Huynh v. Liberty Mutual Fire Insurance Company et al, No. 3:2022cv00461 - Document 17 (S.D. Cal. 2022)
Court Description: Order Granting 16 Joint Motion for Entry of Protective Order as Modified by the Court. Signed by Magistrate Judge Nita L. Stormes on 12/16/2022. (All non-registered users served via U.S. Mail Service)(exs)
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Huynh v. Liberty Mutual Fire Insurance Company et al Doc. 17 Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.171 Page 1 of 15 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 ANH HUYNH, Case No.: 22cv461-LL (NLS) Plaintiff, 12 13 v. 14 16 LIBERTY MUTUAL FIRE INSURANCE COMPANY; LIBERTY MUTUAL INSURANCE COMPANY; and DOES 1 through 20, inclusive, 17 Defendants. 15 ORDER GRANTING JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER AS MODIFIED BY THE COURT [ECF No. 16] 18 19 20 21 The Court having read the parties’ Joint Stipulated Motion for Protective Order (ECF No. 16), finding no objection and good cause appearing, IT IS HEREBY ORDERED that this motion is GRANTED. The following 22 Protective Order is entered, as modified by the Court (see paragraphs VI.A, XII.A, 23 XII.C). 24 25 PROTECTIVE ORDER The Court recognizes that at least some of the documents and information 26 ("materials") being sought through discovery in the above-captioned action are, for 27 competitive reasons, normally kept confidential by the parties. The parties have agreed to 28 be bound by the terms of this Protective Order (“Order”) in this action. 1 22cv461-LL (NLS) Dockets.Justia.com Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.172 Page 2 of 15 1 The materials to be exchanged throughout the course of the litigation between the 2 parties may contain trade secret or other confidential research, technical, cost, price, 3 marketing or other commercial information, as is contemplated by Federal Rule of Civil 4 Procedure 26(c)(1)(G). The purpose of this Order is to protect the confidentiality of such 5 materials as much as practical during the litigation. 6 I. GOOD CAUSE STATEMENT 7 A. 8 other valuable research, development, commercial, financial, technical and/or 9 proprietary information for which special protection from public disclosure and This action is likely to involve trade secrets, customer and pricing lists and 10 from use for any purpose other than prosecution of this action is warranted. Such 11 confidential and proprietary materials and information consist of, among other 12 things, confidential business or financial information, information regarding 13 confidential business practices, or other confidential research, development, or 14 commercial information (including information implicating privacy rights of third 15 parties), information otherwise generally unavailable to the public, or which may 16 be privileged or otherwise protected from disclosure under state or federal statutes, 17 court rules, case decisions, or common law. Accordingly, to expedite the flow of 18 information, to facilitate the prompt resolution of disputes over confidentiality of 19 discovery materials, to adequately protect information the parties are entitled to 20 keep confidential, to ensure that the parties are permitted reasonable necessary uses 21 of such material in preparation for and in the conduct of trial, to address their 22 handling at the end of the litigation, and serve the ends of justice, a protective order 23 for such information is justified in this matter. It is the intent of the parties that 24 information will not be designated as confidential for tactical reasons and that 25 nothing be so designated without a good faith belief that it has been maintained in 26 a confidential, non-public manner, and there is good cause why it should not be 27 part of the public record of this case. 28 // 2 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.173 Page 3 of 15 1 II. DEFINITIONS 2 A. 3 Fire Insurance Company; Liberty Mutual Insurance Company; and Does 1 4 through 20, inclusive, United States District Court for the Central District of 5 California, Case No. 22-cv-0461-LL-NLS. 6 B. 7 information or items under this Order. 8 C. 9 is generated, stored or maintained) or tangible things that qualify for protection 10 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 11 Cause Statement. 12 D. 13 support staff). 14 E. 15 items that it produces in disclosures or in responses to discovery as 16 “CONFIDENTIAL.” 17 F. 18 the medium or manner in which it is generated, stored, or maintained (including, 19 among other things, testimony, transcripts, and tangible things), that are produced 20 or generated in disclosures or responses to discovery in this matter. 21 G. 22 pertinent to the litigation who has been retained by a Party or its counsel to serve 23 as an expert witness or as a consultant in this Action. 24 H. 25 House Counsel does not include Outside Counsel of Record or any other outside 26 counsel. 