The opinion
Case 2:21-cv-09356-JAK-MAA Document 41 Filed 09/30/22 Page 1 of 14 Page ID #:256
1 David E Czelusniak, Esq. (SBN: 118483)
SKEBBA, BUECHLER & ORLOV
2 777 South Figueroa Street, Suite 1507
Los Angeles, CA 90017
3
Telephone: (714) 824-0359
4 Facsimile: (213) 689-3523
Authorized E-Service Address: David.Czelusniak@aig.com
5
6 Attorneys for Defendant, Vornado Air, LLC
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12 ALLIANCE OF SCHOOL CASE NO. 2:21-cv-09356-JAK-MAA
COOPERATIVE INSURANCE
13 PROGRAMS, STIPULATED PROTECTIVE ORDER
14
Plaintiff,
AS REVISED BY COURT
15
vs.
16
(Assigned to U.S. District John A. Kronstadt)
17 VORNADO AIR LLC, A KANSAS
Complaint Filed: 12/02/2021
CORPORATION; VORNADO AIR
18 CIRCULATION SYSTEMS, INC., A Trial Date: 02/26/2022
DISSOLVED KANSAS
19
CORPORATION; and Does 1 to 30
20 inclusive,
21 Defendants.
22
23 I.PURPOSES AND LIMITATIONS
24 A.Discovery in this action is likely to involve production of confidential, proprietary, or
25 private information for which special protection from public disclosure and from use for any
26 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby
27 stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties
28 acknowledge that this Order does not confer blanket protections on all disclosures or responses
1
STIPULATED PROTECTED ORDER
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1 to discovery and that the protection it affords from public disclosure and use extends only to the
2 limited information or items that are entitled to confidential treatment under the applicable legal
3 principles. The parties further acknowledge, as set forth in Section XIII(C), below, that this
4 Stipulated Protective Order does not entitle them to file confidential information under seal;
5 Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will
6 be applied when a party seeks permission from the Court to file material under seal.
7 II.GOOD CAUSE STATEMENT
8 A.This action is likely to involve trade secrets, customer and pricing lists and other
9 valuable research, development, commercial, financial, technical and/or proprietary information,
10 accounts receivable, customer credit balances, retail sales, expenses, inventory, raw materials for
11 which special protection from public disclosure and from use for any purpose other than
12 prosecution of this action is warranted. Such confidential and proprietary materials and
13 information consist of, among other things, confidential business or financial information,
14 information regarding confidential business practices, or other confidential research,
15 development, or commercial information (including information implicating privacy rights of
16 third parties), information otherwise generally unavailable to the public, or which may be
17 privileged or otherwise protected from disclosure under state or federal statutes, court rules, case
18 decisions, or common law. Accordingly, to expedite the flow of information, to facilitate the
19 prompt resolution of disputes over confidentiality of discovery materials, to adequately protect
20 information the parties are entitled to keep confidential, to ensure that the parties are permitted
21 reasonable necessary uses of such material in preparation for and in the conduct of trial, to
22 address their handling at the end of the litigation, and serve the ends of justice, a protective order
23 for such information is justified in this matter. It is the intent of the parties that information will
24 not be designated as confidential for tactical reasons and that nothing be so designated without a
25 good faith belief that it has been maintained in a confidential, non-public manner, and there is
26 good cause why it should not be part of the public record of this case.
27 ///
28 ///
2
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1 III.DEFINITIONS
2 A.Action: Alliance of School Cooperative Insurance Programs vs. Vornado Air, LLC.
3 Case Number 2:21-cv-09356-JAK-MAA.
4 B.Challenging Party: A Party or Non-Party that challenges the designation of
5 information or items under this Order.
6 C.“CONFIDENTIAL” Information or Items: Information (regardless of how it is
7 generated, stored or maintained) or tangible things that qualify for protection under
8 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
9 Statement.
10 D.Counsel: Outside Counsel of Record and House Counsel (as well as their support
11 staff).
12 E.Designating Party: A Party or Non-Party that designates information or items that it
13 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
14 F.Disclosure or Discovery Material: All items or information, regardless of the medium
15 or manner in which it is generated, stored, or maintained (including, among other things,
16 testimony, transcripts, and tangible things), that are produced or generated in disclosures
17 or responses to discovery in this matter.
18 G.Expert: A person with specialized knowledge or experience in a matter pertinent to
19 the litigation who has been retained by a Party or its counsel to serve as an expert witness
20 or as a consultant in this Action.
