The opinion
1 Douglas E. Dexter (State Bar No. 115868)
ddexter@fbm.com
2 Jamie E.S. Talt (State Bar No. 312853)
jtalt@fbm.com
3 Emily J. Tripodi (State Bar No. 334054)
etripodi@fbm.com
4 Farella Braun + Martel LLP
One Bush Street, Suite 900
5 San Francisco, California 94104
Telephone: (415) 954-4400
6 Facsimile: (415) 954-4480
7 Attorneys for Defendant AMAZON.COM
SERVICES LLC
8
Neama Rahmani (State Bar No. 223819)
9 efilings@westcoasttriallawyers.com
Ronald L. Zambrano (State Bar No. 255613)
10 ron@westcoasttriallawyers.com
Crystal F. Mohsin (State Bar No. 333299)
11 crystal@westcoasttriallawyers.com
West Coast Employment Lawyers, APLC
12 1147 South Hope Street
Los Angeles, California 90015
13 Telephone: (213) 927-3700
Facsimile: (213) 927-3701
14
Attorneys for Plaintiff SCOTT BROCK
15
16 UNITED STATES DISTRICT COURT
17 EASTERN DISTRICT OF CALIFORNIA
18
19 SCOTT BROCK, an individual, Case No. 1:23-CV-00613-KES-CDB
20 Plaintiff, JOINT STIPULATED PROTECTIVE
ORDER
21 vs.
The Hon. U.S. Magistrate Judge Christopher
22 AMAZON.COM SERVICES LLC, a D. Baker
Delaware Corporation; and DOES ` through
23 10, inclusive, Action Filed: March 14, 2023
Removal Date: April 24, 2023
24 Defendants. Trial Date: April 22, 2025
25
26 1. PURPOSES AND LIMITATIONS
27 Disclosure and discovery activity in this action are likely to involve production of
1 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,
2 Defendant Amazon.com Services LLC (“Amazon” or “Defendant”) and Plaintiff Scott Brock
3 (“Plaintiff”) (collectively, “the parties”), by and through their counsel of record, hereby stipulate to
4 and petition the court to enter the following Joint Stipulated Protective Order.
5 This Protective Order will provide protection for materials in which the Plaintiff or third
6 parties have a legally cognizable privacy interest, such as confidential business or financial
7 information, information regarding confidential business practices, sensitive information regarding
8 third parties, medical records, employees’ personnel records, or other confidential information
9 otherwise generally unavailable to the public or which may be privileged or otherwise protected
10 from disclosure under state or federal statutes, court rules, case decisions, or common law. The
11 sensitivity and confidentiality of these documents necessitates protection of these documents to be
12 addressed by court order. Accordingly, to expedite the flow of information, to facilitate the prompt
13 resolution of disputes over confidentiality of discovery materials, to adequately protect information
14 the parties are entitled to keep confidential, to ensure that the parties are permitted reasonable
15 necessary uses of such material in preparation for and in the conduct of trial, to address their
16 handling at the end of the litigation, and serve the ends of justice, a protective order for such
17 information is justified in this matter. The parties acknowledge that this Order does not confer
18 blanket protections on all disclosures or responses to discovery and that the protection it affords
19 from public disclosure and use extends only to the limited information or items that are entitled to
20 confidential treatment under the applicable legal principles. The parties further acknowledge, as set
21 forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file
22 confidential information under seal; Civil Local Rule 141 sets forth the procedures that must be
23 followed and the standards that will be applied when a party seeks permission from the court to file
24 material under seal.
25 2. DEFINITIONS
26 2.1 Challenging Party: a Party or Non-Party that challenges the designation of
27 information or items under this Order.
1 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is
2 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of
3 Civil Procedure 26(c).
4 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
5 as their support staff).
6 2.4 Designating Party: a Party or Non-Party that designates information or items that it
7 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
8 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium
9 or manner in which it is generated, stored, or maintained (including, among other things, testimony,
10 transcripts, and tangible things), that are produced or generated in disclosures or responses to
11 discovery in this matter.
12 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to
13 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
14 consultant in this action.
15 2.7 House Counsel: attorneys who are employees of a party to this action. House
16 Counsel does not include Outside Counsel of Record or any other outside counsel.
17 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
18 entity not named as a Party to this action.
19 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action
20 but are retained to represent or advise a party to this action and have appeared in this action on
21 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
22 2.10 Party: any party to this action, including all of its officers, directors, employees,
23 consultants, retained experts and investigators, and Outside Counsel of Record (and their support
24 staffs).
