1 2 3 4 5 6 7 8 THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 Shannon Welch, Case No. 1:22-cv-00755-ADA-HBK 12 Plaintiff, APPROVED STIPULATED 13 PROTECTIVE ORDER vs. 14 15 COUNTY OF TULARE; NICHOLAS SANDOVAL; HECTOR 16 RODRIGUEZ; DAVID RANDOLPH; and DOES 1-10, inclusive, 17 Defendants. 18

19 20 1. A. 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 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 4 B. GOOD CAUSE STATEMENT 5 Defendant County of Tulare, acting by and through the Tulare County 6 Sheriff’s Office (TCSO), may be producing documents that contain information 7 that is unavailable to the public and/or privileged or otherwise protected from 8 disclosure under state or federal statues, court rules, case decisions, or common 9 law. Defendants may also be producing documents that contain personal and 10 confidential information regarding individuals which information is unavailable to 11 the public, including peace officer personnel records and records related to third 12 parties. 13 Accordingly, to expedite the flow of information, to facilitate the prompt 14 resolution of disputes over confidentiality of discovery materials, to adequately 15 protect information the parties are entitled to keep confidential, to ensure that the 16 parties are permitted reasonable necessary uses of such material in preparation for 17 and in the conduct of trial, to address their handling at the end of the litigation, and 18 serve the ends of justice, a protective order for such information is justified in this 19 matter. It is the intent of the parties that information will not be designated as 20 confidential for tactical reasons and that nothing be so designated without a good 21 faith belief that it has been maintained in a confidential, non-public manner, and 22 there is good cause why it should not be part of the public record of this case. 23 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 24 The parties further acknowledge, as set forth in Section 12.3, below, that this 25 Stipulated Protective Order does not entitle them to file confidential information 26 under seal; Civil Local Rules 141, 141.1(e) set forth the procedures that must be 27 followed and the standards that will be applied when a party seeks permission from 28 the court to file material under seal. 1 There is a strong presumption that the public has a right of access to 2 judicial proceedings and records in civil cases. In connection with non-dispositive 3 motions, good cause must be shown to support a filing under seal. See Kamakana 4 v. City and Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. 5 Ests. of Byrd v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), 6 Makar-Welbon v. Sony Elecs., Inc.,

(E.D. Wis. 1999) (even 7 stipulated protective orders require good cause showing), and a specific showing 8 of good cause or compelling reasons with proper evidentiary support and legal 9 justification, must be made with respect to Protected Material that a party seeks to 10 file under seal. The parties’ mere designation of Disclosure or Discovery Material 11 as CONFIDENTIAL does not—without the submission of competent evidence by 12 declaration, establishing that the material sought to be filed under seal qualifies as 13 confidential, privileged, or otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, 15 then compelling reasons, not only good cause, for the sealing must be shown, and 16 the relief sought shall be narrowly tailored to serve the specific interest to be 17 protected. See Pintos v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 18 2010). For each item or type of information, document, or thing sought to be filed 19 or introduced under seal in connection with a dispositive motion or trial, the party 20 seeking protection must articulate compelling reasons, supported by specific facts 21 and legal justification, for the requested sealing order. Again, competent evidence 22 supporting the application to file documents under seal must be provided by 23 declaration. 24 Any document that is not confidential, privileged, or otherwise protectable in 25 its entirety will not be filed under seal if the confidential portions can be redacted. 26 If documents can be redacted, then a redacted version for public viewing, omitting 27 only the confidential, privileged, or otherwise protectable portions of the document, 28 1 shall be filed. Any application that seeks to file documents under seal in their 2 entirety should include an explanation of why redaction is not feasible. 3 4 2. DEFINITIONS 5 2.1 Action: Shannon Welch v. County of Tulare, et al., United States District 6 Court for the Eastern District of California case number 1:22-cv-00755-ADA-HBK. 7 2.2 Challenging Party: a Party or Non-Party that challenges the designation 8 of information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 10 how it is generated, stored or maintained) or tangible things that qualify for 11 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 12 the Good Cause Statement, including: police investigatory records, i.e., evidence 13 gathered in and for the sole purpose of a criminal investigation, personal 14 information of police officers, identity of complaining witnesses, medical, financial, 15 or other federally protected information . 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 17 support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless of 22 the medium or manner in which it is generated, stored, or maintained (including, 23 among other things, testimony, transcripts, and tangible things), that are produced 24 or generated in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as 27 an expert witness or as a consultant in this Action. 