21 H.House Counsel: Attorneys who are employees of a party to this Action. House
22 Counsel does not include Outside Counsel of Record or any other outside counsel.
23 I. Non-Party: Any natural person, partnership, corporation, association, or other legal
24 entity not named as a Party to this action.
25 J.Outside Counsel of Record: Attorneys who are not employees of a party to this Action
26 but are retained to represent or advise a party to this Action and have appeared in this
27 Action on behalf of that party or are affiliated with a law firm which has appeared on
28 behalf of that party, and includes support staff.
3
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1 K.Party: Any party to this Action, including all of its officers, directors, employees,
2 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
3 L.Producing Party: A Party or Non-Party that produces Disclosure or Discovery Material
4 in this Action.
5 M.Professional Vendors: Persons or entities that provide litigation support services (e.g.,
6 photocopying, videotaping, translating, preparing exhibits or demonstrations, and
7 organizing, storing, or retrieving data in any form or medium) and their employees and
8 subcontractors.
9 N.Protected Material: Any Disclosure or Discovery Material that is designated as
10 “CONFIDENTIAL.”
11 O.Receiving Party: A Party that receives Disclosure or Discovery Material from a
12 Producing Party.
13 IV.SCOPE
14 A.The protections conferred by this Stipulation and Order cover not only Protected
15 Material (as defined above), but also (1) any information copied or extracted from
16 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
17 Material; and (3) any testimony, conversations, or presentations by Parties or their
18 Counsel that might reveal Protected Material.
19 B.Any use of Protected Material at trial shall be governed by the orders of the trial judge.
20 This Order does not govern the use of Protected Material at trial.
21 V.DURATION
22 A. Once a case proceeds to trial, all of the information that was designated as
23 confidential or maintained pursuant to this Protective Order becomes public and will be
24 presumptively available to all members of the public, including the press, unless
25 compelling reasons supported by specific factual findings to proceed otherwise are made
26 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,
27 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
28 documents produced in discovery from “compelling reasons” standard when merits-
4
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1 related documents are part of court record). Accordingly, the terms of this Protective
2 Order do not extend beyond the commencement of the trial.
3 B. Even after final disposition of this litigation, the confidentiality obligations
4 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in
5 writing or a court order otherwise directs. Final disposition shall be deemed to be the
6 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice;
7 and (2) final judgment herein after the completion and exhaustion of all appeals,
8 rehearings, remands, trials, or reviews of this Action, including the time limits for filing
9 any motions or applications for extension of time pursuant to applicable law.
10 VI.DESIGNATING PROTECTED MATERIAL
11 A.Exercise of Restraint and Care in Designating Material for Protection
12 1.Each Party or Non-Party that designates information or items for protection
13 under this Order must take care to limit any such designation to specific material that
14 qualifies under the appropriate standards. The Designating Party must designate for
15 protection only those parts of material, documents, items, or oral or written
16 communications that qualify so that other portions of the material, documents, items, or
17 communications for which protection is not warranted are not swept unjustifiably within
18 the ambit of this Order.
19 2.Mass, indiscriminate, or routinized designations are prohibited. Designations
20 that are shown to be clearly unjustified or that have been made for an improper
21 purpose (e.g., to unnecessarily encumber the case development process or to
22 impose unnecessary expenses and burdens on other parties) may expose the
23 Designating Party to sanctions.
24 3.If it comes to a Designating Party’s attention that information or items that it
25 designated for protection do not qualify for protection, that Designating Party
26 must promptly notify all other Parties that it is withdrawing the inapplicable
27 designation.
28 ///
5
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1 B.Manner and Timing of Designations
2 1.Except as otherwise provided in this Order (see, e.g., Section B(2)(b) below),
3 or as otherwise stipulated or ordered, Disclosure or Discovery Material that
4 qualifies for protection under this Order must be clearly so designated before the
5 material is disclosed or produced.
6 2.Designation in conformity with this Order requires the following:
7 a.For information in documentary form (e.g., paper or electronic
8 documents, but excluding transcripts of depositions or other pretrial or
9 trial proceedings), that the Producing Party affix at a minimum, the legend
10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each
11 page that contains protected material. If only a portion or portions of the
12 material on a page qualifies for protection, the Producing Party also must
13 clearly identify the protected portion(s) (e.g., by making appropriate
14 markings in the margins).
