Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 1 of 16
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`SIPCO, LLC, and IP CO, LLC
`(d/b/a INTUS IQ),
`
`Plaintiffs,
`
` v.
`
` Civil Action No. 6:15-cv-907
`
`EMERSON ELECTRIC CO., EMERSON
`PROCESS MANAGEMENT LLLP, FISHER-
`ROSEMOUNT SYSTEMS, INC.,
`ROSEMOUNT INC., BP, p.l.c., BP
`AMERICA, INC., and BP AMERICA
`PRODUCTION COMPANY,
`
`Defendants.
`
`PROTECTIVE ORDER
`
`
`
`THIS MATTER having come before the Court on the parties' joint motion for entry of a
`
`protective order, and the Court having determined that there is good cause under Federal Rule of
`
`Civil Procedure 26(c) for entry of a protective order to limit disclosure of trade secrets and
`
`confidential research, development, and commercial information as those terms are used in
`
`Federal Rule of Civil Procedure 26(c)(l)(G), and information that the party is under a legal duty
`
`to maintain in confidence,
`
`THEREFORE, IT IS HEREBY ORDERED that:
`
`1.
`
`Scope. This Protective Order shall govern any information produced or disclosed in this
`
`action by any party or by any third party.
`
`2.
`
`Proprietary Information.
`
`“Proprietary Information” means any information,
`
`document, electronically stored information, or thing that contains or is a trade secret or other
`
`confidential research, development, or commercial information as those terms are used in
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 2 of 16
`
`Federal Rule of Civil Procedure 26(c)(1)(G), and information that the party is under a legal duty
`
`to maintain in confidence, provided that such information, document, electronically stored
`
`information, or thing is designated as set forth herein. Any Proprietary Information may be
`
`designated as CONFIDENTIAL. Proprietary Information relating to highly sensitive financial
`
`information, including but not limited to, customer identification, marketing, sales, pricing
`
`information, profit margins and business plans or strategies, and highly sensitive technical
`
`information, including but not limited to, product design and development materials, source
`
`code, or other highly sensitive, trade secret technical information, may be designated as
`
`ATTORNEYS EYES ONLY.
`
`Any party to this action and any third party may designate as CONFIDENTIAL or
`
`ATTORNEYS EYES ONLY all or part of the following material: (a) answers to interrogatories
`
`or requests for admission; (b) deposition testimony; (c) documents produced by it or made
`
`available for inspection; and (d) any other materials or information produced or disclosed during
`
`the course of this litigation. As used herein, “Designating Party” shall refer to any party or third
`
`party to this action that designates information that it or another party has produced or provided,
`
`and “Receiving Party” shall refer to any party or third party that receives such information.
`
`3.
`
`Designation of Documentary Material. Documentary material may be designated as
`
`CONFIDENTIAL or ATTORNEYS EYES ONLY by stamping or otherwise marking each page
`
`with the appropriate confidentiality designation and with the identity of the classifying party
`
`unless it is indicated as part of the production number (e.g., “Plaintiff P00001”) contained on the
`
`document. Except with respect to documents produced by any party prior to the execution by the
`
`parties of this Stipulated Protective Order, the identification and designation of Proprietary
`
`Information shall be made at the time when the answer to the interrogatory or the answer to the
`
`2
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 3 of 16
`
`request for admission is served and when a copy of the document is provided to the requesting
`
`party.
`
`Unless otherwise designated or agreed by the parties, all documents made available for
`
`inspection prior to copying and production shall be presumed to have been marked
`
`ATTORNEYS EYES ONLY. No documents of the party or third party producing documents
`
`shall be removed from the site of the inspection or copied until such producing party or third
`
`party has had an opportunity to review and designate such documents in the manner previously
`
`explained.
`
`With regard to non-written material, such as recordings, magnetic media, photographs
`
`and things, the designation of any information as CONFIDENTIAL or ATTORNEYS EYES
`
`ONLY for purposes of this Protective Order shall be made by affixing a CONFIDENTIAL or
`
`ATTORNEYS EYES ONLY designation to the material, or a container for the material, in any
`
`suitable manner at the time of copying (if any).