2.8 Final Disposition: the later of (1) dismissal of all claims and 28 1 defenses in this Action, with or without prejudice; and (2) final judgment 2 herein after the completion and exhaustion of all appeals, rehearings, 3 remands, trials, or reviews of this Action, including the time limits for 4 filing any motions or applications for extension of time pursuant to 5 applicable law. 6 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 7 In-House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.10 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.11 Outside Counsel of Record: attorneys who are not employees of a party 12 to this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm 14 which has appeared on behalf of that party, and includes support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 28 1 2 3. SCOPE 3 The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or 5 extracted from Protected Material; (2) all copies, excerpts, summaries, or 6 compilations of Protected Material; and (3) any testimony, conversations, or 7 presentations by Parties or their Counsel that might reveal Protected Material. 8 However, the protections conferred by this Stipulation and its associated Order do 9 not cover the following information: (a) any information that is in the public 10 domain at the time of disclosure to a Receiving Party or becomes part of the public 11 domain after its disclosure to a Receiving Party as a result of publication not 12 involving a violation of this Order, including becoming part of the public record 13 through trial or otherwise; and (b) any information known to the Receiving Party 14 prior to the disclosure or obtained by the Receiving Party after the disclosure from a 15 source who obtained the information lawfully and under no obligation of 16 confidentiality to the Designating Party. 17 Any use of Protected Material at trial shall be governed by the orders of the 18 trial judge. This Order does not govern the use of Protected Material at trial. 19 20 4. DURATION 21 Even after final disposition of this litigation, the confidentiality obligations 22 imposed by this Order shall remain in effect until a Designating Party agrees 23 otherwise in writing or a court order otherwise directs. Final disposition shall be 24 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 25 with or without prejudice; and (2) final judgment herein after the completion and 26 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 27 including the time limits for filing any motions or applications for extension of time 28 pursuant to applicable law. 1 2 5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for Protection. 4 Each Party or Non-Party that designates information or items for protection 5 under this Order must take care to limit any such designation to specific material 6 that qualifies under the appropriate standards. The Designating Party must 7 designate for protection only those parts of material, documents, items, or oral or 8 written communications that qualify so that other portions of the material, 9 documents items, or communications for which protection is not warranted are not 10 swept unjustifiably within the ambit of this Order. 11 Mass, indiscriminate, or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper 13 purpose (e.g., to unnecessarily encumber the case development process or to 14 impose unnecessary expenses and burdens on other parties) may expose the 15 Designating Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in this 20 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 22 under this Order must be clearly so designated before the material is disclosed or 23 produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic documents, 26 but excluding transcripts of depositions or other pretrial or trial proceedings), that 27 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 28 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 1 material. If only a portion or portions of the material on a page qualifies for 2 protection, the Producing Party also must clearly identify the protected portion(s) 3 by making appropriate markings in the margins. 4 A Party or Non-Party that makes original documents available for inspection 5 need not designate them for protection until after the inspecting Party has indicated 6 which documents it would like copied and produced. During the inspection and 7 before the designation, all of the material made available for inspection shall be 8 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 9 documents it wants copied and produced, the Producing Party must determine 10 which documents, or portions thereof, qualify for protection under this Order. Then, 11 before producing the specified documents, the Producing Party must affix the 12 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 13 portion or portions of the material on a page qualifies for protection, the Producing 14 Party also must clearly identify the protected portion(s) (e.g., by making 15 appropriate markings in the margins). 16 (b) for testimony given in depositions, that the Designating Party identify the 17 Disclosure or Discovery Material on the record, before the close of the deposition 18 all protected testimony. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants 23 protection, the Producing Party, to the extent practicable, shall identify the 24 protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive 27 the Designating Party’s right to secure protection under this Order for such 28 material. Upon timely correction of a designation, the Receiving Party must make 1 reasonable efforts to assure that the material is treated in accordance with the 2 provisions of this Order. 3 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 designation of confidentiality at any time that is consistent with the Court’s 7 Scheduling Order. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 9 resolution process under Local Rule 37.1 et seq. 10 6.3 The burden of persuasion in any such challenge proceeding shall be on 11 the Designating Party. Frivolous challenges, and those made for an improper 12 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 13 parties) may expose the Challenging Party to sanctions. Unless the Designating 14 Party has waived or withdrawn the confidentiality designation, all parties shall 15 continue to afford the material in question the level of protection to which it is 16 entitled under the Producing Party’s designation until the Court rules on the 17 challenge. 18 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this 22 Action only for prosecuting, defending, or attempting to settle this Action. Such 23 Protected Material may be disclosed only to the categories of persons and under the 24 conditions described in this Order. When the Action has been terminated, a 25 Receiving Party must comply with the provisions of section 13 below (FINAL 26 DISPOSITION). 27 Protected Material must be stored and maintained by a Receiving Party at a 28 location and in a secure manner that ensures that access is limited to the persons 1 authorized under this Order. 2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 otherwise ordered by the court or permitted in writing by the Designating Party, a 4 Receiving Party may disclose any information or item designated 5 “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 7 as employees of said Outside Counsel of Record to whom it is reasonably necessary 8 to disclose the information for this Action; 9 (b) the officers, directors, and employees (including In-House Counsel) of 10 the Receiving Party to whom disclosure is reasonably necessary for this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to whom 12 disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff; 16 (f) professional jury or trial consultants, mock jurors, and Professional 17 Vendors to whom disclosure is reasonably necessary for this Action and who have 18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the information; 21 (h) during their depositions, witnesses, and attorneys for witnesses, in the 22 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 23 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 24 will not be permitted to keep any confidential information unless they sign the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 26 agreed by the Designating Party or ordered by the court. Pages of transcribed 27 deposition testimony or exhibits to depositions that reveal Protected Material may 28 be separately bound by the court reporter and may not be disclosed to anyone 1 except as permitted under this Stipulated Protective Order; and 2 (i) any mediator or settlement officer, and their supporting personnel, 3 mutually agreed upon by any of the parties engaged in settlement discussions. 4 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 6 OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification shall include 15 a copy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 the subpoena or court order shall not produce any information designated in this 20 action as “CONFIDENTIAL” before a determination by the court from which the 21 subpoena or order issued, unless the Party has obtained the Designating Party’s 22 permission. The Designating Party shall bear the burden and expense of seeking 23 protection in that court of its confidential material and nothing in these provisions 24 should be construed as authorizing or encouraging a Receiving Party in this Action 25 to disobey a lawful directive from another court. 26 /// 27 28 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION 3 (a) Application. The terms of this Order are applicable to information 4 produced by a Non- Party in this Action and designated as “CONFIDENTIAL.” 5 Such information produced by Non-Parties in connection with this litigation is 6 protected by the remedies and relief provided by this Order. Nothing in these 7 provisions should be construed as prohibiting a Non-Party from seeking additional 8 protections. 9 (b) Notification. In the event that a Party is required, by a valid discovery 10 request, to produce a Non-Party’s confidential information in its possession, and the 11 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 12 confidential information, then the Party shall: 13 (1) promptly notify in writing the Requesting Party and the Non-Party 14 that some or all of the information requested is subject to a confidentiality 15 agreement with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated 17 Protective Order in this Action, the relevant discovery request(s), and a reasonably 18 specific description of the information requested; and 19 (3) make the information requested available for inspection by the 20 Non-Party, if requested. 