Gabrielle Alberici et al v. County of Los Angeles et al

Filing 107

STIPULATION AND PROTECTIVE ORDER FOR DEFENDANTS' PERSONNEL RECORDS by Magistrate Judge Victor B. Kenton. The parties agreed to the following Stipulated Protective Order to obtain some of the records requested and protect any potential confidential information. 104 [SEE ORDER FOR FURTHER DETAILS] (gr)

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DANIEL K. SPRADLIN - State Bar No. 82950
[e-mail]
JEANNE L. TOLLISON - State Bar No. 238970
[e-mail]
WOODRUFF, SPRADLIN & SMART, APC
555 Anton Boulevard, Suite 1200
Costa Mesa, California 92626-7670
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
COUNTY OF ORANGE, a public entity, and LAURA MCLUCKEY,
VERONICA ZUNIGA, SANDRA PARRISH-REHOREG, LAURI
LUCHONOK, GALE WESTBROOK, ELVIA VILLA, BRIAN
SATTERFIELD, as employees of COUNTY OF ORANGE, a public
entity

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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GABRIELLE ALBERICI, NICHOLAS
GROSS, JOHN A., a Minor, and
GREGORY A., a Minor, by and through
their Guardian Ad Litem, VERONICA T.
HEBERT,

CASE NO.: CV 12-10511-JFW (VBK)
“DISCOVERY MATTER”
STIPULATION AND [PROPOSED]
PROTECTIVE ORDER FOR
DEFENDANTS' PERSONNEL
RECORDS

Plaintiff,

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v.

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COUNTY OF LOS ANGELES,
COUNTY OF ORANGE, LAURA
MCLUCKEY, VERONICA ZUNIGA,
SANDRA PARRISH-REHOREG,
LAURIE LUCHONOK, GALE
WESTBROOK, ELVIA VILLA, BRIAN
SATTERFIELD, PAULINE DAVIS,
SANDRA WILLIAMS, GARY
KIRKLAND, CATHERINE
WOILLARD, and PRISCILLA
ASHBURN,

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HEARING DATES:
Type:
Pre-Trial Conference
Date:
October 18, 2013
Time:
10:00 a.m.
Type:
Date:
Time:

Trial
November 5, 2013
8:30 a.m.

Defendants.

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1.

PURPOSES AND LIMITATIONS

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Disclosure and discovery activity in this action are likely to involve production

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of confidential, proprietary, or private information for which special protection from
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public disclosure and from use for any purpose other than prosecuting this litigation

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may be warranted. Accordingly, the parties hereby stipulate to and petition the court

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

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

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

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

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applicable legal principles. The parties further acknowledge, as set forth in Section

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12.3, below, that this Stipulated Protective Order does not entitle them to file

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confidential information under seal; the Local Rules set forth the procedures that must

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

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the court to file material under seal.

ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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Plaintiffs seek personnel records related to Defendants Laura Mcluckey,

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Veronica Zuniga, Sandra Parrish-Rehoreg, Lauri Luchonok, Gale Westbrook, Elvia

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Villa, and Brian Satterfield. In response, Defendants have objected and met and

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conferred, asserting that the wholesale production may violate Defendants' state and

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federal constitutional rights of privacy, as well as the official information privilege.

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Defendants further object to the production unless and until the parties enter into a

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suitable protective order, approved by the Court.

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Plaintiffs maintain that they have always offered to enter into a protective order

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as indicated by the discovery demands themselves, and have repeatedly offered to do

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so. Plaintiffs reserve all rights to seek sanctions and other relief as concerns what they

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believe to be discovery abuses by Defendants. Defendants dispute these allegations.

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Plaintiffs further aver that Defendants objections are without merit in federal civil

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rights cases as has been oft-told to them.

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The parties agreed to the following Stipulated Protective Order to obtain some

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of the records requested and protect any potential confidential information.

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2.

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DEFINITIONS
2.1

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Challenging Party: a Party or Non-Party that challenges the designation
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of information or items under this Order.

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2.2

“CONFIDENTIAL” Information or Items: information (regardless of

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

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under Federal Rule of Civil Procedure 26(c).

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2.3

Counsel (without qualifier):

Outside Counsel of Record and House

Counsel (as well as their support staff).

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2.4

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

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

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“CONFIDENTIAL.”

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2.5

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

ATTORNEYS AT LAW
COSTA MESA

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

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& SMART

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

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generated in disclosures or responses to discovery in this matter.

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2.6

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

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

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expert witness or as a consultant in this action.

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2.7

House Counsel: attorneys who are employees of a party to this action.

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

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counsel.

