Opinion

Renard Owens v. City of Beverly Hills

Court: District Court, C.D. California
Filed: Feb 1, 2022
Cited by: 0 cases
Authority: More cited than 16.3%

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

How later courts described this case

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

Written by the judges who cited it.

The opinion

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WOODRUFF, SPRADLIN & SMART, APC

DANIEL K. SPRADLIN - State Bar No. 82950

dspradlin@wss-law.com

WALTER M. CRANDALL - State Bar No. 250976

wcrandall@wss-law.com

555 Anton Boulevard, Suite 1200

Costa Mesa, California 92626-7670 NOTE: CHANGES MADE BY THE COURT

Telephone: (714) 558-7000

Facsimile: (714) 835-7787

Attorneys for Defendants CITY OF BEVERLY HILLS, a public

entity, and Officer ZACHARY TRAVNITZ, as an employee of the

City of Beverly Hills, a public entity

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

RENARD OWENS, CASE NO.: 2:21-cv-01738 AB (JPRx)

Plaintiff, BEFORE THE HONORABLE

ANDRÉ BIROTTE JR.

CITY OF BEVERLY HILLS; a public “DISCOVERY MATTER”

entity; ZACHARY TRAVNITZ, an

individual; and DOES 1 through 10, STIPULATION RE: [PROPOSED]

inclusive, PROTECTIVE ORDER

Defendants.

Plaintiff RENARD OWENS and Defendants CITY OF BEVERLY HILLS, a

public entity, and Officer ZACHARY TRAVNITZ, as an employee of the City of

Beverly Hills, a public entity, by and through their respective counsel, hereby stipulate

and agree as follows:

1. PURPOSES AND LIMITATIONS

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

proprietary or private information for which special protection from public disclosure

and from use for any purpose other than prosecuting this litigation may be warranted.

Accordingly, the parties hereby stipulate to and petition the Court to enter the

following Stipulated Protective Order. The parties acknowledge that this Order does

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not confer blanket protections on all disclosures or responses to discovery and that the

protection it affords from public disclosure and use extends only to the limited

information or items that are entitled to confidential treatment under the applicable

legal principles.

The parties further acknowledge, as set forth in Section 13.3, below, that this

Stipulated Protective Order does not automatically entitle them to file confidential

information under seal and that Local Civil Rule 79-5 sets forth the procedures that

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

from the Court to file material under seal. This order is necessary to allow Plaintiff to

prosecute – and permit Defendants to defend – this civil rights action. The parties

agree that this protective order does not waive the parties’ rights to object to discovery

demands or requests for documents and/or information.

2. GOOD CAUSE STATEMENT

This action is likely to involve medical records and law enforcement records for

which special protection from public disclosure and from use for any purpose other

than prosecution of this action is warranted. Such confidential materials and

information may consist of, among other things, medical records and law enforcement

records (including information implicating privacy rights of third parties), information

otherwise generally unavailable to the public, or which may be privileged or otherwise

protected from disclosure under state or federal statutes, court rules, case decisions, or

common law. Accordingly, to expedite the flow of information, to facilitate the

prompt resolution of disputes over confidentiality of discovery materials, to

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

that the parties are permitted reasonable necessary uses of such material in preparation

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

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

matter. It is the intent of the parties that information will not be designated as

confidential for tactical reasons and that nothing be so designated without a good faith

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belief that it has been maintained in a confidential, non-public manner, and there is

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

3. DEFINITIONS

3.1 Action: Owens v. City of Beverly Hills, et al. Case No. 2:21-cv-01738

AB (JPRx).

3.2 Challenging Party: A Party or Non-Party that challenges the designation

of information or items under this Order.

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

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

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

Cause Statement. This also includes (1) any information copied or extracted from the

Confidential information; (2) all copies, excerpts, summaries, abstracts or

compilations of Confidential information; and (3) any testimony, conversations, or

presentations that might reveal Confidential information.

3.4 Counsel: Counsel of record for the parties to this civil litigation and their

support staff.

3.5 Designating Party: A Party or Non-Party that designates information or

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

“CONFIDENTIAL.”

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

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

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

generated in disclosures or responses to discovery in this matter.

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

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

expert witness or as a consultant in this Action.

