Opinion

The Travelers Indemnity Company of Connecticut v. Sky High Investment Company LLC

Court
District Court, C.D. California
Filed
Jun 22, 2020
Cited by
0 cases
Authority
More cited than 17.9%

even stipulated protective orders require good 5 cause showing

How later courts described this case

  • even stipulated protective orders require good 5 cause showing

Written by the judges who cited it.

The opinion

1 DAVID R. FISHER, ESQ. (SBN 119773)

JEFFREY R. KLEIN, ESQ. (SBN 273310)

2 FISHER & WOLFE, LLP

9401 Wilshire Boulevard, Suite 640

3 Beverly Hills, California 90212-2913

Telephone: (310) 278-4300

4 Facsimile: (310) 278-5430

E-mail: drf@fisherwolfe.com

5

Attorneys for Defendants Sky High

6 Investment Company LLC, Morad Ben

Neman and Neman Real Estate

7 Investments, LLC

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DISTRICT

10

THE TRAVELERS INDEMNITY CASE NO.: 2:19-cv-08706-JFW (SPx)

11 COMPANY OF CONNECTICUT, a

Connecticut Corporation, STIPULATED PROTECTIVE

12 ORDER

Plaintiffs,

13

v.

14

SKY HIGH INVESTMENT COMPANY

15 LLC, a California Limited Liability Complaint October 9, 2019

Company, MORAD BEN NEMAN, an Filed:

16 individual, NEMAN REAL ESTATE

INVESTMENTS, LLC, a California

17 Limited Liability Company, and DOES 1-

10,

18

Defendants.

19

1. PURPOSES AND LIMITATIONS

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Discovery in this Action is likely to involve production of confidential,

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proprietary or private information for which special protection from public disclosure

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and from use for any purpose other than pursuing this litigation may be warranted.

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Accordingly, the parties hereby stipulate to and petition the Court to enter the following

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Stipulated Protective Order. The parties acknowledge that this Order does not confer

25

blanket protections on all disclosures or responses to discovery and that the protection it

26

affords from public disclosure and use extends only to the limited information or items

27

that are entitled to confidential treatment under the applicable legal principles.

1 2. GOOD CAUSE STATEMENT

2 This Action is likely to involve trade secrets, customer and pricing lists and other

3 valuable research, development, commercial, financial, technical and/or proprietary

4 information for which special protection from public disclosure and from use for any

5 purpose other than prosecution of this Action is warranted. Such confidential and

6 proprietary materials and information consist of, among other things, confidential

7 business or financial information, information regarding confidential business practices,

8 or other confidential research, development, or commercial information (including

9 information implicating privacy rights of third parties), information otherwise generally

10 unavailable to the public, or which may be privileged or otherwise protected from

11 disclosure under state or federal statutes, court rules, case decisions, or common law.

12 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of

13 disputes over confidentiality of discovery materials, to adequately protect information

14 the parties are entitled to keep confidential, to ensure that the parties are permitted

15 reasonable necessary uses of such material in preparation for and in the conduct of trial,

16 to address their handling at the end of the litigation, and serve the ends of justice, a

17 protective order for such information is justified in this matter. It is the intent of the

18 parties that information will not be designated as confidential for tactical reasons and

19 that nothing be so designated without a good faith belief that it has been maintained in a

20 confidential, non-public manner, and there is good cause why it should not be part of the

21 public record of this case.

22 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE

23 The parties further acknowledge, as set forth in Section 14.3, below, that this

24 Stipulated Protective Order does not entitle them to file confidential information under

25 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the

26 standards that will be applied when a party seeks permission from the court to file

27 material under seal. There is a strong presumption that the public has a right of access to

1 motions, good cause must be shown to support a filing under seal. See Kamakana v. City

2 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

3 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

4 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

5 cause showing), and a specific showing of good cause or compelling reasons with proper

6 evidentiary support and legal justification, must be made with respect to Protected

7 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure

8 or Discovery Material as CONFIDENTIAL does not— without the submission of

9 competent evidence by declaration, establishing that the material sought to be filed under

10 seal qualifies as confidential, privileged, or otherwise protectable—constitute good

11 cause.

