# Fite v. Shamrock Foods Company

> District Court, E.D. California · November 29, 2021

URL: https://www.frixlaw.com/law-library/cases/10031936

## Case

- **Court:** District Court, E.D. California
- **Decided:** November 29, 2021
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 SHTEACNTO SR. M RA. MLLAIRSOTINN (ECZa l(.C Satla. tSe tBataer BNaor. N1o84. 2109613) 36)
DANIEL C. KELLER (Cal. State Bar No 332576)
2 MALLISON & MARTINEZ
1939 Harrison Street, Suite 730
3 Oakland, California 94612-3547
Telephone: (510) 832-9999
4 Facsimile: (510) 832-1101
stanm@themmlawfirm.com
5 hectorm@themmlawfirm.com
dkeller@themmlawfirm.com
6
Attorneys for Plaintiff
7 GLENN FITE

8 ANDREW J. SOMMER (Cal. State Bar No. 192844)
MEGAN S. SHAKED (Cal. State Bar No. 274174)
9 CONN MACIEL CAREY LLP
870 Market Street, Suite 1151
10 San Francisco, California 94102
Telephone: (415) 268-8894
11 Facsimile: (415) 268-8889
asommer@connmaciel.com
12 mshaked@connmaciel.com

13 Attorneys for Defendant,
SHAMROCK FOODS COMPANY
14
UNITED STATES DISTRICT COURT
15
EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION
16
GLENN FITE, individually, and CASE NO. 2:21-CV-00023-JAM-KJN
17 acting on behalf of a class of
similarly situated employees, Before the Honorable John A. Mendez
18
Plaintiff, STIPULATED PROTECTIVE
19 ORDER
v.
20
SHAMROCK FOODS COMPANY;
21 an Arizona corporation, and DOES 1 Trial Set: October 3, 2022
to 50, inclusive,
22
Defendants.
23
24
1. 1.1. PURPOSES AND LIMITATIONS
25
Discovery in this action is likely to involve production of confidential,
26
proprietary or private information for which special protection from public
27
disclosure and from use for any purpose other than prosecuting this litigation may
1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
enter the following Stipulated Protective Order. The parties acknowledge that this
2
Order does not confer blanket protections on all disclosures or responses to
3
discovery and that the protection it affords from public disclosure and use extends
4
only to the limited information or items that are entitled to confidential treatment
5
under the applicable legal principles. The parties further acknowledge, as set forth
6
in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
7
file confidential information under seal; Local Rule 141 sets forth the procedures
8
that must be followed and the standards that will be applied when a party seeks
9
permission from the court to file material under seal.
10
1.2. GOOD CAUSE STATEMENT
11
This action is likely to involve trade secrets, confidential, and proprietary
12
information for which special protection from public disclosure and from use for
13
any purpose other than prosecution of this action is warranted. Such confidential
14
and proprietary materials and information consist of, among other things,
15
confidential business or financial information, information regarding confidential
16
business practices, or other confidential research, development, or commercial
17
information (including information implicating privacy rights of employees and
18
other third parties), information otherwise generally unavailable to the public, or
19
which may be privileged or otherwise protected from disclosure under state or
20
federal statutes, court rules, case decisions, or common law. Accordingly, to
21
expedite the flow of information, to facilitate the prompt resolution of disputes over
22
confidentiality of discovery materials, to adequately protect information the parties
23
are entitled to keep confidential, to ensure that the parties are permitted reasonable
24
necessary uses of such material in preparation for and in the conduct of trial, to
25
address their handling at the end of the litigation, and serve the ends of justice, a
26
protective order for such information is justified in this matter. It is the intent of the
27
parties that information will not be designated as confidential for tactical reasons
1 and that nothing be so designated without a good faith belief that it has been
maintained in a confidential, non-public manner, and there is good cause why it
2
should not be part of the public record of this case.
3
2. DEFINITIONS
4
2.1 Action: This pending class action in this Court entitled, Glenn Fite v.
5
Shamrock Foods Company, an Arizona corporation, and DOES 1 to 50, Case
6
No. 2:21-CV-00023-JAM-KJN.
7
2.2 Challenging Party: a Party or Non-Party that challenges the
8
designation of information or items under this Order.
9
2.3 “CONFIDENTIAL” Information or Items: information (regardless of
10
how it is generated, stored or maintained) or tangible things that qualify for
11
protection under Federal Rule of Civil Procedure 26(c), and as specified above in
12
the Good Cause Statement.
13
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
14
their support staff).
15
2.5 Designating Party: a Party or Non-Party that designates information or
16
items that it produces in disclosures or in responses to discovery as
17
“CONFIDENTIAL.”
18
2.6 Disclosure or Discovery Material: all items or information, regardless
19
of the medium or manner in which it is generated, stored, or maintained (including,
20
among other things, testimony, transcripts, and tangible things), that are produced
21
or generated in disclosures or responses to discovery in this matter.
22
2.7 Expert: a person with specialized knowledge or experience in a matter
23
pertinent to the litigation who has been retained by a Party or its counsel to serve as
24
an expert witness or as a consultant in this Action.
25
2.8 House Counsel: attorneys who are employees of a corporate party to
26
this Action. House Counsel does not include Outside Counsel of Record or any
27
other outside counsel.
1 2.9 Non-Party: any natural person, partnership, corporation, association or
other legal entity not named as a Party to this action.
2
2.10 Outside Counsel of Record: attorneys who are not employees of a
3
