Opinion

Cassandra Jones v. MVT Services, LLC

Court: District Court, C.D. California
Filed: Oct 12, 2021
Cited by: 0 cases
Authority: More cited than 18.0%

distinguishing “good cause” 9 || showing for sealing documents produced in discovery from “compelling reasons” 10 || standard when merits-related documents are part of court record

How later courts described this case

distinguishing “good cause” 9 || showing for sealing documents produced in discovery from “compelling reasons” 10 || standard when merits-related documents are part of court record
even stipulated protective orders 10 || require good cause showing

Written by the judges who cited it.

The opinion

1 || Peter Dubrawski (Bar No. 65677)

pdubrawski@hbblaw.com

2 || Austin Smith (Bar No. 327354)

aw. com

3 || HAIGHT BROWN & BONESTEEL LLP

555 South Flower Street, Forty-Fitth Floor

4 || Los Angeles, California 9007

Telephone: 213.542.8000

5 ||Facsimile: 213.542.8100

6 || Attorneys for Defendants, MVT

SERVICES. LLC, dba MESILLA

7|| VALLEY TRANSPORTATION, and

MVT LEASING, LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

11 ae

CASSANDRA JONES, an individual; Case No. 2:21-cv-03753-MWF-RAO

12 || C.Z.S., a minor by and through her

Guardian ad Litem, NICOL AMENDED STIPULATION FOR

13 ||] BURSON, PROTECTIVE ORDER

OD 14 Plaintiffs,

MVT SERVICES, LLC, dba MESILLA

VALLEY TRANSPORTATION, a

17 || business entity; MVT LEASING, LLC,

a business entity; RENE DAVID

18 || MOOT, an individual; and DOES 1

through 50, inclusive,

Defendants.

22 1. A. PURPOSES AND LIMITATIONS

23 Discovery in this action is likely to involve production of confidential,

24 || proprietary or private information for which special protection from public

25 || disclosure and from use for any purpose other than prosecuting this litigation may

26 ||be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

27 || enter the following Stipulated Protective Order. The parties acknowledge that this

28 || Order does not confer blanket protections on all disclosures or responses to

Case No. 2:21-cv-03753-MWF-RAC

1 || discovery and that the protection it affords from public disclosure and use extends

2 || only to the limited information or items that are entitled to confidential treatment

3 || under the applicable legal principles.

4 B. GOOD CAUSE STATEMENT

5 This action is likely to involve trade secrets, customer and pricing lists and

6 || other valuable research, development, commercial, financial, technical and/or

7 || proprietary information for which special protection from public disclosure and

8 || from use for any purpose other than prosecution of this action is warranted. Such

9 || confidential and proprietary materials and information consist of, among other

10 || things, confidential business or financial information, information regarding

11 || confidential business practices, or other confidential research, development, or

12 || commercial information (including information implicating privacy rights of third

13 || parties), information otherwise generally unavailable to the public, or which may be

ON 14 || privileged or otherwise protected from disclosure under state or federal statutes,

16 || information, to facilitate the prompt resolution of disputes over confidentiality of

17 || discovery materials, to adequately protect information the parties are entitled to keep

18 || confidential, to ensure that the parties are permitted reasonable necessary uses of

19 such material in preparation for and in the conduct of trial, to address their handling

20 || at the end of the litigation, and serve the ends of justice, a protective order for such

21 || information is justified in this matter. It 1s the intent of the parties that information

22 || will not be designated as confidential for tactical reasons and that nothing be so

23 || designated without a good faith belief that it has been maintained in a confidential,

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

25 || record of this case.

26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

27 The parties further acknowledge, as set forth in Section 12.3, below, that this

28 || Stipulated Protective Order does not entitle them to file confidential information

Case No. 2:21-cv-03753-MWF-RAC

1 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

2 || and the standards that will be applied when a party seeks permission from the court

3 || to file material under seal.

