# Cassandra Jones v. MVT Services, LLC

> District Court, C.D. California · October 12, 2021

URL: https://www.frixlaw.com/law-library/cases/10042221

## Case

- **Court:** District Court, C.D. California
- **Decided:** October 12, 2021
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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
8
UNITED STATES DISTRICT COURT
9
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
10
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,
© 15 V.
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,
19
Defendants.
20
21
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,
© 15 || court rules, case decisions, or common law. Accordingly, to expedite the flow of
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
© 15 || material sought to be filed under seal qualifies as confidential, privileged, or
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
Case No. 2:21-cv-03753-MWF-RAC

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.
4
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
© 15 || their support staff).
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.
Case No. 2:21-cv-03753-MWF-RAC

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)
© 15 || and their employees and subcontractors.
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.
20
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.
Case No. 2:21-cv-03753-MWF-RAC

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.
12
||5. DESIGNATING PROTECTED MATERIAL
ON 14 5.1 Exercise of Restraint and Care in Designating Material for Protection.
© 15 || Each Party or Non-Party that designates information or items for protection under
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
Case No. 2:21-cv-03753-MWF-RAC

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).
© 15 A Party or Non-Party that makes original documents available for inspection
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
Case No. 2:21-cv-03753-MWF-RAC

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
© 15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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.
Case No. 2:21-cv-03753-MWF-RAC

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
© 15 || “CONFIDENTIAL” only to:
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);
Case No. 2:21-cv-03753-MWF-RAC

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
© 1518. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
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
Case No. 2:21-cv-03753-MWF-RAC

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.
8
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
© 15 || construed as prohibiting a Non-Party from seeking additional protections.
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
Case No. 2:21-cv-03753-MWF-RAC

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.
8
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
© 15 || persons to whom unauthorized disclosures were made of all the terms of this Order,
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.
18
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
Case No. 2:21-cv-03753-MWF-RAC

1 || product protection, the parties may incorporate their agreement in the stipulated
2 || protective order submitted to the court.
3
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
© 15 || specific Protected Material at issue. If a Party’s request to file Protected Material
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.
18
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 \\//
28
Case No. 2:21-cv-03753-MWF-RAC

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
6
7
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
11

12 || Dated: October 8, 2021 HAIGHT BROWN & BONESTEEL LLP
2B
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
17
1g Dated: October 8, 2021 HIGGS, FLETCHER & MACK LLP

19
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
3
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.
© 15 ||I further agree to submit to the jurisdiction of the United States District Court for the
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:
25
26 || Printed name:
27
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
4
_ 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
6
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
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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
1
Attorneys for Plaintiffs
11
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
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Case No. 2:21-cv-03753-MWF-RAC

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10042221. Public record. Not legal advice.