12 Further, if a party requests sealing related to a dispositive motion or trial, the

13 compelling reasons, not only good cause, for the sealing must be shown, and the relief

14 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

15 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type

16 of information, document, or thing sought to be filed or introduced under seal, the party

17 seeking protection must articulate compelling reasons, supported by specific facts and

18 legal justification, for the requested sealing order. Again, competent evidence supporting

19 the application to file documents under seal must be provided by declaration.

20 Any document that is not confidential, privileged, or otherwise protectable in its

21 entirety will not be filed under seal if the confidential portions can be redacted. If

22 documents can be redacted, then a redacted version for public viewing, omitting only

23 the confidential, privileged, or otherwise protectable portions of the document, shall be

24 filed. Any application that seeks to file documents under seal in their entirety should

25 include an explanation of why redaction is not feasible.

26 4. DEFINITIONS

27 4.1. Action: this pending federal lawsuit.

1 information or items under this Order.

2 4.3. “CONFIDENTIAL” Information or Items: information (regardless of how

3 it is generated, stored or maintained) or tangible things that qualify for protection under

4 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

5 Statement.

6 4.4. Counsel: Outside Counsel of Record and House Counsel (as well as their

7 support staff).

8 4.5. Designating Party: a Party or Non-Party that designates information or

9 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

10 4.6. Disclosure or Discovery Material: all items or information, regardless of

11 the medium or manner in which it is generated, stored, or maintained (including, among

12 other things, testimony, transcripts, and tangible things), that are produced or generated

13 in disclosures or responses to discovery in this matter.

14 4.7. Expert: a person with specialized knowledge or experience in a matter

15 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

16 expert witness or as a consultant in this Action.

17 4.8. House Counsel: attorneys who are employees of a party to this Action.

18 House Counsel does not include Outside Counsel of Record or any other outside counsel.

19 4.9. Non-Party: any natural person, partnership, corporation, association, or

20 other legal entity not named as a Party to this Action.

21 4.10. Outside Counsel of Record: attorneys who are not employees of a party to

22 this Action but are retained to represent or advise a party to this Action and have

23 appeared in this Action on behalf of that party or are affiliated with a law firm that has

24 appeared on behalf of that party or are affiliated with a law firm that has appeared on

25 behalf of that party, and includes support staff.

26 4.11. Party: any party to this Action, including all of its officers, directors,

27 employees, consultants, retained experts, and Outside Counsel of Record (and their

1 4.12. Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this Action.

3 4.13. Professional Vendors: persons or entities that provide litigation support

4 services (e.g., photocopying, videotaping, translating, preparing exhibits or

5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

6 their employees and subcontractors.

7 4.14. Protected Material: any Disclosure or Discovery Material that is designated

8 as “CONFIDENTIAL.”

9 4.15. Receiving Party: a Party that receives Disclosure or Discovery Material

10 from a Producing Party.

11 5. SCOPE

12 The protections conferred by this Stipulation and Order cover not only Protected

13 Material (as defined above), but also (1) any information copied or extracted from

14 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

15 Material; and (3) any testimony, conversations, or presentations by Parties or their

16 Counsel that might reveal Protected Material.

17 Any use of Protected Material at trial shall be governed by the orders of the trial

18 judge and other applicable authorities. This Order does not govern the use of Protected

19 Material at trial.

20 6. DURATION

21 Once a case proceeds to trial, information that was designated as

22 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as

23 an exhibit at trial becomes public and will be presumptively available to all members of

24 the public, including the press, unless compelling reasons supported by specific factual

25 findings to proceed otherwise are made to the trial judge in advance of the trial. See

26 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing

27 documents produced in discovery from “compelling reasons” standard when merits-

1 order do not extend beyond the commencement of the trial.

2 7. DESIGNATING PROTECTED MATERIAL

3 7.1. Exercise of Restraint and Care in Designating Material for Protection. Each

4 Party or Non-Party that designates information or items for protection under this Order

5 must take care to limit any such designation to specific material that qualifies under the

6 appropriate standards. The Designating Party must designate for protection only those

7 parts of material, documents, items, or oral or written communications that qualify so

8 that other portions of the material, documents, items, or communications for which

9 protection is not warranted are not swept unjustifiably within the ambit of this Order.

10 Mass, indiscriminate, or routinized designations are prohibited. Designations that

11 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

12 to unnecessarily encumber or retard the case development process or to impose

13 unnecessary expenses and burdens on other parties) expose the Designating Party to

14 sanctions.

