1 JEMMA E. DUNN Nevada Bar No. 16891 2 MATTHEW T. HALE Nevada Bar No. 16880 3 MARIAN MASSEY Nevada Bar No. 14579 4 GREENBERG GROSS LLP 1980 Festival Plaza Drive, Suite 730 5 Las Vegas, Nevada 89135 Telephone: (702) 777-0888 6 Facsimile: (702) 777-0801 [email protected] 7 [email protected] [email protected] 8 Attorneys for Plaintiff Patricia Jancaterino 9 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 PATRICIA JANCATERINO, an individual, Case No.: 2:25-cv-00157-ART-DJA 13 14 Plaintiff, STIPULATED PROTECTIVE ORDER 15 v. 16 ENCOMPASS HEALTH REHABILITATION HOSPITAL OF LAS VEGAS, LLC, a 17 Delaware limited liability company, 18 Defendant. 19 20 21 STIPULATION FOR HIPAA QUALIFIED PROTECTIVE ORDER 22 IT IS HEREBY STIPULATED by and between PATRICIA JANCATERINO (“Plaintiff”) 23 and ENCOMPASS HEALTH REHABILITATION HOSPITAL OF LAS VEGAS, LLC 24 (collectively the “Parties”), by and through their respective counsel of record, that in order to 25 facilitate the exchange of information and documents which may be subject to confidential, 26 proprietary, trade secret, private, other individually identifiable health or medical-related 27 information, and/or confidential investigation records and related documentation for which special 1 protection from public disclosure and from use for any purpose other than prosecuting this litigation 2 may be warranted due to federal laws, state laws, and privacy rights, and in accordance with the 3 Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended by the Health 4 Information Technology for Economic and Clinical Health Act (HITECH Act), including all 5 applicable regulations issued by the Secretary of the United States Department of Health and Human 6 Services, including specifically

(e)(1), the Parties stipulate as follows: 7 1. Definitions. 8 In this Stipulation and Protective Order, the words set forth below shall have the following 9 meanings: 10 a. “Proceeding” means the above-entitled proceeding, Case No. 2:25-cv- 11 00157-ART-DJA. 12 b. “Court” means the Hon. Anne R. Traum, Hon. Daniel J. Albregts, or any 13 other judge to which this Proceeding may be assigned, including Court staff participating in 14 such proceedings. 15 c. “Confidential” means any information which is in the possession of a 16 Designating Party who believes in good faith that such information is entitled to confidential 17 treatment under applicable law. 18 d. “Confidential Materials” means any Documents, Testimony or Information 19 as defined below designated as “Confidential” pursuant to the provisions of this Stipulation 20 and Protective Order. 21 e. “Designating Party” means the Party that designates materials as 22 “Confidential.” 23 f. “Disclose” or “Disclosed” or “Disclosure” means to reveal, divulge, give, or 24 make available materials, or any part thereof, or any information contained therein. 25 g. “Documents” means any “writing,” “recording,” and “duplicate” as those 26 terms are defined by the Federal Rules of Evidence, Rule 1001. 27 h. “Information” means the content of Documents or Testimony. 1 or other legal entity not named as a Party to this Proceeding. 2 j. “Party” means any party to this action, including all of its officers, directors, 3 and employees, consultants, Experts, and all Outside Counsel. 4 k. “Producing Party” means a Party or Non-Party that produces Disclosure, 5 Documents, or Testimony in this Proceeding. 6 l. “Receiving Party” means a Party that receives Disclosure, Documents, or 7 Testimony from a Producing Party. 8 m. “Testimony” means all depositions, declarations or other testimony taken or 9 used in this Proceeding. 10 2. Scope. 11 a. The Designating Party shall have the right to designate as “Confidential” any 12 Documents, Testimony or Information that the Designating Party in good faith believes to 13 contain non-public information that is entitled to confidential treatment under applicable 14 law. 15 b. The protections conferred by this Stipulation and Protective Order cover not 16 only Confidential Materials (as defined above), but also (1) any confidential information 17 copied or extracted from Confidential Materials; (2) all copies, excerpts, summaries, or 18 compilations of Confidential Materials; and (3) any testimony, conversations, or 19 presentations by Parties or their counsel that might reveal Confidential Materials. However, 20 the protections conferred by this Stipulation and Protective Order do not cover the following 21 information: (a) any information that is in the public domain at the time of disclosure to a 22 Receiving Party or becomes part of the public domain after its disclosure to a Receiving 23 Party as a result of publication not involving a violation of this Order; and (b) any 24 information known to the Receiving Party prior to the disclosure or obtained by the 25 Receiving Party after the disclosure from a source who obtained the information lawfully 26 and under no obligation of confidentiality to the Designating Party. 27 c. The entry of this Stipulation and Protective Order does not alter, waive, 1 respect to the discovery of matters, including but not limited to any Party’s right to assert 2 the attorney-client privilege, the attorney work product doctrine, or other privileges, or any 3 Party’s right to contest any such assertion. 4 d. “Covered entities,” as defined by