`
`4.
`
`Designation of Depositions. Deposition or other oral testimony given in this case may
`
`be designated as CONFIDENTIAL or ATTORNEYS EYES ONLY by any party or third party
`
`either (a) during the deposition or proceeding during which the testimony is given, or (b) by
`
`written notice to the court reporter and to all counsel of record, within five (5) days of receipt,
`
`either by mail or email, of the deposition transcript. Unless otherwise ordered by the Court,
`
`pending the expiration of this five (5) day period, all parties and persons shall treat the testimony
`
`as if it has been designated ATTORNEYS EYES ONLY. Unless otherwise ordered by the Court,
`
`the designating party shall have the right to have all persons, except the witness, his or her
`
`counsel, the court reporter, and such other persons authorized to receive the designating party’s
`
`Proprietary Information pursuant to this Protective Order, excluded from a deposition or
`
`3
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 4 of 16
`
`proceeding, or any portion thereof, before the taking therein of testimony that has been so
`
`designated. The court reporter shall mark the cover of the original and all copies of the transcript
`
`or the portion of the transcript containing testimony designated as either CONFIDENTIAL or
`
`ATTORNEYS EYES ONLY with the appropriate legend.
`
`5.
`
`Belated Designation. Notwithstanding the obligations to timely designate Proprietary
`
`Information under the foregoing paragraphs 3 and 4, nothing contained herein shall preclude a
`
`party or a third party from later changing that designation and notifying the other parties in
`
`writing of that change; provided, however, that it shall not be deemed a breach of this Order for
`
`any action to have been taken by a party or its counsel with respect to such information
`
`consistent with the original designation of such information prior to receipt of such notice. A
`
`party receiving such written notice shall make every reasonable effort to retrieve any such
`
`materials from persons not authorized to receive them pursuant to this Protective Order and to
`
`avoid any further unauthorized disclosure. Any party that changes the designation of any
`
`materials under this Order shall timely provide the other parties to this action with new copies of
`
`the materials with the new designation(s).
`
`6.
`
`Non-use.
`
`All Proprietary Information shall be used only for purposes of this
`
`litigation.
`
`7.
`
`Access to CONFIDENTIAL and ATTORNEYS EYES ONLY Materials.
`
`Materials designated CONFIDENTIAL or ATTORNEYS EYES ONLY shall not be
`
`disclosed to any person except:
`
`a.
`
`the Court and its officers and staff;
`
`4
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 5 of 16
`
`b.
`
`outside counsel of record in this action for each party (i.e., counsel of record for a
`
`party who is not an employee of the party or its affiliates) and employees of such
`
`outside counsel;
`
`c.
`
`outside experts who are not regularly employed by a party and who have been
`
`expressly retained to assist a party’s counsel in the prosecution or defense of the
`
`litigation, and the secretarial, technical and clerical staff of such experts, provided
`
`that such experts have been approved pursuant to paragraph 8 hereof;
`
`current or former employees of the disclosing party during the deposition of such
`
`employees or during examination of such employees at trial;
`
`any party or non-party who authored, received, or reviewed the material prior to
`
`its production in the litigation;
`
`three representatives of each party that are identified to opposing counsel, and
`
`necessary support staff of those individuals, provided that each such
`
`representative has first signed a written statement under oath in the form attached
`
`as Exhibit A hereto, and a copy of that statement has been provided to opposing
`
`counsel;
`
`court reporters and videographers, solely for the purpose of transcribing and/or
`
`recording testimony in the litigation;
`
`independent litigation support services personnel, including copying services,
`
`imaging and coding services, trial exhibit preparation services, solely for the
`
`purpose of assisting a party with the litigation;
`
`d.
`
`e.
`
`f.
`
`g.
`
`h.
`
`i.
