distinguishing “good cause” showing for sealing documents 21 produced in discovery from “compelling reasons” standard when merits-related 22 documents are part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing documents 21 produced in discovery from “compelling reasons” standard when merits-related 22 documents are part of court record
Written by the judges who cited it.
The opinion
1 WOODRUFF, SPRADLIN & SMART, APC
CAROLINE A. BYRNE – State Bar No. 196541
2 cbyrne@wss-law.com
JEANNE L. TOLLISON – State Bar No. 238970
3 jtollison@wss-law.com
555 Anton Boulevard, Suite 1200
4 Costa Mesa, California 92626-7670
Telephone: (714) 558-7000
5 Facsimile: (714) 835-7787
6 Attorneys for Defendant CITY OF GARDEN GROVE, a public entity
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 DIECENIA CHAVEZ and RAFAEL CASE NO.: 8:20-cv-01589 JVS (ADSx)
CHAVEZ, Plaintiffs, and as Successors-
12 in-Interest for Decedent RAFAEL BEFORE THE HONORABLE
CHAVEZ FRANCO, JAMES V. SELNA
13 COURTROOM 10C
Plaintiffs,
14 “DISCOVERY MATTER”
v.
15 STIPULATION RE: [PROPOSED]
CITY OF GARDEN GROVE, CITY PROTECTIVE ORDER
16 OF WESTMINSTER, and DOES 1
through 10, inclusive, HEARING DATES PENDING:
17 Type: Final Pretrial Conference
Defendants. Date: December 20, 2021
18 Time: 11:00 a.m.
19 Type: Trial
Date: January 11, 2022
20 Time: 8:30 a.m.
21
22 Plaintiffs DIECENIA CHAVEZ and RAFAEL CHAVEZ and Defendant CITY
23 OF GARDEN GROVE, a public entity, by and through their respective counsel,
24 hereby stipulate and agree as follows:
25 1. PURPOSES AND LIMITATIONS
26 Discovery in this action is likely to involve production of confidential,
27 proprietary or private information for which special protection from public disclosure
and from use for any purpose other than prosecuting this litigation may be warranted.
1 Accordingly, the parties hereby stipulate to and petition the Court to enter the
2 following Stipulated Protective Order. The parties acknowledge that this Order does
3 not confer blanket protections on all disclosures or responses to discovery and that the
4 protection it affords from public disclosure and use extends only to the limited
5 information or items that are entitled to confidential treatment under the applicable
6 legal principles.
7 The parties further acknowledge, as set forth in Section 12.3, below, that this
8 Stipulated Protective Order does not automatically entitle them to file confidential
9 information under seal and that Local Civil Rule 79-5 sets forth the procedures that
10 must be followed and the standards that will be applied when a party seeks permission
11 from the Court to file material under seal. The parties agree that this protective order
12 does not waive the parties’ rights to object to discovery demands or requests for
13 documents and/or information.
14 2. DEFINITIONS
15 2.1 Action: Chavez, et al. v. City of Garden Grove, et al. 8:20-cv-01589-
16 JVS.
17 2.2 Challenging Party: A Party or Non-Party that challenges the designation
18 of information or items under this Order.
19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
20 how it is generated, stored or maintained) or tangible things that qualify for protection
21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
22 Cause Statement. This also includes (1) any information copied or extracted from the
23 Confidential information; (2) all copies, excerpts, summaries, abstracts or
24 compilations of Confidential information; and (3) any testimony, conversations, or
25 presentations that might reveal Confidential information.
26 2.4 Counsel: Counsel of record for the parties to this civil litigation and their
27 support staff.
1 items that it produces in disclosures or in responses to discovery as
2 “CONFIDENTIAL.”
3 2.6 Disclosure or Discovery Material: all items or information, regardless
4 of the medium or manner in which it is generated, stored, or maintained (including,
5 among other things, testimony, transcripts, and tangible things), that are produced or
6 generated in disclosures or responses to discovery in this matter.
7 2.7 Expert: a person with specialized knowledge or experience in a matter
8 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
9 expert witness or as a consultant in this Action.
10 2.8 Final Disposition: when this Action has been fully and completely
11 terminated by way of settlement, dismissal, trial and/or appeal.
