1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 || STEVEN WALPERT, an individual, Case No. 2:21-cv-01259 FMO-JC 12 Plaintiff, STIPULATED PROTECTIVE 13 || v. ORDER RE: DISCLOSURE OF CONFIDENTIAL INFORMATION 14 || CITY OF LOS ANGELES; a public entity; and DOES 1-10, individually [CHANGES MADE BY COURT TO 15 || and in their official capacity as Los ARAGRAPHS 3, 8 & 9] 6 Angeles Police Officers, inclusive, Defendants. 17 18 19 || 1. GENERAL 20 1.1. Purposes and Limitations. 21 Discovery in this action is likely to involve production of confidential, 22 || proprietary or private information for which special protection from public 23 || disclosure and from use for any purpose other than prosecuting this litigation may 24 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 || enter the following Stipulated Protective Order. The parties acknowledge that this 26 || Order does not confer blanket protections on all disclosures or responses to 27 || discovery and that the protection it affords from public disclosure and use extends 28 | /// E, WILLIAMS & DED -1-

1 || only to the limited information or items that are entitled to confidential treatment 2 || under the applicable legal principles. 3 1.2 Good Cause Statement. 4 This action involves the City of Los Angeles and members of the Los 5 || Angeles Police Department. Plaintiff is seeking materials and information that 6 || Defendants the City of Los Angeles et al. (“City”) maintains as confidential, such 7 || as personnel files of the police officers involved in this incident, Internal Affairs 8 || materials and information, video recordings (including Body-Worn Video 9 || recordings and Digital In-Car Video recordings), audio recordings, and information 10 || and other administrative materials and information currently in the possession of 11 || the City and which the City believes needs special protection from public disclosure 12 || and from use for any purpose other than prosecuting this litigation. Plaintiff is also 13 || seeking official information contained in the personnel files of the police officers 14 || involved in the subject incident, which the City maintains as strictly confidential 15 || and which the City believes needs special protection from public disclosure and 16 || from use for any purpose other than prosecuting this litigation. 17 The City asserts that the confidentiality of the materials and information 18 || sought by Plaintiff is recognized by California and federal law, as evidenced inter 19 || alia by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for 20 || ND. Cal.,

(9th Cir. 1975), aff'd,

(1976). The City 21 || has not publicly released the materials and information referenced above except 22 || under protective order or pursuant to a court order, if at all. These materials and 23 || information are of the type that has been used to initiate disciplinary action against 24 || Los Angeles Police Department (“LAPD”’) officers, and has been used as evidence 25 || in disciplinary proceedings, where the officers’ conduct was considered to be 26 || contrary to LAPD policy. 27 The City contends that absent a protective order delineating the 28 || responsibilities of nondisclosure on the part of the parties hereto, there is a specific WILLIAMS & LLP _2-

1 || risk of unnecessary and undue disclosure by one or more of the many attorneys, 2 || secretaries, law clerks, paralegals and expert witnesses involved in this case, as well 3 || as the corollary risk of embarrassment, harassment and professional and legal harm 4 || on the part of the LAPD officers referenced in the materials and information. 5 Accordingly, to expedite the flow of information, to facilitate the prompt 6 || resolution of disputes over confidentiality of discovery materials, to adequately 7 || protect information the parties are entitled to keep confidential, to ensure that the 8 || parties are permitted reasonably necessary uses of such material in preparation for 9 || and in the conduct of trial, to address their handling at the end of the litigation, and 10 || serve the ends of justice, a protective order for such information is justified in this 11 || matter. It is the intent of the parties that information will not be designated as 12 || confidential for tactical reasons and that nothing be so designated without a good 13 || faith belief that it has been maintained in a confidential, non-public manner, and 14 || there is good cause why it should not be part of the public record of this case. 15 13 Acknowledgment of Procedure for Filing Under Seal. 16 The parties agree that any pleadings, motions, briefs, declarations, 17 || stipulations, exhibits or other written submissions to the Court in this litigation 18 || which contain or incorporate Confidential Material shall be lodged with an 19 || application and/or joint stipulation to file the papers or the portion thereof 20 || containing the Confidential Material, under seal. 21 The parties agree that they will meet and confer regarding the necessity of 22 || seeking an order from the Court filing under seal any pleadings, motions, briefs, 23 || declarations, stipulations, exhibits or other documents and/or materials at least five 24 || (5) days prior to filing any application and/or joint stipulation to file under seal. 25 The parties further acknowledge, as set forth in Section 12.3, below, that this 26 || Stipulated Protective Order does not automatically entitle them to file confidential 27 || information under seal and that Local Civil Rule 79-5 sets forth the procedures that 28 | ///

