Maria Romero v. Target Corporation

Case 2:21-cv-09761-SB-AFM Document 16 Filed 02/25/22 Page 1 of 17 Page ID #:193

1 DAVID G. HALM, ESQ., SBN: 179957

David.Halm@qpwblaw.com

2 QUINTAIROS, PRIETO, WOOD & BOYER, P.A.

500 N. Brand Boulevard, Suite 1650

3 Glendale, California 91203

4 Telephone: 213.486.0048

Facsimile: 213.486.0049

5

Attorneys for Defendant

6 TARGET CORPORATION

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

10

11 MARIA ROMERO, an individual, CASE NO. 2:21-cv-09761-SB-AFM

12 Plaintiff, STIPULATED PROTECTIVE

ORDER

13 vs.

14 TARGET CORPORATION, and DOES

1 through 25, inclusively,

15

Defendants.

16

17

18

19 1. A. PURPOSES AND LIMITATIONS

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

21 proprietary or private information for which special protection from public

22 disclosure and from use for any purpose other than prosecuting this litigation may

23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

24 enter the following Stipulated Protective Order. The parties acknowledge that this

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

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

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

28

STIPULATED PROTECTIVE ORDER

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1 under the applicable legal principles.

2 B. GOOD CAUSE STATEMENT

3 This action is likely to involve trade secrets, customer and other valuable

4 research, development, commercial, financial, technical and/or proprietary

5 information for which special protection from public disclosure and from use for

6 any purpose other than prosecution of this action is warranted. Such confidential

7 and proprietary materials and information consist of, among other things,

8 confidential business or financial information, information regarding confidential

9 business practices, or other confidential research, development, or commercial

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

11 information otherwise generally unavailable to the public, or which may be

12 privileged or otherwise protected from disclosure under state or federal statutes,

13 court rules, case decisions, or common law. Accordingly, to expedite the flow of

14 information, to facilitate the prompt resolution of disputes over confidentiality of

15 discovery materials, to adequately protect information the parties are entitled to

16 keep confidential, to ensure that the parties are permitted reasonable necessary uses

17 of such material in preparation for and in the conduct of trial, to address their

18 handling at the end of the litigation, and serve the ends of justice, a protective order

19 for such information is justified in this matter. It is the intent of the parties that

20 information will not be designated as confidential for tactical reasons and that

21 nothing be so designated without a good faith belief that it has been maintained in a

22 confidential,

23 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

24 SEAL

25 The parties further acknowledge, as set forth in Section 12.3, below, that this

26 Stipulated Protective Order does not entitle them to file confidential information

27 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

28 and the standards that will be applied when a party seeks permission from the court

2

STIPULATED PROTECTIVE ORDER

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1 to file material under seal.

2 There is a strong presumption that the public has a right of access to judicial

3 proceedings and records in civil cases. In connection with non-dispositive motions,

4 good cause must be shown to support a filing under seal. See Kamakana v. City and

5 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

6 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

7 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

8 require good cause showing), and a specific showing of good cause or compelling

9 reasons with proper evidentiary support and legal justification, must be made with

10 respect to Protected Material that a party seeks to file under seal. The parties’ mere

11 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

12 without the submission of competent evidence by declaration, establishing that the

13 material sought to be filed under seal qualifies as confidential, privileged, or

14 otherwise protectable—constitute good cause.

15 Further, if a party requests sealing related to a dispositive motion or trial,

16 then compelling reasons, not only good cause, for the sealing must be shown, and

17 the relief sought shall be narrowly tailored to serve the specific interest to be

18 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.

19 2010). For each item or type of information, document, or thing sought to be filed

20 or introduced under seal in connection with a dispositive motion or trial, the party

21 seeking protection must articulate compelling reasons, supported by specific facts

22 and legal justification, for the requested sealing order. Again, competent evidence

23 supporting the application to file documents under seal must be provided by

24 declaration.

25 Any document that is not confidential, privileged, or otherwise protectable in

26 its entirety will not be filed under seal if the confidential portions can be redacted.

27 If documents can be redacted, then a redacted version for public viewing, omitting

28 only the confidential, privileged, or otherwise protectable portions of the document,

3

STIPULATED PROTECTIVE ORDER

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1 shall be filed. Any application that seeks to file documents under seal in their

2 entirety should include an explanation of why redaction is not feasible.

3 2. DEFINITIONS

4 2.1 Action: this pending federal lawsuit.

5 2.2 Challenging Party: a Party or Non-Party that challenges the designation

6 of information or items under this Order.

7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

10 the Good Cause Statement.

11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

12 support staff).

13 2.5 Designating Party: a Party or Non-Party that designates information or

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

15 “CONFIDENTIAL.”

16 2.6 Disclosure or Discovery Material: all items or information, regardless of

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

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

19 or generated in disclosures or responses to discovery in this matter.

20 2.7 Expert: a person with specialized knowledge or experience in a matter

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

22 an expert witness or as a consultant in this Action.

23 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

25 counsel.