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2.8

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

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

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2.9

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

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

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appeared in this action on behalf of that party or are affiliated with a law firm which

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has appeared on behalf of that party.

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2.10 Party: any party to this action, including all of its officers, directors,

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

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support staffs).
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2.11 Producing Party:

a Party or Non-Party that produces Disclosure or

Discovery Material in this action.

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2.12 Professional Vendors: persons or entities that provide litigation support

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

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

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and their employees and subcontractors.

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2.13 Protected Material:

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any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”

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2.14 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE

ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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The protections conferred by this Stipulation and Order cover not only

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

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

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

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or their Counsel that might reveal Protected Material. However, the protections

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conferred by this Stipulation and Order do not cover the following information: (a)

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any information that is in the public domain at the time of disclosure to a Receiving

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Party or becomes part of the public domain after its disclosure to a Receiving Party as

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a result of publication not involving a violation of this Order, including becoming part

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of the public record through trial or otherwise; and (b) any information known to the

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Receiving Party prior to the disclosure or obtained by the Receiving Party after the

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disclosure from a source who obtained the information lawfully and under no

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obligation of confidentiality to the Designating Party. Any use of Protected Material at

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trial shall be governed by a separate agreement or order.

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4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees
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otherwise in writing or a court order otherwise directs. Final disposition shall be

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deemed to be the later of (1) dismissal of all claims and defenses in this action, with or

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without prejudice; and (2) final judgment herein after the completion and exhaustion

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of all appeals, rehearings, remands, trials, or reviews of this action, including the time

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limits for filing any motions or applications for extension of time pursuant to

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applicable law.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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

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

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ATTORNEYS AT LAW
COSTA MESA

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

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WOODRUFF, SPRADLIN
& SMART

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only those parts of material, documents, items, or oral or written communications that

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

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for which protection is not warranted are not swept unjustifiably within the ambit of

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this Order.

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

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

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

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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

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

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

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produced.

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Designation in conformity with this Order requires:

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

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

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Producing Party affix the legend “CONFIDENTIAL” to each page that contains

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protected material. If only a portion or portions of the material on a page qualifies for
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protection, the Producing Party also must clearly identify the protected portion(s)

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

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

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indicated which material it would like copied and produced. During the inspection and

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

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

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

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

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

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to each page that contains Protected Material. If only a portion or portions of the

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COSTA MESA

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

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& SMART

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

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

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margins).

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(b) for testimony given in deposition or in other pretrial or trial proceedings,

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that the Designating Party identify on the record, before the close of the deposition,

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hearing, or other proceeding, all protected testimony.

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

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

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

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

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

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protected portion(s).

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

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

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

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designation of confidentiality at any time. Unless a prompt challenge to a Designating

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Party’s confidentiality designation is necessary to avoid foreseeable, substantial

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unfairness, unnecessary economic burdens, or a significant disruption or delay of the

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litigation, a Party does not waive its right to challenge a confidentiality designation by

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electing not to mount a challenge promptly after the original designation is disclosed.

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6.2

Meet and Confer.

The Challenging Party shall initiate the dispute

and describing the basis for each challenge. To avoid ambiguity as to whether a

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ATTORNEYS AT LAW
COSTA MESA

resolution process by providing written notice of each designation it is challenging

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WOODRUFF, SPRADLIN
& SMART

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challenge has been made, the written notice must recite that the challenge to

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confidentiality is being made in accordance with this specific paragraph of the

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Protective Order. The parties shall attempt to resolve each challenge in good faith and

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must begin the process by conferring directly (in voice to voice dialogue; other forms

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of communication are not sufficient) within 14 days of the date of service of notice. In

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conferring, the Challenging Party must explain the basis for its belief that the

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confidentiality designation was not proper and must give the Designating Party an

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opportunity to review the designated material, to reconsider the circumstances, and, if

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no change in designation is offered, to explain the basis for the chosen designation. A

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Challenging Party may proceed to the next stage of the challenge process only if it has

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engaged in this meet and confer process first or establishes that the Designating Party

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is unwilling to participate in the meet and confer process in a timely manner.

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6.3

Judicial Intervention. If the Parties cannot resolve a challenge without

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court intervention, the Challenging Party may file a motion challenging a

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confidentiality designation at any time if there is good cause for doing so, including a

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challenge to the designation of a deposition transcript or any portions thereof. Any

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motion brought pursuant to this provision must be accompanied by a competent
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declaration affirming that the movant has complied with the meet and confer

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requirements imposed by the preceding paragraph.