1 || must be followed and the standards that will be applied when a party seeks 2 || permission from the Court to file material under seal. 3 || 2. DEFINITIONS 4 2.1. Action: Steven Walpert v. City of Los Angeles, et al. Case No. 2:21- 5 || cv-01259 FMO-JC. 6 2.2 Challenging Party: a Party or Non-Party that challenges the 7 || designation of information or items under this Order. 8 2.3 “CONFIDENTIAL” Information or Items: information (regardless 9 || of how it is generated, stored or maintained) or tangible things that qualify for 10 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 || the Good Cause Statement. This also includes (1) any information copied or 12 || extracted from the Confidential information; (2) all copies, excerpts, summaries, 13 || abstracts or compilations of Confidential information; and (3) any testimony, 14 || conversations, or presentations that might reveal Confidential information. 15 2.4 Counsel: Counsel of record for the parties to this civil litigation and 16 || their support staff. 17 2.5 Designating Party: a Party or Non-Party that designates information 18 || or items that it produces in disclosures or in responses to discovery as 19 || “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, 21 || regardless of the medium or manner in which it is generated, stored, or maintained 22 || (including, among other things, testimony, transcripts, and tangible things), that are 23 || produced or generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 || an expert witness or as a consultant in this Action. 27 2.8 Final Disposition: when this Action has been fully and completely 28 || terminated by way of settlement, dismissal, trial and/or appeal. LLP 4.

1 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph 2 || 2.4) and who are employees of a party to this Action. 3 2.10 Non-Party: any natural person, partnership, corporation, association 4 | or other legal entity not named as a Party to this action. 5 2.11 Outside Counsel of Record: attorneys who are not employees of a 6 || party to this Action but are retained to represent or advise a party to this Action and 7 || have appeared in this Action on behalf of that party or are affiliated with a law firm 8 || that has appeared on behalf of that party, and includes support staff. 9 2.12 Party: any party to this Action, including all of its officers, directors, 10 || boards, departments, divisions, employees, consultants, retained experts, and 11 || Outside Counsel of Record (and their support staffs). 12 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 13 || Discovery Material in this Action. 14 2.14 Professional Vendors: persons or entities that provide litigation 15 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 16 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 17 || and their employees and subcontractors. 18 2.15 Protected Material: any Disclosure or Discovery Material that is 19 || designated as “CONFIDENTIAL.” 20 2.16 Receiving Party: a Party that receives Disclosure or Discovery 21 || Material from a Producing Party. 22 || 3. SCOPE 23 The protections conferred by this Stipulation and Order cover not only 24 || Protected Material (as defined above), but also (1) any information copied or 25 || extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or 26 || compilations of Protected Material; and (3) any testimony, conversations, or 27 || presentations by Parties or their Counsel that might reveal Protected Material, other 28 || than during a court hearing or at trial. LLP _5-

1 Any use of Protected Material during a court hearing or at trial shall be 2 || governed by the orders of the presiding judge. This Order does not govern the use 3 || of Protected Material during a court hearing or at trial. 4 || 4. DURATION 5 Once a trial commences in this Action, information that was designated as 6 || CONFIDENTIAL or maintained pursuant to this protective order and that is 7 || introduced or admitted as an exhibit at trial becomes public and will be 8 || presumptively available to all members of the public, including the press, unless 9 || compelling reasons supported by specific factual findings to proceed otherwise are 10 || made to the trial judge in advance of the trial. See Kamakana v. City and County of 11 || Honolulu,