15 If it comes to a Designating Party’s attention that information or items that it

16 designated for protection do not qualify for protection, that Designating Party must

17 promptly notify all other Parties that it is withdrawing the mistaken designation.

18 7.2. Manner and Timing of Designations. Except as otherwise provided in this

19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

20 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

21 must be clearly so designated before the material is disclosed or produced.

22 Designation in conformity with this Order requires:

23 (a) for information in documentary form (e.g., paper or electronic

24 documents, but excluding transcripts of depositions or other pretrial or trial proceedings),

25 that the Producing Party affix the legend “CONFIDENTIAL” to each page that contains

26 protected material. If only a portion or portions of the material on a page qualifies for

27 protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,

1 A Party or Non-Party that makes original documents or materials available for

2 inspection need not designate them for protection until after the inspecting Party has

3 indicated which material it would like copied and produced. During the inspection and

4 before the designation, all of the material made available for inspection shall be deemed

5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

6 copied and produced, the Producing Party must determine which documents, or portions

7 thereof, qualify for protection under this Order. Then, before producing the specified

8 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page

9 that contains Protected Material. If only a portion or portions of the material on a page

10 qualifies for protection, the Producing Party also must clearly identify the protected

11 portion(s) (e.g., by making appropriate markings in the margins).

12 (b) for testimony given in deposition or in other pretrial or trial proceedings,

13 that the Designating Party identify on the record, before the close of the deposition,

14 hearing, or other proceeding, all protected testimony.

15 (c) for information produced in some form other than documentary and for

16 any other tangible items, that the Producing Party affix in a prominent place on the

17 exterior of the container or containers in which the information or item is stored the

18 legend “CONFIDENTIAL.” If only a portion or portions of the information or item

19 warrant protection, the Producing Party, to the extent practicable, shall identify the

20 protected portion(s).

21 7.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

22 to designate qualified information or items does not, standing alone, waive the

23 Designating Party’s right to secure protection under this Order for such material. Upon

24 timely correction of a designation, the Receiving Party must make reasonable efforts to

25 assure that the material is treated in accordance with the provisions of this Order.

26 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

27 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation

1 8.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution

2 process under Local Rule 37-1 et seq.

3 8.3. Joint Stipulation. Any challenge submitted to the Court shall be via a joint

4 stipulation pursuant to Local Rule 37-2.

5 8.4. The burden of persuasion in any such challenge proceeding shall be on the

6 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

7 to harass or impose unnecessary expenses and burdens on other parties) may expose the

8 Challenging Party to sanctions. Unless the Designating Party has waived the

9 confidentiality designation by failing to file a motion to retain confidentiality as

10 described above, all parties shall continue to afford the material in question the level of

11 protection to which it is entitled under the Producing Party’s designation until the court

12 rules on the challenge.

13 9. ACCESS TO AND USE OF PROTECTED MATERIAL

14 9.1. Basic Principles. A Receiving Party may use Protected Material that is

15 disclosed or 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 Protected

17 Material may be disclosed only to the categories of persons and under the conditions

18 described in this Order. When the Action has been terminated, a Receiving Party must

19 comply with the provisions of section 15 below (FINAL DISPOSITION).

20 Protected Material must be stored and maintained by a Receiving Party at a

21 location and in a secure manner that ensures that access is limited to the persons

22 authorized under this Order.

23 9.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

24 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

25 may disclose any information or item designated “CONFIDENTIAL” only to:

26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

27 as employees of said Outside Counsel of Record to whom it is reasonably necessary to

1 (b) the officers, directors, and employees (including House Counsel) of the

2 Receiving Party to whom disclosure is reasonably necessary for this Action;

3 (c) Experts (as defined in this Order) of the Receiving Party to whom

4 disclosure is reasonably necessary for this Action and who have signed the

5 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

6 (d) the court and its personnel;

7 (e) court reporters and their staff,

8 (f) professional jury or trial consultants, mock jurors, and Professional

9 Vendors to whom disclosure is reasonably necessary for this Action and who have signed

10 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

11 (g) the author or recipient of a document containing the information or a

12 custodian or other person who otherwise possessed or knew the information.