are authorized to 5 disclose the protected health information, as defined by

and .501, of 6 Plaintiff to all attorneys in this action, and such protected health information shall only be 7 used in connection with this Proceeding, including any appeals. 8 3. Designating Confidential Material. 9 Except as otherwise provided in this Stipulated Protective Order, any Documents, Testimony 10 or Information to be designated as “Confidential” must be clearly so designated before the 11 Document, Testimony or Information is Disclosed or produced. The Parties may agree that the case 12 name and number are to be part of the “Confidential” designation. The “Confidential” designation 13 should not obscure or interfere with the legibility of the designated Information. 14 Designation in conformity with this Stipulated Protective Order requires: 15 a. For Documents (apart from transcripts of depositions or other pretrial or trial 16 proceedings), the Designating Party must affix the legend “Confidential” on each page of 17 any Document containing such designated Confidential Material. 18 b. For Testimony given in depositions the Designating Party may either: 19 i. identify on the record, before the close of the deposition, all 20 “Confidential” Testimony, by specifying all portions of the Testimony that qualify 21 as “Confidential;” or 22 ii. designate the entirety of the Testimony at the deposition as 23 “Confidential” (before the deposition is concluded) with the right to identify more 24 specific portions of the Testimony as to which protection is sought within 30 days 25 following receipt of the deposition transcript. In circumstances where portions of the 26 deposition Testimony are designated for protection, the transcript pages containing 27 “Confidential” Information may be separately bound by the court reporter, who must 1 Designating Party. 2 iii. For Testimony given in other pretrial or trial proceedings, the 3 Designating Party shall identify either on the record, before the close of the hearing 4 or other proceeding, or within 30 days of receipt of the transcript of the proceeding, 5 all protected testimony. In circumstances where portions of the pretrial or trial 6 proceedings Testimony are designated for protection, the transcript pages containing 7 “Confidential” Information may be separately bound by the court reporter, who must 8 affix to the top of each page the legend “Confidential,” as instructed by the 9 Designating Party. 10 c. For Information produced in some form other than Documents, and for any 11 other tangible items, including, without limitation, compact discs or DVDs, the Designating 12 Party must affix in a prominent place on the exterior of the container or containers in which 13 the Information or item is stored the legend “Confidential.” If only portions of the 14 Information or item warrant protection, the Designating Party, to the extent practicable, shall 15 identify the “Confidential” portions. 16 4. Designation of Documents Produced by Non-Parties. 17 a. Designation by Non-Party. Any Information that may be produced by a Non- 18 Party witness in discovery in the Proceeding pursuant to subpoena or otherwise may be 19 designated by such Non-Party as “Confidential” under the terms of this Stipulation and 20 Protective Order, and any such designation by a Non-party shall have the same force and 21 effect, and create the same duties and obligations, as if made by one of the undersigned 22 Parties hereto. Any such designation shall also function as consent by such Producing Party 23 to the authority of the Court in the Proceeding to resolve and conclusively determine any 24 motion or other application made by any person or party with respect to such designation, 25 or any other matter otherwise arising under this Stipulation and Protective Order. 26 b. Designation by Party. Any Party may designate as “CONFIDENTIAL” any 27 document that is produced or disclosed without such designation by any Non-Party within 1 writing), provided that such document contains Confidential Information which was not 2 redacted. 3 i. Parties to the Proceeding may designate such documents as 4 “CONFIDENTIAL” by sending written notice of such designation, accompanied by 5 copies of the designated document bearing the “CONFIDENTIAL” stamp, to all 6 other Parties in possession or custody of such previously undesignated document. 7 Any Party receiving such notice and copy of the designated document pursuant to 8 this subparagraph shall, within ten (10) calendar days of receipt of such notice (or 9 such other time as may be agreed in writing), either (a) destroy all undesignated 10 copies of such document in their custody or possession, or (b) alternately shall affix 11 the “CONFIDENTIAL” stamp to all copies of such designated document in their 12 custody or possession. 