`
`trial consultants, jury consultants, and mock jurors, focus group members and the
`
`like selected by trial consultants, jury consultants or by counsel in preparation for
`
`5
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 6 of 16
`
`trial; provided that such persons have executed a confidentiality agreement in the
`
`form of Exhibit A and such agreement shall be kept by counsel for reference; and
`
`j.
`
`other persons as ordered by the Court or agreed to in writing or on the record by
`
`the parties, provided that each such person has first signed a written statement
`
`under oath in the form attached as Exhibit A hereto, and a copy of that statement
`
`has been provided to opposing counsel.
`
`This Protective Order has no effect upon and shall not apply to (1) any party’s use of its
`
`own Proprietary Information for any purpose, or (2) any party’s use of documents or other
`
`information developed or obtained independently of discovery in this action for any purpose.
`
`Nothing herein shall bar or otherwise restrict an attorney, who is a qualified recipient under the
`
`terms of paragraph 7(b) of this Protective Order, from rendering advice to his or her client with
`
`respect to this action, and in the course thereof, from generally relying upon his or her
`
`examination of Proprietary Information. In rendering such advice or in other communications
`
`with the client, the attorney shall not disclose any Proprietary Information of another party or
`
`third party where such disclosure would not otherwise be permitted under the terms of this
`
`Protective Order.
`
`8.
`
`Approval of Experts. A party seeking to disclose another party’s Proprietary Information
`
`to an outside expert shall serve such other party with a copy of the Undertaking attached hereto
`
`as “Exhibit A” signed by the expert, along with the expert’s current resume, identifying (by
`
`employer and position) all past and current employment relating to his or her field of expertise,
`
`including the last five years of employment as a consultant. The party receiving such
`
`Undertaking and resume shall have ten (10) calendar days after such service within which to
`
`object to such disclosure. Failure to object within this period shall be deemed approval. If the
`
`6
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 7 of 16
`
`parties are unable to reach agreement within ten (10) days after service of an objection, the party
`
`objecting to disclosure to an expert shall raise its objection with the Court within fifteen (15)
`
`calendar days of such service of the objection. Failure to raise such objection with the Court
`
`within this period shall be deemed approval. Any party objecting to disclosure to an expert under
`
`this Protective Order shall bear the burden of proving that it will be harmed by such disclosure
`
`and that the protections of this Order are insufficient to reasonably protect such parties’
`
`proprietary interests.
`
`9.
`
`Filing Proprietary Information. Any Proprietary Information that is filed with the
`
`Court shall be filed under seal and shall remain under seal until further order of the Court. The
`
`filing party shall be responsible for informing the Clerk of the Court that the filing should be
`
`sealed and for placing the legend “FILED UNDER SEAL PURSUANT TO PROTECTIVE
`
`ORDER” above the caption and conspicuously on each page of the filing. Exhibits to a filing
`
`shall conform to the labeling requirements set forth in this Protective Order. If a pretrial pleading
`
`filed with the Court, or an exhibit thereto, discloses or relies on confidential documents,
`
`information or material, such confidential portions shall be redacted to the extent necessary and
`
`the pleading or exhibit filed publicly with the Court.
`
`This Protective Order applies to pretrial discovery. Nothing in this Protective Order shall
`
`be deemed to prevent the Parties from introducing any Proprietary Information into evidence at
`
`the trial of this Action, or from using any information contained in Proprietary Information at the
`
`trial of this Action, subject to any pretrial order issued by this Court.
`
`10.
`
`Inadvertent Disclosure of Privileged or Immune Materials.
`
`Federal Rule of Civil
`
`Procedure 26(b)(5)(B) governs the inadvertent or mistaken production of information that is
`
`subject to a claim of privilege or of protection as trial-preparation material. The inadvertent
`
`7
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 8 of 16
`
`disclosure of information that is privileged or otherwise immune from discovery shall not, by
`
`itself, constitute a waiver of the privilege or immunity.
`
`11.
`
`Disclosure of Proprietary Information to Unauthorized Person(s).