15 b.A Party or Non-Party that makes original documents available for
16 inspection need not designate them for protection until after the inspecting
17 Party has indicated which documents it would like copied and produced.
18 During the inspection and before the designation, all of the material made
19 available for inspection shall be deemed “CONFIDENTIAL.” After the
20 inspecting Party has identified the documents it wants copied and
21 produced, the Producing Party must determine which documents, or
22 portions thereof, qualify for protection under this Order. Then, before
23 producing the specified documents, the Producing Party must affix the
24 “CONFIDENTIAL legend” to each page that contains Protected Material.
25 If only a portion or portions of the material on a page qualifies for
26 protection, the Producing Party also must clearly identify the protected
27 portion(s) (e.g., by making appropriate markings in the margins).
28 ///
6
STIPULATED PROTECTED ORDER
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1 c.For testimony given in depositions, that the Designating Party identify
2 the Disclosure or Discovery Material on the record, before the close of the
3 deposition all protected testimony.
4 d.For information produced in form other than document and for any
5 other tangible items, that the Producing Party affix in a prominent place on
6 the exterior of the container or containers in which the information is
7 stored the legend “CONFIDENTIAL.” If only a portion or portions of the
8 information warrants protection, the Producing Party, to the extent
9 practicable, shall identify the protected portion(s).
10 C.Inadvertent Failure to Designate
11 1.If timely corrected, an inadvertent failure to designate qualified information or
12 items does not, standing alone, waive the Designating Party’s right to secure
13 protection under this Order for such material. Upon timely correction of a
14 designation, the Receiving Party must make reasonable efforts to assure that the
15 material is treated in accordance with the provisions of this Order.
16 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17 A.Timing of Challenges
18 1.Any party or Non-Party may challenge a designation of confidentiality at any
19 time that is consistent with the Court’s Scheduling Order.
20 B.Meet and Confer
21 1.The Challenging Party shall initiate the dispute resolution process under Local
22 Rule 37.1 et seq. and pursuant to Magistrate Judge Maria A. Audero's Mandatory
Telephonic Conference for Discovery Disputes. See http://
23 www.cacd.uscourts.gov/honorable-maria-audero.
24 C.The burden of persuasion in any such challenge proceeding shall be on the
25 Designating Party. Frivolous challenges, and those made for an improper purpose
26 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
27 expose the Challenging Party to sanctions. Unless the Designating Party has waived
28 or withdrawn the confidentiality designation, all parties shall continue to afford the
material in question the level of protec7t ion to which it is entitled under the Producing
STIPULATED PROTECTED ORDER
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1 Party's designation until the Court rules on the challenge.
2 VIII.ACCESS TO AND USE OF PROTECTED MATERIAL
3 A.Basic Principles
4 1.A Receiving Party may use Protected Material that is disclosed or produced by
5 another Party or by a Non-Party in connection with this Action only for
6 prosecuting, defending, or attempting to settle this Action. Such Protected
7 Material may be disclosed only to the categories of persons and under the
8 conditions described in this Order. When the Action has been terminated, a
9 Receiving Party must comply with the provisions of Section XIV below.
10 2.Protected Material must be stored and maintained by a Receiving Party at a
11 location and in a secure manner that ensures that access is limited to the persons
12 authorized under this Order.
13 B.Disclosure of “CONFIDENTIAL” Information or Items
14 1.Unless otherwise ordered by the Court or permitted in writing by the
15 Designating Party, a Receiving Party may disclose any information or item
16 designated “CONFIDENTIAL” only to:
17 a.The Receiving Party’s Outside Counsel of Record in this Action, as well
18 as employees of said Outside Counsel of Record to whom it is reasonably
19 necessary to disclose the information for this Action;
20 b.The officers, directors, and employees (including House Counsel) of the
21 Receiving Party to whom disclosure is reasonably necessary for this
22 Action;
23 c.Experts (as defined in this Order) of the Receiving Party to whom
24 disclosure is reasonably necessary for this Action and who have signed the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
26 d.The Court and its personnel;
27 e.Court reporters and their staff;
28 ///
8
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1 f.Professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary or this Action and
3 who have signed the “Acknowledgment and Agreement to be Bound”
4 attached as Exhibit A hereto;
5 g.The author or recipient of a document containing the information or a
6 custodian or other person who otherwise possessed or knew the
7 information;
8 h.During their depositions, witnesses, and attorneys for witnesses, in the
9 Action to whom disclosure is reasonably necessary provided: (i) the
10 deposing party requests that the witness sign the “Acknowledgment and
11 Agreement to Be Bound;” and (ii) they will not be permitted to keep any
12 confidential information unless they sign the “Acknowledgment and
13 Agreement to Be Bound,” unless otherwise agreed by the Designating
14 Party or ordered by the Court. Pages of transcribed deposition testimony
15 or exhibits to depositions that reveal Protected Material may be separately
16 bound by the court reporter and may not be disclosed to anyone except as
17 permitted under this Stipulated Protective Order; and
18 i.Any mediator or settlement officer, and their supporting personnel,
19 mutually agreed upon by any of the parties engaged in settlement
20 discussions.