27 I. 28 other legal entity not named as a Party to this action. Action: This pending federal law suit, entitled Anh Huynh v. Liberty Mutual Challenging Party: A Party or Non-Party that challenges the designation of “CONFIDENTIAL” Information or Items: Information (regardless of how it Counsel: Outside Counsel of Record and House Counsel (as well as their Designating Party: A Party or Non-Party that designates information or Disclosure or Discovery Material: All items or information, regardless of Expert: A person with specialized knowledge or experience in a matter House Counsel: Attorneys who are employees of a party to this Action. Non-Party: Any natural person, partnership, corporation, association, or 3 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.174 Page 4 of 15 1 2 J. 3 this Action but are retained to represent or advise a party to this Action and have 4 appeared in this Action on behalf of that party or are affiliated with a law firm 5 which has appeared on behalf of that party, and includes support staff. 6 K. 7 employees, consultants, retained experts, and Outside Counsel of Record (and their 8 support staffs). 9 L. Outside Counsel of Record: Attorneys who are not employees of a party to Party: Any party to this Action, including all of its officers, directors, Producing Party: A Party or Non-Party that produces Disclosure or 10 Discovery Material in this Action. 11 M. 12 services (e.g., photocopying, videotaping, translating, preparing exhibits or 13 demonstrations, and organizing, storing, or retrieving data in any form or medium) 14 and their employees and subcontractors. 15 N. 16 as “CONFIDENTIAL.” 17 O. 18 from a Producing Party. 19 III. Professional Vendors: Persons or entities that provide litigation support Protected Material: Any Disclosure or Discovery Material that is designated Receiving Party: A Party that receives Disclosure or Discovery Material SCOPE 20 A. 21 Protected Material (as defined above), but also (1) any information copied or 22 extracted from Protected Material; (2) all copies, excerpts, summaries, or 23 compilations of Protected Material; and (3) any testimony, conversations, or 24 presentations by Parties or their Counsel that might reveal Protected Material. 25 B. 26 trial judge. This Order does not govern the use of Protected Material at trial. 27 28 IV. The protections conferred by this Stipulation and Order cover not only Any use of Protected Material at trial shall be governed by the orders of the DURATION A. Even after final disposition of this litigation, the confidentiality obligations 4 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.175 Page 5 of 15 1 imposed by this Order shall remain in effect until a Designating Party agrees 2 otherwise in writing or a court order otherwise directs. Final disposition shall be 3 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 4 with or without prejudice; and (2) final judgment herein after the completion and 5 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 6 including the time limits for filing any motions or applications for extension of 7 time pursuant to applicable law. 8 9 V. DESIGNATING PROTECTED MATERIAL A. Exercise of Restraint and Care in Designating Material for Protection 10 1. 11 protection under this Order must take care to limit any such designation to 12 specific material that qualifies under the appropriate standards. The 13 Designating Party must designate for protection only those parts of material, 14 documents, items, or oral or written communications that qualify so that 15 other portions of the material, documents, items, or communications for 16 which protection is not warranted are not swept unjustifiably within the 17 ambit of this Order. 18 2. 19 Designations that are shown to be clearly unjustified or that have been made 20 for an improper purpose (e.g., to unnecessarily encumber the case 21 development process or to impose unnecessary expenses and burdens on 22 other parties) may expose the Designating Party to sanctions. 23 3. 24 that it designated for protection do not qualify for protection, that 25 Designating Party must promptly notify all other Parties that it is 26 withdrawing the inapplicable designation. 27 28 B. Each Party or Non-Party that designates information or items for Mass, indiscriminate, or routinized designations are prohibited. If it comes to a Designating Party’s attention that information or items Manner and Timing of Designations 1. Except as otherwise provided in this Order (see, e.g., Section B(2)(b) 5 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.176 Page 6 of 15 1 below), or as otherwise stipulated or ordered, Disclosure or Discovery 2 Material that qualifies for protection under this Order must be clearly so 3 designated before the material is disclosed or produced. 4 2. Designation in conformity with this Order requires the following: 5 a. 6 documents, but excluding transcripts of depositions or other pretrial or 7 trial proceedings), that the Producing Party affix at a minimum, the 8 legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), 9 to each page that contains protected material. If only a portion or For information in documentary form (e.g., paper or electronic 10 portions of the material on a page qualifies for protection, the 11 Producing Party also must clearly identify the protected portion(s) 12 (e.g., by making appropriate markings in the margins). 