Gabriel Martinez v. Prime Source Building Products Inc.

United States District Court for the Central District of California

Gabriel Martinez v. Prime Source Building Products Inc.

Trial Court Opinion

1 Richard C. Moreno (SBN 190869) [email protected] 2 Todd G. Lezon (SBN 283141) [email protected] 3 MURCHISON & CUMMING, LLP 801 South Grand Avenue, Ninth Floor 4 Los Angeles, California 90017-4613 Telephone: (213) 623-7400 5 Facsimile: (213) 623-6336 6 Attorneys for Third-Party Defendant, SCHNEIDER NATIONAL CARRIERS, 7 INC. 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 10 11 GABRIEL MARTINEZ, CASE NO. 2:23-CV-08125-SPG-SSC 12 Plaintiff, STIPULATED PROTECTIVE 13 ORDER vs. 14 PRIME SOURCE BUILDING Honorable Sherilyn Peace Garnett, 15 PRODUCTS, INC.; PARK RIVER Judge of the United States District HOLDINGS, INC.; SCHNEIDER Court 16 NATIONAL CARRIERS, INC.; and DOES 1 to 100, inclusive, 17 Trial Date: April 22, 2025 Defendants. 18 19 PRIME SOURCE BUILDING PRODUCTS INC. and PARK RIVER 20 HOLDINGS, INC.,, 21 Third Party Plaintiff, 22 vs. 23 SCHNEIDER NATIONAL CARRIERS, INC. and Roes 1 to 50, 24 Inclusive, 25 Third Party Defendant. 26 27 1 The parties, Plaintiff, GABRIEL MARTINEZ ("Plaintiff") and Third-Party 2 Defendant, SCHNEIDER NATIONAL CARRIERS, INC. ("Third-Party Defendant") by 3 their respective counsel, hereby agree to this Stipulation of Confidentiality and Protective 4 Order (this "Order"). To expedite the flow of discovery material, facilitate the prompt 5 resolution of disputes over confidentiality, protect material entitled to be kept 6 confidential, and ensure that protection is afforded only to material entitled to such 7 treatment, the parties agree as follows: 8 9 I. Introduction 10 1.1 Purposes and Limitations. Discovery in this action is likely to involve 11 production of confidential, proprietary, or private information for which special 12 protection from public disclosure and from use for any purpose other than prosecuting 13 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition 14 the court to enter the following Stipulated Protective Order. The parties acknowledge that 15 this Order does not confer blanket protections on all disclosures or responses to discovery 16 and that the protection it affords from public disclosure and use extends only to the limited 17 information or items that are entitled to confidential treatment under the applicable legal 18 principles. 19 1.2 Good Cause Statement. This action is likely to involve customer and pricing 20 lists and other valuable research, development, commercial, financial, technical and/or 21 proprietary information for which special protection from public disclosure and from use 22 for any purpose other than prosecution of this action is warranted. Such confidential and 23 proprietary materials and information consist of, among other things, confidential 24 business or financial information, information regarding confidential business practices, 25 or other confidential research, development, or commercial information (including 26 information implicating privacy rights of third parties), information otherwise generally 27 unavailable to the public, or which may be privileged or otherwise protected from 1 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 2 of disputes over confidentiality of discovery materials, to adequately protect information 3 the parties are entitled to keep confidential, to ensure that the parties are permitted 4 reasonable necessary uses of such material in preparation for and in the conduct of trial, 5 to address their handling at the end of the litigation, and serve the ends of justice, a 6 protective order for such information is justified in this matter. It is the intent of the 7 parties that information will not be designated as confidential for tactical reasons and 8 that nothing be so designated without a good faith belief that it has been maintained in a 9 confidential, non-public manner, and there is good cause why it should not be part of the 10 public record of this case. 11 1.3 Acknowledgement of Procedure for Filing Under Seal. The parties further 12 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 13 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 14 forth the procedures that must be followed and the standards that will be applied when a 15 party seeks permission from the court to file material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, good 18 cause must be shown to support a filing under seal. See Kamakana v. City and Cnty. of 19 Honolulu,

447 F.3d 1172

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. 20 Motors Corp.,

307 F.3d 1206

, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., 21 Inc.,

187 F.R.D. 576, 577

(E.D. Wis. 1999) (even stipulated protective orders require good 22 cause showing), and a specific showing of good cause or compelling reasons with proper 23 evidentiary support and legal justification, must be made with respect to Protected 24 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure 25 or Discovery Material as CONFIDENTIAL does not— without the submission of 26 competent evidence by declaration, establishing that the material sought to be filed under 27 seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the relief 3 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 4 v. Pac. Creditors Ass’n,