3.8 Final Disposition: when this Action has been fully and completely

terminated by way of settlement, dismissal, trial and/or appeal.

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3.9 House Counsel: attorneys other than Counsel (as defined in paragraph

3.4) and who are employees of a party to this Action.

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

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

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

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

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

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

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

boards, departments, divisions, employees, consultants, retained experts, and Outside

Counsel of Record (and their support staffs).

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

Discovery Material in this Action.

3.14 Professional Vendors: persons or entities that provide litigation support

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

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

and their employees and subcontractors.

3.15 Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

3.16 Receiving Party: A Party that receives Disclosure or Discovery Material

from a Producing Party.

4. SCOPE

The protections conferred by this Stipulation and Order cover not only

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

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

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

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

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

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

5. DURATION

Once a trial commences in this Action, information that was designated as

CONFIDENTIAL or maintained pursuant to this protective order and that is

introduced or admitted as an exhibit at trial becomes public and will be presumptively

available to all members of the public, including the press, unless compelling reasons

supported by specific factual findings to proceed otherwise are made to the trial judge

in advance of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172,

1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents

produced in discovery from “compelling reasons” standard when merits-related

documents are part of court record). Accordingly, the terms of this protective order do

not extend beyond the commencement of the trial as to the CONFIDENTIAL

information and materials introduced or admitted as an exhibit at trial.

6. DESIGNATING PROTECTED MATERIAL

6.1 Exercise of Restraint and Care in Designating Material for

Protection.

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

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

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

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

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

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

within the ambit of this Order.

Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

unnecessary expenses and burdens on other parties) may expose the Designating Party

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to sanctions.

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

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

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

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

this Order (see, e.g., second paragraph of section 6.2(a) below), or as otherwise

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

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

produced.

Designation in conformity with this Order requires:

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

but excluding transcripts of depositions or other pretrial or trial proceedings), that the

Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a

similar effect, and that includes the case name and case number (hereinafter

“CONFIDENTIAL legend”), to each page that contains protected material. If only a

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

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

the margins).

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

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

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

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

“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

copied and produced, the Producing Party must determine which documents, or

portions thereof, qualify for protection under this Order. Then, before producing the

specified documents, the Producing Party must affix the “CONFIDENTIAL legend”

to each page that contains Protected Material. If only a portion of the material on a

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

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

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

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

protected testimony.

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

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

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

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

portion(s).

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

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

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

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

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

Order.

7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

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

Scheduling Order.

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

resolution process under Local Rule 37.1 et seq.

7.3 Burden and Protection During Challenge. The burden of persuasion in

any such challenge proceeding shall be on the Designating Party. Frivolous

challenges, and those made for an improper purpose (e.g., to harass or impose

unnecessary expenses and burdens on other parties) may expose the Challenging Party

to sanctions. Unless the Designating Party has waived or withdrawn the

confidentiality designation, all parties shall continue to afford the material in question

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the level of protection to which it is entitled under the Producing Party’s designation

until the Court rules on the challenge.

8. ACCESS TO AND USE OF PROTECTED MATERIAL

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

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

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

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

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

Party must comply with the provisions of section 14 below (FINAL DISPOSITION).

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

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

authorized under this Order.

8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Receiving Party may disclose any information or item designated “CONFIDENTIAL”

only to:

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

employees of said Counsel of Record to whom it is reasonably necessary to disclose

the information for this Action;

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

is reasonably necessary for this Action and who have signed the “Acknowledgment

and Agreement to Be Bound” (Exhibit A);

(e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

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

deposition testimony or exhibits to depositions that reveal Protected Material may be

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

permitted under this Stipulated Protective Order; and

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

agreed upon by any of the parties engaged in settlement discussions or appointed by

the Court and, except as to judicial officers, who have signed the “Acknowledgment

and Agreement to Be Bound” (Exhibit A).

8.3. Counsel making the disclosure to any qualified person described herein

shall retain the original executed copy of the Acknowledgment and Agreement to Be

Bound until sixty (60) days after this litigation has become final, including any

appellate review, and monitoring of an injunction. Counsel for the Receiving Party

shall maintain all signed Acknowledgments and Agreements to Be Bound and shall

produce the original signature page upon reasonable written notice from opposing

counsel. If an issue arises regarding a purported unauthorized disclosure of

Confidential Information, counsel for the Receiving Party may be required to submit

the signed Acknowledgments and Agreements to Be Bound, as well as a list of the

disclosed materials, in camera with the Court having jurisdiction of the Stipulation.

