Opinion

Norman Gainer v. County of San Bernardino

Court
District Court, C.D. California
Filed
Nov 27, 2024
Cited by
0 cases
Authority
More cited than 33.2%

The opinion

1 BURRIS, NISENBAUM, CURRY, AND LACY LLP

JOHN L. BURRIS, Esq. (SBN 69888)

2

Airport Corporate Centre

3 7677 Oakport Street, Suite 1120

Oakland, California 94621

4

Telephone: (510) 839-5200

5 Facsimile: (844) 273-6873

john.burris@johnburrislaw.com

6

7 BURRIS, NISENBAUM, CURRY, AND LACY LLP

8

DEWITT M. LACY, Esq. (SBN 258789)

JULIA N. QUESADA, Esq. (SBN 337872)

9 LENA P. ANDREWS, Esq. (SBN 342471)

9701 Wilshire Blvd., Suite 1000

10

Beverly Hills, California 90212

11 Telephone: (310) 601-7070

Facsimile: (844) 273-6873

12

dewitt@bncllaw.com

13 julia.quesada@bncllaw.com

lena.andrews@bncllaw.com

14

15 Attorneys for Plaintiffs,

Norman Gainer, Sharon Haywood

16

Rebecca Gainer, and William Roper

17

UNITED STATES DISTRICT COURT

18

19 CENTRAL DISTRICT OF CALIFORNIA

20

NORMAN GAINER, individually and Case No.: 5:24-cv-01438-MWC-SPx

21 as Successor-in-Interest to Decedent

Ryan Gainer; SHARON HAYWOOD, (District Judge Hon. Michelle Williams

22

individually and as Successor-in- Court; Magistrate Judge Hon. Sheri

23 Interest to Decedent Ryan Gainer; Pym)

24 REBECCA GAINER, an individual,

and WILLIAM ROPER, an individual, STIPULATED PROTECTIVE

25 ORDER

26 Plaintiffs,

vs.

27

1 COUNTY OF SAN BERNARDINO, a

municipal entity; BRANDON

2

CLANCY, individually and in his

3 official capacity as Sheriff’s Deputy for

the San Bernardino County Sheriff’s

4

Department; and WYATT

5 EISENBREY, individually and in his

official capacity as Sheriff’s Deputy for

6

the San Bernardino County Sheriff’s

7 Department, and DOES 1 through 50,

inclusive, individually and in official

8

capacity as deputies for the County of

9 San Bernardino Sheriff’s Department,

10

Defendants.

11

12

TO THE HONORABLE COURT:

13 By and through their counsel of record, Plaintiffs NORMAN GAINER,

14 SHARON HAYWOOD, REBECCA GAINER and WILLIAM ROPER,

15 individually (collectively hereinafter “Plaintiffs”), and Defendants COUNTY OF

16 SAN BERNARDINO, BRANDON CLANCY, and WYATT EISENBREY

17 (hereinafter collectively “Defendants”) – the Parties – hereby stipulate for the

18 purpose of jointly requesting that the honorable Court enter a protective order

19 regarding the confidential documents in this matter, pursuant to Fed. R. Civ. P. 5.2,

20 7, and 26; U.S. Dist. Ct., C.D. Cal. Local Rule 79-5.2.2; and any applicable Orders

21 of the Court, as follows:

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

1

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

2

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

3

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

4

under the applicable legal principles. The parties further acknowledge, as set forth

5

in Section 12.3, below, that this Stipulated Protective Order does not entitle them to

6

file confidential information under seal; Civil Local Rule 79-5 sets forth the

7

procedures that must be followed and the standards that will be applied when a party

8

seeks permission from the court to file material under seal.

9

B. GOOD CAUSE STATEMENT

10

The parties maintain that good cause exists for entry of a protective order in

11

this action. Oliner v. Kontrabecki, 745 F.3d 1024, 1026 (9th Cir. 2014).

12

This litigation is in the early stages of discovery. In light of the nature of the

13

claims and allegations in this case, the Parties contend that some of the documents

14

and information that will be produced during the discovery process contain

15

confidential information.

16

Specifically, private medical records and information will likely be exchanged

17

between the parties, which warrants special protection from public disclosure and

18

from use for any purpose other than prosecution of this action. Moreover, Defendant

19

Deputies are peace officers whose personnel records are confidential under

20

California law. Portions of police personnel records may be disclosed, as well as

21

documents reflecting policies, functioning, training, schedules, or other operational

22

details of law enforcement, and these must also be protected from public disclosure

23

in order to ensure the safety and security of law enforcement and the public. The

24

personnel records warrant special protection from public disclosure and from use for

25

any purpose other than prosecution of this action. The disclosure of certain

26

information may also jeopardize the security of the County's operations and

27

jeopardize the safety of its peace officers. Such confidential and proprietary

1

materials and information consist of, among other things, confidential employment

2

and personnel information relating to a peace officer which is otherwise generally

3

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

4

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

5

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

6

resolution of disputes over confidentiality of discovery materials, to adequately

7

protect information the parties are entitled to keep confidential, to ensure that the

8

parties are permitted reasonable necessary uses of such material in preparation for

9

and in the conduct of trial, to address their handling at the end of the litigation, and

10

serve the ends of justice, a protective order for such information is justified in this

11

matter. The parties shall not designate any information/documents as confidential

12

without a good faith belief that such information/documents have been maintained

13

in a confidential, non-public manner, and that there is good cause or a compelling

14

reason why it should not be part of the public record of this case.