4 There is a strong presumption that the public has a right of access to judicial

5 || proceedings and records in civil cases. In connection with non-dispositive motions,

6 || good cause must be shown to support a filing under seal. See Kamakana v. City and

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

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

9 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

10 || require good cause showing), and a specific showing of good cause or compelling

11 || reasons with proper evidentiary support and legal justification, must be made with

12 || respect to Protected Material that a party seeks to file under seal. The parties’ mere

13 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

ON 14 || without the submission of competent evidence by declaration, establishing that the

16 || otherwise protectable—constitute good cause.

17 Further, if a party requests sealing related to a dispositive motion or trial, then

18 || compelling reasons, not only good cause, for the sealing must be shown, and the

19 || relief sought shall be narrowly tailored to serve the specific interest to be protected.

20 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

21 || each item or type of information, document, or thing sought to be filed or introduced

22 || under seal in connection with a dispositive motion or trial, the party seeking

23 || protection must articulate compelling reasons, supported by specific facts and legal

24 || justification, for the requested sealing order. Again, competent evidence supporting

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

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

27 || its entirety will not be filed under seal if the confidential portions can be redacted.

28 || If documents can be redacted, then a redacted version for public viewing, omitting

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1 || only the confidential, privileged, or otherwise protectable portions of the document

2 || shall be filed. Any application that seeks to file documents under seal in their

3 || entirety should include an explanation of why redaction is not feasible.

5 || 2. DEFINITIONS

6 2.1 Action: United States District Court for the Central District of

7 || California Case No: 2:21-cv-03753-MWEF-RAO.

8 2.2 Challenging Party: a Party or Non-Party that challenges the

9 || designation of information or items under this Order.

10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

11 || how it is generated, stored or maintained) or tangible things that qualify for

12 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in

13 || the Good Cause Statement.

ON 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

16 2.5 Designating Party: a Party or Non-Party that designates information or

17 || items that 1t produces in disclosures or in responses to discovery as

18 || “CONFIDENTIAL.”

19 2.6 Disclosure or Discovery Material: all items or information, regardless

20 || of the medium or manner in which it is generated, stored, or maintained (including,

21 |)among other things, testimony, transcripts, and tangible things) that are produced or

22 || generated in disclosures or responses to discovery in this matter.

23 2.7 Expert: a person with specialized knowledge or experience in a matter

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

25 ||an expert witness or as a consultant in this Action.

26 2.8 House Counsel: attorneys who are employees of a party to this Action.

27 || House Counsel does not include Outside Counsel of Record or any other outside

28 || counsel.

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l 2.9 Non-Party: any natural person, partnership, corporation, association or

2 || other legal entity not named as a Party to this action.

3 2.10 Outside Counsel of Record: attorneys who are not employees of a

4 || party to this Action but are retained to represent or advise a party to this Action and

5 || have appeared in this Action on behalf of that party or are affiliated with a law firm

6 || that has appeared on behalf of that party, and includes support staff.

7 2.11 Party: any party to this Action, including all of its officers, directors,

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

9 || support staffs).

10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

11 || Discovery Material in this Action.

12 2.13 Professional Vendors: persons or entities that provide litigation

13 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or

ON 14 || demonstrations, and organizing, storing, or retrieving data in any form or medium)

16 2.14 Protected Material: any Disclosure or Discovery Material that is

17 || designated as “CONFIDENTIAL.”

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery

19 || Material from a Producing Party.

21/3. SCOPE

22 The protections conferred by this Stipulation and Order cover not only

23 || Protected Material (as defined above), but also (1) any information copied or

24 || extracted from Protected Material; (2) all copies, excerpts, summaries, or

25 || compilations of Protected Material; and (3) any testimony, conversations, or

26 || presentations by Parties or their Counsel that might reveal Protected Material.

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

28 || trial judge. This Order does not govern the use of Protected Material at trial.