party to this Action but are retained to represent a party to this Action and have
4
appeared in this Action on behalf of that party.
5
2.11 Party: any natural person, partnership, corporation, association or other
6
legal entity named as a party to this Action.
7
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
8
Discovery Material in this Action.
9
2.13 Professional Vendors: persons or entities that provide litigation
10
support services (e.g., photocopying, videotaping, translating, preparing exhibits or
11
demonstrations, and organizing, storing, or retrieving data in any form or medium)
12
and their employees and subcontractors.
13
2.14 Protected Material: any Disclosure or Discovery Material that is
14
designated as “CONFIDENTIAL.”
15
2.15 Receiving Party: a Party that receives Disclosure or Discovery
16
Material from a Producing Party.
17
3. SCOPE
18
The protections conferred by this Stipulation and Order cover not only
19
Protected Material (as defined above), but also (1) any information copied or
20
extracted from Protected Material; (2) all copies, excerpts, summaries, or
21
compilations of Protected Material; and (3) any testimony, conversations, or
22
presentations by Parties or their Counsel that might reveal Protected Material.
23
Any use of Protected Material at trial shall be governed by the orders of the
24
trial judge. This Order does not govern the use of Protected Material at trial.
25
4. DURATION
26
Even after final disposition of this litigation, the confidentiality obligations
27
imposed by this Order shall remain in effect until a Designating Party agrees
1 otherwise in writing or a court order otherwise directs. Final disposition shall be
deemed to be the later of (1) dismissal of all claims and defenses in this Action,
2
with or without prejudice; and (2) final judgment herein after the completion and
3
exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
4
including the time limits for filing any motions or applications for extension of time
5
pursuant to applicable law.
6
5. DESIGNATING PROTECTED MATERIAL
7
5.1 Exercise of Restraint and Care in Designating Material for Protection.
8
Each Party or Non-Party that designates information or items for protection
9
under this Order must take care to limit any such designation to specific material
10
that qualifies under the appropriate standards. The Designating Party must
11
designate for protection only those parts of material, documents, items or oral or
12
written communications that qualify so that other portions of the material,
13
documents, items or communications for which protection is not warranted are not
14
swept unjustifiably within the ambit of this Order.
15
Mass, indiscriminate or routinized designations are prohibited. Designations
16
that are shown to be clearly unjustified or that have been made for an improper
17
purpose (e.g., to unnecessarily encumber the case development process or to
18
impose unnecessary expenses and burdens on other parties) may expose the
19
Designating Party to sanctions.
20
If it comes to a Designating Party’s attention that information or items that it
21
designated for protection do not qualify for protection, that Designating Party must
22
promptly notify all other Parties that it is withdrawing the inapplicable designation.
23
5.2 Manner and Timing of Designations. Except as otherwise provided in
24
this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
25
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26
under this Order must be clearly so designated before the material is disclosed or
27
produced.
1 Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
2
documents, but excluding transcripts of depositions or other pretrial or trial
3
proceedings), that the Producing Party affix at a minimum, the legend
4
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5
contains protected material. If only a portion of the material on a page qualifies for
6
protection, the Producing Party also must clearly identify the protected portion(s)
7
(e.g., by making appropriate markings in the margins).
8
A Party or Non-Party that makes original documents available for inspection
9
need not designate them for protection until after the inspecting Party has indicated
10
which documents it would like copied and produced. During the inspection and
11
before the designation, all of the material made available for inspection shall be
12
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
13
documents it wants copied and produced, the Producing Party must determine
14
which documents, or portions thereof, qualify for protection under this Order. Then,
15
before producing the specified documents, the Producing Party must affix the
16
“CONFIDENTIAL legend” to each page that contains Protected Material. If only a
17
portion of the material on a page qualifies for protection, the Producing Party also
18
must clearly identify the protected portion(s) (e.g., by making appropriate markings
19
in the margins).
20
(b) for testimony given in depositions that the Designating Party
21
identifies the Disclosure or Discovery Material on the record, within 30 days of
22
receipt of the deposition transcript all protected testimony.
23
(c) for information produced in some form other than documentary and
24
for any other tangible items, that the Producing Party affix in a prominent place on
25
the exterior of the container or containers in which the information is stored the
26
legend “CONFIDENTIAL.” If only a portion or portions of the information
27
warrants protection, the Producing Party, to the extent practicable, shall identify the
1 protected portion(s).
5.3 Inadvertent Failures to Designate. If timely corrected upon discovery,
2
an inadvertent failure to designate qualified information or items does not, standing
3
alone, waive the Designating Party’s right to secure protection under this Order for
4
such material. Upon timely correction of a designation, the Receiving Party must