12 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph
13 2.4) and who are employees of a party to this Action.
14 2.10 Non-Party: any natural person, partnership, corporation, association or
15 other legal entity not named as a Party to this action.
16 2.11 Outside Counsel of Record: attorneys who are not employees of a party
17 to this Action but are retained to represent or advise a party to this Action and have
18 appeared in this Action on behalf of that party or are affiliated with a law firm that has
19 appeared on behalf of that party, and includes support staff.
20 2.12 Party: any party to this Action, including all of its officers, directors,
21 boards, departments, divisions, employees, consultants, retained experts, and Outside
22 Counsel of Record (and their support staffs).
23 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
24 Discovery Material in this Action.
25 2.14 Professional Vendors: persons or entities that provide litigation support
26 services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium)
1 2.15 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 2.16 Receiving Party: A Party that receives Disclosure or Discovery Material
4 from a Producing Party.
5 3. SCOPE
6 The protections conferred by this Stipulation and Order cover not only
7 Protected Material (as defined above), but also (1) any information copied or extracted
8 from Protected Material; (2) all copies, excerpts, abstracts, summaries, or
9 compilations of Protected Material; and (3) any deposition testimony, conversations,
10 or presentations by Parties or their Counsel that might reveal Protected Material.
11 Any use of Protected Material at trial shall be governed by the orders of the trial
12 judge. This Order does not govern the use of Protected Material at trial.
13 4. DURATION
14 Once a trial commences in this Action, information that was designated as
15 CONFIDENTIAL or maintained pursuant to this protective order and that is
16 introduced or admitted as an exhibit at trial becomes public and will be presumptively
17 available to all members of the public, including the press, unless compelling reasons
18 supported by specific factual findings to proceed otherwise are made to the trial judge
19 in advance of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172,
20 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
21 produced in discovery from “compelling reasons” standard when merits-related
22 documents are part of court record). Accordingly, the terms of this protective order do
23 not extend beyond the commencement of the trial as to the CONFIDENTIAL
24 information and materials introduced or admitted as an exhibit at trial.
25 5. DESIGNATING PROTECTED MATERIAL
26 5.1 Exercise of Restraint and Care in Designating Material for
27 Protection.
1 under this Order must take care to limit any such designation to specific material that
2 qualifies under the appropriate standards. The Designating Party must designate for
3 protection only those parts of material, documents, items or oral or written
4 communications that qualify so that other portions of the material, documents, items
5 or communications for which protection is not warranted are not swept unjustifiably
6 within the ambit of this Order.
7 Mass, indiscriminate or routinized designations are prohibited. Designations
8 that are shown to be clearly unjustified or that have been made for an improper
9 purpose (e.g., to unnecessarily encumber the case development process or to impose
10 unnecessary expenses and burdens on other parties) may expose the Designating Party
11 to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection, that Designating Party must
14 promptly notify all other Parties that it is withdrawing the inapplicable designation.
15 5.2 Manner and Timing of Designations. Except as otherwise provided in
16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
18 under this Order must be clearly so designated before the material is disclosed or
19 produced.
20 Designation in conformity with this Order requires:
21 (a) for information in documentary form (e.g., paper or electronic documents,
22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a
24 similar effect, and that includes the case name and case number (hereinafter
25 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
26 portion of the material on a page qualifies for protection, the Producing Party also
27 must clearly identify the protected portion(s) (e.g., by making appropriate markings in
1 A Party or Non-Party that makes original documents available for inspection
2 need not designate them for protection until after the inspecting Party has indicated
3 which documents it would like copied and produced. During the inspection and before
4 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
7 portions thereof, qualify for protection under this Order. Then, before producing the
8 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
9 to each page that contains Protected Material. If only a portion of the material on a
10 page qualifies for protection, the Producing Party also must clearly identify the
11 protected portion(s) (e.g., by making appropriate markings in the margins).
12 (b) for testimony given in depositions that the Designating Party identifies the
13 Disclosure or Discovery Material on the record, before the close of the deposition all
14 protected testimony.