605 F.3d 665

, 677–79 (9th Cir. 2010). For each item or type of 5 information, document, or thing sought to be filed or introduced under seal in connection 6 with a dispositive motion or trial, the party seeking protection must articulate compelling 7 reasons, supported by specific facts and legal justification, for the requested sealing 8 order. Again, competent evidence supporting the application to file documents under 9 seal must be provided by declaration. 10 Any document that is not confidential, privileged, or otherwise protectable in its 11 entirety will not be filed under seal if the confidential portions can be redacted. If 12 documents can be redacted, then a redacted version for public viewing, omitting only 13 the confidential, privileged, or otherwise protectable portions of the document, shall be 14 filed. Any application that seeks to file documents under seal in their entirety should 15 include an explanation of why redaction is not feasible. 16 17 2. Definitions 18 2.1 Action: this pending federal lawsuit. 19 2.2 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information 22 (regardless of how it is generated, stored or maintained) or tangible things that qualify 23 for protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as 24 specified above in the Good Cause Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as 26 well as their support staff). 27 2.5 Designating Party: a Party or Non-Party that designates information or items that 1 2.6 Disclosure or Discovery Material: all items or information, 2 regardless of the medium or manner in which it is generated, stored, or maintained 3 (including, among other things, testimony, transcripts, and tangible things), that are 4 produced or generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in 6 a matter pertinent to the litigation who has been retained by a Party or its counsel to 7 serve as an expert witness or as a consultant in this Action. 8 2.8 Final Disposition: the later of (1) dismissal of all claims and 9 defenses in this Action, with or without prejudice; and (2) final judgment herein after 10 the completion and exhaustion of all appeals, re-hearings, remands, trials, or reviews 11 of this Action, including the time limits for filing any motions or applications for 12 extension of time pursuant to applicable law. 13 2.9 In-House Counsel: attorneys who are employees of a party to 14 this Action. In-House Counsel does not include Outside Counsel of Record or any 15 other outside counsel. 16 2.10 Non-Party: any natural person, partnership, corporation, association, or other 17 legal entity not named as a Party to this action. 18 2.11 Outside Counsel of Record: attorneys who are not employees of a party to this 19 Action but are retained to represent or advise a party to this Action and have appeared 20 in this Action on behalf of that party or are affiliated with a law firm which has 21 appeared on behalf of that party, and includes support staff. 22 2.12 Party: any party to this Action, including all of its officers, directors, employees, 23 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 24 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 25 Material in this Action. 26 2.14 Professional Vendors: persons or entities that provide litigation- support services 27 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, 1 and organizing, storing, or retrieving data in any form or medium) and their

2 employees and subcontractors.