13 ii. Upon notice of designation pursuant to this paragraph, Parties shall 14 also: (i) make no further disclosure of such designated document or information 15 contained therein except as allowed under this Order; (ii) take reasonable steps to 16 notify any persons who were provided copies of such designated document of the 17 terms of this Order; and (iii) take reasonable steps to reclaim any such designated 18 document in the possession of any person not permitted access to such information 19 under the terms of this Order. 20 5. Inadvertent Failure to Designate. 21 The inadvertent production by any of the Parties or Non-Party to the Proceeding of any 22 Document, Testimony or Information during discovery in this Proceeding without a “Confidential” 23 designation, shall be without prejudice to any claim that such item is “Confidential” and such Party 24 shall not be held to have waived any rights by such inadvertent production. In the event that any 25 Document, Testimony or Information that is subject to a “Confidential” designation is inadvertently 26 produced without such designation, the Party that inadvertently produced the document shall give 27 written notice of such inadvertent production within twenty (20) days of discovery of the inadvertent 1 designated as “Confidential” (the “Inadvertent Production Notice”). Upon receipt of such 2 Inadvertent Production Notice, the Party that received the inadvertently produced Document, 3 Testimony or Information shall promptly destroy the inadvertently produced Document, Testimony 4 or Information and all copies thereof, or, at the expense of the Producing Party, return such together 5 with all copies of such Document, Testimony or Information to counsel for the Producing Party and 6 shall retain only the “Confidential” designated Materials. Should the Receiving Party choose to 7 destroy such inadvertently produced Document, Testimony or Information, the Receiving Party 8 shall notify the Producing Party in writing of such destruction within ten (10) days of receipt of 9 written notice of the inadvertent production. This provision is not intended to apply to any 10 inadvertent production of any Information protected by attorney-client or work product privileges. 11 In the event that this provision conflicts with any applicable law regarding waiver of confidentiality 12 through the inadvertent production of Documents, Testimony or Information, such law shall govern. 13 6. Challenging Confidentiality Designations. 14 a. Objection and Meet and Confer. In the event that counsel for a Party receiving 15 Documents, Testimony or Information in discovery designated as “Confidential” objects to 16 such designation with respect to any or all of such items, said counsel shall advise counsel 17 for the Designating Party, in writing, of such objections, the specific Documents, Testimony 18 or Information to which each objection pertains, and the specific reasons and support for 19 such objections (the “Designation Objections”). The Parties’ respective counsel shall 20 attempt to resolve each challenge in good faith and must begin the process by meeting and 21 conferring via an in person meeting, videoconference, or teleconference within fourteen (14) 22 days of the date of service of notice. In conferring, the Challenging Party must explain the 23 basis for its belief that the confidentiality designation was not proper and the Designating 24 Party must reconsider the circumstances, and, if no change in designation is offered, explain 25 the basis for the chosen designation. A Challenging Party may proceed to the next stage of 26 the challenge process only if it has engaged in this meet and confer process first or establishes 27 that the Designating Party is unwilling to participate in the meet and confer process in a 1 b. Judicial Intervention. If the Parties cannot resolve a challenge without court 2 intervention, the Challenging Party shall file and serve a motion challenging 3 whether the particular Protected Material should be entitled to confidential 4 treatment. Each such motion must be accompanied by a competent declaration 5 affirming that the movant has complied with the meet and confer requirements 6 imposed in the preceding paragraph and Local Rule 26-6. 7 The Designating Party bears the burden of demonstrating to the Court that the 8 Protected Material warrants protection. The Parties shall continue to afford the 9 Protected Material in question the level of confidential protection to which it is 10 entitled under the Designating Party’s designation until the Court rules on the 11 challenge. 12 7. Access to Confidential Materials. 13 Access to and/or Disclosure of Confidential Materials designated as “Confidential” shall be 14 permitted only to the following persons: 15 a. the Court; 16 b. Plaintiff Patricia Jancaterino; 17 c. attorneys of record in the Proceeding and their affiliated attorneys, paralegals, 18 clerical and secretarial staff employed by such attorneys who are actively involved in the 19 Proceeding and are not employees of any Party; in-house counsel to the undersigned Parties 20 and the paralegal, clerical and secretarial staff employed by such counsel. Provided, 21 however, that each non-lawyer given access to Confidential Materials shall be advised that 22 such Confidential Materials are being Disclosed pursuant to, and are subject to, the terms of 23 this Stipulation and Protective Order and that they may not be Disclosed other than pursuant 24 to its terms; 25 d. those officers, directors, partners, members, employees and agents of all 26 Parties that counsel for such Parties deems necessary to aid counsel in the prosecution and 27 defense of this Proceeding; provided, however, that prior to the Disclosure of Confidential 1 Party making the Disclosure shall deliver a copy of this Stipulation and Protective Order to 2 such person, shall explain that such person is bound to follow the terms of such Order, and 3 shall secure the signature of such person on a statement in the form attached hereto as Exhibit 4 A; 5 e. court reporters in this Proceeding (whether at depositions, hearings, or any 6 other proceeding); 7 f. any deposition, trial or hearing witness in the Proceeding who previously has 8 had access to the Confidential Materials, or who is currently or was previously an officer, 9 director, partner, member, employee or agent of an entity that has had access to the 10 Confidential Materials; 11 g. any deposition or non-trial hearing witness in the Proceeding who previously 12 did not have access to the Confidential Materials; provided, however, that each such witness 13 given access to Confidential Materials shall be advised that such Materials are being 14 Disclosed pursuant to, and are subject to, the terms of this Stipulation and Protective Order 15 and that they may not be Disclosed other than pursuant to its terms; 16 h. outside experts or expert consultants consulted by the undersigned Parties or 17 their counsel in connection with the Proceeding, whether or not retained to testify at any oral 18 hearing; provided, however, that prior to the Disclosure of Confidential Materials to any 19 such expert or expert consultant, counsel for the Party making the Disclosure shall deliver a 20 copy of this Stipulation and Protective Order to such person, shall explain its terms to such 21 person, and shall secure the signature of such person on a statement in the form attached 22 hereto as Exhibit A. It shall be the obligation of counsel, upon learning of any breach or 23 threatened breach of this Stipulation and Protective Order by any such expert or expert 24 consultant, to promptly notify counsel for the Designating Party of such breach or threatened 25 breach; and 26 i. any other person that the Designating Party agrees to in writing. 27 8. Ability to Modify or Seek Relief From This Stipulation and Protective Order. 1 Stipulation and Protective Order) may ask the Court, after appropriate notice to the other 2 Parties to the Proceeding, to modify or grant relief from any provision of this Stipulation and 3 Protective Order. 4 b. Entering into, agreeing to, and/or complying with the terms of this Stipulation 5 and Protective Order shall not: 6 i. operate as an admission by any person that any particular Document, 7 Testimony or Information marked “Confidential” contains or reflects trade secrets, 8 proprietary, confidential or competitively sensitive business, commercial, financial 9 or personal information; or 10 ii. prejudice in any way the right of any Party (or any other person 11 subject to the terms of this Stipulation and Protective Order): 12 1. to seek a determination by the Court of whether any particular 13 Confidential Material should be subject to protection as “Confidential” under 14 the terms of this Stipulation and Protective Order; or 15 2. to seek relief from the Court on appropriate notice to all other 16 Parties to the Proceeding from any provision(s) of this Stipulation and 17 Protective Order, either generally or as to any particular Document, Material 18 or Information. 19 9. Use of Confidential Materials 20 a. Confidential Materials shall be used by the persons receiving them only for 21 the purposes of preparing for, conducting, participating in the conduct of, and/or prosecuting 22 and/or defending the Proceeding, and not for any business or other purpose whatsoever. 23 b. Filing Confidential Material. The Parties agree to discuss filing Confidential 24 Material in good faith in advance of each instance so that they can jointly request that the 25 Court permit the filing under seal or with redactions, as appropriate. Without written 26 permission from the Designating Party or a court order secured after appropriate notice to 27 all interested persons, a Party may not file in the public record in this action any Confidential 1 must comply with Local Rule IA 10-5 and file a contemporaneous motion for leave to file 2 documents under seal addressing the substantive standards set forth in Kamakana v. City & 3 Cnty. Of Honolulu,