`
`If Proprietary
`
`Information is disclosed to any person other than those authorized to receive such information by
`
`this Order, the party responsible for the disclosure shall immediately inform the designating
`
`party of all pertinent facts relating to such disclosure and shall make every reasonable effort to
`
`prevent disclosure by each unauthorized person who received such information and to obtain the
`
`return of such information.
`
`12.
`
`Conclusion of the Litigation.
`
`Within ninety (90) days after entry of a final
`
`judgment or dismissal with prejudice in this litigation (including appeals or petitions for review)
`
`finally disposing of all issues raised in this litigation, counsel for the parties and all other persons
`
`having possession, custody or control of another party’s or third party’s Proprietary Information
`
`shall: (a) destroy all Proprietary Information and any copies thereof, or (b) if requested by the
`
`producing party, return all Proprietary Information and any copies thereof to the producing party.
`
`Notwithstanding paragraph 12(b), a receiving party shall destroy all Proprietary Information of
`
`another party or third party containing or contained in any notes, summaries, digest, synopses or
`
`other documents created by or on behalf of the receiving party. Counsel for each party shall give
`
`a written certification to counsel for all other parties that all of the producing party’s Proprietary
`
`Information has either been destroyed or returned pursuant to this paragraph. If requested,
`
`counsel shall also provide the opposing party with the originals of all Undertaking forms
`
`executed by experts pursuant to paragraph 8.
`
`Notwithstanding the foregoing paragraph, outside counsel may retain (a) copies of the
`
`pleadings and other Court filings, (b) copies of the deposition, hearing, and trial transcripts and
`
`8
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 9 of 16
`
`any related exhibits, and (c) one file copy of all materials produced in this litigation that are
`
`specifically referred to in an expert report, a motion, pleading or other paper filed with the Court.
`
`13.
`
`Contested Designations.
`
`The parties shall use reasonable care to avoid designating
`
`as CONFIDENTIAL or ATTORNEYS EYES ONLY any documents or information that has
`
`been published or otherwise entered the public domain. A party shall not be obligated to
`
`challenge the propriety of any other party’s designation of materials or information as
`
`Proprietary Information at the time such designation is made, and failure promptly to challenge
`
`the designation shall not preclude a subsequent challenge thereto. In the event that a party
`
`disagrees at any stage of these proceedings with the designation of any information as
`
`CONFIDENTIAL or ATTORNEYS EYES ONLY, the parties shall try first to resolve such
`
`dispute in good faith on an informal basis. If the dispute cannot be resolved, the objecting party
`
`may seek appropriate relief from this Court. The party asserting that the material is entitled to
`
`confidential treatment shall have the burden of proof. All Proprietary Information shall remain
`
`under the protection of this Order until otherwise ordered by the Court.
`
`14.
`
`Source Code Protocol.
`
`Source code, which refers to human-readable text files used
`
`as input to computer programs that generate machine-readable files, includes without limitation
`
`files containing program text in “C”, “C++”, assembler, VHDL, Verilog, Java and digital signal
`
`processor (DSP) programming languages. Source code further includes “make” files, link files
`
`and other human-readable text files used in the generation and/or building of software directly
`
`executed on a microprocessor, microcontroller or DSP. Source code does not include binary
`
`executable files and object code files. To the extent that any party seeks the production of source
`
`code, such source code shall be produced pursuant to the following protocol:
`
`a.
`
`Source code shall be designated “ATTORNEYS’ EYES ONLY.”
`
`9
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 10 of 16
`
`b.
`
`The Designating Party shall make all agreed-upon and properly requested source
`
`code available electronically and in text searchable form at a single secure third-
`
`party escrow facility (e.g. Iron Mountain) paid for by the Receiving Party in or
`
`near one geographic location specified by the Receiving Party. The Designating
`
`Party shall make the source code available for inspection on a stand-alone, non-
`
`networked personal computer running a reasonably current version of the
`
`Microsoft Windows operating system (“Source Code Computer”). The Receiving
`
`Party may use appropriate tool software on the Source Code Computer, which
`
`shall be installed by the Designating Party, including text editors like Visual Slick
`
`Edit and multi-file text search tools such as “grep,” and/or an integrated
`
`development environment like Microsoft Visual C++. The Receiving Party and
`
`the Designating Party may agree upon the use of other tools as necessary.