3 2.15 Protected Material: any Disclosure or Discovery Material that is designated as 4 “CONFIDENTIAL.” 5 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material from a 6 Producing Party. 7 8 III. Scope 9 The protections conferred by this Stipulation and Order cover not only Protected 10 Material (as defined above), but also (1) any information copied or extracted from 11 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 12 Material; and (3) any testimony, conversations, or presentations by Parties or their 13 Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the trial 15 judge. This Stipulated Protective Order does not govern the use of Protected Material 16 at trial. 17 18 IV. Trial and Duration 19 The terms of this Stipulated Protective Order apply through Final Disposition of 20 the Action. 21 Once a case proceeds to trial, information that was designated as 22 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used 23 or introduced as an exhibit at trial becomes public and will be presumptively available 24 to all members of the public, including the press, unless compelling reasons supported 25 by specific factual findings to proceed otherwise are made to the trial judge in advance 26 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” 27 showing for sealing documents produced in discovery from “compelling reasons” 1 such materials, the terms of this Stipulated Protective Order do not extend beyond the 2 commencement of the trial. 3 Even after Final Disposition of this litigation, the confidentiality obligations 4 imposed by this Stipulated Protective Order shall remain in effect until a Designating 5 Party agrees otherwise in writing or a court order otherwise directs. 6 7 V. Designating Protected Material 8 5.1 Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Non-Party that designates information or items for protection under this 10 Order must take care to limit any such designation to specific material that qualifies 11 under the appropriate standards. The Designating Party must designate for protection 12 only those parts of material, documents, items, or oral or written communications that 13 qualify so that other portions of the material, documents, items, or communications 14 for which protection is not warranted are not swept unjustifiably within the ambit of 15 this Order. 16 Mass, indiscriminate, or routinized designations are prohibited. Designations 17 that are shown to be clearly unjustified or that have been made for an improper 18 purpose (e.g., to unnecessarily encumber the case development process or to impose 19 unnecessary expenses and burdens on other parties) may expose the Designating Party 20 to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 designated for protection do not qualify for protection, that Designating Party must 23 promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2 Manner and Timing of Designations. Except as otherwise provided in this 25 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or 26 as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 27 protection under this Stipulated Protective Order must be clearly so designated before 1 Designation in conformity with this Stipulated Protective Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and before 11 the designation, all of the material made available for inspection shall be deemed 12 CONFIDENTIAL. After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or 14 portions thereof, qualify for protection under this Stipulated Protective Order. Then, 15 before producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 17 portion or portions of the material on a page 18 qualifies for protection, the Producing Party also must clearly identify the protected 19 portion(s) (e.g., by making appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identify the 21 Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. 23 (c) for information produced in some form other than 24 documentary and for any other tangible items, that the Producing Party affix in a 25 prominent place on the exterior of the container or containers in which the information 26 is stored the “CONFIDENTIAL” legend. If only a portion or portions of the 27 information warrants protection, the Producing Party, to the extent practicable, shall 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 2 designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. Upon 4 timely correction of a designation, the Receiving Party must make reasonable efforts 5 to assure that the material is treated in accordance with the provisions of this Stipulated 6 Protective Order. 7 8 VI. Challenging Confidentiality Designations 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 10 confidentiality at any time that is consistent with the court’s Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 12 process under Local Rule 37.1 et seq. and with Section 2 of Judge Christensen’s Civil 13 Procedures titled “Brief Pre-Discovery Motion Conference.”2 14 6.3 The burden of persuasion in any such challenge proceeding shall be on the 15 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 16 to harass or impose unnecessary expenses and burdens on other parties) may expose 17 the Challenging Party to sanctions. Unless the Designating Party has waived or 18 withdrawn the confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the court rules on the challenge. 21 22 VII. Access To And Use Of Protected Material 23 7.1 Basic Principles. A Receiving Party may use Protected 24 Material that is disclosed or produced by another Party or by a Non-Party in connection 25 with this Action only for prosecuting, defending, or attempting to settle this Action. 26 Such Protected Material may be disclosed only to the categories of persons and under 27 the conditions described in this Order. When the Action reaches a Final Disposition, a 1 Protected Material must be stored and maintained by a Receiving Party at a location 2 and in a secure manner that ensures that access is limited to the persons authorized 3 under this Stipulated Protective Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only: 8 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well 9 as employees of said Outside Counsel of Record to whom it is reasonably 10 necessary to disclose the information for this Action; 11 (b) to the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) to Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) to the court and its personnel; 17 (e) to court reporters and their staff; 18 (f) to professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who 20 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) to the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary, provided: (1) the deposing 25 party requests that the witness sign the “Acknowledgment and Agreement to Be 26 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any 27 confidential information unless they sign the “Acknowledgment and Agreement 1 ordered by the court. Pages of transcribed deposition testimony or exhibits to 2 depositions that reveal Protected Material may be separately bound by the court 3 reporter and may not be disclosed to anyone except as permitted under this 4 Stipulated Protective Order; and 5 (i) to any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 8 VIII. Protected Material Subpoenaed Or Ordered Produced In Other 9 Litigation 10 If a Party is served with a subpoena or a court order issued in other litigation that 11 compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification shall 14 include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the 17 subpoena or order is subject to this Protective Order. Such notification shall 18 include a copy of this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 the subpoena or court order shall not produce any information designated in this 23 action as “CONFIDENTIAL” before a determination by the court from which 24 the subpoena or order issued, unless the Party has obtained the Designating 25 Party’s permission. The Designating Party shall bear the burden and expense of 26 seeking protection in that court of its confidential material and nothing in these 27 provisions should be construed as authorizing or encouraging a Receiving Party 1 2 IX. A Non-Party's Protected Material Sought To Be Produced In This 3 Litigation 4 9.1 Application. The terms of this Stipulated Protective Order are applicable to 5 information produced by a Non-Party in this Action and designated as 6 “CONFIDENTIAL.” Such information produced by Non-Parties in connection 7 with this litigation is protected by the remedies and relief provided by this Order. 8 Nothing in these provisions should be construed as prohibiting a Non-Party from 9 seeking additional protections. 10 9.2 Notification. In the event that a Party is required, by a valid discovery request, 11 to produce a Non-Party’s confidential information in its possession, and the 12 Party is subject to an agreement with the Non-Party not to produce the Non- 13 Party’s confidential information, then the Party shall: 14 (a) 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 (b) make the information requested available for inspection by the Non-Party, 18 if requested. 19 9.3 Conditions of Production. If the Non-Party fails to seek a protective order from 20 this court within 14 days of receiving the notice and accompanying information, the 21 Receiving Party may produce the Non-Party’s confidential information responsive to 22 the discovery request. If the Non-Party timely seeks a protective order, the Receiving 23 Party shall not produce any information in its possession or control that is subject to 24 the confidentiality agreement with the Non-Party before a determination by the court. 25 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 26 of seeking protection in this court of its Protected Material. 27 1 X. Unauthorized Disclosure Of Protected Material 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) 8 request such person or persons to execute the “Acknowledgment and Agreement to Be 9 Bound”. 10 11 XI. Inadvertent Production Of Privileged Or Otherwise Protected Material 12 When a Producing Party gives notice to Receiving Parties that certain inadvertently 13 produced material is subject to a claim of privilege or other protection, the obligations 14 of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the Federal Rules of 15 Civil Procedure. This provision is not intended to modify whatever procedure may be 16 established in an e-discovery order that provides for production without prior privilege 17 review. Pursuant to Rules 502(d) and (e) of the Federal Rules of Evidence, insofar as 18 the parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the court. 22 23 XII. Miscellaneous 24 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order abridges the 25 right of any person to seek its modification by the court in the future. 26 12.2 Right to Assert Other Objections. By stipulating to the entry of this Stipulated 27 Protective Order no Party waives any right it otherwise would have to object to 1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Stipulated Protective 3 Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 5 Material must comply with Local Rule 79-5. Protected Material may only be filed 6 under seal pursuant to a court order authorizing the sealing of the specific Protected 7 Material at issue. If a Party's request to file Protected Material under seal is denied by 8 the court, then the Receiving Party may file the information in the public record unless 9 otherwise instructed by the court. 10 11 XIII. 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 return 14 all Protected Material to the Producing Party or destroy such material. As used in this 15 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 18 must submit a written certification to the Producing Party (and, if not the same person 19 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 20 category, where appropriate) all the Protected Material that was returned or destroyed 21 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 22 compilations, summaries or any other format reproducing or capturing any of the 23 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 24 archival copy of all pleadings, motion papers, trial, deposition, and hearing 25 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 26 reports, attorney work product, and consultant and expert work product, even if such 27 materials contain Protected Material. Any such archival copies that contain or 1 || constitute Protected Material remain subject to this Protective Order as set forth in Section 4. 3 4 XIV. Violation 5 Any violation of this Stipulated Protective Order may be punished by any and 6 || all appropriate measures including, without limitation, contempt proceedings and/or 7|| monetary sanctions. 8 □□ ISSO STIPULATED. DATED: August 27, 2024 MURCHISON & CUMMING, LLP 11 12 By: /s/Todd G. Lezon B Richard C. Moreno Todd G. Lezon 14 Attorneys for Third-Party Defendant, SCHNEIDER NATIONAL CARRIERS, 15 INC. 16 DATED: Augusild 3024 LAW OFFICES OF GERALD L. MARCUS 18 19 | / By: We [set 7 20 Gerald L. Marcus 41 T. Vincent Consolo Attorneys for Plaintiff, GABRIEL 22 MARTINEZ 23 FOR GOOD CAUSE SHOWN, IT IS ORDERED. 24 25 || Dated: September 5, 2024