15 (c) for information produced in some form other than documentary and for any
16 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 is stored the legend
18 “CONFIDENTIAL.” If only a portion or portions of the information warrants
19 protection, the Producing Party, to the extent practicable, shall identify the protected
20 portion(s).
21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
22 failure 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.
24 Upon timely correction of a designation, the Receiving Party must make reasonable
25 efforts to assure that the material is treated in accordance with the provisions of this
26 Order.
27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
1 designation of confidentiality at any time that is consistent with the Court’s
2 Scheduling Order.
3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
4 resolution process under Local Rule 37.1 et seq.
5 6.3 The burden of persuasion in any such challenge proceeding shall be on
6 the Designating Party. Frivolous challenges, and those made for an improper purpose
7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
8 expose the Challenging Party to sanctions. Unless the Designating Party has waived or
9 withdrawn the confidentiality designation, all parties shall continue to afford the
10 material in question the level of protection to which it is entitled under the Producing
11 Party’s designation until the Court rules on the challenge.
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this
15 Action only for prosecuting, defending or attempting to settle this Action. Such
16 Protected Material may be disclosed only to the categories of persons and under the
17 conditions described in this Order. When the Action has been terminated, a Receiving
18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
23 otherwise ordered by the court or permitted in writing by the Designating Party, a
24 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
25 only to:
26 (a) the Receiving Party’s Counsel of Record in this Action, as well as
27 employees of said Counsel of Record to whom it is reasonably necessary to disclose
1 (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure
2 is reasonably necessary for this Action and who have signed the “Acknowledgment
3 and Agreement to Be Bound” (Exhibit A);
4 (c) the court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
7 to whom disclosure is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (g) the author or recipient of a document containing the information or a
10 custodian or other person who otherwise possessed or knew the information;
11 (h) during their depositions, witnesses, and attorneys for witnesses, in the
12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
13 requests that the witness sign the form attached as Exhibit “A” hereto; and (2) they
14 will not be permitted to keep any confidential information unless they sign the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit “A”), unless otherwise
16 agreed by the Designating Party or ordered by the court. Pages of transcribed
17 deposition testimony or exhibits to depositions that reveal Protected Material may be
18 separately bound by the court reporter and may not be disclosed to anyone except as
19 permitted under this Stipulated Protective Order; and
20 (i) any mediator or settlement officer, and their supporting personnel, mutually
21 agreed upon by any of the parties engaged in settlement discussions and who have
22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A).
23 7.3. Counsel making the disclosure to any qualified person described herein
24 shall retain the original executed copy of the Nondisclosure Agreement until sixty (60)
25 days after this litigation has become final, including any appellate review, and
26 monitoring of an injunction. Counsel for the Receiving Party shall maintain all signed
27 Nondisclosure Agreements and shall produce the original signature page upon
1 purported unauthorized disclosure of Confidential Information, upon noticed motion
2 of contempt filed by the Designating Party, counsel for the Receiving Party may be
3 required to file the signed Nondisclosure Agreements, as well as a list of the disclosed
4 materials, in camera with the Court having jurisdiction of the Stipulation.
5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
6 IN OTHER LITIGATION
7 If a Party is served with a subpoena or a court order issued in other litigation
8 that compels disclosure of any information or items designated in this Action as
9 “CONFIDENTIAL,” that Party must:
10 (a) promptly notify in writing the Designating Party. Such notification shall
11 include a copy of the subpoena or court order;
12 (b) promptly notify in writing the party who caused the subpoena or order to
13 issue in the other litigation that some or all of the material covered by the subpoena or
14 order is subject to this Protective Order. Such notification shall include a copy of this
15 Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be pursued by
17 the Designating Party whose Protected Material may be affected.
18 The Party served with the subpoena or court order shall not produce any
19 information designated in this action as “CONFIDENTIAL”, unless the Party has
20 obtained the Designating Party’s permission or an order from the court from which the
21 subpoena or order issued. Nothing in these provisions should be construed as
22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
23 directive from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a Non-
27 Party in this Action and designated as “CONFIDENTIAL.” Such information
1 remedies and relief provided by this Order. Nothing in these provisions should be
2 construed as prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is
5 subject to an agreement with the Non-Party not to produce the Non-Party’s
6 confidential information, then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-Party
8 that some or all of the information requested is subject to a
9 confidentiality agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this Action, the relevant discovery request(s), and a
12 reasonably specific description of the information requested; and
13 (3) make the information requested available for inspection by the
14 Non-Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this court within 14
16 days of receiving the notice and accompanying information, the Receiving Party may
17 produce the Non-Party’s confidential information responsive to the discovery request.
