ProSource Discounts, Inc. v. Kipp K. Dye et al, No. 2:2019cv00489 - Document 45 (C.D. Cal. 2019)

Court Description: ORDER GRANTING STIPLATED PROTECTIVE ORDER by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order 44 . (sbou)

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ProSource Discounts, Inc. v. Kipp K. Dye et al Doc. 45 1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 CENTRAL DISTRICT OF CALIFORNIA 8 9 10 ProSource Discounts, Inc., a California corporation, 11 Plaintiff, Case No. 2:19-cv-00489-AB-JC Hon. Andre Birotte Jr. ORDER GRANTING STIPULATED PROTECTIVE ORDER 12 v. 13 Kipp K. Dye, an individual; Performance Complaint filed: Solutions, LLC, a Massachusetts limited liability company; and DOES 1-10, inclusive, 14 15 January 22, 2019 Defendants. 16 17 18 Performance Solutions, LLC, a Massachusetts limited liability company 19 20 21 22 Counter-Claimant, v. ProSource Discounts, Inc., a California corporation, Counter-Defendant. 23 24 25 26 27 28 Active\101995648.v1-9/4/19 Dockets.Justia.com 1 2 1. A. PURPOSES AND LIMITATIONS As the parties have represented that discovery in this action is likely to 3 involve production of confidential, proprietary, or private information for which 4 special protection from public disclosure and from use for any purpose other than 5 prosecuting this litigation may be warranted, this Court enters the following 6 Protective Order. This Order does not confer blanket protections on all disclosures 7 or responses to discovery. The protection it affords from public disclosure and use 8 extends only to the limited information or items that are entitled to confidential 9 treatment under the applicable legal principles. Further, as set forth in Section 12.3, 10 below, this Protective Order does not entitle the parties to file confidential 11 information under seal. Rather, when the parties seek permission from the court to 12 file material under seal, the parties must comply with Civil Local Rule 79-5 and 13 with any pertinent orders of the assigned District Judge and Magistrate Judge. 14 B. GOOD CAUSE STATEMENT 15 In light of the nature of the claims and allegations in this case and the parties’ 16 representations that discovery in this case will involve the production of confidential 17 records, and in order to expedite the flow of information, to facilitate the prompt 18 resolution of disputes over confidentiality of discovery materials, to adequately 19 protect information the parties are entitled to keep confidential, to ensure that the 20 parties are permitted reasonable necessary uses of such material in connection with 21 this action, to address their handling of such material at the end of the litigation, and 22 to serve the ends of justice, a protective order for such information is justified in this 23 matter. The parties shall not designate any information/documents as confidential 24 without a good faith belief that such information/documents have been maintained 25 in a confidential, non-public manner, and that there is good cause or a compelling 26 reason why it should not be part of the public record of this case. 27 28 2 Active\101995648.v1-9/4/19 1 2. DEFINITIONS 2 2.1 Action: The instant action: Prosource Discounts, Inc. v. Kipp K. 3 Dye, et al., Case No. 2:19-cv-00489-AB-JC. 2.2 4 5 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 2.3 6 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 2.4 10 “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY” 11 Information or Items: extremely sensitive “CONFIDENTIAL” Information or 12 Items, the disclosure of which to another Party or Non-Party would create a 13 substantial risk of serious harm that could not be avoided by less restrictive means. 2.5 14 15 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.6 16 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 19 ONLY.” 2.7 20 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 2.8 24 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 /// 28 3 Active\101995648.v1-9/4/19 1 2.9 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 5 6 2.10 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.11 Outside Counsel of Record: attorneys who are not employees of a 7 party to this Action but are retained to represent or advise a party to this Action and 8 have appeared in this Action on behalf of that party or are affiliated with a law firm 9 which has appeared on behalf of that party, and includes support staff. 10 2.12 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 14 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 15 2.14 Professional Vendors: persons or entities that provide litigation 16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 2.15 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- 21 ATTORNEYS’ EYES ONLY.” 22 23 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 24 3. SCOPE 25 The protections conferred by this Order cover not only Protected Material (as 26 defined above), but also (1) any information copied or extracted from Protected 27 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 28 4 Active\101995648.v1-9/4/19 1 and (3) any deposition testimony, conversations, or presentations by Parties or their 2 Counsel that might reveal Protected Material, other than during a court hearing or at 3 trial. 4 Any use of Protected Material during a court hearing or at trial shall be 5 governed by the orders of the presiding judge. This Order does not govern the use 6 of Protected Material during a court hearing or at trial. 7 4. 8 Even after final disposition of this litigation, the confidentiality obligations 9 DURATION imposed by this Order shall remain in effect until a Designating Party agrees 10 otherwise in writing or a court order otherwise directs. Final disposition shall be 11 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 12 or without prejudice; and (2) final judgment herein after the completion and 13 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 14 including the time limits for filing any motions or applications for extension of time 15 pursuant to applicable law. 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection under 19 this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items, or oral or written 22 communications that qualify so that other portions of the material, documents, 23 items, or communications for which protection is not warranted are not swept 24 unjustifiably within the ambit of this Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 5 Active\101995648.v1-9/4/19 1 unnecessary expenses and burdens on other parties) may expose the Designating 2 Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 11 12 produced. Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions), that the Producing Party affix 14 at a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- 15 ATTORNEYS’ EYES ONLY” to each page that contains protected material. If 16 only a portion or portions of the material on a page qualifies for protection, the 17 Producing Party also must clearly identify the protected portion(s) (e.g., by making 18 appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine which 25 documents, or portions thereof, qualify for protection under this Order. Then, 26 before producing the specified documents, the Producing Party must affix the 27 “CONFIDENTIAL”, or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 28 6 Active\101995648.v1-9/4/19 1 ONLY” legend to each page that contains Protected Material. If only a portion or 2 portions 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). (b) for testimony given in depositions that the Designating Party identifies 5 6 on the record, before the close of the deposition as protected testimony. (c) for information produced in some form other than documentary and 7 8 for any other tangible items, that the Producing Party affix in a prominent place on 9 the exterior of the container or containers in which the information is stored the 10 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ 11 EYES ONLY.” If only a portion or portions of the information warrants protection, 12 the Producing Party, to the extent practicable, shall identify the protected portion(s). 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 14 failure to designate qualified information or items does not, standing alone, waive 15 the Designating Party’s right to secure protection under this Order for such material. 16 Upon timely correction of a designation, the Receiving Party must make reasonable 17 efforts to assure that the material is treated in accordance with the provisions of this 18 Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 24 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process under Local Rule 37-1 et seq. 6.3 The burden of persuasion in any such challenge proceeding shall be on 26 the Designating Party. Frivolous challenges, and those made for an improper 27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 28 7 Active\101995648.v1-9/4/19 1 parties) may expose the Challenging Party to sanctions. Unless the Designating 2 Party has waived or withdrawn the confidentiality designation, all parties shall 3 continue to afford the material in question the level of protection to which it is 4 entitled under the Producing Party’s designation until the Court rules on the 5 challenge. 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 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. 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 21 well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) of 24 the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 8 Active\101995648.v1-9/4/19 1 (d) the court and its personnel; 2 (e) private court reporters and their staff to whom disclosure is reasonably 3 necessary for this Action and who have signed the “Acknowledgment and 4 Agreement to Be Bound” (Exhibit A); (f) professional jury or trial consultants, mock jurors, and Professional 5 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a 8 9 custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses, and attorneys for witnesses, in the 10 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 13 (Exhibit A); and (2) they will not be permitted to keep any confidential information 14 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 15 unless otherwise agreed by the Designating Party or ordered by the court. Pages of 16 transcribed deposition testimony or exhibits to depositions that reveal Protected 17 Material may be separately bound by the court reporter and may not be disclosed to 18 anyone except as permitted under this Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 19 20 mutually agreed upon by any of the parties engaged in settlement discussions. 7.3 21 Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 22 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 23 writing by the Designating Party, a Receiving Party may disclose any information or 24 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 25 to: 26 /// 27 /// 28 9 Active\101995648.v1-9/4/19 1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 2 as employees of said Outside Counsel of Record to whom it is reasonably necessary 3 to disclose the information for this Action; 4 (b) Experts (as defined in this Order) of the Receiving Party to whom 5 disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (c) the court and its personnel; 8 (d) private court reporters and their staff to whom disclosure is reasonably 9 10 11 necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (e) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 15 16 17 18 19 20 (f) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; and (g) any mediator or settlement officer, and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 23 ONLY,” that Party must: 24 25 26 27 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order unless prohibited by law; (b) promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the 28 10 Active\101995648.v1-9/4/19 1 subpoena or order is subject to this Protective Order. Such notification shall include 2 a copy of this Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 3 4 pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 5 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ 8 EYES ONLY” before a determination by the court from which the subpoena or 9 order issued, unless the Party has obtained the Designating Party’s permission, or 10 unless otherwise required by the law or court order. The Designating Party shall 11 bear the burden and expense of seeking protection in that court of its confidential 12 material and nothing in these provisions should be construed as authorizing or 13 encouraging a Receiving Party in this Action to disobey a lawful directive from 14 another court. 