Sheila Bates v. City of Torrance

Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 1 of 18 Page ID #:190

1 WOODRUFF, SPRADLIN & SMART, APC

PATRICK M. DESMOND - State Bar No. 215029

2 pdesmond@wss-law.com

555 Anton Boulevard, Suite 1200

3 Costa Mesa, California 92626-7670

Telephone: (714) 558-7000

4 Facsimile: (714) 835-7787

5 Attorneys for Defendants CITY OF TORRANCE, a public entity,

OFFICER BRIAN KAWAMOTO, OFFICER CHRISTOPHER

6 ALLEN-YOUNG, OFFICER NELSON and OFFICER T. KNOX

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 SHEILA BATES, CASE NO.: 8:21-cv-00839-JLS-DFMx

12 Plaintiff, JUDGE: JOSEPHINE L. STATON

MAGISTRATE JUDGE: DOUGLAS F.

13 v. McCORMICK

14 CITY OF TORRANCE; OFFICER

KAWAMOTO and DOES 1 through 10 STIPULATED PROTECTIVE

15 inclusive, ORDER1

16 Defendants.

17

18 1. A. PURPOSES AND LIMITATIONS

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

20 proprietary or private information for which special protection from public disclosure

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

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

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

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

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

26

27

1 This Stipulated Protective Order is substantially based on the model protective

28

order utilized by judges within the Central District of California.

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

2 legal principles.

3

4 B. GOOD CAUSE STATEMENT

5 This action is likely to involve personal, medical, financial, and/or other

6 information for which special protection from public disclosure and from use for any

7 purpose other than prosecution of this action is warranted. Such confidential and

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

9 regarding confidential government investigations, confidential medical records and

10 information, confidential information pertaining to third parties, information

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

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

13 or common law.

14 Specifically, this action is brought under 42 U.S.C. §1983, and involves

15 allegations by Plaintiff that Defendant City of Torrance and/or its peace officer

16 employees unlawfully arrested and utilized excessive force against her in violation of

17 her Constitutional rights. The discovery sought, and likely to be sought in the future,

18 includes, but is not limited to, documents and records relating to internal affairs

19 investigation files and related complaints, statements, and records (which also relate

20 to third parties); police officers’ personnel files; and individual parties’ medical and

21 financial information. The public and uncontrolled release of these documents,

22 without first allowing the affected parties and non-parties to identify confidential

23 information and claim protection, could cause the parties personal and institutional

24 embarrassment and harm.

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

26 resolution of disputes over confidentiality of discovery materials, to adequately

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

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

2

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

2 the ends of justice, a protective order for such information is justified in this matter.

3 It is the intent of the parties that information will not be designated as confidential for

4 tactical reasons and that nothing be so designated without a good faith belief that it

5 has been maintained in a confidential, non-public manner, and there is good cause

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

7

8 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

9 SEAL

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

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

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

13 the standards that will be applied when a party seeks permission from the court to file

14 material under seal.

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

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

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

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

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

20 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

21 cause showing), and a specific showing of good cause or compelling reasons with

22 proper evidentiary support and legal justification, must be made with respect to

23 Protected Material that a party seeks to file under seal. The parties’ mere designation

24 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

25 submission of competent evidence by declaration, establishing that the material

26 sought to be filed under seal qualifies as confidential, privileged, or otherwise

27 protectable—constitute good cause.

28 ///

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

2 compelling reasons, not only good cause, for the sealing must be shown, and the relief

3 sought shall be narrowly tailored to serve the specific interest to be protected. See

4 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each

5 item or type of information, document, or thing sought to be filed or introduced under

6 seal in connection with a dispositive motion or trial, the party seeking protection must

7 articulate compelling reasons, supported by specific facts and legal justification, for

8 the requested sealing order. Again, competent evidence supporting the application to

9 file documents under seal must be provided by declaration.

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

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

12 documents can be redacted, then a redacted version for public viewing, omitting only

13 the confidential, privileged, or otherwise protectable portions of the document shall

14 be filed. Any application that seeks to file documents under seal in their entirety

15 should include an explanation of why redaction is not feasible.

16

17 2. DEFINITIONS

18 2.1 Action: this pending federal lawsuit.

19 2.2 Challenging Party: a Party or Non-Party that challenges the

20 designation of information or items under this Order.