21 (c) If the Non-Party fails to seek a protective order from this court within 14 22 days of receiving the notice and accompanying information, the Receiving Party 23 may produce the Non-Party’s confidential information responsive to the discovery 24 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 25 not produce any information in its possession or control that is subject to the 26 confidentiality agreement with the Non-Party before a determination by the court. 27 Absent a court order to the contrary, the Non-Party shall bear the burden and 28 expense of seeking protection in this court of its Protected Material. 1 2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 4 Protected Material to any person or in any circumstance not authorized under this 5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 6 writing the Designating Party of the unauthorized disclosures, (b) use its best 7 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 8 person or persons to whom unauthorized disclosures were made of all the terms of 9 this Order, and (d) request such person or persons to execute the “Acknowledgment 10 and Agreement to Be Bound” that is attached hereto as Exhibit A. 11 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 25 12. MISCELLANEOUS 26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 27 person to seek its modification by the Court in the future. 28 12.2 Right to Assert Other Objections. By stipulating to the entry of this 1 Protective Order no Party waives any right it otherwise would have to object to 2 disclosing or producing any information or item on any ground not addressed in 3 this Stipulated Protective Order. Similarly, no Party waives any right to object on 4 any ground to use in evidence of any of the material covered by this Protective 5 Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Civil Local Rules 141, 141.1(e). Protected 8 Material may only be filed under seal pursuant to a court order authorizing the 9 sealing of the specific Protected Material at issue. If a Party’s request to file 10 Protected Material under seal is denied by the court, then the Receiving Party may 11 file the information in the public record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 4, within 60 14 days of a written request by the Designating Party, each Receiving Party must 15 return all Protected Material to the Producing Party or destroy such material. As 16 used in this subdivision, “all Protected Material” includes all copies, abstracts, 17 compilations, summaries, and any other format reproducing or capturing any of the 18 Protected Material. Whether the Protected Material is returned or destroyed, the 19 Receiving Party must submit a written certification to the Producing Party (and, if 20 not the same person or entity, to the Designating Party) by the 60 day deadline that 21 (1) identifies (by category, where appropriate) all the Protected Material that was 22 returned or destroyed and (2) affirms that the Receiving Party has not retained any 23 copies, abstracts, compilations, summaries or any other format reproducing or 24 capturing any of the Protected Material. Notwithstanding this provision, Counsel 25 are entitled to retain an archival copy of all pleadings, motion papers, trial, 26 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 27 and trial exhibits, expert reports, attorney work product, and consultant and expert 28 work product, even if such materials contain Protected Material. Any such archival 1 | copies that contain or constitute Protected Material remain subject to this Protective 2 | Order as set forth in Section 4 (DURATION). 3 | 14. VIOLATION OF ORDER 4 Any violation of this Order may be punished by any and all appropriate 5 | measures including, without limitation, contempt proceedings and/or monetary 6 | sanctions. 7 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 Dated: August 2_, 2023 Respectfully submitted, 1] JENNIFER M. FLORES D County counsel for the County of Tulare 3 /s/ Amy I. Myers (authorized on 8/2/202. AMY I. MYERS 14 Deputy County Counsel Attorneys for Defendants 15 County of Tulare, Nicholas Sandoval, Hector Rodriguez, and David 16 Randolph. 17 Dated: August 2, 2023 LAW OFFICES OF DALE K. GALIPO 18 CHAIN |COHN | CLARK 19 /s/ RANHEE LEE 20 DALE K. GALIPO RANHEE LEE 21 MATTHEW C. CLARK 99 Attorneys for Plaintiff Shannon Welch 23 34 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25 | Dated: _ August 2, 2023 oe Uh. Sareh Bactte HELENA M. BARCH-KUCHTA 26 U.S. MAGISTRATE JUDGE 27 28 15

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 ____________________________________________ [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Eastern District of California on ____________[date] in the case of Shannon 8 Welch v. County of Tulare, et al., United States District Court for the Eastern 9 District of California case number 1:22-cv-00755-ADA-HBK. I agree to comply 10 with and to be bound by all the terms of this Stipulated Protective Order and I 11 understand and acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I will not 13 disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Eastern District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint __________________________ [print 20 or type full name] of _______________________________________ [print or type 21 full address and telephone number] as my California agent for service of process in 22 connection with this action or any proceedings related to enforcement of this 23 Stipulated Protective Order. 24 Date: _________________ __________________________________ 25 [signature] 26 27 __________________________________[ 28 [City and State where sworn]_