25 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
26 Material in this action.
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1 2.12 Professional Vendors: persons or entities that provide litigation support services
2 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
3 storing, or retrieving data in any form or medium) and their employees and subcontractors.
4 2.13 Protected Material: any Disclosure or Discovery Material that is designated as
5 “CONFIDENTIAL.”
6 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
7 Producing Party.
8 3. SCOPE
9 The types of information eligible for protection under this Stipulation and Order include the
10 following: Plaintiff’s medical records; Plaintiff’s personnel records containing information which is
11 private pursuant to Article 1 Section 1 of the California Constitution. Courts have routinely
12 recognized a legally cognizable privacy interest in records of this nature. See e.g., Doe v. A. J. Boggs
13 & Co., No. 118CV01464AWIBAM, 2019 WL 1517567, at *6 (E.D. Cal. Apr. 8, 2019) (citing Pettus
14 v. Cole, 49 Cal. App. 4th 402, 440 (1996)) (ordering discovery of Plaintiffs’ medical information as
15 subject to protective order because “California law recognizes a constitutional right to privacy in an
16 individual’s medical history”); Buchanan v. Santos, No. 1:08-CV-01174-AWI, 2011 WL 2112475,
17 at *5 (E.D. Cal. May 26, 2011) (ordering discovery of personnel records as subject to protective
18 order); Sanchez v. Cty. of Sacramento Sheriff’s Dep’t, No. 2:19-CV-01545 MCE AC, 2020 WL
19 3542328, at *5 (E.D. Cal. June 30, 2020) (ordering discovery of personnel records as subject to
20 protective order).
21 The protections conferred by this Stipulation and Order cover not only Protected Material (as
22 defined above), but also (1) any information copied or extracted from Protected Material; (2) all
23 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
24 conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
25 However, the protections conferred by this Stipulation and Order do not cover the following
26 information: (a) any information that is in the public domain at the time of disclosure to a Receiving
27 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of
1 through trial or otherwise; and (b) any information known to the Receiving Party prior to the
2 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the
3 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of
4 Protected Material at trial shall be governed by a separate agreement or order.
5 4. DURATION
6 Even after final disposition of this litigation, the confidentiality obligations imposed by this
7 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
8 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and
9 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion
10 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the
11 time limits for filing any motions or applications for extension of time pursuant to applicable law.
12 5. DESIGNATING PROTECTED MATERIAL
13 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or
14 Non-Party that designates information or items for protection under this Order must take care to
15 limit any such designation to specific material that qualifies under the appropriate standards. The
16 Designating Party must designate for protection only those parts of material, documents, items, or
17 oral or written communications that qualify – so that other portions of the material, documents,
18 items, or communications for which protection is not warranted are not swept unjustifiably within
19 the ambit of this Order.
20 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown
21 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
22 encumber or retard the case development process or to impose unnecessary expenses and burdens on
23 other parties) expose the Designating Party to sanctions.
24 If it comes to a Designating Party’s attention that information or items that it designated for
25 protection do not qualify for protection, that Designating Party must promptly notify all other Parties
26 that it is withdrawing the mistaken designation.
27 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order
1 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
2 designated before the material is disclosed or produced.
3 Designation in conformity with this Order requires:
4 (a) for information in documentary form (e.g., paper or electronic documents, but
5 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
6 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion
7 or portions of the material on a page qualifies for protection, the Producing Party also must clearly
8 identify the protected portion(s) (e.g., by making appropriate markings in the margins).
9 A Party or Non-Party that makes original documents or materials available for inspection need not
10 designate them for protection until after the inspecting Party has indicated which material it would
11 like copied and produced. During the inspection and before the designation, all of the material made
12 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
13 identified the documents it wants copied and produced, the Producing Party must determine which
14 documents, or portions thereof, qualify for protection under this Order. Then, before producing the
15 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
16 that contains Protected Material. If only a portion or portions of the material on a page qualifies for
17 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making
18 appropriate markings in the margins).
19 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the
20 Designating Party identify on the record, before the close of the deposition, hearing, or other
21 proceeding, all protected testimony.
22 (c) for information produced in some form other than documentary and for any other
23 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or
24 containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
25 portion or portions of the information or item warrant protection, the Producing Party, to the extent
26 practicable, shall identify the protected portion(s).
27 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
1 right to secure protection under this Order for such material. Upon timely correction of a
2 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in
3 accordance with the provisions of this Order.
