Business Partner Solutions v. Novacoast, Inc. ( 2024 )

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE CENTRAL DISTRICT OF CALIFORNIA 10 BUSINESS PARTNER SOLUTIONS, Case No. 2:23-cv-02961-DSF-MAA 11 INC., STIPULATED PROTECTIVE 12 Plaintiff, ORDER 13 v. Magistrate Judge: Hon. Maria A. Audero Judge: Hon. Dale S. Fischer 14 NOVACOAST, INC.; and DOES 1 Dept.: 7D through 20, inclusive, 15 Complaint Filed: April 19, 2023 Defendants. Trial Date: None set yet 16 17 18 19 20 21 22 23 24 25 26 27 1 A. PURPOSE AND LIMITATIONS 2 Discovery in this Action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The Parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery, and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This Action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this Action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the Parties are entitled to 25 keep confidential, to ensure that the Parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a protective order 1 information will not be designated as confidential for tactical reasons and that 2 nothing be so designated without a good faith belief that it has been maintained in a 3 confidential, non-public manner, and there is a good cause why it should not be part 4 of the public record of this case. 5 C. PROCEDURE FOR FILING UNDER SEAL 6 The Parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file Confidential Information 8 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. 11 Accordingly, the Parties stipulate and agree that when information has been 12 designated Confidential pursuant to this Stipulated Protective Order, the Parties 13 shall follow the procedures set forth in Civil Local Rule 79-5.2.2, subsection (b). 14 Any document that is not confidential, privileged, or otherwise protectable in its 15 entirety will not be filed under seal if the confidential portions can be redacted. If 16 Protected Material can be redacted, then a redacted version for public viewing, 17 omitting only the confidential, privileged, or otherwise protectable portions of the 18 document, shall be filed. Any application that seeks to file Protected Material under 19 seal in its entirety should include an explanation of why redaction is not feasible. 20 2. DEFINITIONS 21 2.1 Action: The above entitled proceeding, bearing Case No. 2:23-cv- 22 02961-DSF-MAA. 23 2.2 Challenging Party: A Party or Non-Party that challenges the 24 designation of information or items under this Order. 25 2.3 Confidential Information or Items: Information (regardless of how it is 26 generated, stored or maintained) or tangible things that qualify for protection under 27 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 1 2.4 Court: The Honorable Dale S. Fischer, the Honorable Maria A. Audero, 2 or any other judge to which this Action may be assigned, including Court staff 3 participating in such proceedings. 4 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 5 their support staff). 6 2.6 Designating Party: A Party or Non-Party that designates information or 7 items that it produces or discloses in responses to discovery as “Confidential.” 8 2.7 Disclosure or Discovery Material: All items or information, regardless 9 of the medium or manner in which it is generated, stored, or maintained (including, 10 among other things, testimony, transcripts, and tangible things), that are produced or 11 generated in disclosures or responses to discovery in this matter. 12 2.8 Expert: A person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as 14 an expert witness or as a consultant in this Action. 15 2.9 House Counsel: Attorneys who are employees of a party to this Action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 2.10 Non-Party: Any natural person, partnership, corporation, association, or 19 other legal entity not names as a Party to this Action. 20 2.11 Outside Counsel of Record: Attorneys who are not employees of a 21 Party to this Action but are retained to represent or advise a party to this Action and 22 have appeared in this Action on behalf of that party or are affiliated with a law firm 23 which has appeared on behalf of that party, and includes support staff. 24 2.12 Party or Parties: Any party to this Action, including all of its officers, 25 directors, employees, consultants, retained experts, and Outside Counsel of Record 26 (and their support staffs). 27 2.13 Producing Party: A Party or Non-Party that produces Disclosure or 1 2.14 Professional Vendors: Persons or entities that a Party has retained or 2 consulted with in order to provide litigation support services (e.g., photocopying, 3 videotaping, translating, preparing exhibits or demonstrations, and organizing, 4 storing, or retrieving data in any form or medium) and their employees and 5 subcontractors, whether or not retained to testify at any oral hearing. 6 2.15 Protected Material: Any Disclosure or Discovery Material that is 7 designated as “Confidential.” 8 2.16 Receiving Party: A Party that receives Disclosure or Discovery 9 Material from a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or 13 extracted from Protected Material; (2) all copies, excerpts, summaries, or 14 compilations of Protected Material; and (3) any testimony, conversations, or 15 presentations by Parties or their Counsel that might reveal Protected Material. 