5
make reasonable efforts to assure that the material is treated in accordance with the
6
provisions of this Order.
7
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
9
designation of confidentiality at any time that is consistent with the Court’s
10
Scheduling Order.
11
6.2 Meet and Confer. The Challenging Party shall meet and confer with
12
the Designating Party before filing a motion with the court.
13
6.3 The burden of persuasion in any such challenge proceeding shall be on
14
the Designating Party. Frivolous challenges, and those made for an improper
15
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
16
parties) may expose the Challenging Party to sanctions. Unless the Designating
17
Party has waived or withdrawn the confidentiality designation, all parties shall
18
continue to afford the material in question the level of protection to which it is
19
entitled under the Producing Party’s designation until the Court rules on the
20
challenge.
21
7. ACCESS TO AND USE OF PROTECTED MATERIAL
22
7.1 Basic Principles. A Receiving Party may use Protected Material that is
23
disclosed or produced by another Party or by a Non-Party in connection with this
24
Action only for prosecuting, defending or attempting to settle this Action. Such
25
Protected Material may be disclosed only to the categories of persons and under the
26
conditions described in this Order. When the Action has been terminated, a
27
Receiving Party must comply with the provisions of section 13 below (FINAL
1 DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
2
location and in a secure manner that ensures that access is limited to the persons
3
authorized under this Order.
4
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5
otherwise ordered by the court or permitted in writing by the Designating Party, a
6
Receiving Party may disclose any information or item designated
7
“CONFIDENTIAL” only to:
8
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
9
well as employees of said Outside Counsel of Record to whom it is reasonably
10
necessary to disclose the information for this Action;
11
(b) Where the Receiving Party is a partnership, corporation,
12
association or other legal entity, the officers, directors, and employees (including
13
House Counsel) of that Receiving Party to whom disclosure is reasonably necessary
14
for this Action;
15
(c) Experts (as defined in this Order) of the Receiving Party to whom
16
disclosure is reasonably necessary for this Action and who have signed the
17
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
18
(d) the court and its personnel;
19
(e) engaged court reporters and their staff;
20
(f) engaged professional jury or trial consultants, mock jurors, and
21
Professional Vendors to whom disclosure is reasonably necessary for this Action
22
and who have signed the “Acknowledgment and Agreement to Be Bound”
23
(Exhibit A);
24
(g) an individual who authored or has personal knowledge of that
25
information provided that individual (1) has signed the form attached as Exhibit A
26
hereto, and (2) is not permitted to keep any confidential information, unless
27
otherwise agreed by the Designating Party or ordered by the court;
1 (h) during their depositions, witnesses, and attorneys for witnesses, in
the Action to whom disclosure is reasonably necessary provided: (1) the deposing
2
party requests that the witness sign the form attached as Exhibit A hereto; and (2)
3
they will not be permitted to keep any confidential information, unless otherwise
4
agreed by the Designating Party or ordered by the court. Pages of transcribed
5
deposition testimony or exhibits to depositions that reveal Protected Material may
6
be separately bound by the court reporter and may not be disclosed to anyone
7
except as permitted under this Stipulated Protective Order; and
8
(i) any mediator or settlement officer, and their supporting personnel,
9
mutually agreed upon by any of the parties engaged in settlement discussions.
10
7.3 Aggrieved Employee Information. Contact information and any other
11
personal identifying information for aggrieved employees pursuant to Plaintiff’s
12
Private Attorneys General Act claims shall only be used for purposes of this action,
13
and for no other reason.
14
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
15
IN OTHER LITIGATION
16
If a Party is served with a subpoena or a court order issued in other litigation
17
that compels disclosure of any information or items designated in this Action as
18
“CONFIDENTIAL,” that Party must:
19
(a) promptly notify in writing the Designating Party. Such notification shall
20
include a copy of the subpoena or court order;
21
(b) promptly notify in writing the party who caused the subpoena or order to
22
issue in the other litigation that some or all of the material covered by the subpoena
23
or order is subject to this Protective Order. Such notification shall include a copy of
24
this Stipulated Protective Order; and
25
(c) cooperate with respect to all reasonable procedures sought to be pursued
26
by the Designating Party whose Protected Material may be affected.
27
If the Designating Party timely seeks a protective order, the Party served with
1 the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” before a determination by the court from which the
2
subpoena or order issued, unless the Party has obtained the Designating Party’s
3
permission. The Designating Party shall bear the burden and expense of seeking
4
protection in that court of its confidential material and nothing in these provisions
5
should be construed as authorizing or encouraging a Receiving Party in this Action
6
to disobey a lawful directive from another court.
7
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
8
PRODUCED IN THIS LITIGATION
9
(a) The terms of this Order are applicable to information produced by a Non-
10
Party in this Action and designated as “CONFIDENTIAL.” Such information