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 16 PRODUCED IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a 18 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 19 CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such information produced by 20 Non-Parties in connection with this litigation is protected by the remedies and relief 21 provided by this Order. Nothing in these provisions should be construed as 22 prohibiting a Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery request, to 24 produce a Non-Party’s confidential information in its possession, and the Party is 25 subject to an agreement with the Non-Party not to produce the Non-Party’s 26 confidential information, then the Party shall: 27 /// 28 11 Active\101995648.v1-9/4/19 (1) promptly notify in writing the Requesting Party and the Non-Party 1 2 that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Protective 4 5 Order in this Action, the relevant discovery request(s), and a reasonably specific 6 description of the information requested; and (3) make the information requested available for inspection by the 7 8 Non-Party, if requested. (c) If a Non-Party represented by counsel fails to commence the process 9 10 called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the 11 notice and accompanying information or fails contemporaneously to notify the 12 Receiving Party that it has done so, the Receiving Party may produce the Non- 13 Party’s confidential information responsive to the discovery request. If an 14 unrepresented Non-Party fails to seek a protective order from this court within 14 15 days of receiving the notice and accompanying information, the Receiving Party 16 may produce the Non-Party’s confidential information responsive to the discovery 17 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 18 not produce any information in its possession or control that is subject to the 19 confidentiality agreement with the Non-Party before a determination by the court 20 unless otherwise required by the law or court order. Absent a court order to the 21 contrary, the Non-Party shall bear the burden and expense of seeking protection in 22 this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Protective Order, the Receiving Party must immediately (a) notify in writing the 27 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 28 12 Active\101995648.v1-9/4/19 1 all unauthorized copies of the Protected Material, (c) inform the person or persons to 2 whom unauthorized disclosures were made of all the terms of this Order, and 3 (d) request such person or persons to execute the “Acknowledgment and Agreement 4 to Be Bound” (Exhibit A). 5 11. OTHERWISE PROTECTED MATERIAL 6 7 INADVERTENT PRODUCTION OF PRIVILEGED OR When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 11 procedure may be established in an e-discovery order that provides for production 12 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 13 (e), insofar as the parties reach an agreement on the effect of disclosure of a 14 communication or information covered by the attorney-client privilege or work 15 product protection, the parties may incorporate their agreement into this Protective 16 Order. 17 12. 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 19 MISCELLANEOUS person to seek its modification by the Court in the future. 20 12.2 Right to Assert Other Objections. No Party waives any right it 21 otherwise would have to object to disclosing or producing any information or item 22 on any ground not addressed in this Protective Order. Similarly, no Party waives 23 any right to object on any ground to use in evidence of any of the material covered 24 by this Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Civil Local Rule 79-5 and with any pertinent 27 orders of the assigned District Judge and Magistrate Judge. Protected Material may 28 13 Active\101995648.v1-9/4/19 1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party’s request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in Section 4, within 60 7 days of a written request by the Designating Party, each Receiving Party must return 8 all Protected Material to the Producing Party or destroy such material. As used in 9 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 summaries, and any other format reproducing or capturing any of the Protected 11 Material. Whether the Protected Material is returned or destroyed, the Receiving 12 Party must submit a written certification to the Producing Party (and, if not the same 13 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 14 (by category, where appropriate) all the Protected Material that was returned or 15 destroyed and (2) affirms that the Receiving Party has not retained any copies, 16 abstracts, compilations, summaries or any other format reproducing or capturing any 17 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 18 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 20 reports, attorney work product, and consultant and expert work product, even if such 21 materials contain Protected Material. Any such archival copies that contain or 22 constitute Protected Material remain subject to this Protective Order as set forth in 23 Section 4. 24 /// 25 /// 26 /// 27 /// 28 14 Active\101995648.v1-9/4/19 1 14. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 5 6 IT IS HEREBY ORDERED that the Stipulated Protective Order is GRANTED. DATED: September 6, 2019 7 _____________/s/_____________________ Honorable Jacqueline Chooljian United States Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 Active\101995648.v1-9/4/19 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Protective Order that was issued 7 by the United States District Court for the Central District of California on 8 September 6, 2019 in the case of Prosource Discounts, Inc. v. Kipp K. Dye, Case 9 No. 2:19-cv-00489-AB-JC. I agree to comply with and to be bound by all the terms 10 of this Protective Order and I understand and acknowledge that failure to so comply 11 could expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is subject 13 to this Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint __________________________ [print or type full 19 name] of _______________________________________ [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 16 Active\101995648.v1-9/4/19

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