16 The Parties stipulate and agree to follow the procedures set forth in Civil 17 Local Rule 79-5.2.2, subsection (b) before filing any Protected Material and that any 18 document that is not confidential, privileged, or otherwise protectable in its entirety 19 will not be filed under seal if the confidential portions can be redacted. Any use of 20 Protected Material at trial shall be governed by the orders of the trial judge. 21 4. DURATION 22 The confidentiality obligations imposed by this Stipulation and Order will 23 remain in effect throughout all proceedings—including pretrial proceedings and 24 after final disposition of this litigation—unless and until a Designating Party agrees 25 otherwise in writing or a court order otherwise directs. The Parties acknowledge, 26 however, that where a case proceeds to trial, information designated Confidential 27 pursuant to this Stipulation and Order may become public unless the Designating 1 compelling reasons supported by specific factual findings to proceed otherwise. See 2 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 3 (distinguishing “good cause” showing for sealing documents produced in discovery 4 from “compelling reasons” standard when merits-related documents are part of court 5 record)). 6 Accordingly, the Parties shall meet and confer regarding the procedures for 7 use of any Protected Materials at trial—including in pretrial proceedings—and shall 8 move the Court for entry of an appropriate order no later than the Final Pretrial 9 Conference. Nothing in this Stipulation and Order shall affect the admissibility into 10 evidence of Protected Material, or abridge the rights of any person to seek judicial 11 review or to pursue other appropriate judicial action with respect to any ruling made 12 by the Court concerning the issue of the status of any Protected Material. 13 Even after final disposition of this litigation, the confidentiality obligations 14 imposed by this Order shall remain in effect until a Designating Party agrees 15 otherwise in writing or a court order otherwise directs. Final disposition shall be 16 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 17 or without prejudice and (2) final judgment herein after the completion and 18 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 19 including the time limits for filing any motions or applications for extension of time 20 pursuant to applicable law. 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection 24 under this Order must take care to limit any such designation to specific material 25 that qualifies under the appropriate standards. The Designating Party must designate 26 for protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, item, 1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 under this Order must be so designated before the material is disclosed or produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic documents, 17 but excluding transcripts of depositions or other pretrial or trial proceedings), that 18 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 19 “Confidential Legend”), to each page that contains Protected Material. If only a 20 portion or portions of the material on a page qualifies for protection, then the 21 Producing Party also must clearly identify the protected portion(s) (e.g., by making 22 appropriate markings in the margins or by some other suitable method). 23 A Party or Non-Party that makes original documents available for inspection 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 provisionally deemed “CONFIDENTIAL.” After the inspecting Party has identified 1 which documents, or portions thereof, contain Confidential Information and qualify 2 for protection under this Order. Before producing the specified documents, the 3 Producing Party must affix the Confidential Legend to each page that contains 4 Protected Material. If only a portion or portions of the material on a page qualifies 5 for protection, then the Producing Party also must clearly identify the protected 6 portion(s) (e.g., by making appropriate markings in the margins or by some other 7 suitable method). 8 (b) for testimony given in depositions, a Producing Party or its counsel may 9 designate deposition exhibits or portions of deposition transcripts as Protected 10 Material either by: (a) indicating on the record during the deposition that a question 11 calls for Confidential Information, in which case the reporter will bind the transcript 12 of the designated testimony in a separate volume and mark it as “Confidential 13 Information Governed by Protective Order”; or (b) notifying the reporter and all 14 counsel of record, in writing, within 30 days after a deposition has concluded, of the 15 specific pages and lines of the transcript that contain Confidential Information and 16 are to be designated “CONFIDENTIAL” in which case all counsel receiving the 17 transcript will be responsible for marking the copies of the designated transcript in 18 their possession or under their control as directed by the Producing Party of that 19 person’s counsel. The entire deposition transcript shall be provisionally deemed 20 "CONFIDENTIAL" for the 30-day period following the deposition. 