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
6 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
7 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens,
8 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a
9 confidentiality designation by electing not to mount a challenge promptly after the original
10 designation is disclosed.
11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process
12 by providing written notice of each designation it is challenging and describing the basis for each
13 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
14 recite that the challenge to confidentiality is being made in accordance with this specific paragraph
15 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must
16 begin the process by conferring directly (in voice to voice dialogue; other forms of communication
17 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging
18 Party must explain the basis for its belief that the confidentiality designation was not proper and
19 must give the Designating Party an opportunity to review the designated material, to reconsider the
20 circumstances, and, if no change in designation is offered, to explain the basis for the chosen
21 designation. A Challenging Party may proceed to the next stage of the challenge process only if it
22 has engaged in this meet and confer process first or establishes that the Designating Party is
23 unwilling to participate in the meet and confer process in a timely manner.
24 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
25 intervention, the Designating Party shall file and serve a motion to retain confidentiality as per
26 applicable judicial standing orders and local rules within 21 days of the initial notice of challenge or
27 within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute,
1 that the movant has complied with the meet and confer requirements imposed in the preceding
2 paragraph. Failure by the Designating Party to make such a motion including the required
3 declaration within 21 days (or 14 days, if applicable) shall automatically waive the confidentiality
4 designation for each challenged designation. In addition, the Challenging Party may file a motion
5 challenging a confidentiality designation at any time if there is good cause for doing so, including a
6 challenge to the designation of a deposition transcript or any portions thereof. Any motion brought
7 pursuant to this provision must be accompanied by a competent declaration affirming that the
8 movant has complied with the meet and confer requirements imposed by the preceding paragraph.
9 The burden of persuasion in any such challenge proceeding shall be on the Designating
10 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
11 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
12 Unless the Designating Party has waived the confidentiality designation by failing to file a motion to
13 retain confidentiality as described above, all parties shall continue to afford the material in question
14 the level of protection to which it is entitled under the Producing Party’s designation until the court
15 rules on the challenge.
16 7. ACCESS TO AND USE OF PROTECTED MATERIAL
17 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
18 produced by another Party or by a Non-Party in connection with this case only for prosecuting,
19 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
20 the categories of persons and under the conditions described in this Order. When the litigation has
21 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
22 DISPOSITION).
23 Protected Material must be stored and maintained by a Receiving Party at a location and in a
24 secure manner that ensures that access is limited to the persons authorized under this Order.
25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
26 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
27 information or item designated “CONFIDENTIAL” only to:
1 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees
2 of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for
3 this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is
4 attached hereto as Exhibit A;
5 (b) the officers, directors, and employees (including House Counsel) of the Receiving
6 Party to whom disclosure is reasonably necessary for this litigation and who have signed the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
9 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement
10 to Be Bound” (Exhibit A);
11 (d) the court and its personnel;
12 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, and
13 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have
14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (f) during their depositions, witnesses in the action to whom disclosure is reasonably
16 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
17 unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
18 deposition testimony or exhibits to depositions that reveal Protected Material must be separately
19 bound by the court reporter and may not be disclosed to anyone except as permitted under this
20 Stipulated Protective Order.
21 (g) the author or recipient of a document containing the information or a custodian or
22 other person who otherwise possessed or knew the information.
23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
24 LITIGATION
25 If a Party is served with a subpoena or a court order issued in other litigation that compels
26 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
27 must:
1 (a) promptly notify in writing the Designating Party. Such notification shall include a
2 copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena or order to issue in the
4 other litigation that some or all of the material covered by the subpoena or order is subject to this
5 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
6 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
7 Designating Party whose Protected Material may be affected.
8 If the Designating Party timely seeks a protective order, the Party served with the subpoena
9 or court order shall not produce any information designated in this action as “CONFIDENTIAL”
10 before a determination by the court from which the subpoena or order issued, unless the Party has
11 obtained the Designating Party’s permission. The Designating Party shall bear the burden and
12 expense of seeking protection in that court of its confidential material – and nothing in these
13 provisions should be construed as authorizing or encouraging a Receiving Party in this action to
14 disobey a lawful directive from another court.
15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
16 LITIGATION
17 (a) The terms of this Order are applicable to information produced by a Non-Party in this
18 action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
19 connection with this litigation is protected by the remedies and relief provided by this Order.
20 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional
21 protections.