21 IX.PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
22 LITIGATION
23 A. If a Party is served with a subpoena or a court order issued in other litigation that
24 compels disclosure of any information or items designated in this Action as
25 “CONFIDENTIAL,” that Party must:
26 1.Promptly notify in writing the Designating Party. Such notification shall
27 include a copy of the subpoena or court order;
28 ///
9
STIPULATED PROTECTED ORDER
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1 2.Promptly notify in writing the party who caused the subpoena or order to issue
2 in the other litigation that some or all of the material covered by the subpoena or
3 order is subject to this Protective Order. Such notification shall include a copy of
4 this Stipulated Protective Order; and
5 3.Cooperate with respect to all reasonable procedures sought to be pursued by the
6 Designating Party whose Protected Material may be affected.
7 B.If the Designating Party timely seeks a protective order, the Party served with the
8 subpoena or court order shall not produce any information designated in this action as
9 “CONFIDENTIAL” before a determination by the Court from which the subpoena or
10 order issued, unless the Party has obtained the Designating Party’s permission. The
11 Designating Party shall bear the burden and expense of seeking protection in that court of
12 its confidential material and nothing in these provisions should be construed as
13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
14 from another court.
15 X.A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN
16 THIS LITIGATION
17 A.The terms of this Order are applicable to information produced by a Non-Party in this
18 Action and designated as “CONFIDENTIAL.” Such information produced by Non-
19 Parties in connection with this litigation is protected by the remedies and relief provided
20 by this Order. Nothing in these provisions should be construed as prohibiting a Non-
21 Party from seeking additional protections.
22 B.In the event that a Party is required, by a valid discovery request, to produce a Non-
23 Party’s confidential information in its possession, and the Party is subject to an agreement
24 with the Non-Party not to produce the Non-Party’s confidential information, then the
25 Party shall:
26 1.Promptly notify in writing the Requesting Party and the Non-Party that some or
27 all of the information requested is subject to a confidentiality agreement with a
28 Non-Party;
10
STIPULATED PROTECTED ORDER
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1 2.Promptly provide the Non-Party with a copy of the Stipulated Protective Order
2 in this Action, the relevant discovery request(s), and a reasonably specific
3 description of the information requested; and
4 3.Make the information requested available for inspection by the Non-Party, if
5 requested.
6 C.If the Non-Party fails to seek a protective order from this court within 14 days of
7 receiving the notice and accompanying information, the Receiving Party may produce the
8 Non-Party’s confidential information responsive to the discovery request. If the Non-
9 Party timely seeks a protective order, the Receiving Party shall not produce any
10 information in its possession or control that is subject to the confidentiality agreement
11 with the Non-Party before a determination by the court. Absent a court order to the
12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
13 court of its Protected Material.
14 XI.UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 A. If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing
18 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve
19 all unauthorized copies of the Protected Material, (3) inform the person or persons to
20 whom unauthorized disclosures were made of all the terms of this Order, and (4) request
21 such person or persons to execute the “Acknowledgment and Agreement to be Bound”
22 that is attached hereto as Exhibit A.
23 XII.INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
24 PROTECTED MATERIAL
25 A.When a Producing Party gives notice to Receiving Parties that certain inadvertently
26 produced material is subject to a claim of privilege or other protection, the obligations of
27 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
28 This provision is not intended to modify whatever procedure may be established in an e-
11
STIPULATED PROTECTED ORDER
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1 discovery order that provides for production without prior privilege review. Pursuant to
2 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
3 effect of disclosure of a communication or information covered by the attorney-client
4 privilege or work product protection, the parties may incorporate their agreement in the
5 Stipulated Protective Order submitted to the Court.
6 XIII.MISCELLANEOUS
7 A.Right to Further Relief
8 1.Nothing in this Order abridges the right of any person to seek its
9 modification by the Court in the future.