`
`Licensed copies of agreed upon tool software shall be installed on the Source
`
`Code Computer by the Designating Party, with the Receiving Party covering the
`
`cost of the tool software.
`
`i.
`
`The Source Code Computer shall be equipped to print copies of the source
`
`code on watermarked pre-Bates numbered and pre-confidentiality
`
`designated (but otherwise blank) printing paper, which shall be provided
`
`by the Designating Party. Source code may be printed only on such paper
`
`and on the watermarked side of such paper using the printer provided by
`
`the Designating Party and located at the secure facility. Counsel for the
`
`Designating Party will keep the originals of any printed documents, and
`
`copies shall be made for counsel for the Receiving Party on watermarked
`
`10
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 11 of 16
`
`paper either at the time they are requested (if less than 100 pages) or
`
`within 72 hours (if more than 100 pages). Counsel for the Receiving Party
`
`may request up to 10 copies of printed source code. No more than 3000
`
`pages of the total source code for any software release or any hardware
`
`product may be in printed form at any one time, and all printed source
`
`code shall be logged by the Receiving Party as noted in Paragraph 11.c.iii
`
`below. If necessary, the Receiving Party may request to print additional
`
`pages in excess of the 3000 pages of total source code for a software
`
`release, which request the Designating Party shall not unreasonably deny.
`
`In addition to other reasonable steps to maintain the security and
`
`confidentiality of the Designating Party’s source code, printed copies of
`
`the source code maintained by the Receiving Party must be kept in a
`
`locked storage container when not in use. Other than in connection with
`
`pleadings filed under seal and depositions designated “ATTORNEYS’
`
`EYES ONLY”, no subsequent copies shall be made of the printed copies
`
`provided by the Designating Party to the Receiving Party. Hard copies of
`
`the source code also may not be converted into an electronic document
`
`and may not be scanned using optical character recognition (“OCR")
`
`technology, except that non-OCR PDF or TIFF copies of watermarked,
`
`Bates-labeled source code printouts may be created solely if required for
`
`filing with the court or for use as a trial exhibit. No electronic copies of the
`
`source code printouts, or portions thereof, will be provided except upon
`
`agreement of the parties or by Court order.
`
`11
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 12 of 16
`
`c.
`
`Before any individual who is permitted to receive “ATTORNEYS’ EYES ONLY
`
`INFORMATION” (excluding those individuals identified under Section 7.f)
`
`accesses source code for the first time and at least ten (10) business days before
`
`any such access, the Receiving Party’s outside counsel shall provide to outside
`
`counsel for the Designating Party the names of any individual seeking access to
`
`the Designating Party’s source code.
`
`i.
`
`Thereafter, individuals who have been previously identified according to
`
`this Paragraph may access the secure facility, consistent with the normal
`
`practice at the facility, without further approval, although the Designating
`
`Party shall be informed at least two (2) business days before any such
`
`person accesses the secure facility. Any person or party who fails to
`
`observe the notice requirement may be denied access.
`
`ii.
`
`No more than five (5) individuals for the Receiving Party who qualify
`
`under Paragraph 7 may have access to the Source Code Computer. In
`
`addition, no more than ten (10) additional individuals for the Receiving
`
`Party who qualify under Paragraph 7 may have access to printed copies of
`
`any portion of the Designating Party’s source code.
`
`iii.
`
`The Receiving Party’s counsel shall keep a log that records the identity of
`
`each individual to whom each hard copy of the source code is provided
`
`and when it was provided to that person. Such a log shall be provided to
`
`the Designating Party upon reasonable request during the pendency of this
`
`litigation and, in all events, at the conclusion of this litigation, including
`
`appeals.
`
`12
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 13 of 16
`
`d.
`
`If any individual inspecting the Designating Party’s source code seeks to take
`
`notes, all such notes will be taken on bound (spiral or other type of permanently
`
`bound) notebooks. No loose paper or other paper that can be used in a printer may
`
`be brought into the secure facility.