15

2. DEFINITIONS

16

2.1 Action: Gainer, et al. v. County of San Bernardino, et al., Case No.:

17

5:24-cv-01438-KK-SP

18

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

19

of information or items under this Order.

20

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

21

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

22

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

23

the Good Cause Statement.

24

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

25

their support staff).

26

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

27

items that it produces in disclosures or in responses to discovery as

1

“CONFIDENTIAL.”

2

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

3

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

4

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

5

generated in disclosures or responses to discovery in this matter.

6

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

7

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

8

an expert witness or as a consultant in this Action.

9

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

10

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

11

counsel.

12

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

13

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

14

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

15

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

16

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

17

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

18

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

19

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

20

support staffs).

21

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

22

Discovery Material in this Action.

23

2.13 Professional Vendors: persons or entities that provide litigation support

24

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

25

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

26

and their employees and subcontractors.

27

2.14 Protected Material: any Disclosure or Discovery Material that is

1

designated as “CONFIDENTIAL.”

2

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

3

from a Producing Party.

4

3. SCOPE

5

The protections conferred by this Stipulation and Order cover not only

6

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

7

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

8

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

9

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

10

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

11

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

12

4. DURATION

13

Even after final disposition of this litigation, the confidentiality obligations

14

imposed by this Order shall remain in effect until a Designating Party agrees

15

otherwise in writing or a court order otherwise directs. Final disposition shall be

16

deemed to be the later of (1) dismissal of all claims and defenses in this Action,

17

with or without prejudice; and (2) final judgment herein after the completion and

18

exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

19

including the time limits for filing any motions or applications for extension of

20

time pursuant to applicable law.

21

5. DESIGNATING PROTECTED MATERIAL

22

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

23

Each Party or Non-Party that designates information or items for protection under

24

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

25

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

26

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

27

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

1

or communications for which protection is not warranted are not swept unjustifiably

2

within the ambit of this Order.

3

Mass, indiscriminate, or routinized designations are prohibited. Designations

4

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

5

purpose (e.g., to unnecessarily encumber or retard the case development process or

6

to impose unnecessary expenses and burdens on other parties) expose the

7

Designating Party to sanctions.

8

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

9

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

10

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

11

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

12

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

13

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

14

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

15

produced.

16

Designation in conformity with this Order requires:

17

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

18

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

19

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

20

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

21

contains protected material. If only a portion or portions of the material on a page

22

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

23

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

24

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

25

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

26

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

27

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

1

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

2

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

3

documents, or portions thereof, qualify for protection under this Order. Then, before

4

producing the specified documents, the Producing Party must affix the

5

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

6

portion or portions of the material on a page qualifies for protection, the Producing

7

Party also must clearly identify the protected portion(s) (e.g., by making appropriate

8

markings in the margins).

9

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

10

the Disclosure or Discovery Material on the record, before the close of the deposition

11

all protected testimony.

12

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

13

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

14

exterior of the container or containers in which the information is stored the legend

15

“CONFIDENTIAL.” If only a portion or portions of the information warrants

16

protection, the Producing Party, to the extent practicable, shall identify the protected

17

portion(s).

18

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

19

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

20

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

21

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

22

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

23

Order.

24

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

25

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

26

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

27

Scheduling Order.

1

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

2

resolution process under Local Rule 37.1 et seq.

3

6.3 Burden of Persuasion. The burden of persuasion in any such challenge

4

proceeding shall be on the Designating Party. Frivolous challenges, and those made

5

for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens

6

on other parties) may expose the Challenging Party to sanctions. Unless the

7

Designating Party has waived or withdrawn the confidentiality designation, all

8

parties shall continue to afford the material in question the level of protection to

9

which it is entitled under the Producing Party’s designation until the Court rules on

10

the challenge.

11

7. ACCESS TO AND USE OF PROTECTED MATERIAL

12

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

13

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

14

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

15

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

16

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

17

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

18

DISPOSITION).

19

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

20

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

21

authorized under this Order.