10 B.Right to Assert Other Objections
11 1.By stipulating to the entry of this Protective Order, no Party waives any right it
12 otherwise would have to object to disclosing or producing any information or item
13 on any ground not addressed in this Stipulated Protective Order. Similarly, no
14 Party waives any right to object on any ground to use in evidence of any of the
15 material covered by this Protective Order.
16 C.Filing Protected Material
17 1.A Party that seeks to file under seal any Protected Material must comply with
18 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant
19 to a court order authorizing the sealing of the specific Protected Material at issue.
20 If a Party's request to file Protected Material under seal is denied by the Court,
21 then the Receiving Party may file the information in the public record unless
22 otherwise instructed by the Court.
23 XIV.FINAL DISPOSITION
24 A.After the final disposition of this Action, as defined in Section V, within sixty (60)
25 days of a written request by the Designating Party, each Receiving Party must return all
26 Protected Material to the Producing Party or destroy such material. As used in this
27 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
28 summaries, and any other format reproducing or capturing any of the Protected Material.
12
STIPULATED PROTECTED ORDER
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] Whether the Protected Material is returned or destroyed, the Receiving Party must submit
2 a written certification to the Producing Party (and, if not the same person or entity, to the
3 Designating Party) by the 60 day deadline that (1) identifies (by category, where
4 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that
5 the Receiving Party has not retained any copies, abstracts, compilations, summaries or
6 any other format reproducing or capturing any of the Protected Material.
7 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
8 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
9 correspondence, deposition and trial exhibits, expert reports, attorney work product, and
10 consultant and expert work product, even if such materials contain Protected Material.
11 Any such archival copies that contain or constitute Protected Material remain subject to
12 this Protective Order as set forth in Section V.
13 B. Any violation of this Order may be punished by any and all appropriate measures
14 including, without limitation, contempt proceedings and/or monetary sanctions.
15 ||} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16
17 || Dated:__September 27,2020
Attorney for Plaintiff, Alliance of Schools for
18 Cooperative Insurance Program
19 .
Dated: September 27, 2022 DA wi C Cgebeeneate
20 Attorney for Defendant, Vornado Air, LLC
21
22
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED,
23 so
24 || Dated: September 30, 2022
HONO LE MARIA A. AUDERO
25 United States Magistrate Judge
26
27
28
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STIPULATED PROTECTED ORDER
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1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, )
3 COUNTY OF LOS ANGELES )ss.
)
I am employed in the County of Los Angeles, State of California. I am over the age of
5 || eighteen years and not a party to the within action. My business address is: 777 South
‘ Figueroa Street, Suite 1507, Los Angeles, CA 90017.
7 On September 28, 2022, I served the foregoing document described as
STIPULATED PROTECTIVE ORDER on interested parties in this action by placing
g || true copies thereof enclosed in sealed envelopes addressed as follows:
9 || Katherine A. Sandoval, Esq.
MATTHIESEN, WICKET & LEHRER S.C.
10 || 1851 East First Stree, Suite 1150,
1 Santa Ana, CA 92705
Tel: (800) 637-9176
12. || Fax: (262) 673-3766
Authorized Address:
13 || ksandoval@mwl-law.com
yvillela@mwl-law.com
14 Attorneys for Plaintiff, Alliance of Schools
15 Cooperative Insurance Programs
16
x] BY EMAIL OR ELECTRONIC TRANSMISSION [CRC Rule 2.260(c)]: Only by e-
17 mailing the document(s) to the persons at the authorized e-mail address(es) listed, in
accordance with S.B. 1146, signed into law on September 18, 2020. I confirm that prior
18 to initially serving any represented party electronically, I confirmed by telephone or
19 email the appropriate electronic service address for the counsel being served. No
electronic message or other indication that the transmission was unsuccessful was
20 received within a reasonable time after the transmission.
21
Xx] STATE - I declare under penalty of perjury under the laws of the State of California that
22 the above is true and correct.
23 Executed on September 28, 2022 in Los Angeles, California. _ :
24
5 Krystine Tally és
26
27
28
14
STIPULATED PROTECTED ORDER