18 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
19 any information in its possession or control that is subject to the confidentiality
20 agreement with the Non-Party before a determination by the court. Absent a court
21 order to the contrary, the Non-Party shall bear the burden and expense of seeking
22 protection in this court of its Protected Material.
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
1 persons to whom unauthorized disclosures were made of all the terms of this Order,
2 and (d) request such person or persons to execute the “Acknowledgment and
3 Agreement to Be Bound” that is attached hereto as Exhibit A.
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain
7 inadvertently produced material is subject to a claim of privilege or other protection,
8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
10 may be established in an e-discovery order that provides for production without prior
11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
12 parties reach an agreement on the effect of disclosure of a communication or
13 information covered by the attorney-client privilege or work product protection, the
14 parties may incorporate their agreement in the stipulated protective order submitted to
15 the court.
16 12. MISCELLANEOUS
17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
18 person to seek its modification by the Court in the future.
19 12.2 Right to Assert Other Objections. By stipulating to the entry of this
20 Protective Order, no Party waives any right it otherwise would have to object to
21 disclosing or producing any information or item on any ground not addressed in this
22 Stipulated Protective Order. Similarly, no Party waives any right to object on any
23 ground to use in evidence of any of the material covered by this Protective Order.
24 12.3 Filing Protected Material. A Party that seeks to file under seal any
25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
26 only be filed under seal pursuant to a court order authorizing the sealing of the
27 specific Protected Material at issue. If a Party’s request to file Protected Material
1 the public record unless otherwise instructed by the court.
2 13. FINAL DISPOSITION
3 After the FINAL DISPOSITION of this Action, as defined in paragraph 2.8,
4 within 30 days of a written request by the Designating Party, each Receiving Party
5 must return all Protected Material to the Producing Party. As used in this subdivision,
6 “all Protected Material” includes all copies, abstracts, compilations, summaries, and
7 any other format reproducing or capturing any of the Protected Material. The
8 Receiving Party must submit a written certification to the Producing Party (and, if not
9 the same person or entity, to the Designating Party) by the 30-day deadline that (1)
10 identifies (by category, where appropriate) all the Protected Material that was returned
11 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
12 compilations, summaries or any other format reproducing or capturing any of the
13 Protected Material.
14 14. VIOLATION
15 Any violation of this Order may be punished by appropriate measures
16 including, without limitation, contempt proceedings and/or monetary sanctions.
17
18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
19
20 DATED: February 2, 2021 CARRILLO LAW FIRM, LLP
21
22 By:/s/ J. Miguel Flores ___________________
MICHAEL S. CARRILLO
23
J. MIGUEL FLORES
24 Attorneys for Plaintiffs
25
26
27
1 DATED: February 2, 2021 WOODRUFF, SPRADLIN & SMART, APC
2
3 By:/s/ Jeanne L. Tollison___________________
CAROLINE A. BYRNE
4
JEANNE L. TOLLISON
5 Attorneys for Defendant CITY OF GARDEN
GROVE, a public entity
6
7
8 Pursuant to local 5-4.3.4, I, Jeanne L. Tollison, attest that J. Miguel Flores
9 concurs with the content of this joint stipulation and has authorized the filing of the
10 same.