(9th Cir. 2006). The motion to seal must: (1) specifically 4 identify each document or portion thereof containing “Confidential information” that the 5 party seeks to file under seal; (2) demonstrate good cause (for non-dispositive papers or 6 pleadings filed with the Court) or compelling reasons (for dispositive papers and pleadings 7 filed with the Court) why the Confidential information should be protected; and (3) explain 8 why redaction or other alternatives to sealing are not sufficient. Any response to a motion to 9 seal must be filed within fourteen (14) days with the Court unless otherwise ordered by the 10 Court. If no timely response is filed, the Court may grant the motion as unopposed. All 11 papers or pleadings seeking leave of court to file which contain “Confidential” information 12 shall be provisionally filed under seal and will remain sealed until the Court either denies 13 the motion to seal or enters an order unsealing them. Any party who files a paper or pleading 14 with the Court under seal must serve an unredacted version on opposing counsel via a secure 15 file transfer method and paper service as delineated in LR IC 4-1(c)(4). 16 c. Use of Confidential Materials at Trial. The Parties shall meet and confer 17 regarding the procedures for use of Confidential Materials at trial and may move the Court 18 for entry of an appropriate order. 19 d. Nothing in this Stipulation and Protective Order shall affect the admissibility 20 into evidence of Confidential Materials, or abridge the rights of any person to seek judicial 21 review or to pursue other appropriate judicial action with respect to any ruling made by the 22 Court concerning the issue of the status of Confidential Material. 23 10. Duration. 24 a. This Stipulation and Protective Order shall continue to be binding after the 25 conclusion of this Proceeding and all subsequent proceedings arising from this Proceeding, 26 except that a Party may seek the written permission of the Designating Party or may move 27 the Court for relief from the provisions of this Stipulation and Protective Order. To the extent 1 Stipulation and Protective Order, even after the Proceeding is terminated. 2 b. Upon written request made within thirty (30) days after the settlement or 3 other termination of the Proceeding, the Parties shall have thirty (30) days to either (a) 4 promptly return to counsel for each Designating Party all Confidential Materials and all 5 copies thereof except that counsel for each Party may maintain all contents of its files in 6 accordance with the Nevada Rules of Professional Conduct or other applicable record- 7 keeping requirements, in continuing compliance with the terms of this Stipulation and 8 Protective Order, all work product, and pleadings filed with the Court, deposition transcripts 9 and/or recordings together with the exhibits marked at the deposition, trial and hearing 10 transcripts, and expert reports and work product), (b) agree with counsel for the Designating 11 Party upon appropriate methods and certification of destruction or other disposition of such 12 Confidential Materials, or (c) as to any Documents, Testimony or other Information not 13 addressed by sub-paragraphs (a) and (b), file a motion seeking a Court order regarding proper 14 preservation of such Materials. To the extent permitted by law the Court shall retain 15 continuing jurisdiction to review and rule upon the motion referred to in sub-paragraph (c) 16 herein. 17 c. Whether the Confidential Material is returned or destroyed, the receiving 18 Party must submit a written certification to the producing Party (and, if not the same person 19 or entity, to the Designating Party) by the thirty (30) day deadline confirming that all the 20 Confidential Material was returned or destroyed and affirming that the receiving Party has 21 not retained any copies, abstracts, compilations, summaries or any other format reproducing 22 or capturing any of the Confidential Material, subject to the terms of this Stipulation and 23 Protective Order. Notwithstanding this provision, counsel for each Party may maintain all 24 contents of its files in accordance with the Nevada Rules of Professional Conduct or other 25 applicable record-keeping requirements. A Party’s failure to comply with this provision of 26 this Stipulation and Protective Order shall be deemed immaterial and shall not be considered 27 a breach of this agreement. If a Party fails to comply with this paragraph, the other party 1 provided as soon as practicable in its files, in continuing compliance with the terms of this 2 Stipulation and Protective Order, all work product, and correspondence, pleadings filed with 3 the Court, deposition transcripts and/or recordings together with the exhibits marked at the 4 deposition, trial and hearing transcripts, and expert reports and work product. 5 11. Miscellaneous. 