27 Hon. Stephanie S. Christensen 28 United States Magistrate Judge

Exhibit "A" 1 EXHIBIT A 2 AGREEMENT TO BE BOUND BY PROTECTIVE ORDER 3 I, ______________ [print or type full name], of _______ [print or type full 4 address], declare under penalty of perjury that I have read and understand the Protective 5 Order that was issued by the United States District Court-Central District of California, 6 on __________, 2024, in the case Gabriel Martinez vs. Prime Source Building 7 Products, Inc., et al., Court Case Number 2:23-cv-08125-SPG-SSC, I agree to comply 8 with, and be bound by, all the terms of the Protective Order and I understand and 9 acknowledge that failure to comply could expose me to court-imposed sanctions or 10 contempt. I promise that I will not disclose any information or documents that are 11 subject to the Protective Order except in strict compliance with the provisions of the 12 Protective Order. I further agree to submit to the jurisdiction of the United States 13 District Court-Central District of California, for the purposes of enforcing the terms of 14 the Protective Order, even if such enforcement proceedings occur after termination of 15 this case. 16 17 Printed name: _____________________________ 18 Physical address: __________________________ 19 Mailing address: __________________________ 20 Phone number: ___________________________ 21 Email Address: ___________________________ 22 Signature: _______________________________ 23 Date: ___________________________________ 24 25 26 27

Reference

Status
Unknown