13 b. 14 for inspection need not designate them for protection until after the 15 inspecting Party has indicated which documents it would like copied 16 and produced. During the inspection and before the designation, all of 17 the material made available for inspection shall be deemed 18 “CONFIDENTIAL.” After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must 20 determine which documents, or portions thereof, qualify for protection 21 under this Order. Then, before producing the specified documents, 22 the Producing Party must affix the “CONFIDENTIAL legend” to each 23 page that contains Protected Material. If only a portion or portions of 24 the material on a page qualifies for protection, the Producing Party 25 also must clearly identify the protected portion(s) (e.g., by making 26 appropriate markings in the margins). 27 c. 28 identify the Disclosure or Discovery Material on the record, before the A Party or Non-Party that makes original documents available For testimony given in depositions, that the Designating Party 6 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.177 Page 7 of 15 1 close of the deposition all protected testimony. 2 d. 3 any other tangible items, that the Producing Party affix in a prominent 4 place on the exterior of the container or containers in which the 5 information is stored the legend “CONFIDENTIAL.” If only a 6 portion or portions of the information warrants protection, the 7 Producing Party, to the extent practicable, shall identify the protected 8 portion(s). 9 C. For information produced in form other than document and for Inadvertent Failure to Designate 10 1. 11 information or items does not, standing alone, waive the Designating Party’s 12 right to secure protection under this Order for such material. Upon timely 13 correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions 15 of this Order. 16 17 VI. If timely corrected, an inadvertent failure to designate qualified CHALLENGING CONFIDENTIALITY DESIGNATIONS A. 18 Timing of Challenges 1. Any party or Non-Party may challenge a designation of 19 confidentiality at any time that is consistent with the Court’s Scheduling 20 Order. The party objecting to confidentiality must notify, in writing, 21 counsel for the designating party of the objected-to materials and the 22 grounds for the objection. Such objection on designation of any 23 Confidential Information shall be raised in writing within 30 days of the 24 challenging party’s receipt of the materials at issue. If the dispute is not 25 resolved consensually between the parties within 7 days of receipt of 26 such written notice, the parties shall file a joint motion for 27 determination of discovery dispute, as outlined in this Court’s 28 Chambers Rules, no later than 45 days after the challenging party’s 7 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.178 Page 8 of 15 1 2 receipt of the designated material in issue. B. Meet and Confer 3 1. 4 under Civil Local Rule 26.1(a) et seq. The Challenging Party shall initiate the dispute resolution process 5 C. 6 Designating Party. Frivolous challenges, and those made for an improper purpose 7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 8 expose the Challenging Party to sanctions. Unless the Designating Party has 9 waived or withdrawn the confidentiality designation, all parties shall continue to 10 afford the material in question the level of protection to which it is entitled under 11 the Producing Party’s designation until the Court rules on the challenge. 12 13 The burden of persuasion in any such challenge proceeding shall be on the VII. ACCESS TO AND USE OF PROTECTED MATERIAL A. Basic Principles 14 1. 15 produced by another Party or by a Non-Party in connection with this Action 16 only for prosecuting, defending, or attempting to settle this Action. Such 17 Protected Material may be disclosed only to the categories of persons and 18 under the conditions described in this Order. When the Action has been 19 terminated, a Receiving Party must comply with the provisions of Section 20 XIII below. 21 2. 22 Party at a location and in a secure manner that ensures that access is limited 23 to the persons authorized under this Order. 24 B. A Receiving Party may use Protected Material that is disclosed or Protected Material must be stored and maintained by a Receiving Disclosure of “CONFIDENTIAL” Information or Items 25 1. 