`
`e.
`
`Except for the computer and printer specified in Paragraph 11.b, no computer
`
`component or peripheral that may be suitable for use with the Source Code
`
`Computer or printer in the room (including hard drives and floppy drives, tape
`
`drives, modems, modem cards, memory sticks, thumb drives, etc.) is permitted in
`
`the secure facility.
`
`f.
`
`At the end of each working day, all originally printed pages will be left at the
`
`secure facility for identified representatives of the Designating Party. Unless a
`
`request has been made pursuant to Paragraph 11.b.i, within 72 hours, such
`
`representative will provide one photocopy of the selected source code to an
`
`individual designated by the Receiving Party that selected that source code.
`
`No originally printed paper shall be removed from the facility other than by
`
`representatives of the Designating Party.
`
`The Designating Party shall not record, monitor, or otherwise attempt to obtain
`
`the work product of the Receiving Party during the inspection.
`
`Nothing in this Paragraph 14 is intended to waive or concede any party’s right to
`
`challenge the necessity of source code production or the scope of any such
`
`g.
`
`h.
`
`i.
`
`production.
`
`13
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 14 of 16
`
`15.
`
`Trial Procedures. A party may request that the Court implement appropriate
`
`procedures to protect Proprietary Information that may be disclosed at the trial or any hearing in
`
`this matter consistent with the spirit and scope of this Order.
`
`16.
`
` Modification.Stipulations may be made between counsel for the respective parties as to
`
`the application of this Order to specific situations provided that such stipulations are recorded in
`
`writing or contained in the record of any oral proceeding. Nothing contained herein shall
`
`preclude any party from seeking an order of the Court modifying or supplementing this Order.
`
`17.
`
`Effect. This Protective Order shall continue in effect until further order of this Court.
`
`14
`
`So ORDERED and SIGNED this 15th day of March, 2016.
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 15 of 16
`
`EXHIBIT A
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`SIPCO, LLC, and IP CO, LLC
`(d/b/a INTUS IQ),
`
`Plaintiffs,
`
` v.
`
` Civil Action No. 6:15-cv-907
`
`EMERSON ELECTRIC CO., EMERSON
`PROCESS MANAGEMENT LLLP, FISHER-
`ROSEMOUNT SYSTEMS, INC.,
`ROSEMOUNT INC., BP, p.l.c., BP
`AMERICA, INC., and BP AMERICA
`PRODUCTION COMPANY,
`
`Defendants.
`
`UNDERTAKING AND CONSENT TO BE BOUND BY
`PROTECTIVE ORDER
`
`I, ___________________________________, hereby declare as follows:
`
`1.
`
`My address is ________________________________________________
`
`_____________________________________________. My current employer is
`
`_________________________________________. My current occupation is
`
`_________________________________________.
`
`2.
`
`I have received a copy of the Protective Order entered in the above-captioned
`
`action (the “Protective Order”). I have carefully read and understand the provisions of the
`
`Protective Order.
`
`3.
`
`I will comply with all the provisions of the Protective Order. I will hold in
`
`confidence, will not disclose to anyone not qualified under the Protective Order, and will use
`
`only for purposes of this action any Proprietary Information that is disclosed to me.
`
`15
`
`

`

`Case 1:16-cv-02690-AT Document 68 Filed 03/15/16 Page 16 of 16
`
`4.
`
`Promptly upon termination of this action, I will return all Proprietary Information
`
`that came into my possession, and all documents and things that I have prepared relating thereto,
`
`to counsel for the party by whom I am employed or retained.
`
`5.
`
`I hereby submit to the jurisdiction of this Court for the purpose of enforcement of
`
`the Protective Order in this action.
`
`6.
`
`I understand that this Undertaking and the Protective Order are enforceable after
`
`the termination of this action.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: ____________________
`
`____________________________________
`(Signature)
`
`____________________________________
`(Printed Name)
`
`16
`
`