13 (h) during their depositions, witnesses, and attorneys for witnesses, in the

14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

16 not be permitted to keep any confidential information unless they sign the

17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

18 by the Designating Party or ordered by the court. Pages of transcribed deposition

19 testimony or exhibits to depositions that reveal Protected Material may be separately

20 bound by the court reporter and may not be disclosed to anyone except as permitted

21 under this Stipulated Protective Order; and

22 (i) any mediators or settlement officers and their supporting personnel,

23 mutually agreed upon by any of the parties engaged in settlement discussions.

24 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

25 OTHER LITIGATION

26 If a Party is served with a subpoena or a court order issued in other litigation that

27 compels disclosure of any information or items designated in this Action as

1 (a) promptly notify in writing the Designating Party. Such notification shall

2 include a copy of the subpoena or court order;

3 (b) promptly notify in writing the party who caused the subpoena or order to issue

4 in the other litigation that some or all of the material covered by the subpoena or order

5 is subject to this Protective Order. Such notification shall include a copy of this

6 Stipulated Protective Order; and

7 (c) cooperate with respect to all reasonable procedures sought to be pursued by

8 the Designating Party whose Protected Material may be affected. If the Designating

9 Party timely seeks a protective order, the Party served with the subpoena or court order

10 shall not produce any information designated in this Action as “CONFIDENTIAL”

11 before a determination by the court from which the subpoena or order issued, unless the

12 Party has obtained the Designating Party’s permission. The Designating Party shall bear

13 the burden and expense of seeking protection in that court of its confidential material –

14 and nothing in these provisions should be construed as authorizing or encouraging a

15 Receiving Party in this Action to disobey a lawful directive from another court.

16 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

17 IN THIS LITIGATION

18 (a) The terms of this Order are applicable to information produced by a Non-Party

19 in this Action and designated as “CONFIDENTIAL.” Such information produced by

20 Non-Parties in connection with this litigation is protected by the remedies and relief

21 provided by this Order. Nothing in these provisions should be construed as prohibiting a

22 Non-Party from seeking additional protections.

23 (b) In the event that a Party is required, by a valid discovery request, to produce a

24 Non-Party’s confidential information in its possession, and the Party is subject to an

25 agreement with the Non-Party not to produce the Non-Party’s confidential information,

26 then the Party shall:

27 (1) promptly notify in writing the Requesting Party and the Non-Party that

1 Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective

2 Order in this litigation, the relevant discovery request(s), and a reasonably specific

3 description of the information requested; and

4 (3) make the information requested available for inspection by the Non-

5 Party.

6 (c) If the Non-Party fails to object or seek a protective order from this court within

7 14 days of receiving the notice and accompanying information, the Receiving Party may

8 produce the Non-Party’s confidential information responsive to the discovery request. If

9 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

10 information in its possession or control that is subject to the confidentiality agreement

11 with the Non-Party before a determination by the court. Absent a court order to the

12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

13 court of its Protected Material.

14 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

16 Protected Material to any person or in any circumstance not authorized under this

17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

19 all unauthorized copies of the Protected Material, (c) inform the person or persons to

20 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

21 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

22 that is attached hereto as Exhibit A.

23 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24 PROTECTED MATERIAL

25 When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection, the

27 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure

1 established in an e-discovery order that provides for production without prior privilege

2 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

3 an agreement on the effect of disclosure of a communication or information covered by

4 the attorney-client privilege or work product protection, the parties may incorporate their

5 agreement in the stipulated protective order submitted to the court.

6 14. MISCELLANEOUS

7 14.1. Right to Further Relief. Nothing in this Order abridges the right of any

8 person to seek its modification by the court in the future.

9 14.2. Right to Assert Other Objections. By stipulating to the entry of this

10 Protective Order no Party waives any right it otherwise would have to object to

11 disclosing or producing any information or item on any ground not addressed in this

12 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground

13 to use in evidence of any of the material covered by this Protective Order.

14 14.3. Filing Protected Material. A Party that seeks to file under seal any Protected

15 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed

16 under seal pursuant to a court order authorizing the sealing of the specific Protected

17 Material. If a Party’s request to file Protected material under seal is denied by the court,

18 then the Receiving Party may file the information in the public record unless otherwise

19 instructed by the court.

20 15. FINAL DISPOSITION

21 After the final disposition of this Action, as defined in paragraph 6, within 60

22 days of a written request by the Designating Party, each Receiving Party must return all

23 Protected Material to the Producing Party or destroy such material. As used in this

24 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

25 summaries, and any other format reproducing or capturing any of the Protected Material.