26 Designating Party, a Receiving Party may disclose any information or item 27 designated “CONFIDENTIAL” only to: Unless otherwise ordered by the Court or permitted in writing by the 28 8 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.179 Page 9 of 15 1 a. 2 Action, as well as employees of said Outside Counsel of Record to 3 whom it is reasonably necessary to disclose the information for this 4 Action; 5 b. 6 Counsel) of the Receiving Party to whom disclosure is reasonably 7 necessary for this Action; 8 c. 9 whom disclosure is reasonably necessary for this Action and who 10 have signed the “Acknowledgment and Agreement to Be Bound” 11 (Exhibit A); 12 d. The Court and its personnel; 13 e. Court reporters and their staff; 14 f. Professional jury or trial consultants, mock jurors, and 15 Professional Vendors to whom disclosure is reasonably necessary for 16 this Action and who have signed the “Acknowledgment and 17 Agreement to be Bound” attached as Exhibit A hereto; 18 g. 19 information or a custodian or other person who otherwise possessed or 20 knew the information; 21 h. 22 in the Action to whom disclosure is reasonably necessary provided: (i) 23 the deposing party requests that the witness sign the 24 “Acknowledgment and Agreement to Be Bound;” and (ii) they will 25 not be permitted to keep any confidential information unless they sign 26 the “Acknowledgment and Agreement to Be Bound,” unless 27 otherwise agreed by the Designating Party or ordered by the Court. 28 Pages of transcribed deposition testimony or exhibits to depositions The Receiving Party’s Outside Counsel of Record in this The officers, directors, and employees (including House Experts (as defined in this Order) of the Receiving Party to The author or recipient of a document containing the During their depositions, witnesses, and attorneys for witnesses, 9 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.180 Page 10 of 15 1 that reveal Protected Material may be separately bound by the court 2 reporter and may not be disclosed to anyone except as permitted under 3 this Stipulated Protective Order; and 4 i. 5 personnel, mutually agreed upon by any of the parties engaged in 6 settlement discussions. 7 Any mediator or settlement officer, and their supporting VIII. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 8 OTHER LITIGATION 9 A. If a Party is served with a subpoena or a court order issued in other litigation 10 that compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 1. 13 shall include a copy of the subpoena or court order; 14 2. 15 to issue in the other litigation that some or all of the material covered by the 16 subpoena or order is subject to this Protective Order. Such notification shall 17 include a copy of this Stipulated Protective Order; and 18 3. 19 pursued by the Designating Party whose Protected Material may be affected. Promptly notify in writing the Designating Party. Such notification Promptly notify in writing the party who caused the subpoena or order Cooperate with respect to all reasonable procedures sought to be 20 B. 21 with the subpoena or court order shall not produce any information designated in 22 this action as “CONFIDENTIAL” before a determination by the Court from which 23 the subpoena or order issued, unless the Party has obtained the Designating Party’s 24 permission. The Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these provisions 26 should be construed as authorizing or encouraging a Receiving Party in this Action 27 to disobey a lawful directive from another court. If the Designating Party timely seeks a protective order, the Party served 28 10 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.181 Page 11 of 15 1 IX. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 A. 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 B. 9 a Non-Party’s confidential information in its possession, and the Party is subject to The terms of this Order are applicable to information produced by a Non- In the event that a Party is required, by a valid discovery request, to produce 10 an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 1. 13 that some or all of the information requested is subject to a confidentiality 14 agreement with a Non-Party; 15 2. 16 Protective Order in this Action, the relevant discovery request(s), and a 17 reasonably specific description of the information requested; and 18 3. 19 Party, if requested. Promptly notify in writing the Requesting Party and the Non-Party Promptly provide the Non-Party with a copy of the Stipulated Make the information requested available for inspection by the Non- 20 C. 21 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and 27 expense of seeking protection in this court of its Protected Material. 