9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:

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

include a copy of the subpoena or court order unless prohibited by law;

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

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

order is subject to this Protective Order. Such notification shall include a copy of this

Stipulated Protective Order; and

the Designating Party whose Protected Material may be affected.

The Party served with the subpoena or court order shall not produce any

information designated in this action as “CONFIDENTIAL” unless the Party has

obtained the Designating Party’s permission or a Court so orders. Nothing in these

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

Action to disobey a lawful directive from another court.

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

PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

confidential information, then the Party shall:

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

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

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confidentiality agreement with a Non-Party;

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

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

reasonably specific description of the information requested; and

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

Non-Party, if requested.

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

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

If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

any information in its possession or control that is subject to the confidentiality

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

order to the contrary, the Non-Party shall bear the burden and expense of seeking

protection in this court of its Protected Material.

11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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

12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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

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

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

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

parties may incorporate their agreement in the stipulated protective order submitted to

the court provided the Court so allows.

13. MISCELLANEOUS

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

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

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

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

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

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

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

13.3 Filing Protected Material. Without written permission from the

Designating Party or a court order secured after appropriate notice to all

interested persons, a Party may not file in the public record in this action any

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

comply with Local Civil Rule 79-5. Protected Material may only be filed under seal

pursuant to a court order authorizing the sealing of the specific Protected Material at

issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request

establishing that the Protected Material at issue is privileged, protectable as a trade

secret, or otherwise entitled to protection under the law. If a Receiving Party's request

to file Protected Material under seal pursuant to Civil Local Rule 79-5.2.2(b) is denied

by the court, then the Receiving Party may file the information in the public record

pursuant to Civil Local Rule 79-5.2.2(b)(ii) unless otherwise instructed by the court.

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14. FINAL DISPOSITION

After the FINAL DISPOSITION of this Action, as defined in paragraph 3.8,

within 30 days of a written request by the Designating Party, each Receiving Party

must return all Protected Material to the Producing Party. As used in this subdivision,

“all Protected Material” includes all copies, abstracts, compilations, summaries, and

any other format reproducing or capturing any of the Protected Material. The

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

the same person or entity, to the Designating Party) by the 30-day deadline that (1)

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

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

compilations, summaries or any other format reproducing or capturing any of the

Protected Material.

15. VIOLATION

Any violation of this Order may be punished by appropriate measures

including, without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

DATED: January 31, 2022 WILLIAMS & SEEMAN

By:_/s/Bart Seeman_______________________

BART SEEMAN

Attorneys for Plaintiff

RENARD OWENS

DATED: Janaury 31, 2022 LAW OFFICES OF ERIN DARLING

By:_/s/Erin Darling_______________________

ERIN DARLING

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Attorneys for Plaintif

RENARD OWENS

DATED: January 31, 2022 WOODRUFF, SPRADLIN & SMART, APC

By: _/s/Walter M. Crandall_________________

DANIEL K. SPRADLIN

WALTER M. CRANDALL

Attorneys for Defendants CITY OF

BEVERLY HILLS, a public entity, and

Officer ZACHARY TRAVNITZ, as an

employee of the City of Beverly Hills, a

public entity

Pursuant to local 5-4.3.4, I, Walter M. Crandall, attest that Bart Seeman and

Erin Darling concur with the content of this joint stipulated protective order and have

authorized the filing of the same.