22 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-
23 Party’s confidential information in its possession, and the Party is subject to an agreement with the
24 Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
25 (1) promptly notify in writing the Requesting Party and the Non-Party that some or
26 all of the information requested is subject to a confidentiality agreement with a Non-Party;
27
1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in
2 this litigation, the relevant discovery request(s), and a reasonably specific description of the
3 information requested; and
4 (3) make the information requested available for inspection by the Non-Party.
5 (c) If the Non-Party fails to object or seek a protective order from this court within 14
6 days of receiving the notice and accompanying information, the Receiving Party may produce the
7 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely
8 seeks a protective order, the Receiving Party shall not produce any information in its possession or
9 control that is subject to the confidentiality agreement with the Non-Party before a determination by
10 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of
11 seeking protection in this court of its Protected Material.
12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
14 Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
15 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
16 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
17 inform the person or persons to whom unauthorized disclosures were made of all the terms of this
18 Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
19 Be Bound” that is attached hereto as Exhibit A.
20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
21 MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced
23 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties
24 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to
25 modify whatever 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 (e), insofar as the
27 parties reach an agreement on the effect of disclosure of a communication or information covered by
1 the attorney-client privilege or work product protection, the parties may incorporate their agreement
2 in the stipulated protective order submitted to the court.
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek
5 its modification by the court in the future.
6 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order
7 no Party waives any right it otherwise would have to object to disclosing or producing any
8 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
9 Party waives any right to object on any ground to use in evidence of any of the material covered by
10 this Protective Order.
11 12.3 Filing Protected Material. Without written permission from the Designating Party or a
12 court order secured after appropriate notice to all interested persons, a Party may not file in the
13 public record in this action any Protected Material. A Party that seeks to file under seal any Protected
14 Material must comply with Civil Local Rules 140 and 141.
15 13. FINAL DISPOSITION
16 Within 60 days after the final disposition of this action, as defined in paragraph 4, each
17 Receiving Party must return all Protected Material to the Producing Party or destroy such material.
18 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
19 summaries, and any other format reproducing or capturing any of the Protected Material. Whether
20 the Protected Material is returned or destroyed, the Receiving Party must submit a written
21 certification to the Producing Party (and, if not the same person or entity, to the Designating Party)
22 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material
23 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies,
24 abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected
25 Material.
26 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
27 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
1 || and expert work product, even if such materials contain Protected Material. Any such archival copi
2 || that contain or constitute Protected Material remain subject to this Protective Order as set forth in
3 || Section 4 (DURATION).
4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5 || Dated: April 19, 2024 FARELLA BRAUN + MARTEL LLP
7 By: /s/ Emily J. Tripodi
Emily J. Tripodi
° Attorneys for Defendant AMAZON.COM SERVICES
9 LLC
Dated: April 19, 2024 WEST COAST EMPLOYMENT LAWYERS, APLC
11
12 By: /s/ Crystal F. Mohsin
13 Crystal F. Mohsin
4 Attorneys for Plaintiff SCOTT BROCK
1S IT IS SO ORDERED.
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Dated: _ April 22, 2024 | hannD Pr
17 UNITED STATES MAGISTRATE JUDGE
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of _________________ [print or
4 type full address], declare under penalty of perjury that I have read in its entirety and understand the
5 Stipulated Protective Order that was issued by the United States District Court for the Eastern
6 District of California on [date] in the case of Scott Brock v. Amazon.com Services LLC, Case No.
7 1:23-cv-00613-KES-CDB. I agree to comply with and to be bound by all the terms of this Stipulated
8 Protective Order and I understand and acknowledge that failure to so comply could expose me to
9 sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in
10 any manner any information or item that is subject to this Stipulated Protective Order to any person
11 or entity except in strict compliance with the provisions of this Order.
12 I further agree to submit to the jurisdiction of the United States District Court for the Eastern District
13 of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such
14 enforcement proceedings occur after termination of this action.
15 I hereby appoint __________________________ [print or type full name] of
16 _______________________________________ [print or type full address and telephone number] as
17 my California agent for service of process in connection with this action or any proceedings related
18 to enforcement of this Stipulated Protective Order.
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20 Date: ______________________________________
21 City and State where sworn and signed: _________________________________
22 Printed name: _______________________________
23 Signature: __________________________________
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1 ATTESTATION
2 I hereby attest that all other signatories listed, and on whose behalf the filing is submitted,
3 concur in the filing’s content and have authorized the filing.
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Dated: April 19, 2024 FARELLA BRAUN + MARTEL LLP
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By: /s/ Emily J. Tripodi
7 Emily J. Tripodi
8 Attorneys for Defendant AMAZON.COM SERVICES
LLC
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