21 2.3 “CONFIDENTIAL” Information or Items: information (regardless

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

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

24 Good Cause Statement.

25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

26 their support staff).

27 2.5 Designating Party: a Party or Non-Party that designates information or

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

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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 that

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

28 designated as “CONFIDENTIAL.”

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1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

2 from a Producing Party.

3 3. SCOPE

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

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

6 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

7 Protected Material; and (3) any testimony, conversations, or presentations by Parties

8 or their Counsel that might reveal Protected Material.

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

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

11

12 4. DURATION

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

14 CONFIDENTIAL or maintained pursuant to this protective order which is used or

15 introduced as an exhibit at trial becomes public and will be presumptively available

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

17 by specific factualfindings to proceed otherwise are made to the trial judge in advance

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

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

20 standard when merits-related documents are part of court record). Accordingly, with

21 respect to material that is used or introduced as an exhibit at trial, the terms of this

22 protective order do not extend beyond the commencement of trial. In all other respects

23 (i.e. Confidential Material which is not used or introduced as an exhibit at trial), the

24 terms of this protective order shall survive the conclusion of trial in this case.

25 5. DESIGNATING PROTECTED MATERIAL

26 5.1 Exercise of Restraint and Care in Designating Material for

27 Protection.

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

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

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

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

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

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

6 within the ambit of this Order.

7 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

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

11 Party to sanctions.

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

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

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

15 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

19 produced.

20 Designation in conformity with this Order requires:

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

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

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

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

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

26 protection, the Producing Party also must clearly identify the protected portion(s)

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

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

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

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

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

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

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

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

7 the specified documents, the Producing Party must affix the “CONFIDENTIAL

8 legend” to each page that contains Protected Material. If only a portion of the material

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

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

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

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

13 all protected testimony.

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

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

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

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

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

19 portion(s).

20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

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

25 Order.

26

27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

28 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

2 Scheduling Order.

3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

4 resolution process under Local Rule 37.1 et seq.

5 6.3 Burden and Protection During Challenge. The burden of persuasion

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

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

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

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

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

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

12 until the Court rules on the challenge.

13

14 7. ACCESS TO AND USE OF PROTECTED MATERIAL

15 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

19 conditions described in this Order. When the Actionhas been terminated, a Receiving

20 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

23 authorized under this Order.

24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

26 Receiving Party may disclose any information or item designated

27 “CONFIDENTIAL” only to:

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

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

2 to disclose the information for this Action;

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

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

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

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

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

8 (d) the court and its personnel;

9 (e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

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

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

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

23 permitted under this Stipulated Protective Order; and

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

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

26 ///

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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

2 PRODUCED IN OTHER LITIGATION

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

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

5 “CONFIDENTIAL,” that Party must:

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

7 include a copy of the subpoena or court order;

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

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

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

11 this Stipulated Protective Order; and

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

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

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

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

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

17 or order issued, unless the Party has obtained the Designating Party’s permission. The

18 Designating Party shall bear the burden and expense of seeking protection in that court

19 of its confidential material and nothing in these provisions should be construed as

20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

21 directive from another court.

22

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

24 PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

5 confidential information, then the Party shall:

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

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

8 with a Non-Party;

9

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

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

12 specific description of the information requested; and

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

14 Party, if requested.

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

16 14 days of receiving the notice and accompanying information, the Receiving Party

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

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

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

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

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

22 of seeking protection in this court of its Protected Material.

23

24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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

5

6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

7 PROTECTED MATERIAL

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

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

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

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

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

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

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

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

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

17 to the court.

18

19 12. MISCELLANEOUS

20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

22 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

27 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

2 Protected Material at issue. If a Party’s request to file Protected Material under seal

3 is denied by the court, then the Receiving Party may file the information in the public

4 record unless otherwise instructed by the court.