11
produced by Non-Parties in connection with this litigation is protected by the
12
remedies and relief provided by this Order. Nothing in these provisions should be
13
construed as prohibiting a Non-Party from seeking additional protections.
14
(b) In the event that a Party is required, by a valid discovery request, to
15
produce a Non-Party’s confidential information in its possession, and the Party is
16
subject to an agreement with the Non-Party not to produce the Non-Party’s
17
confidential information, then the Party shall:
18
(1) promptly notify in writing the Requesting Party and the Non-Party
19
that some or all of the information requested is subject to a confidentiality
20
agreement with a Non-Party;
21
(2) promptly provide the Non-Party with a copy of the Stipulated
22
Protective Order in this Action, the relevant discovery request(s), and a reasonably
23
specific description of the information requested; and
24
(3) make the information requested available for inspection by the
25
Non-Party, if requested.
26
(c) If the Non-Party fails to seek a protective order from this court within 14
27
days of receiving the notice and accompanying information, the Receiving Party
1 may produce the Non-Party’s confidential information responsive to the discovery
request. If the Non-Party timely seeks a protective order, the Receiving Party shall
2
not produce any information in its possession or control that is subject to the
3
confidentiality agreement with the Non-Party before a determination by the court.
4
Absent a court order to the contrary, the Non-Party shall bear the burden and
5
expense of seeking protection in this court of its Protected Material.
6
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
7
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
8
Protected Material to any person or in any circumstance not authorized under this
9
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
10
writing the Designating Party of the unauthorized disclosures, (b) use its best
11
efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
12
person or persons to whom unauthorized disclosures were made of all the terms of
13
this Order, and (d) request such person or persons to execute the “Acknowledgment
14
and Agreement to Be Bound” that is attached hereto as Exhibit A.
15
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
16
PROTECTED MATERIAL
17
When a Producing Party gives notice to Receiving Parties that certain
18
inadvertently produced material is subject to a claim of privilege or other
19
protection, the obligations of the Receiving Parties are those set forth in Federal
20
Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
21
whatever procedure may be established in an e-discovery order that provides for
22
production without prior privilege review. Pursuant to Federal Rule of Evidence
23
502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
24
of a communication or information covered by the attorney-client privilege or work
25
product protection, the parties may incorporate their agreement in the stipulated
26
protective order submitted to the court.
27
1 12. MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
2
person to seek its modification by the Court in the future.
3
12.2 Right to Assert Other Objections. By stipulating to the entry of this
4
Protective Order, no Party waives any right it otherwise would have to object to
5
disclosing or producing any information or item on any ground not addressed in
6
this Stipulated Protective Order. Similarly, no Party waives any right to object on
7
any ground to use in evidence of any of the material covered by this Protective
8
Order.
9
12.3 Filing Protected Material. A Party that seeks to file under seal any
10
Protected Material must comply with Civil Rule 141. Protected Material may only
11
be filed under seal pursuant to a court order authorizing the sealing of the specific
12
Protected Material at issue. If a Party’s request to file Protected Material under seal
13
is denied by the court, then the Receiving Party may file the information in the
14
public record unless otherwise instructed by the court.
15
13. FINAL DISPOSITION
16
After the final disposition of this Action, as defined in Section 4, within 60
17
days of a written request by the Designating Party, each Receiving Party must
18
return all Protected Material to the Producing Party or destroy such material. As
19
used in this subdivision, “all Protected Material” includes all copies, abstracts,
20
compilations, summaries, and any other format reproducing or capturing any of the
21
Protected Material. Whether the Protected Material is returned or destroyed, the
22
Receiving Party must submit a written certification to the Producing Party (and, if
23
not the same person or entity, to the Designating Party) by the 60 day deadline that
24
(1) identifies (by category, where appropriate) all the Protected Material that was
25
returned or destroyed and (2) affirms that the Receiving Party has not retained any
26
copies, abstracts, compilations, summaries or any other format reproducing or
27
capturing any of the Protected Material. Notwithstanding this provision, Counsel
1 are entitled to retain an archival copy of all pleadings, motion papers, trial,
deposition, and hearing transcripts, legal memoranda, correspondence, deposition
2
and trial exhibits, expert reports, attorney work product, and consultant and expert
3
work product, even if such materials contain Protected Material. Any such archival
4
copies that contain or constitute Protected Material remain subject to this Protective
5
Order as set forth in Section 4 (DURATION).
6
14. REMEDIES
7
Any violation of this Order may be punished by appropriate measures
8
including, without limitation, contempt proceedings and/or monetary sanctions.
9
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
10 DATED: November 29, 2021 LAUBY MANKIN & LAUBY, LLP

