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
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