21 (c) for information produced in some form other than documentary and for 22 any other tangible items, that the Producing Party affix in a prominent place on the 23 exterior of the container or containers in which the information is stored the 24 Confidential Legend. If only a portion or portions of the information warrants 25 protection, then the Producing Party shall identify the protected portion(s) to the 26 extent practicable. 27 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 1 the Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make reasonable 3 efforts to assure that the material is treated in accordance with the provisions of this 4 Order. 5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 7 confidentiality designation at any time consistent with Court’s Scheduling Order. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 9 resolution process, which shall comply with Local Rule 37.1 et seq., and with 10 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic Conference for 11 Discovery Disputes”).1 12 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via 13 joint stipulation pursuant to Local Rule 37-2. 14 6.4 The burden of persuasion in any such challenge proceeding shall be on 15 the Designating Party. Frivolous challenges, and those made for an improper 16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 17 Parties) may expose the Challenging Party to sanctions. Unless the Designating 18 Party has waived or withdrawn the confidentiality designation, all Parties shall 19 continue to afford the material in question the level of protection to which it is 20 entitled under Section 4 of this Stipulation and Order unless and until the Court 21 orders otherwise. 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this 25 Action only for prosecuting, defending, or attempting to settle this Action. Such 26 Protected Material may be disclosed only to the categories of persons and under the 27 1 Judge Audero’s Procedures are available at 1 conditions described in this Order. When the Action has been terminated, a 2 Receiving Party must comply with the provisions of Section 13 below. 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Procedure Governing the Filing of Confidential Information. Unless 7 otherwise ordered by the Court, any Party (or signatory to the “Acknowledgment 8 and Agreement to Be Bound” attached as "Exhibit A" hereto) seeking to file a 9 document designated “CONFIDENTIAL” or containing Protected Material must 10 follow the following procedures set forth in Civil Local Rule 79-5.2.2, subsection (b). 11 7.3 Disclosure of Confidential Information or Items. Unless otherwise 12 ordered by the Court or permitted in writing by the Designating Party, a Receiving 13 Party may disclose any information or item designated “CONFIDENTIAL” only to: 14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 15 employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this Action; (b) the officers, directors, and employees 17 (including House Counsel) of the Receiving Party to whom disclosure is reasonably 18 necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound”; 22 (d) the Court and its personnel subject to the procedures set forth in Section 23 7.2 above; 24 (e) Court reporters and their staff; 25 (f) outside professionals consulted by the Parties, including jury or trial 26 consultants, mock jurors, and Professional Vendors to whom disclosure is 27 reasonably necessary for this Action and who have signed the “Acknowledgment 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information and 3 who have signed the “Acknowledgment and Agreement to Be Bound”; 4 (h) during their depositions, witnesses, and attorneys for witnesses, in the 5 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 6 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 7 and (2) unless otherwise agreed by the Designating Party or ordered by the Court, 8 they will not be permitted to keep any Confidential Information unless they sign the 9 “Acknowledgment and Agreement to Be Bound.” Pages of transcribed deposition 10 testimony or exhibits to depositions that reveal Protected Material may be separately 11 bound by the court reporter and may not be disclosed to anyone except as permitted 12 under this Stipulated Protective Order; and 13 (i) any mediator or settlement officer, and their supporting personnel, 14 mutually agreed upon by any of the Parties engaged in settlement discussions. 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 16 PRODUCED IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 that compels disclosure of any information or items designated in this Action as 19 “CONFIDENTIAL,” that Party must: 20 (a) Promptly notify in writing the Designating Party. Such notification shall 21 include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order to 23 issue that some or all of the material covered by the subpoena or order is subject to 24 this Protective Order. Such notification shall include a copy of this Stipulated 25 Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued 27 by the Designating Party whose Protected Material may be affected. 1 If the Designating Party timely seeks a protective order in the other litigation, 2 then the Party served with the subpoena or court order shall not produce any 3 information designated in this Action as “CONFIDENTIAL” before a determination 4 by the court from which the subpoena or order issued, unless the Party has obtained 5 the Designating Party’s permission. The Designating Party shall bear the burden and 6 expense of seeking protection of its confidential material, and nothing in these 7 provisions should be construed as authorizing or encouraging a Receiving Party in 8 this Action to disobey a lawful directive from another court. 