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2 DURATION

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

4 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced

5 ||as an exhibit at trial becomes public and will be presumptively available to all

6 || members of the public, including the press, unless compelling reasons supported by

7 || specific factual findings to proceed otherwise are made to the trial judge in advance

8 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

9 || showing for sealing documents produced in discovery from “compelling reasons”

10 || standard when merits-related documents are part of court record). Accordingly, the

11 || terms of this protective order do not extend beyond the commencement of the trial.

||5. DESIGNATING PROTECTED MATERIAL

ON 14 5.1 Exercise of Restraint and Care in Designating Material for Protection.

16 || this Order must take care to limit any such designation to specific material that

17 || qualifies under the appropriate standards. The Designating Party must designate for

18 || protection only those parts of material, documents, items or oral or written

19 || communications that qualify so that other portions of the material, documents, items

20 |] or communications for which protection is not warranted are not swept unjustifiably

21 || within the ambit of this Order.

22 Mass, indiscriminate or routinized designations are prohibited. Designations

23 || that are shown to be clearly unjustified or that have been made for an improper

24 || purpose (e.g., to unnecessarily encumber the case development process or to impose

25 ||] unnecessary expenses and burdens on other parties) may expose the Designating

26 || Party to sanctions.

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

28 || designated for protection do not qualify for protection, that Designating Party must

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1 || promptly notify all other Parties that it is withdrawing the inapplicable designation.

2 5.2 Manner and Timing of Designations. Except as otherwise provided in

3 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

4 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

5 || under this Order must be clearly so designated before the material is disclosed or

6 || produced.

7 Designation in conformity with this Order requires:

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

9 || documents, but excluding transcripts of depositions or other pretrial or trial

10 || proceedings), that the Producing Party affix at a minimum, the legend

11 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

12 || contains protected material. If only a portion of the material on a page qualifies for

13 || protection, the Producing Party also must clearly identify the protected portion(s)

ON (e.g., by making appropriate markings in the margins).

16 || need not designate them for protection until after the inspecting Party has indicated

17 || which documents it would like copied and produced. During the inspection and

18 || before the designation, all of the material made available for inspection shall be

19 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the

20 || documents it wants copied and produced, the Producing Party must determine which

21 |}documents, or portions thereof, qualify for protection under this Order. Then,

22 || before producing the specified documents, the Producing Party must affix the

23 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

24 || portion of the material on a page qualifies for protection, the Producing Party also

25 || must clearly identify the protected portion(s) (e.g., by making appropriate markings

26 in the margins).

27 (b) for testimony given in depositions that the Designating Party identifies

28 || the Disclosure or Discovery Material on the record, before the close of the

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1 || deposition all protected testimony.

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

3 || for any other tangible items, that the Producing Party affix in a prominent place on

4 || the exterior of the container or containers in which the information is stored the

5 || legend “CONFIDENTIAL.” If only a portion or portions of the information

6 || warrants protection, the Producing Party, to the extent practicable, shall identify the

7 || protected portion(s).

8 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent

9 || failure to designate qualified information or items does not, standing alone, waive

10 || the Designating Party’s right to secure protection under this Order for such material.

11 || Upon timely correction of a designation, the Receiving Party must make reasonable

12 || efforts to assure that the material is treated in accordance with the provisions of this

13 || Order.

ON 14

16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

17 || designation of confidentiality at any time that is consistent with the Court’s

18 || Scheduling Order.

19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

20 || resolution process under Local Rule 37.1 et seq.

21 6.3 The burden of persuasion in any such challenge proceeding shall be on

22 || the Designating Party. Frivolous challenges, and those made for an improper

23 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other

24 || parties) may expose the Challenging Party to sanctions. Unless the Designating

25 || Party has waived or withdrawn the confidentiality designation, all parties shall

26 || continue to afford the material in question the level of protection to which it is

27 || entitled under the Producing Party’s designation until the Court rules on the

28 || challenge.

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1||7. ACCESS TO AND USE OF PROTECTED MATERIAL

2 7.1. Basic Principles. A Receiving Party may use Protected Material that is

3 || disclosed or produced by another Party or by a Non-Party in connection with this

4 || Action only for prosecuting, defending or attempting to settle this Action. Such

5 || Protected Material may be disclosed only to the categories of persons and under the

6 || conditions described in this Order. When the Action has been terminated, a

7 || Receiving Party must comply with the provisions of section 13 below (FINAL

8 || DISPOSITION).

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

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

11 || authorized under this Order.

12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

13 || otherwise ordered by the court or permitted in writing by the Designating Party, a

ON 14 || Receiving Party may disclose any information or item designated

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

17 || well as employees of said Outside Counsel of Record to whom it is reasonably

18 || necessary to disclose the information for this Action;

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

20 || the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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

24 (d) the court and its personnel;

25 (e) court reporters and their staff;

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

27 || Vendors to whom disclosure is reasonably necessary for this Action and who have

28 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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

2 || custodian or other person who otherwise possessed or knew the information;

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

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

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

6 || will not be permitted to keep any confidential information unless they sign the

7 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

8 || agreed by the Designating Party or ordered by the court. Pages of transcribed

9 || deposition testimony or exhibits to depositions that reveal Protected Material may

10 || be separately bound by the court reporter and may not be disclosed to anyone except

11 || as permitted under this Stipulated Protective Order; and

12 (i) any mediator or settlement officer, and their supporting personnel,

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

ON 14

16 IN OTHER LITIGATION

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

18 || that compels disclosure of any information or items designated in this Action as

19 || “CONFIDENTIAL,” that Party must:

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

21 shall include a copy of the subpoena or court order;

22 (b) promptly notify in writing the party who caused the subpoena or order

23 || to issue in the other litigation that some or all of the material covered by the

24 || subpoena or order is subject to this Protective Order. Such notification shall include

25 ||a copy of this Stipulated Protective Order; and

26 (c) cooperate with respect to all reasonable procedures sought to be

27 || pursued by the Designating Party whose Protected Material may be affected.

28 If the Designating Party timely seeks a protective order, the Party served with

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1 || the subpoena or court order shall not produce any information designated in this

2 || action as “CONFIDENTIAL” before a determination by the court from which the

3 || subpoena or order issued, unless the Party has obtained the Designating Party’s

4 || permission. The Designating Party shall bear the burden and expense of seeking

5 || protection in that court of its confidential material and nothing in these provisions

6 || should be construed as authorizing or encouraging a Receiving Party in this Action

7 || to disobey a lawful directive from another court.

91/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

10 PRODUCED IN THIS LITIGATION

11 (a) The terms of this Order are applicable to information produced by a

12 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

13 || produced by Non-Parties in connection with this litigation is protected by the

ON 14 || remedies and relief provided by this Order. Nothing in these provisions should be

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

17 || produce a Non-Party’s confidential information in its possession, and the Party is

18 || subject to an agreement with the Non-Party not to produce the Non-Party’s

19 || confidential information, then the Party shall:

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

21 that some or all of the information requested is subject to a confidentiality

22 ||agreement with a Non-Party;

23 (2) promptly provide the Non-Party with a copy of the Stipulated

24 || Protective Order in this Action, the relevant discovery request(s), and a reasonably

25 || specific description of the information requested; and

26 (3) make the information requested available for inspection by the

27 || Non-Party, if requested.

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

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1 || 14 days of receiving the notice and accompanying information, the Receiving Party

2 ||may produce the Non-Party’s confidential information responsive to the discovery

3 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall

4 || not produce any information in its possession or control that is subject to the

5 || confidentiality agreement with the Non-Party before a determination by the court.

6 || Absent a court order to the contrary, the Non-Party shall bear the burden and

7 || expense of seeking protection in this court of its Protected Material.

9}}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

12 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in

13 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

ON 14 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

16 || and (d) request such person or persons to execute the “Acknowledgment and

17 || Agreement to Be Bound” that is attached hereto as Exhibit A.

19/}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

20 PROTECTED MATERIAL

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

22 || inadvertently produced material is subject to a claim of privilege or other protection,

23 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

24 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever

25 || procedure may be established in an e-discovery order that provides for production

26 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

27 (e), insofar as the parties reach an agreement on the effect of disclosure of a

28 || communication or information covered by the attorney-client privilege or work

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1 || product protection, the parties may incorporate their agreement in the stipulated

2 || protective order submitted to the court.

4/12. MISCELLANEOUS

5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

6 || person to seek its modification by the Court in the future.

7 12.2 Right to Assert Other Objections. By stipulating to the entry of this

8 || Protective Order, no Party waives any right it otherwise would have to object to

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

10 || Stipulated Protective Order. Similarly, no Party waives any right to object on any

11 || ground to use in evidence of any of the material covered by this Protective Order.

12 12.3 Filing Protected Material. A Party that seeks to file under seal any

13 || Protected Material must comply with Local Civil Rule 79-5. Protected Material

ON 14 || may only be filed under seal pursuant to a court order authorizing the sealing of the

16 || under seal is denied by the court, then the Receiving Party may file the information

17 || in the public record unless otherwise instructed by the court.

19]}13. FINAL DISPOSITION

20 After the final disposition of this Action, as defined in paragraph 4, within 60

21 || days of a written request by the Designating Party, each Receiving Party must return

22 all Protected Material to the Producing Party or destroy such material. As used in

23 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

24 ||summaries, and any other format reproducing or capturing any of the Protected

25 || Material. Whether the Protected Material is returned or destroyed, the Receiving

26 || Party must submit a written certification to the Producing Party (and, if not the same

27 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

28 || (by category, where appropriate) all the Protected Material that was returned or

Case No. 2:21-cv-03753-MWF-RAC

1 || destroyed and (2) affirms that the Receiving Party has not retained any copies,

2 || abstracts, compilations, summaries or any other format reproducing or capturing any

3 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to

4 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

5 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

6 || reports, attorney work product, and consultant and expert work product, even if such

7 || materials contain Protected Material. Any such archival copies that contain or

8 || constitute Protected Material remain subject to this Protective Order as set forth in

9 || Section 4 (DURATION).

10}|//

11 |]//

12 ||//

13 ||//

ON 14 //

16 |1//

||//

18 //

20 || //

\|//

22 |\//

23 //

24 |} //

25 ||//

26 //

27 \\//

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1}/14. VIOLATION

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

3 || without limitation, contempt proceedings and/or monetary sanctions.

4|}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5 || Dated: October 8, 2021 PANISH SHEA & BOYLE LLP

8 By: /s/ Pete Kaufman

Brian Panish, Pete Kaufman, Whitney T. Smith

9 Attorneys for Plaintiffs, CASSANDRA JONES,

C.Z.S, a minor, by and through her Guardian ad

10 Litem, NICOLE BURSON

12 || Dated: October 8, 2021 HAIGHT BROWN & BONESTEEL LLP

ON 14 By: /s/ Peter Dubrawski

Peter Dubrawski, Austin Smith

15 Attorneys for Defendants, MVT SERVICES,

16 LLC, dba MESILLA VALLEY

TRANSPORTATION, and MVT LEASING, LLC

1g Dated: October 8, 2021 HIGGS, FLETCHER & MACK LLP

20 By: /s/ Peter S. Doody

Peter S. Doody, Nicholas S. Brauns

Attorneys for Defendant, RENE DAVID MOOT

73 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: October 12, 2021

25 7 .

26 } . On , .

27|| HON. ROZELLA A. OLIVER

28 United States Magistrate Judge

Case No. 2:21-cv-03753-MWF-RAC

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4||I, [print or type full name], of

5 [print or type full address], declare under penalty of perjury

6 || that I have read in its entirety and understand the Stipulated Protective Order that

7 || was issued by the United States District Court for the Central District of California

8 || on [date] in the case of Cassandra Jones et al. v. MVT Services, LLC et al., Case #

9 || 2:21-cv-03753-MWE-RAO. I agree to comply with and to be bound by all the

10 || terms of this Stipulated Protective Order and I understand and acknowledge that

11 || failure to so comply could expose me to sanctions and punishment in the nature of

12 contempt. I solemnly promise that I will not disclose in any manner any

13 || information or item that is subject to this Stipulated Protective Order to any person

ON 14 || or entity except in strict compliance with the provisions of this Order.

16 || Central District of California for enforcing the terms of this Stipulated Protective

17 || Order, even if such enforcement proceedings occur after termination of this action.

18 || | hereby appoint [print or type full name] of

19 [print or type full address and

20 || telephone number] as my California agent for service of process in connection with

21 || this action or any proceedings related to enforcement of this Stipulated Protective

22 || Order.

23 || Date:

24 || City and State where sworn and signed:

26 || Printed name:

28 || Signature:

Case No. 2:21-cv-03753-MWF-RAC

1 PROOF OF SERVICE

2 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

3 || Jones, et al. v. MVT Services, LLC, et al.

Case No. 2:21-cv-03753-MWF-RAO

_ At the time of service, I was over 18 years of age and not a party to this

5 ||action. Iam employed in the County of Los Angeles, State of California. My

business address is 555 South Flower Street, Forty-Fifth Floor, Los Angeles, CA

7 _On October 11, 2021, I served true copies of the following document(s)

described as STIPULATED PROTECTIVE ORDER on the interested parties in

8 || this action as follows:

9 SEE ATTACHED SERVICE LIST

10 BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed

the document(s) with the Clerk of the Court by using the CM/ECF system.

11 Participants in the case who are registered CM/ECF users will be served by □□□

CM/ECF system. Participants in the case who are not registered CM/ECF users will

12 || be served by mail or by other means permitted by the court rules.

13 I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct and that I am employed in the office

14 of a member of the bar of this Court at whose direction the service was made.

15 Executed on October 11, 2021, at Los Angeles, California.

17 /s/ Julie C. Mentesana

18 Julie C. Mentesana

Case No. 2:21-cv-03753-MWF-RAC

1 SERVICE LIST

Jones, et al. v. MVT Services, LLC, et al.

2 Case No. 2:21-cv-03753-MWF-RAO

3 || Brian J. Panish, Esq. Nick Movagar, Esq.

Peter Kaufman, Esq. MOVAGAR & YAMIN, PLC

4 Whitney Smith, <4. 4929 Wilshire Blvd., Suite 960

PANISH SHEA & BOYLE LLP Los Angeles, CA 90010

5 11111 Santa Monica Boulevard, Suite

700 Telephone: 877.771.8175

6 || Los Angeles, CA 90025 Facsimile: 323.475.7773

Email:contactmylaw@projects.filevine.com

|| Telephone: 310.477.1700 nick@mylawcompany.com

Facsimile: 310.477.1699

8 || Email: kaufman@psblaw.com

wsmith@psblaw.com Attorneys for Plaintiffs

9 aranda@psblaw.com

0 lam@psblaw.com

Attorneys for Plaintiffs

Peter S. Doody

12 || Nicholas D. Brauns

HIGGS FLETCHER & MACK LLP

_13]}401 West A Street, Suite 2600

San Diego, CA 92101-7910

14}/Telephone: 619.236.1551

Facsimile: 619.696.1410

15 || Email: doody@higgslaw.com

braunsn@higeslaw.com

16 richardson iggslaw.com

17 || Attorneys for Defendant, Rene David

Moot

Case No. 2:21-cv-03753-MWF-RAC

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