(9th Cir. 2006) (distinguishing “good cause” 12 || showing for sealing documents produced in discovery from “compelling reasons” 13 || standard when merits-related documents are part of court record). Accordingly, the 14 || terms of this protective order do not extend beyond the commencement of the trial 15 || as to the CONFIDENTIAL information and materials introduced or admitted as an 16 || exhibit at trial. 17 || 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for 19 || Protection. 20 Each Party or Non-Party that designates information or items for protection 21 || under this Order must take care to limit any such designation to specific material 22 || that qualifies under the appropriate standards. The Designating Party must 23 || designate for protection only those parts of material, documents, items or oral or 24 || written communications that qualify so that other portions of the material, 25 || documents, items or communications for which protection is not warranted are not 26 || swept unjustifiably within the ambit of this Order. 27 Mass, indiscriminate or routinized designations are prohibited. Designations 28 || that are shown to be clearly unjustified or that have been made for an improper

1 || purpose (e.g., to unnecessarily encumber the case development process or to 2 || impose unnecessary expenses and burdens on other parties) may expose the 3 || Designating Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 || designated for protection do not qualify for protection, the Designating Party must 6 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 5.2. Manner and Timing of Designations. Except as otherwise provided 8 || in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 9 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 10 || under this Order must be clearly so designated before the material is disclosed or 11 || produced. 12 Designation in conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic 14 || documents, but excluding transcripts of depositions or other pretrial or trial 15 || proceedings), that the Producing Party affix at a minimum, the legend 16 || “CONFIDENTIAL” or words of a similar effect, and that includes the case name 17 || and case number (hereinafter “CONFIDENTIAL legend”), to each page that 18 || contains protected material. If only a portion of the material on a page qualifies for 19 || protection, the Producing Party also must clearly identify the protected portion(s) 20 || (e.g., by making appropriate markings in the margins). 21 A Party or Non-Party that makes original documents available for inspection 22 || need not designate them for protection until after the inspecting Party has indicated 23 || which documents it would like copied and produced. During the inspection and 24 || before the designation, all of the material made available for inspection shall be 25 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 26 || documents it wants copied and produced, the Producing Party must determine 27 || which documents, or portions thereof, qualify for protection under this Order. Then, 28 || before producing the specified documents, the Producing Party must affix the

1 |) “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 2 || portion of the material on a page qualifies for protection, the Producing Party also 3 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 4 || in the margins). 5 (b) for testimony given in depositions that the Designating Party 6 || identifies the Disclosure or Discovery Material on the record, before the close of 7 || the deposition all protected testimony. 8 (c) for information produced in some form other than documentary 9 || and for any other tangible items, that the Producing Party affix in a prominent place 10 || on the exterior of the container or containers in which the information is stored the 11 || legend “CONFIDENTIAL.” If only a portion or portions of the information 12 || warrants protection, the Producing Party, to the extent practicable, shall identify the 13 || protected portion(s). 14 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 || failure to designate qualified information or items does not, standing alone, waive 16 || the Designating Party’s right to secure protection under this Order for such 17 || material. Upon timely correction of a designation, the Receiving Party must make 18 || reasonable efforts to assure that the material is treated in accordance with the 19 || provisions of this Order. 20 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 || designation of confidentiality at any time that is consistent with the Court’s 23 || Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 || resolution process under Local Rule 37.1 et seq. 26 6.3. Burden. The burden of persuasion in any such challenge proceeding 27 || shall be on the Designating Party. Frivolous challenges, and those made for an 28 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on WILLIAMS & LLP _8-

1 || other parties) may expose the Challenging Party to sanctions. Unless the 2 || Designating Party has waived or withdrawn the confidentiality designation, all 3 || parties shall continue to afford the material in question the level of protection to 4 || which it is entitled under the Producing Party’s designation until the Court rules on 5 || the challenge. 6 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1. Basic Principles. A Receiving Party may use Protected Material that 8 || 1s disclosed or produced by another Party or by a Non-Party in connection with this 9 || Action only for prosecuting, defending or attempting to settle this Action. Such 10 || Protected Material may be disclosed only to the categories of persons and under the 11 || conditions described in this Order. When the Action has been terminated, a 12 || Receiving Party must comply with the provisions of section 13 below (FINAL 13 || DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 || location and in a secure manner that ensures that access is limited to the persons 16 || authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 18 || otherwise ordered by the court or permitted in writing by the Designating Party, a 19 || Receiving Party may disclose any information or item designated 20 || “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Counsel of Record in this Action, as well 22 || as employees of said Counsel of Record to whom it is reasonably necessary to 23 || disclose the information for this Action; 24 (b) Experts (as defined in this Order) of the Receiving Party to 25 || whom disclosure is reasonably necessary for this Action and who have signed the 26 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (c) the court and its personnel; 28 (d) court reporters and their staff; LLP _9-

1 (e) professional jury or trial consultants, mock jurors, and 2 || Professional Vendors to whom disclosure is reasonably necessary for this Action 3 || and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 4 || A); 5 (f) the author or recipient of a document containing the information 6 || or a custodian or other person who otherwise possessed or knew the information; 7 (g) during their depositions, witnesses, and attorneys for witnesses, 8 || in the Action to whom disclosure is reasonably necessary provided: (1) the 9 || deposing party requests that the witness sign the form attached as Exhibit “A” 10 || hereto; and (2) they will not be permitted to keep any confidential information 11 || unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 12 || “A’’), unless otherwise agreed by the Designating Party or ordered by the court. 13 || Pages of transcribed deposition testimony or exhibits to depositions that reveal 14 || Protected Material may be separately bound by the court reporter and may not be 15 || disclosed to anyone except as permitted under this Stipulated Protective Order; and 16 (h) any mediator or settlement officer, and their supporting 17 || personnel, mutually agreed upon by any of the parties engaged in settlement 18 || discussions and who have signed the “Acknowledgment and Agreement to Be 19 || Bound” (Exhibit A). 20 7.3 Counsel making the disclosure to any qualified person described 21 || herein shall retain the original executed copy of the Nondisclosure Agreement until 22 || sixty (60) days after this litigation has become final, including any appellate review, 23 || and monitoring of an injunction. Counsel for the Receiving Party shall maintain all 24 || signed Nondisclosure Agreements and shall produce the original signature page 25 || upon reasonable written notice from opposing counsel. If an issue arises regarding a 26 || purported unauthorized disclosure of Confidential Information, upon noticed 27 || motion of contempt filed by the Designating Party, counsel for the Receiving Party 28 LLP -10-

1 || may be required to file the signed Nondisclosure Agreements, as well as a list of the 2 || disclosed materials, in camera with the Court having jurisdiction of the Stipulation. 3 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 4 PRODUCED IN OTHER LITIGATION 5 Ifa Party is served with a subpoena or a court order issued in other litigation 6 || that 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 9 || notification shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or 11 || order to issue in the other litigation that some or all of the material covered by the 12 || subpoena or order is subject to this Protective Order. Such notification shall include 13 || a copy of this 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 The Party served with the subpoena or court order shall not produce any 17 || information designated in this action as “CONFIDENTIAL” before a determination 18 || by the court from which the subpoena or order issued, unless the Party has obtained 19 || the Designating Party’s permission, or unless otherwise required by the law or court 20 || order. The Designating Party shall bear the burden and expense of seeking 21 || protection in that court of its confidential material and nothing in these provisions 22 || should be construed as authorizing or encouraging a Receiving Party in this Action 23 || to disobey a lawful directive from another court. 24 || 9. A 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 27 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 28 || information produced by Non-Parties in connection with this litigation is protected LLP --

1 || by the remedies and relief provided by this Order. Nothing in these provisions 2 || should be construed as prohibiting a Non-Party from seeking additional protections. 3 (b) Inthe event that a Party is required, by a valid discovery 4 || request, to produce a Non-Party’s confidential information in its possession, and the 5 || Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 6 || confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the 8 || Non-Party that some or all of the information requested is subject to a 9 || confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the 11 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a 12 || reasonably specific description of the information requested; and 13 (3) make the information requested available for inspection 14 || by the Non-Party, if requested. 15 (c) Ifthe Non-Party fails to seek a protective order from this court 16 || within 14 days of receiving the notice and accompanying information, the 17 || Receiving Party may produce the Non-Party’s confidential information responsive 18 || to the discovery request. If the Non-Party timely seeks a protective order, the 19 || Receiving Party shall not produce any information in its possession or control that 20 || is subject to the confidentiality agreement with the Non-Party before a 21 || determination by the court unless otherwise required by the law or court order. 22 || Absent a court order to the contrary, the Non-Party shall bear the burden and 23 || expense of seeking protection in this court of its Protected Material. 24 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 || Protected Material to any person or in any circumstance not authorized under this 27 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 || writing the Designating Party of the unauthorized disclosures, (b) use its best LLP -12-