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- 12 Party in this Action and designated as “CONFIDENTIAL.” Such information 13 produced by Non-Parties in connection with this litigation is protected by the 14 remedies and relief provided by this Order. Nothing in these provisions should be 15 construed as prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s Confidential Information in its possession, and the Party is 18 subject to an agreement with the Non-Party not to produce the Non-Party’s 19 Confidential Information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality 22 agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 Non-Party, if requested. 1 (c) If the Non-Party fails to seek a protective order from this court within 2 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s Confidential Information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court. 7 Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this court of its Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, then the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosure(s); (b) use its best 14 efforts to retrieve all unauthorized copies of the Protected Material; (c) inform the 15 person(s) to whom unauthorized disclosures were made of all the terms of this 16 Order; and (d) request such person(s) to execute the “Acknowledgment and 17 Agreement to Be Bound.” 18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, 22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 Procedure 26(b)(5)(B). 24 This provision is not intended to modify whatever procedure may be 25 established in a separate order that provides for production without prior privilege 26 review (e.g., an e-discovery order). Pursuant to Federal Rule of Evidence 502(d) and 27 (e), insofar as the Parties reach an agreement on the effect of disclosure of a 1 product protection, the Parties may incorporate their agreement in a stipulated 2 protective order submitted to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it would otherwise have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 13. FINAL DISPOSITION 12 Following the final disposition of this Action, as defined in Section 4, within 13 60 days of a written request by the Designating Party, each Receiving Party must 14 return All Protected Material to the Producing Party or destroy such material. As 15 used in this Section, “All Protected Material” includes all copies, abstracts, 16 compilations, summaries, and any other format reproducing or capturing any of the 17 Protected Material. Whether the Protected Material is returned or destroyed, the 18 Receiving Party must submit a written certification to the Producing Party (and, if 19 not the same person or entity, to the Designating Party) by the 60-day deadline that 20 (1) identifies (by category, where appropriate) all the Protected Material that was 21 returned or destroyed and (2) affirms that the Receiving Party has not retained any 22 copies, abstracts, compilations, summaries or any other format reproducing or 23 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 24 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 25 and hearing transcripts, legal memoranda, correspondence, deposition and trial 26 exhibits, expert reports, attorney work product, and consultant and expert work 27 product, even if such materials contain Protected Material. Any such archival copies 1 that contain or constitute Protected Material remain subject to this Protective Order 2 as set forth in Section 4. 3 14. Any violation of this Order my be punished by any and all appropriate 4 measures including, without limitation, contempt proceedings and or/monetary 5 sanctions. 6 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 SCHWARTZ SEMERDJIAN 10 CAULEY & EVANS LLP 11 12 Dated: December 14, 2023 By: /s/ John A. Schena John A. Schena 13 Mikayla M. Kuhn 14 Attorneys for Plaintiff Business Partner Solutions, Inc. 15 16 17 REICKER, PFAU, PYLE & MCROY, LLP 18 19 Dated: December 14, 2023 By: /s/ Megan K. Woodsome Meghan K. Woodsome 20 Attorneys for Defendant Novacoast, Inc. 21 22 23 24 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25 January 11, 2024 26 Dated: Maria A. Audero 27 United States Magistrate Judge 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 that I have 6 read in its entirety and understand the Stipulated Protective Order that was issue by 7 the United States District Court for the Central District of California on [DATE] in 8 the case of Business Partner Solutions, Inc. v. Novacoast, Inc., et al, Case No. 2:23- 9 cv-02961-DSF-MAA. I agree to comply with and to be bound by all the terms of 10 this Stipulated Protective Order, and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the 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 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint [print or type 19 full name] of [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action 21 or any proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: 24 City and State where sworn and signed: 25 26 Signature: _________ 27 Printed Name: