCLAREN LLP 8 Attorneys for Plaintiff 9 JOHN MARTINEZ
10 || Dated: June 15, 2021 11 12 /s/ Kara A. Cole Jon C. Yonemitsu 13 Kara A. Cole LITTLER MENDELSON, P.C. 14 Attorneys for Defendant 5 TROJAN BATTERY COMPANY, LLC
16 FILER ATTESTATION 17 Pursuant to Local Rule 5-4.3.4(a)(2) I hereby attest that all other signatories 18 || listed, and on whose behalf the filing is submitted, concur in the filing’s content and 19 || have authorized the filing. 20 || Dated: June 15, 2021 21 /s/ Kara A. Cole Kara A. Cole 22 23 || FOR GOOD CAUSE SHOWN, IT IS SOORDERED. 24 || DATED: _ June 16, 2021 25 96 |) —___/s/Sagar Honorable Alka Sagar 27 || United States Magistrate Judge 28 14,
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 5 || of 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 || on [date] in the case of John Martinez v. Trojan Battery Company, LLC, 8 || Case No. 2:21-CV-00436-DSF-AS. 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. I 11 || solemnly promise that I will not disclose in any manner any information or item that is 12 || 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 for 15 || the Central District of California for the purpose of enforcing the terms of this Stipulated 16 || Protective Order, even if such enforcement proceedings occur after termination of this 17 || action. I hereby appoint [print or type full name] of 18 [print or type full address and 19 || telephone number] as my California agent for service of process in connection with 20 || this action or any proceedings related to enforcement of this Stipulated Protective Order. 21 || Date: 22 || City and State where signed: 23 || Printed name: 24 25 || Signature: 26 27 28 15.
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