26 2.9 Non-Party: any natural person, partnership, corporation, association or

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

28 2.10 Outside Counsel of Record: attorneys who are not employees of a party

4

STIPULATED PROTECTIVE ORDER

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

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

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

4 2.11 Party: any party to this Action, including all of its officers, directors,

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

6 support staffs).

7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

8 Discovery Material in this Action.

9 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

12 and their employees and subcontractors.

13 2.14 Protected Material: any Disclosure or Discovery Material that is

14 designated as “CONFIDENTIAL.”

15 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

16 from a Producing Party.

17 3. SCOPE

18 The protections conferred by this Stipulation and Order cover not only

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

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

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

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

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

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

25 4. DURATION

26 Once a case proceeds to trial, information that was designated as

27 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

28 as an exhibit at trial becomes public and will be presumptively available to all

5

STIPULATED PROTECTIVE ORDER

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1 members of the public, including the press, unless compelling reasons supported by

2 specific factual findings to proceed otherwise are made to the trial judge in advance

3 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

4 showing for sealing documents produced in discovery from “compelling reasons”

5 standard when merits-related documents are part of court record). Accordingly, the

6 terms of this protective order do not extend beyond the commencement of the trial.

7 5. DESIGNATING PROTECTED MATERIAL

8 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

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

14 items or communications for which protection is not warranted are not swept

15 unjustifiably within the ambit of this Order.

16 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

19 impose unnecessary expenses and burdens on other parties) may expose the

20 Designating Party to sanctions.

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

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

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

24 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

28 produced.

6

STIPULATED PROTECTIVE ORDER

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1 Designation in conformity with this Order requires:

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

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

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

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

6 contains protected material. If only a portion of the material on a page qualifies for

7 protection, the Producing Party also must clearly identify the protected

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

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

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

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

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

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

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

15 which documents, or portions thereof, qualify for protection under this Order.

16 Then, before producing the specified documents, the Producing Party must affix

17 the “CONFIDENTIAL legend” to each page that contains Protected Material. If

18 only a portion of the material on a page qualifies for protection, the Producing

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

20 appropriate markings in the margins).

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

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

23 deposition all protected testimony

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

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

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

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

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

7

STIPULATED PROTECTIVE ORDER

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1 protected portion(s)

2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

5 material.

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

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

8 Order.

9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

12 Scheduling Order.

13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

14 resolution process under Local Rule 37-1 et seq.

15 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

16 joint stipulation pursuant to Local Rule 37-2.

17 6.4 The burden of persuasion in any such challenge proceeding shall be on

18 the Designating Party. Frivolous challenges, and those made for an improper

19 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

20 parties) may expose the Challenging Party to sanctions. Unless the Designating

21 Party has waived or withdrawn the confidentiality designation, all parties shall

22 continue to afford the material in question the level of protection to which it is

23 entitled under the Producing Party’s designation until the Court rules on the

24 challenge.

25 7. ACCESS TO AND USE OF PROTECTED MATERIAL

26 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

8

STIPULATED PROTECTIVE ORDER

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

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

3 Receiving Party must comply with the provisions of section 13 below

4 (FINALDISPOSITION).

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

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

7 authorized under this Order.

8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

10 Receiving Party may disclose any information or item designated

11 “CONFIDENTIAL” only to:

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

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

14 necessary to disclose the information for this Action;

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

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

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

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

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

20 (d) the court and its personnel;

21 (e) court reporters and their staff;

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

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

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

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

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

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

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

9

STIPULATED PROTECTIVE ORDER

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

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

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

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

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

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

7 except as permitted under this Stipulated Protective Order; and

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

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

10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

11 IN OTHER LITIGATION

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

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

14 “CONFIDENTIAL,” that Party must:

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

16 include a copy of the subpoena or court order;

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

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

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

20 this Stipulated Protective Order; and

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

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

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

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

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

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

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

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

10

STIPULATED PROTECTIVE ORDER

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

2 to disobey a lawful directive from another court.

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

4 PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

13 confidential information, then the Party shall:

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

15 some or all of the information requested is subject to a confidentiality agreement

16 with a Non-Party;

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

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

19 description of the information requested; and

20 (3) make the information requested available for inspection by the Non-

21 Party, if requested.

22 (c) If the Non-Party fails to seek a protective order from this court within 14

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

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

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

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

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

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

11

STIPULATED PROTECTIVE ORDER

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1 expense of seeking protection in this court of its Protected Material.

2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

4 disclosed Protected Material to any person or in any circumstance not authorized

5 under this Stipulated Protective Order, the Receiving Party must immediately (a)

6 notify in writing the Designating Party of the unauthorized disclosures, (b) use its

7 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

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

9 of this Order, and (d) request such person or persons to execute the

10 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

11 A.

12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

13 PROTECTED MATERIAL

14 When a Producing Party gives notice to Receiving Parties that certain

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

16 protection, the obligations of the Receiving Parties are those set forth in Federal

17 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

18 whatever procedure may be established in an e-discovery order that provides for

19 production without prior privilege review. Pursuant to Federal Rule of Evidence

20 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

21 of a communication or information covered by the attorney-client privilege or work

22 product protection, the parties may incorporate their agreement in the stipulated

23 protective order submitted to the court.