11

12 By
:
13
Stan S. Mallison
14 Hector R. Martinez
Liliana Garcia
15
Daniel Keller
16 Attorney for Plaintiff
GLENN FITE
17

18 DATED: November 29, 2021 CONN MACIEL CAREY LLP

19

20 By
21 : Andrew J. Sommer
Megan S. Shaked
22 Attorneys for Defendant
23 SHAMROCK FOODS COMPANY

24
25 ORDER
The court has reviewed the parties’ stipulated protective order. (See ECF
26
No. 24). The stipulation lists categories of information sought to be protected (see
27
1 . . . we
Section 1.2 above), and otherwise comports with the relevant authorities and the
2 .
court’s applicable local rule. See L.R. 141.1(c);! see also Phillips ex rel. Estates of
3 .
Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210 (9th Cir. 2002) (requiring a
4 . . .
showing of good cause for protective orders). The court APPROVES the protective
5 . . . .
order subject to the following clarification. The Local Rules state that once an
action is closed, “unless otherwise ordered, the court will not retain jurisdiction
7 . . .
over enforcement of the terms of any protective order filed in that action.” L.R.
141.1(f). Courts in the district generally do not agree to retain jurisdiction for
9 . . .
disputes concerning protective orders after closure of the case. See, e.g., MD
10 .
Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 (E.D. Cal., Feb. 03, 2017).
1] . Coke ge ge . . .
Thus, the court will not retain jurisdiction over this protective order once the case is
12
closed.
13
Dated: November 29, 2021
14 —-f’ \
KENDALL J. □□
16 UNITED STATES MAGISTRATE JUDGE
17 fite.23
18
19
20
21
22
23
24 ' The Court’s Local Rules instruct the parties, when requesting a protective order, to include in their submission:
(1) A description of the types of information eligible for protection under the order, with the
25 description provided in general terms sufficient to reveal the nature of the information (e.g.,
customer list, formula for soda, diary of a troubled child);
(2) A showing of particularized need for protection as to each category of information proposed
26 to be covered by the order; and
(3) A showing as to why the need for protection should be addressed by a court order, as opposed
27 to a private agreement between or among the parties.
28 Local Rule 141.1(c).

1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
I, _____________________________ [print or type full name], of
3
_________________ [print or type full address], declare under penalty of perjury
4
that I have read in its entirety and understand the Stipulated Protective Order that
5
was issued by the United States District Court for the Eastern District of California
6
on [date] in the case of Glenn Fite v. Shamrock Foods Company, an Arizona
7
corporation, and DOES 1 to 50, Case No. 2:21-CV-00023-JAM-KJN. I agree to
8
comply with and to be bound by all the terms of this Stipulated Protective Order
9
and I understand and acknowledge that failure to so comply could expose me to
10
sanctions and punishment in the nature of contempt. I solemnly promise that I will
11
not disclose in any manner any information or item that is subject to this Stipulated
12
Protective Order to any person or entity except in strict compliance with the
13
provisions of this Order.
14
I further agree to submit to the jurisdiction of the United States District Court for
15
the Eastern District of California for enforcing the terms of this Stipulated
16
Protective Order, even if such enforcement proceedings occur after termination of
17
this action. I hereby appoint __________________________ [print or type full
18
name] of _______________________________________ [print or type full
19
address and telephone number] as my California agent for service of process in
20
connection with this action or any proceedings related to enforcement of this
21
Stipulated Protective Order.
22
Date: ______________________________________
23
City and State where sworn and signed: _________________________________
24
Printed name: _______________________________
25
Signature: __________________________________
26
27

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10031936. Public record. Not legal advice.