28 // If the Non-Party fails to seek a protective order from this court within 14 11 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.182 Page 12 of 15 1 X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 A. 3 disclosed Protected Material to any person or in any circumstance not authorized 4 under this Stipulated Protective Order, the Receiving Party must immediately (1) 5 notify in writing the Designating Party of the unauthorized disclosures, (2) use its 6 best efforts to retrieve all unauthorized copies of the Protected Material, (3) inform 7 the person or persons to whom unauthorized disclosures were made of all the terms 8 of this Order, and (4) request such person or persons to execute the 9 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit 10 11 If a Receiving Party learns that, by inadvertence or otherwise, it has A. XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 12 PROTECTED MATERIAL 13 A. 14 inadvertently produced material is subject to a claim of privilege or other 15 protection, the obligations of the Receiving Parties are those set forth in Federal 16 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 17 whatever procedure may be established in an e-discovery order that provides for 18 production without prior privilege review. Pursuant to Federal Rule of Evidence 19 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 20 of a communication or information covered by the attorney-client privilege or 21 work product protection, the parties may incorporate their agreement in the 22 Stipulated Protective Order submitted to the Court. 23 24 When a Producing Party gives notice to Receiving Parties that certain XII. MISCELLANEOUS A. Right to Further Relief 25 1. 26 modification by the Court in the future. The Court may modify the 27 protective order in the interests of justice or for public policy reasons. 28 B. Nothing in this Order abridges the right of any person to seek its Right to Assert Other Objections 12 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.183 Page 13 of 15 1 1. 2 any right it otherwise would have to object to disclosing or producing any 3 information or item on any ground not addressed in this Stipulated 4 Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective 6 Order. 7 C. By stipulating to the entry of this Protective Order, no Party waives Filing Protected Material 8 1. 9 required to take any action, without separate prior order by the Judge Nothing shall be filed under seal, and the Court shall not be 10 before whom the hearing or proceeding will take place, after application 11 by the affected party with appropriate notice to opposing counsel. The 12 parties shall follow and abide by applicable law, including Civ. L.R. 13 79.2, ECF Administrative Policies and Procedures, Section II.j, and the 14 chambers’ rules, with respect to filing documents under seal. Protected 15 Material may only be filed under seal pursuant to a court order authorizing 16 the sealing of the specific Protected Material at issue. If a Party’s request to 17 file Protected Material under seal is denied by the Court, then the Receiving 18 Party may file the information in the public record unless otherwise 19 instructed by the Court. 20 XIII. FINAL DISPOSITION 21 A. 22 sixty (60) days of a written request by the Designating Party, each Receiving Party 23 must return all Protected Material to the Producing Party or destroy such material. 24 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of the 26 Protected Material. Whether the Protected Material is returned or destroyed, the 27 Receiving Party must submit a written certification to the Producing Party (and, if 28 not the same person or entity, to the Designating Party) by the 60 day deadline that After the final disposition of this Action, as defined in Section V, within 13 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.184 Page 14 of 15 1 (1) identifies (by category, where appropriate) all the Protected Material that was 2 returned or destroyed and (2) affirms that the Receiving Party has not retained any 3 copies, abstracts, compilations, summaries or any other format reproducing or 4 capturing any of the Protected Material. Notwithstanding this provision, Counsel 5 are entitled to retain an archival copy of all pleadings, motion papers, trial, 6 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 7 and trial exhibits, expert reports, attorney work product, and consultant and expert 8 work product, even if such materials contain Protected Material. Any such 9 archival copies that contain or constitute Protected Material remain subject to this 10 Protective Order as set forth in Section IV. 11 B. 12 measures including, without limitation, contempt proceedings and/or monetary 13 sanctions. IT IS SO ORDERED. 14 15 Any violation of this Order may be punished by any and all appropriate Dated: December 16, 2022 16 17 18 19 20 21 22 23 24 25 26 27 28 14 22cv461-LL (NLS) Case 3:22-cv-00461-LL-NLS Document 17 Filed 12/16/22 PageID.185 Page 15 of 15 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 4 I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Southern District of California on [DATE] in the case of Anh 8 Huynh v. Liberty Mutual Fire Insurance Company, et al., Case No. 22-cv-0461-LL-NLS. 9 I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated 13 14 Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for 15 16 17 18 the Southern District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint 19 [print or type full address and telephone number] as my California 20 21 22 23 24 25 26 [print or type full name] of agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. Date: City and State where sworn and signed: Printed Name: Signature: 27 28 15 22cv461-LL (NLS)
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