5

6 13. FINAL DISPOSITION

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

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

9 all Protected Material to the Producing Party or destroy such material as set forth in

10 the written request. As used in this subdivision, “all Protected Material” includes all

11 copies, abstracts, compilations, summaries, and any other format reproducing or

12 capturing any of the Protected Material. Whether the Protected Material is returned

13 or destroyed, the Receiving Party must submit a written certification to the Producing

14 Party (and, if not the same person or entity, to the Designating Party) by the 60 day

15 deadline that (1) identifies (by category, where appropriate) all the Protected Material

16 that was returned or destroyed and (2) affirms that the Receiving Party has not

17 retained any copies, abstracts, compilations, summaries or any other format

18 reproducing or capturing any of the Protected Material. Notwithstanding this

19 provision, Counsel are entitled to retain an archival copy of all pleadings, motion

20 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

21 deposition and trial exhibits, expert reports, attorney work product, and consultant

22 and expert work product, even if such materials contain Protected Material. Any such

23 archival copies that contain or constitute Protected Material remain subject to this

24 Protective Order as set forth in Section 4 (DURATION).

25 14. VIOLATION

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

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

28

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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

3 || DATED: April 12, 2022 LAW OFFICES OF ERIN DARLING

4 By: □ s/Erin Darling

5 Erin Darling, Esq.

Attorney for Plaintiff

6 Sheila Bates

g || DATED: April 12, 2022 WOODRUFF, SPRADLIN & SMART

9 By: Jason McEwen

Patrick Desmond

10 Jason McEwen

il Attorneys for Defendants City of

Torrance, Officer Brian Kawamoto,

12 Officer Christopher Allen-Young,

13 Officer Nelson and Officer T. Knox

14

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

16

17_ || DATED: April 18, 2022

18

19 >? me

HON. BOUGLAS F. McCORMICK

20 || Un'ted States Magictret> T=49¢

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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 that

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

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

8 ___________[date] in the case of Sheila Bates v. City of Torrance, et al. U.S.D.C.

9 Case No. 8:21-cv-0839-JLS (DFMx). I agree to comply with and to be bound by all

10 the terms of this Stipulated Protective Order and I understand and acknowledge that

11 failure to so comply could expose me to sanctions and punishment in the nature of

12 contempt. I solemnly promise that I will not disclose in any manner any information

13 or item that is subject to this Stipulated Protective Order to any person or entity except

14 in strict compliance with the provisions of this Order.

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

16 for the Central District of California for enforcing the terms of this Stipulated

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

18 action. I hereby appoint __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

20 telephone number] as my California agent for service of process in connection with

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25

26 Printed name: _______________________________

27

28 Signature: __________________________________

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PROOF OF SERVICE

5 STATE OF CALIFORNIA, COUNTY OF ORANGE

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

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

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

On Apt 12, 2022, I served the foregoing document(s) described as

5 || STIPULATED PROTECTIVE ORDER

6 || O by placing the true copies thereof enclosed in sealed envelopes addressed as

5 stated on the attached mailing list;

L) by placing L) the original U a true copy thereof enclosed in sealed envelopes

8 addressed as follows:

g || O (BY MAIL) I placed said envelope(s) for collection and mailing. following

ordinary business practices, at the business offices of WOODRUFF,

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

or deposit in the United States Postal Service. | am readily familiar with the

for de he United States Postal S I dily familiar with th

1 practice of WOODRUFF, SPRADLIN & SMART for collection and

processing correspondence for mailing with the United States Postal Service,

12 and said envclope(s) will be deposited with the United States Postal Service on

said date in the ordinary course of business.

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

14 electronically filed using. the Court’s Electronic Filing System which

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

15 attached mailing list.

16 || O (BY OVERNIGHT DELIVERY) I placed said documents in. envelopes) for

collection following ordinary business practices, at the business offices of

17 WOODRUFF, SPRADLIN & SMART, and addressed as shown on_the

attached service list, for collection and delivery to a courier authorized_by

18 to receive said documents, with delivery fees

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

19 PRADLIN & SMART for collection and processing. of documents for

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

20 on said date in the ordinary course of business.

1 (Federal) I declare that | 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 ts true and correct.

22

23 Executed on April 12, 2022, at Costa Mesa, California.

“a s/ Vilay Lee

25 VILAY LEE

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Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 18 of 18 Page ID #:207

SHEILA BATES v. CITY OF TORRANCE, et al.

1

USDC, CENTRAL DISTRICT OF CALIFORNIA

2 CASE NO. 8:21-cv-00839-JLS-DFMx

3 BEFORE THE HONORABLE

JOSEPHINE L. STATON

4 COURTROOM 10A

5 SERVICE LIST

6

Erin Darling Attorney for Plaintiff

7 LAW OFFICES OF ERIN DARLING SHEILA BATES

3435 Wilshire Blvd., Suite 2910

8 Los Angeles, CA 90010

Telephone: (323) 736-2230

9 Email: erin@erindarlinglaw.com

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1648101.1