11 DATED: February 2, 2021 WOODRUFF, SPRADLIN & SMART, APC
12
13 By:/s/ Jeanne L. Tollison___________________
CAROLINE A. BYRNE
14
JEANNE L. TOLLISON
15 Attorneys for Defendant CITY OF GARDEN
GROVE, a public entity
16
17
18
19 PURSUANT TO STIPULATION, IT IS SO ORDERED
20
21
22
DATED: February _5__, 2021 ______/s_/_ A__u_tu_m__n_ D__. _S_p_a_et_h__________
23 Autumn D. Spaeth, Magistrate
United States District Court
24
25
26
27
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
6 penalty of perjury that I have read in its entirety and understand the Stipulated
7 Protective Order that was issued by the United States District Court for the Central
8 District of California on _____________ in the case of Chavez, et al. v. City of
9 Garden Grove, et al., United States District Court Case No. 8:20-cv-01589JVS. I
agree to comply with and to be bound by all the terms of this Stipulated Protective
10
Order and I understand and acknowledge that failure to so comply could expose me to
11
sanctions and punishment in the nature of contempt. I solemnly promise that I will not
12
disclose in any manner any information or item that is subject to this Stipulated
13
Protective Order to any person or entity except in strict compliance with the
14
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
19
type full name] of _______________________________________ [print or type full
20
address and telephone number] as my California agent for service of process in
21
connection with this action or any proceedings related to enforcement of this
22
Stipulated
23
24 Protective Order.
25 Date: ______________________________________
26 City and State where sworn and signed: _________________________________
27 Printed name: _______________________________
Signature: _________________________________
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF ORANGE
3 I am over the age of 18 and not a party to the within action; I am employed by
WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 Anton
4 || Boulevard, Suite 1200, Costa Mesa, CA 92626-7670.
5 On February 4, 2021, I served the toregoine. document(s) described as:
‘ STIPULATION RE: [PROPOSED] PROTECTIVE ORDER
Ll by placing the true copies thereof enclosed in sealed envelopes addressed as
7 stated on the attached mailing list;
8 1} O (BY MAIL) I placed said envelope(s) for collection and mailing. following
ordinary business practices, at the business offices of OODRUFF,
9 SPRADLIN & SMART, and addressed as shown on the attached service list,
for deposit in the United States Postal Service. I am readily familiar with the
10 practice of WOODRUFF, SPRADLIN & SMART for collection and processing
correspondence for mailing with the United States Postal Service, and sai
11 envelope(s) will be deposited with the United States Postal Service on said date
in the ordinary course of business.
(BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be
13 electronically filed using the Court’s Electronic Piling ystem which constitutes
service of the filed document(s) on the individual(s) listed on the attached
«14 mailing list.
§15|/0 (wy OVERNIGHT DELIVERY) I placed said documents in envelope(s) for
collection tollowing ordinary business practices, at the business offices of
16 WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached
service list, for collection and delivery to a courier authorized by
17 __ to receive said documents, with delivery fees
provided for. I am readily familiar with the practices of WOODRUFF,
18 PRADLIN & SMART for collection and processing of documents for
overnight delivery, and said envelope(s) will be deposited for receipt by
19 on said date in the ordinary course of business.
20 |} (BY FACSIMILE) I caused the above-referenced document to be transmitted
to the interested parties via facsimile transmission to the fax number(s) as stated
21 on the attached service list.
22 (BY PERSONAL SERVICE) I delivered such envelope(s) by hand to the
53 offices of the addressee(s).
(Federal) I declare that I am employed in the office of a member of the bar of
24 this court at whose direction the service was made. I declare under
35 penalty of perjury that the above is true and correct.
Executed on February 4, 2021, at Costa Mesa, California.
27 /s/ Diane Castillo
DIANE CASTILLO
28
1z=0
1 DIECENIA CHAVEZ, et al. v. CITY OF GARDEN GROVE, et al.
2 USDC, CENTRAL DISTRICT OF CALIFORNIA
CASE NO. 8:20-cv-01589 JVS (ADSx)
3
BEFORE THE HONORABLE
4 JAMES V. SELNA
COURTROOM 10C
5
SERVICE LIST
6
7 Luis A. Carrillo, Esq. Attorneys for Plaintiffs
Michael S. Carrillo, Esq. DIECENIA CHAVEZ and RAFAEL
8 CARRILLO LAW FIRM, LLP CHAVEZ, Plaintiffs, and as
1499 Huntington Drive, Suite 402 Successors-in-Interest for Decedent
9 South Pasadena, CA 91030 RAFAEL CHAVEZ FRANCO
Telephone: (626) 799-9375
10 Facsimile: (626) 799-9380
Email: lac4justice@gmail.com
11 mc@carrillofirm.com
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14
15 12/10/20
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