24 12. MISCELLANEOUS

25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

27 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

12

STIPULATED PROTECTIVE ORDER

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

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

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

4 Order.

5 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

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

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

10 in the public record unless otherwise instructed by the court.

11 13. FINAL DISPOSITION

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

13 60 days of a written request by the Designating Party, each Receiving Party must

14 return all Protected Material to the Producing Party or destroy such material. As

15 used in this subdivision, “all Protected Material” includes all copies, abstracts,

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

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

18 Receiving Party must submit a written certification to the Producing Party (and, if

19 not the same person or entity, to the Designating Party) by the 60 day deadline that

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

21 returned or destroyed and (2) affirms that the Receiving Party has not retained any

22 copies, abstracts, compilations, summaries or any other format reproducing or

23 capturing any of the Protected Material. Notwithstanding this provision, Counsel

24 are entitled to retain an archival copy of all pleadings, motion papers, trial,

25 deposition, and hearing transcripts, legal memoranda, correspondence, deposition

26 and trial exhibits, expert reports, attorney work product, and consultant and expert

27 work product, even if such materials contain Protected Material. Any such archival

28 copies that contain or constitute Protected Material remain subject to this Protective

13

STIPULATED PROTECTIVE ORDER

Case 4|21-cv-09761-SB-AFM Document 16 Filed 02/25/22 Page 14o0f17 Page ID #:206

1 || Order as set forth in Section 4 (DURATION).

2/14. VIOLATION

3 Any violation of this Order may be punished by appropriate measures

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

6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD

8 || DATED: February 25, 2022

19 || LAW OFFICE OF JOSHUA MOODY

11

12 ||8/ Joshua Moody

13 || Joshua Moody, Esq.

14 || Attorneys for Plaintiff

15 || DATED: February 25, 2022

16 QUINTAIROS, PRIETO, WOOD & BOYER, P.A.

17

18 ||/8/ David G. Halm

19 | David G. Halm

9 || Attorneys for Defendant

21

47 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

23

44 || DATED: 2/25/2022

25 (42 y Woe kK °

a,

26

27 || HON. ALEXANDER F. MacKINNON

2 || United States Magistrate Judge

14

STIPULATED PROTECTIVE ORDER

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

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

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

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

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

8 on [date] in the case of MARIA ROMERO v. TARGET CORPORATION, e et al.,

9 United States District Court, Central District of California – Western Division,

10 Case No. 2:21-cv-90761-SB-AFM. I agree to comply with and to be bound by all

11 the terms of this Stipulated Protective Order and I understand and acknowledge

12 that failure to so comply could expose me to sanctions and punishment in the

13 nature of contempt. I solemnly promise that I will not disclose in any manner any

14 information or item that is subject to this Stipulated Protective Order to any person

15 or entity except in strict compliance with the provisions of this Order.

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

17 Court for the Central District of California for enforcing the terms of this Stipulated

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

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

20 name] of _______________________________________ [print or type full

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

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

23 Stipulated Protective

24 Order.

25

26 Date: ______________________________________

27 City and State where sworn and signed: _________________________________

28

15

STIPULATED PROTECTIVE ORDER

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1 Printed name: _______________________________

2 Signature: __________________________________

3

4 Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer attests that all signatories

5 listed, and on whose behalf the filing is submitted, concur in the filing’s content

6 and have authorized the filing.

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STIPULATED PROTECTIVE ORDER

Case 4|21-cv-09761-SB-AFM Document Filed 02/25/22 Page 17of17 Page ID #:209

1 PROOF OF SERVICE

Iam a citizen of the United States. wy business address is 500 North Brand

2)|Blvd., Suite 1650, Glendale, California 91203. I am employed in the County of Los

Angeles where this service occurs. I am over the age of 18 years, and not a party to

3 || the within cause.

4 On the date set forth below, according to ordinary business practice, I served

5 the foregoing document entitled:

6 STIPULATED PROTECTIVE ORDER

7 (BY CM/ECF) I hereby certify that on this date, I electronically filed the

8 foregoing with the Clerk of the Court using the CM/ECF system which will s

end notification of such filing to the e-mail addresses denoted on the

9 Electronic Mail notice list, and I hereby certify that I have mailed the

10 foregoing document or paper via the United States Postal Service to the non-

CM/ECF participants (if any) indicated on the Manual Notice list.

11

2 (BY E-MAIL) On this date, I personally transmitted the foregoing

document(s) via electronic mail to the e-mail address(es) of the person(s)

13 below.

14

LAW OFFICE OF JOSHUA MOODY

15 Joshua Moody (SBN 308189)

16 17768 Wika Road, Suite 201

Apple Valley, CA 92307

17 T: (760) 867-3300

18 F: (760) 646-9235

jmoody@moodylawyer.com

19 ne moodylawyer.com

30 Attorney for Plaintiff MARIA ROMERO

21

(Federal) I declare under penalty of perjury under the laws of the United

22 States of America that the foregoing 1s true and correct.

23 Executed on February 25, 2022, at Glendale, California.

24

25 /s/Liseth Gonzalez

6 Liseth Gonzalez

27

28

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STIPULATED PROTECTIVE ORDER