1 CRNOABE CROTV CE.R CAHGREIS LTIETNIGSAETNI O(SNB NG R15O1U2P9 6) 2 Email: [email protected] 555 12th Street, Suite 600 3 Oakland, CA 94607 Telephone: 510.645.2300 (Main) 4 510.645.2306 (Direct) Facsimile: 510.645.2323 5 Attorneys for Defendants and Counterclaimants, 6 CONTINENTAL CASUALTY COMPANY and VALLEY FORGE INSURANCE COMPANY 7

8 9 UNITED STATES DISTRICT COURT 10 FOR THE CENTRAL DISTRICT OF CALIFORNIA 11 SOUTHERN DIVISION 12 THEMYERSLG PC, d/b/a THE Case No. 8:20-cv-01106-FLA-DFMx MYERS LAW GROUP; TIVOLI, 13 LLC; NEO-NEON LED USA HOLDINGS, LTD; AMERICAN STIPULATED PROTECTIVE 14 LIGHTING, INC., and PETER JANG ORDER a/k/a JANN HUAN JANG,

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Plaintiffs, 16 v. 17 CNA FINANCIAL CORPORATION; 18 CONTINENTAL CASUALTY COMPANY; VALLEY FORGE 19 INSURANCE COMPANY; and DOES 1 – 50, inclusive, 20 Defendants. 21 22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting this litigation may 26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 enter the following Stipulated Protective Order. The parties acknowledge that this 28 1 Order does not confer blanket protections on all disclosures or responses to 2 discovery and that the protection it affords from public disclosure and use extends 3 only to the limited information or items that are entitled to confidential treatment 4 under the applicable legal principles. 5 B. GOOD CAUSE STATEMENT 6 This action is likely to involve disclosure of proprietary information from the 7 parties to this action for which special protection from public disclosure and from 8 use for any purpose other than prosecution of this action is warranted. Such 9 confidential and proprietary materials and information consist of, among other 10 things, communications concerning and documents produced in the underlying 11 matters placed at issue by the complaint in this action, and other related materials 12 that are not otherwise generally unavailable to the public, or which may be 13 privileged or otherwise protected from disclosure under state or federal statutes, 14 court rules, case decisions, or common law. Accordingly, to expedite the flow of 15 information, to facilitate the prompt resolution of disputes over confidentiality of 16 discovery materials, to adequately protect information the parties are entitled to 17 keep confidential, to ensure that the parties are permitted reasonable necessary uses 18 of such material in preparation for and in the conduct of trial, to address their 19 handling at the end of the litigation, and serve the ends of justice, a protective order 20 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 22 nothing 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 24 of the public record of this case. 25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 26 UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 Stipulated Protective Order does not entitle them to file confidential information 1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 2 and the standards that will be applied when a party seeks permission from the court 3 to file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 proceedings and records in civil cases. In connection with non-dispositive motions, 6 good cause must be shown to support a filing under seal. See Kamakana v. City and 7 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 8 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 9 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 10 require good cause showing), and a specific showing of good cause or compelling 11 reasons with proper evidentiary support and legal justification, must be made with 12 respect to Protected Material that a party seeks to file under seal. The parties’ mere 13 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 14 without the submission of competent evidence by declaration, establishing that the 15 material sought to be filed under seal qualifies as confidential, privileged, or 16 otherwise protectable—constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, 18 then compelling reasons, not only good cause, for the sealing must be shown, and 19 the relief sought shall be narrowly tailored to serve the specific interest to be 20 protected. See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 21 2010). For each item or type of information, document, or thing sought to be filed 22 or introduced under seal in connection with a dispositive motion or trial, the party 23 seeking protection must articulate compelling reasons, supported by specific facts 24 and legal justification, for the requested sealing order. Again, competent evidence 25 supporting the application to file documents under seal must be provided by 26 declaration. 27 Any document that is not confidential, privileged, or otherwise protectable in 28 its entirety will not be filed under seal if the confidential portions can be redacted. 1 If documents can be redacted, then a redacted version for public viewing, omitting 2 only the confidential, privileged, or otherwise protectable portions of the document, 3 shall be filed. Any application that seeks to file documents under seal in their 4 entirety should include an explanation of why redaction is not feasible. 5 2. DEFINITIONS 6 2.1 Action: this pending federal lawsuit, Case No. 8:20-cv-01106-FLA- 7 DFMx. 8 2.2 Challenging Party: a Party or Non-Party that challenges the 9 designation of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for 12 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced 22 or generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.8 House Counsel: attorneys who are employees of a party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside 28 counsel. 1 2.9 Non-Party: any natural person, partnership, corporation, association or 2 other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a 4 party to this Action but are retained to represent or advise a party to this Action and 5 have appeared in this Action on behalf of that party or are affiliated with a law firm 6 that has appeared on behalf of that party, and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation 13 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery 19 Material from a Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or 23 extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 compilations of Protected Material; and (3) any testimony, conversations, or 25 presentations by Parties or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 trial judge. This Order does not govern the use of Protected Material at trial. 