1 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 2 || person or persons to whom unauthorized disclosures were made of all the terms of 3 || this Order, and (d) request such person or persons to execute the “Acknowledgment 4 || and Agreement to Be Bound” that is attached hereto as Exhibit A. 5 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 || inadvertently produced material is subject to a claim of privilege or other 9 || protection, the obligations of the Receiving Parties are those set forth in Federal 10 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 11 || whatever procedure may be established in an e-discovery order that provides for 12 || production without prior privilege review. Pursuant to Federal Rule of Evidence 13 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 14 || of a communication or information covered by the attorney-client privilege or work 15 || product protection, the parties may incorporate their agreement in the stipulated 16 || protective order submitted to the court. 17 | 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of 19 || any person to seek its modification by the Court in the future. 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 Local Civil Rule 79-5. Protected Material 28 || may only be filed under seal pursuant to a court order authorizing the sealing of the

1 || specific Protected Material at issue. If a Party’s request to file Protected Material 2 || under seal is denied by the court, then the Receiving Party may file the information 3 || in the public record unless otherwise instructed by the court. 13. FINAL DISPOSITION 5 After the FINAL DISPOSITION of this Action, as defined in paragraph 2.8, 6 || within 30 days of a written request by the Designating Party, each Receiving Party 7 || must return all Protected Material to the Producing Party. As used in this 8 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 || summaries, and any other format reproducing or capturing any of the Protected 10 || Material. The Receiving Party must submit a written certification to the Producing 11 || Party (and, if not the same person or entity, to the Designating Party) by the 30 day 12 || deadline that (1) identifies (by category, where appropriate) all the Protected 13 || Material that was returned and (2) affirms that the Receiving Party has not retained 14 || any copies, abstracts, compilations, summaries or any other format reproducing or 15 || capturing any of the Protected Material. 16 | 14. VIOLATION 17 Any violation of this Order may be punished by appropriate measures 18 || including, without limitation, contempt proceedings and/or monetary sanctions. 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 20 21 || Dated: September 17, 2021 WILLIAMS & SEEMEN 22 23 By: /s/ Bart A. Seemen 24 Attorneys for Plaintiff STEVEN WALPERT 26 27 28

1 || Dated: September 17, 2021 BURKE, WILLIAMS & SORENSEN, 2 3 By:_/s/ Charles E. Slyngstad 4 Charles E. Slyngstad Attorneys for Defendant CITY OF 5 LOS ANGELES 6 7 8 Having considered the papers and finding that good cause exists, the Parties’ 9 Stipulated Protective Order is granted as modified. 10 IT IS SO ORDERED. 11 12 /s/ 13 || Dated: October 12, 2021 Honorable Jacqueline Chooljian UNITED STATES MAGISTRATE JUDGE 14 15 16 17 18 19 20 21 22 23 24 25 26 27 ||}. —— ' Filer attests that all signatories listed concur in the filing’s content and have 28 || authorized the filing pursuant to Local Rule 5-4.3.4(a)(2)(i). E, WILLIAMS & DED -15-

1 ATTACHMENT “A” 2 NONDISCLOSURE AGREEMENT 3 I, do solemnly swear that I am fully familiar with 4 || the terms of the Protective Order entered in Steven Walpert v. City of Los Angeles, 5 || et al., United States District Court for the Central District of California, Central 6 || Division, Case No. 2:21-cv-01259 FMO-JC, and hereby agree to comply with and 7 || be bound by the terms and conditions of said Order. I hereby consent to the 8 || jurisdiction of the United States District Court for the Central District of California 9 || for purposes of enforcing this Order. 10 Dated: Signed: 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LLP -16-