26 Whether the Protected Material is returned or destroyed, the Receiving Party must

27 submit a written certification to the Producing Party (and, if not the same person or

1 where appropriate) all the Protected Material that was returned or destroyed and (2)

2 affirms that the Receiving Party has not retained any copies, abstracts, compilations,

3 summaries or any other format reproducing or capturing any of the Protected Material.

4 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

5 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

6 correspondence, deposition and trial exhibits, expert reports, attorney work product, and

7 consultant and expert work product, even if such materials contain Protected Material.

8 Any such archival copies that contain or constitute Protected Material remain subject to

9 this Protective Order as set forth in Section 6 (DURATION).

10 16. VIOLATION

11 Any violation of this Order may be punished by appropriate measures including,

12 without limitation, contempt proceedings and/or monetary sanctions.

13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

14

Dated: June 17, 2020 CLYDE & CO US LLP

15

16

By: /s/Yevgenia Altman Wiener

17 Alexander E. Potente

Yevgenia Altman Wiener

18 Attorneys for Plaintiff The Travelers Indemnity

Company of Connecticut

19

20

Dated: June 17, 2020 FISHER & WOLFE LLP

21

22

By: /s/

23 David R. Fisher

Attorneys for Defendants Sky High Investments

24 Company, LLC, Morad Ben Neman, and Neman

Real Estate Investments, LLC

25

26

27

PURSUANT TO STIPULATION, IT IS SO ORDERED

1

2

3 Dated: June 22, 2020 ___

Hon. Sheri Pym

4 United States Magistrate Judge

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EXHIBIT A

1

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, [print or type full name], of

4 [print or type full address], declare under penalty of perjury that I have read in

5 its entirety and understand the Stipulated Protective Order that was issued by the United

6 States District Court for the Central District of California on [date] in the case of The

7 Travelers Indemnity Company of Connecticut v. Sky High Investment Company, LLC,

8 Morad Ben Neman and Neman Real Estate Investments, LLC, USDC Case No. 2:19-cv-

9 08706-JFW (SPx).

10 I agree to comply with and to be bound by all the terms of this Stipulated

11 Protective Order and I understand and acknowledge that failure to so comply could

12 expose me to sanctions and punishment in the nature of contempt. I solemnly promise

13 that I will not disclose in any manner any information or item that is subject to this

14 Stipulated Protective Order to any person or entity except in strict compliance with the

15 provisions of this Order.

16 I further agree to submit to the jurisdiction of the United States District Court for

17 the Central District of California for the purpose of enforcing the terms of this Stipulated

18 Protective Order, even if such enforcement proceedings occur after termination of this

19 Action.

20

21 Date:

22 City and State where sworn and signed:

23 Print Name:

24 Signature:

25

26

27

PROOF OF SERVICE

1

STATE OF CALIFORNIA )

2 ) SS.

COUNTY OF LOS ANGELES )

3

I am employed in the County of Los Angeles, State of California. I am over the age

4 of 18 years and not a party to the within action; my business address is 9401 Wilshire

Boulevard, Suite 640, Beverly Hills, California 90212.

5

On June 19, 2020, I served the foregoing document(s) described as: on the

6 interested parties in this action as follows: [PROPOSED] STIPULATED

PROTECTIVE ORDER

7

BY CM/ECF NOTICE OF ELECTRONIC FILING. By causing such

8 document(s) listed above to be served through this Court’s electronic transmission

facilities via the Notice of Electronic Filing (NEF) and hyperlink, to the parties and/or

9 counsel who are determined this date to be registered CM/ECF Users set forth in the

service listed obtained from this Court on the Electronic Mail Notice List.

10

Electronic Mail Notice List. The following is the list of parties who are currently

11 on the list to receive email notice/service for this case.

12 Alexander E. Potente, Esq. Attorneys for Plaintiffs

Alex.potente@clydeco.us The Travelers Indemnity Company

13 of Connecticut

Yevgenia Altman Wiener, Esq.

14 Yevgenia.wiener@clydeco.us

15

16

I declare that I am employed in the office of a member of this bar of this court at

17 whose direction the service was made.

18

19 Executed on June 19, 2020, at Beverly Hills, California.

20

21

LINDA F. COLLINS

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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