28 / / / 1 4. DURATION 2 Even after final disposition of this litigation, the confidentiality obligations 3 imposed by this Order shall remain in effect until a Designating Party agrees 4 otherwise in writing or a court order otherwise directs. Final disposition shall be 5 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 6 with or without prejudice; and (2) final judgment herein after the completion and 7 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 8 including the time limits for filing any motions or applications for extension of time 9 pursuant to applicable law. 10 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for Protection. 12 Each Party or Non-Party that designates information or items for protection under 13 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, 17 items or communications for which protection is not warranted are not swept 18 unjustifiably within the ambit of this Order. 19 Mass, indiscriminate or routinized designations are prohibited. Designations 20 that are shown to be clearly unjustified or that have been made for an improper 21 purpose (e.g., to unnecessarily encumber the case development process or to 22 impose unnecessary expenses and burdens on other parties) may expose the 23 Designating Party 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 5.2 Manner and Timing of Designations. Except as otherwise provided in 28 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 2 under this Order must be clearly so designated before the material is disclosed or 3 produced. 4 Designation in conformity with this Order requires: 5 (a) for information in documentary form (e.g., paper or electronic 6 documents, but excluding transcripts of depositions or other pretrial or trial 7 proceedings), that the Producing Party affix at a minimum, the legend 8 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 9 contains protected material. If only a portion of the material on a page qualifies for 10 protection, the Producing Party also must clearly identify the protected portion(s) 11 (e.g., by making appropriate markings in the margins). 12 A Party or Non-Party that makes original documents available for inspection 13 need not designate them for protection until after the inspecting Party has indicated 14 which documents it would like copied and produced. During the inspection and 15 before the designation, all of the material made available for inspection shall be 16 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 17 documents it wants copied and produced, the Producing Party must determine 18 which documents, or portions thereof, qualify for protection under this Order. Then, 19 before producing the specified documents, the Producing Party must affix the 20 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 21 portion of the material on a page qualifies for protection, the Producing Party also 22 must clearly identify the protected portion(s) (e.g., by making appropriate markings 23 in the margins). 24 (b) for testimony given in deposition or in other pretrial or trial 25 proceedings, that the Designating Party identify on the record, before the close of 26 the deposition, hearing, or other proceeding, all protected testimony. 27 (c) for information produced in some form other than documentary and 28 for any other tangible items, that the Producing Party affix in a prominent place on 1 the exterior of the container or containers in which the information is stored the 2 legend “CONFIDENTIAL.” If only a portion or portions of the information 3 warrants protection, the Producing Party, to the extent practicable, shall identify the 4 protected portion(s). 5 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 6 failure to designate qualified information or items does not, standing alone, waive 7 the Designating Party’s right to secure protection under this Order for such 8 material. Upon timely correction of a designation, the Receiving Party must make 9 reasonable efforts to assure that the material is treated in accordance with the 10 provisions of this Order. 11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s 14 Scheduling Order. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process under Local Rule 37.1 et seq. 17 6.3 The burden of persuasion in any such challenge proceeding shall be on 18 the Designating Party. Frivolous challenges, and those made for an improper 19 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 20 parties) may expose the Challenging Party to sanctions. Unless the Designating 21 Party has waived or withdrawn the confidentiality designation, all parties shall 22 continue to afford the material in question the level of protection to which it is 23 entitled under the Producing Party’s designation until the Court rules on the 24 challenge. 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this 28 Action only for prosecuting, defending or attempting to settle this Action. Such 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions described in this Order. When the Action has been terminated, a 3 Receiving Party must comply with the provisions of section 13 below (FINAL 4 DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 otherwise ordered by the court or permitted in writing by the Designating Party, a 10 Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 13 well as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 (b) the officers, directors, and employees (including House Counsel) of 16 the Receiving Party to whom disclosure is reasonably necessary for this Action; 17 (c) Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) the court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) the author or recipient of a document containing the information or 26 a custodian or other person who otherwise possessed or knew the information; 27 (h) during their depositions, witnesses, and attorneys for witnesses, in 28 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 1 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 2 they will not be permitted to keep any confidential information unless they sign the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 4 agreed by the Designating Party or ordered by the court. Pages of transcribed 5 deposition testimony or exhibits to depositions that reveal Protected Material may 6 be separately bound by the court reporter and may not be disclosed to anyone 7 except as permitted under this Stipulated Protective Order; and 8 (i) any mediator or settlement officer, and their supporting personnel, 9 mutually agreed upon by any of the parties engaged in settlement discussions. 10 8. 