22

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

23

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

24

Receiving Party may disclose any information or item designated

25

“CONFIDENTIAL” only to:

26

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

27

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

1

necessary to disclose the information for this Action;

2

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

3

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

4

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

5

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

6

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

7

(d) the court and its personnel;

8

(e) court reporters and their staff;

9

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

10

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

11

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

12

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

13

a custodian or other person who otherwise possessed or knew the information;

14

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

15

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

16

party requests that the witness sign the form attached as Exhibit 1 hereto; and (2)

17

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

18

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

19

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

20

deposition testimony or exhibits to depositions that reveal Protected Material may

21

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

22

as permitted under this Stipulated Protective Order; and

23

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

24

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

25

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

26

IN OTHER LITIGATION

27

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

1

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

2

“CONFIDENTIAL,” that Party must:

3

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

4

shall include a copy of the subpoena or court order;

5

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

6

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

7

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

8

a copy of this Stipulated Protective Order; and

9

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

10

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

11

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

12

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

13

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

14

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

15

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

16

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

17

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

18

to disobey a lawful directive from another court.

19

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

20

PRODUCED IN THIS LITIGATION

21

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

22

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

23

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

24

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

25

construed as prohibiting a Non-Party from seeking additional protections.

26

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

27

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

1

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

2

confidential information, then the Party shall:

3

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

4

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

5

agreement with a Non-Party;

6

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

7

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

8

specific description of the information requested; and

9

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

10

Non-Party, if requested.

11

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

12

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

13

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

14

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

15

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

16

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

17

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

18

of seeking protection in this court of its Protected Material.

19

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

20

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

21

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

22

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

23

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

24

to retrieve all unauthorized copies of the Protected Material, (c) inform the person

25

or persons to whom unauthorized disclosures were made of all the terms of this

26

Order, and (d) request such person or persons to execute the “Acknowledgment and

27

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

1

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

2

PROTECTED MATERIAL

3

When a Producing Party gives notice to Receiving Parties that certain

4

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

5

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

6

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

7

may be established in an e-discovery order that provides for production without prior

8

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

9

parties reach an agreement on the effect of disclosure of a communication or

10

information covered by the attorney-client privilege or work product protection, the

11

parties may incorporate their agreement in the stipulated protective order submitted

12

to the court.

13

12. MISCELLANEOUS

14

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

15

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

16

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

17

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

18

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

19

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

20

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

21

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

22

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

23

only be filed under seal pursuant to a court order authorizing the sealing of the

24

specific Protected Material at issue. If a Party's request to file Protected Material

25

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

26

in the public record unless otherwise instructed by the court.

27

1

13. FINAL DISPOSITION

2

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

3

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

4

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

5

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

6

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

7

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

8

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

9

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

10

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

11

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

12

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

13

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

14

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

15

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

16

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

17

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

18

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

19

Section 4 (DURATION).

20

14. Any violation of this Order may be punished by any and all appropriate

21

measures including, without limitation, contempt proceedings and/or monetary

22

sanctions.

23

///

24

///

25

///

26

///

27

///

1

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2

3

DATED: November 22, 2024 BURRIS NISENBAUM CURRY LACY

4

By: /s/ Julia N. Quesada

5 DeWitt M. Lacy

Julia N. Quesada

6

Lena P. Andrews

7

Attorneys for Plaintiffs,

8

Norman Gainer, Sharon Hawyood,

9 Rebecca Gainer, and William Roper

10

11 DATED: November 22, 2024 WESIERSKI AND ZUREK LLP

12 By: /s/ Michelle R. Prescott

Christopher P Wesierski

13

Michelle R Prescott

14 Kristen R. Rodriguez

15

Attorneys for Defendants,

16

County of San Bernardino,

17 Brandon Clancy, and

Wyatt Eisenbrey

18

19

20

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21

22

DATED: November 27, 2024

23

24

25

HONORABLE SHERI PYM

26 United States Magistrate Judge

27

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

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

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

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

7 on [date] in the case of Gainer, et al. v. County of San Bernardino, et al., Case No.:

8 5:24-cv-01438-MWC-SPx. I agree to comply with and to be bound by all the terms

9 of this Stipulated Protective Order and I understand and acknowledge that failure to

10 so comply could expose me to sanctions and punishment in the nature of contempt.

11 I solemnly promise that I will not disclose in any manner any information or item

12 that is subject to this Stipulated Protective Order to any person or entity except in

13 strict compliance with the provisions of this Order.

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

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

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

17 this action. I hereby appoint __________________________ [print or type full

18 name] of _______________________________________ [print or type full address

19 and telephone number] as my California agent for service of process in connection

20 with this action or any proceedings related to enforcement of this Stipulated

21 Protective Order.

22 Date: ______________________________________

23 City and State where sworn and signed: _________________________________

24

25 Printed name: _______________________________

26

27 Signature: __________________________________

1

ELECTRONIC CASE FILING ATTESTATION

2

I, Julia N. Quesada, hereby attest that I have on file all holograph signatures

3

for any signatures indicated by a conformed signature (“/s/”) within this e-filed

4

document or have been authorized by counsel to sow their signature on this

5

document as /s/.

6

7

Dated: November 22, 2024 BURRIS NISENBAUM CURRY LACY

8

9

By: /s/ Julia N. Quesada

10

JULIA N. QUESADA

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.