6 a. If, after execution of this Stipulation and Protective Order, any Confidential 7 Materials submitted by a Designating Party under the terms of this Stipulation and Protective 8 Order is Disclosed by a Receiving Party to any person other than in the manner authorized 9 by this Stipulation and Protective Order, the Receiving Party responsible for the Disclosure 10 shall bring all pertinent facts relating to the Disclosure of such Confidential Materials to the 11 immediate attention of the Designating Party. 12 b. Any Party to the Proceeding who has not executed this Stipulation and 13 Protective Order as of the time it is presented to the Court for signature may thereafter 14 become a Party to this Stipulation and Protective Order by its counsel’s signing and dating 15 a copy thereof and filing the same with the Court, and serving copies of such signed and 16 dated copy upon the other Parties to this Stipulation and Protective Order. 17 c. Nothing in this Stipulation and Protective Order shall be construed to 18 preclude either Party from asserting in good faith that certain Confidential Materials require 19 additional protection. The Parties shall meet and confer to agree upon the terms of such 20 additional protection. 21 d. This Stipulation and Protective Order is entered into without prejudice to the 22 right of any Party to knowingly waive the applicability of this Stipulation and Protective 23 Order to any Confidential Materials designated by that Party. If the Designating Party uses 24 Confidential Materials in a non-Confidential manner, then the Designating Party shall advise 25 that the designation no longer applies. 26 e. After this Stipulation and Protective Order has been signed by counsel for all 27 Parties, it shall be presented to the Court for entry. Counsel agree to be bound by the terms 1 the Court signs this Stipulation and Protective Order. 2 f. The Parties and all signatories to the Certification attached hereto as Exhibit 3 A agree to be bound by this Stipulation and Protective Order pending its approval and entry 4 by the Court. In the event that the Court modifies this Stipulation and Protective Order, or 5 in the event that the Court enters a different Protective Order, the Parties agree to be bound 6 by this Stipulation and Protective Order until such time as the Court may enter such a 7 different Order. It is the Parties’ intent to be bound by the terms of this Stipulation and 8 Protective Order pending its entry so as to allow for immediate production of Confidential 9 Materials under the terms herein. 10 g. This Stipulation and Protective Order may be executed in counterparts. 11 12 IT IS SO STIPULATED. 13 14 || 4s/ Marian L. Massey /s/- Diana G. Dickinson JEMMA E. DUNN WENDY M. KRINCEK 15 |! Nevada Bar No. 16229 Nevada Bar No. 6417 16 || MATTHEW T. HALE DIANA G. DICKINSON Nevada Bar No. 16880 Nevada Bar No. 13477 17 || MARIAN L. MASSEY 8474 Rozita Lee Avenue, Suite 200 Nevada Bar No. 14579 Las Vegas, NV 89113 18 1980 Festival Plaza Drive, Suite 730 19 Las Vegas, Nevada 89135 Attorneys for Defendant 50 Attorneys for Plaintiff 1 ORDER 0 IT IS S@ORDERED:

UNITED STATES MAGISTRATE JUDGE 25 26 DATED: 9/23/2025 27 28 -14-

1 EXHIBIT A 2 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS 3 I hereby acknowledge that I, ___________________________________[NAME], 4 ________________________________________ [POSITION AND EMPLOYER], am about to 5 receive Confidential Materials supplied in connection with the Proceeding, Jancaterino v. 6 Encompass Health Rehabilitation Hospital of Las Vegas, LLC, Case No. 2:25-cv-00157-ART-DJA. 7 I certify that I understand that the Confidential Materials are provided to me subject to the terms and 8 restrictions of the Stipulation and Protective Order filed in this Proceeding. I have been given a 9 copy of the Stipulation and Protective Order; I have read it, and I agree to be bound by its terms. 10 I understand that Confidential Material, as defined in the Stipulation and Protective Order, 11 including any notes or other records that may be made regarding any such materials, shall not be 12 Disclosed to anyone except as expressly permitted by the Stipulation and Protective Order. I will 13 not copy or use, except solely for the purposes of this Proceeding, any Confidential Materials 14 obtained pursuant to this Protective Order, except as provided therein or otherwise ordered by the 15 Court in the Proceeding. 16 I further understand that I am to retain all copies of all Confidential Materials provided to 17 me in the Proceeding in a secure manner, and that all copies of such Materials are to remain in my 18 personal custody until termination of my participation in this Proceeding, whereupon the copies of 19 such Materials will be returned to counsel who provided me with such Materials. 20 I declare under penalty of perjury, under the laws of the United States, that the foregoing is 21 true and correct. 22 DATED: __________________ BY: Signature 23 Title _______________________________________ 24 Address ____________________________________ 25 City, State, Zip ______________________________ 26 Telephone __________________________________ 27