DATED: January 31, 2022 WOODRUFF, SPRADLIN & SMART, APC

By:_/s/Walter M. Crandall_________________

DANIEL K. SPRADLIN

WALTER M. CRANDALL

Attorneys for Defendants CITY OF

BEVERLY HILLS, a public entity, and

Officer ZACHARY TRAVNITZ, as an

employee of the City of Beverly Hills, a

public entity

Case 2:21-cv-01738-AB-JPR Document 28 Filed 02/01/22 Page 15o0f19 Page ID #:325

2 || PURSUANT TO STIPULATION, IT IS SO ORDERED

: hrewhlate~

> || DATED: February 1, 2022 {

6 Jean P. Rosenbluth,

7 U.S. Magistrate Judge

as 13

Eotl

3 e 15

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EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ______________________________________[print or type full name], of

_________________________________ [print or type full address], declare under

penalty of perjury that I have read in its entirety and understand the Stipulated

Protective Order that was issued by the United States District Court for the Central

District of California on _____________ in the case of Owens v. City of Beverly

Hills, et al., United States District Court Case No. 2:21-cv-01738 AB (JPRx). I agree

to comply with and to be bound by all the terms of this Stipulated Protective Order

and I understand and acknowledge that failure to so comply could expose me to

sanctions and punishment in the nature of contempt. I solemnly promise that I will not

disclose in any manner any information or item that is subject to this Stipulated

Protective Order to any person or entity except in strict compliance with the

provisions of this Order.

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

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

Stipulated Protective Order, even if such enforcement proceedings occur after

termination of this action. I hereby appoint __________________________ [print or

type full name] of _______________________________________ [print or type full

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

connection with this action or any proceedings related to enforcement of this

Stipulated

Protective Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: _________________________________

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PROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF ORANGE

I am over the age of 18 and not a party to the within action; I am employed by

WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 Anton

Boulevard, Suite 1200, Costa Mesa, CA 92626-7670.

On January 31, 2022, I served the foregoing document(s) described as

STIPULATION RE: [PROPOSED] PROTECTIVE ORDER

 by placing the true copies thereof enclosed in sealed envelopes addressed as

stated on the attached mailing list;

 by placing  the original  a true copy thereof enclosed in sealed envelopes

addressed as follows:

 (BY MAIL) I placed said envelope(s) for collection and mailing, following

ordinary business practices, at the business offices of WOODRUFF,

SPRADLIN & SMART, and addressed as shown on the attached service list,

for deposit in the United States Postal Service. I am readily familiar with the

practice of WOODRUFF, SPRADLIN & SMART for collection and processing

correspondence for mailing with the United States Postal Service, and said

envelope(s) will be deposited with the United States Postal Service on said date

in the ordinary course of business.

 (BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be

electronically filed using the Court’s Electronic Filing System which constitutes

service of the filed document(s) on the individual(s) listed on the attached

mailing list.

 (BY OVERNIGHT DELIVERY) I placed said documents in envelope(s) for

collection following ordinary business practices, at the business offices of

WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached

service list, for collection and delivery to a courier authorized by

_________________________ to receive said documents, with delivery fees

provided for. I am readily familiar with the practices of WOODRUFF,

SPRADLIN & SMART for collection and processing of documents for

overnight delivery, and said envelope(s) will be deposited for receipt by

_________________________ on said date in the ordinary course of business.

 (BY PERSONAL SERVICE) I delivered such envelope(s) by hand to the

offices of the addressee(s).

 (Federal) I declare that I am employed in the office of a member of the bar of

this court at whose direction the service was made. I declare under

penalty of perjury that the above is true and correct.

Executed on January 31, 2022 at Costa Mesa, California.

s/Kathleen Moore__________________

Kathleen Moore

1657732.1

NILDARPS ,FFURDOOW

TRAMS &

WAL TA SYENROTTA

ASEM ATSOC

Case 2:21-cv-01738-AB-JPR Document 28 Filed 02/01/22 Page 19 of 19 Page ID #:329

RENARD OWENS v. CITY OF BEVERLY HILLS, ET AL.

SERVICE LIST

Bart A. Seemen Attorneys for Plaintiff

Williams & Seemen, A.P.L.C. RENARD OWENS

16255 Ventura Blvd., Suite 1106

Encino, CA 91436

Telephone: (818) 898-8300

Facsimile: (818) 574-3006

Email: bas@latrialteam.com

Email: adw@latrialteam.com

Erin Darling Attorneys for Plaintiff

Law Offices of Erin Darling RENARD OWENS

3435 Wilshire Boulevard, Suite 2910

Los Angeles, CA 90010

Telephone: (323) 736-2230

Email: erin@erin@erindarlinglaw.com

12/02/21

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.