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 13 that 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 shall 16 include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to 18 issue in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to this Protective Order. Such notification shall include a copy of 20 this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be pursued 22 by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with 24 the subpoena or court order shall not produce any information designated in this 25 action as “CONFIDENTIAL” before a determination by the court from which the 26 subpoena or order issued, unless the Party has obtained the Designating Party’s 27 permission. The Designating Party shall bear the burden and expense of seeking 28 protection in that court of its confidential material and nothing in these provisions 1 should be construed as authorizing or encouraging a Receiving Party in this Action 2 to disobey a lawful directive from another court. 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a Non- 6 Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party that 15 some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 18 Order in this Action, the relevant discovery request(s), and a reasonably specific 19 description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 14 23 days of receiving the notice and accompanying information, the Receiving Party 24 may produce the Non-Party’s confidential information responsive to the discovery 25 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 26 not produce any information in its possession or control that is subject to the 27 confidentiality agreement with the Non-Party before a determination by the court. 28 1 Absent a court order to the contrary, the Non-Party shall bear the burden and 2 expense of seeking protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best 8 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 9 person or persons to whom unauthorized disclosures were made of all the terms of 10 this Order, and (d) request such person or persons to execute the “Acknowledgment 11 and Agreement to Be Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other 16 protection, the obligations of the Receiving Parties are those set forth in Federal 17 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 18 whatever procedure may be established in an e-discovery order that provides for 19 production without prior privilege review. Pursuant to Federal Rule of Evidence 20 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 21 of a communication or information covered by the attorney-client privilege or work 22 product protection, the parties may incorporate their agreement in the stipulated 23 protective order submitted to the court. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 28 Protective Order, no Party waives any right it otherwise would have to object to 1 disclosing or producing any information or item on any ground not addressed in 2 this Stipulated Protective Order. Similarly, no Party waives any right to object on 3 any ground to use in evidence of any of the material covered by this Protective 4 Order. 5 12.3 Filing Protected Material. A Party that seeks to file under seal any 6 Protected Material must comply with Local Civil Rule 79-5. Protected Material 7 may only be filed under seal pursuant to a court order authorizing the sealing of the 8 specific Protected Material at issue. If a Party’s request to file Protected Material 9 under seal is denied by the court, then the Receiving Party may file the information 10 in the public record unless otherwise instructed by the court. 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 4, within 60 13 days of a written request by the Designating Party, each Receiving Party must 14 return all Protected Material to the Producing Party or destroy such material. As 15 used in this subdivision, “all Protected Material” includes all copies, abstracts, 16 compilations, summaries, and any other format reproducing or capturing any of the 17 Protected Material. Whether the Protected Material is returned or destroyed, the 18 Receiving Party must submit a written certification to the Producing Party (and, if 19 not the same person or entity, to the Designating Party) by the 60 day deadline that 20 (1) identifies (by category, where appropriate) all the Protected Material that was 21 returned or destroyed and (2) affirms that the Receiving Party has not retained any 22 copies, abstracts, compilations, summaries or any other format reproducing or 23 capturing any of the Protected Material. Notwithstanding this provision, Counsel 24 are entitled to retain an archival copy of all pleadings, motion papers, trial, 25 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 26 and trial exhibits, expert reports, attorney work product, and consultant and expert 27 work product, even if such materials contain Protected Material. Any such archival 28 1 copies that contain or constitute Protected Material remain subject to this Protective 2 Order as set forth in Section 4 (DURATION). 3 If a Party is required by governmental regulation to maintain a copy of 4 Protected Material, the Party may maintain the Protected Material for the period so 5 required, subject to the confidentiality provisions set forth herein. Upon expiration 6 of the regulatory period, the Party shall return or destroy the Protected Material in 7 accordance with this Section. 8 14. VIOLATION 9 Any violation of this Order may be punished by appropriate measures 10 including, without limitation, contempt proceedings and/or monetary sanctions. 11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 13 14 DATED: April 1, 2021 CNA COVERAGE LITIGATION GROUP

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16 By: /s/ Robert C. Christensen Robert Christensen 17 Attorneys for Defendants and Counterclaimants Continental Casualty 18 Company and Valley Forge Insurance Company 19

20 THE MYERS LAW GROUP DATED: April 1, 2021 21 By: /s/ Clifford White 22 Nicholas D. Myers Clifford L. White 23 Attorneys for Plaintiffs THEMYERSLG PC, Tivoli, LLC, Neo-Neon LED USA 24 Holdings, Ltd., American Lighting, Inc., and Peter Jang 25 26

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28 1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || DATED: April 6, 2021 L, □ n_\) HON#DOUGLAS F. McCORMICK 4 UNITED STATES MAGISTRATE JUDGE 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -15- Stipulated Protective Order

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 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of THEMYERSLG PC, v. Continental Casualty Company et 8 al., U.S.D.C., E.D. of Cal., Case No. 8:20-cv-01106-FLA-DFMx. I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint __________________________ [print or type full 19 name] of _______________________________________ [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: 25 _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28