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Unless the Designating Party has waived the confidentiality designation by

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failing to file a motion to retain confidentiality as described above, all parties shall

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

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under the Producing Party’s designation until the court rules on the challenge.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

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

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

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

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COSTA MESA

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

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& SMART

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described in this Order. When the litigation has been terminated, a Receiving Party

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

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

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

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

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

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only to:

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(a)

the Receiving Party’s Outside Counsel of Record in this action, as well as

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

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disclose the information for this litigation and who have signed the “Acknowledgment

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

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(b)

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

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Receiving Party to whom disclosure is reasonably necessary for this litigation and

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

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(c)
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Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this litigation and who have signed the

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

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(d)

the court and its personnel;

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(e)

court reporters and their staff, professional jury or trial consultants, mock

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jurors, and Professional Vendors to whom disclosure is reasonably necessary for this

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litigation and who have signed the “Acknowledgment and Agreement to Be Bound”

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(Exhibit A);

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(f)

during their depositions, witnesses in the action to whom disclosure is

Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered

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by the court. Pages of transcribed deposition testimony or exhibits to depositions that

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COSTA MESA

reasonably necessary and who have signed the “Acknowledgment and Agreement to

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& SMART

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reveal Protected Material must be separately bound by the court reporter and may not

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be disclosed to anyone except as permitted under this Stipulated Protective Order.

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

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

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8.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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PRODUCED IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:

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(a)

promptly notify in writing the Designating Party. Such notification shall

include a copy of the subpoena or court order;

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(b)

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

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

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

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Stipulated Protective Order; and

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(c)

cooperate with respect to all reasonable procedures sought to be pursued

by the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with

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

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

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

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

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

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

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disobey a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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(a)

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

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COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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

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

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

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

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(b)

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

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

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

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confidential information, then the Party shall:

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(1)

promptly notify in writing the Requesting Party and the Non-Party

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

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confidentiality agreement with a Non-Party;

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(2)

promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this litigation, the relevant discovery request(s),

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and a reasonably specific description of the information requested;

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and

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(3)

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make the information requested available for inspection by the
Non-Party.

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(c)

If the Non-Party fails to object or seek a protective order from this court

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within 14 days of receiving the notice and accompanying information, the Receiving

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

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

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Party shall not produce any information in its possession or control that is subject to

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

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

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of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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COSTA MESA

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

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

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

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

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

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

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

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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

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

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

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

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

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12.

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

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

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

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

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

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

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

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

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COSTA MESA

12.3 Filing Protected Material. Without written permission from the

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& SMART

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persons, a Party may not file in the public record in this action any Protected Material.

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A Party that seeks to file under seal any Protected Material must comply with the

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applicable Local Rules and General Orders. Protected Material may only be filed

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under seal pursuant to a court order authorizing the sealing of the specific Protected

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Material at issue. If a Receiving Party's request to file Protected Material under seal

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

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record unless otherwise instructed by the court.

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13.0 FINAL DISPOSITION

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Within 60 days after the final disposition of this action, as defined in paragraph

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4, each Receiving Party must return all Protected Material to the Producing Party or

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destroy such material. As used in this subdivision, “all Protected Material” includes

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

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

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

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

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

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that was returned or destroyed and (2)affirms that the Receiving Party has not retained
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any copies, abstracts, compilations, summaries or any other format reproducing or

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capturing any of the Protected Material.

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Notwithstanding this provision, Counsel are entitled to retain an archival copy

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of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

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memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

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work product, and consultant and expert work product, even if such materials contain

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in Section 4

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(DURATION).

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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DATED: September 9, 2013

WOODRUFF, SPRADLIN & SMART, APC

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By: s/ Jeanne L. Tollison________________
DANIEL K. SPRADLIN
JEANNE L. TOLLISON
Attorneys for Defendants
COUNTY OF ORANGE, a public entity, and
LAURA
MCLUCKEY,
VERONICA
ZUNIGA, SANDRA PARRISH-REHOREG,
LAURI
LUCHONOK,
GALE
WESTBROOK, ELVIA VILLA, BRIAN
SATTERFIELD, as employees of COUNTY
OF ORANGE, a public entity

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DATED: September 9, 2013

PETERSON, BRADFORD BURKWITZ

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By: s/ Diana Ratcliff ________________
DIANA RATCLIFF
Attorneys for Defendants
COUNTY OF LOS ANGELES, PAULINE
DAVIS, GARY KIRKLAND, CATHERINE
WOILLARD and PRISCILLA ASHBURN

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DATED: September 9, 2013

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LAW OFFICES OF VINCENT DAVIS &
ASSOCIATES

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ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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By: s/ Danielle K. Little________________
DANIELLE K. LITTLE
Attorneys for Plaintiffs
GABRIELLE ALBERICI, NICHOLAS
GROSS, JOHN A., a Minor, and GREGORY
A., a Minor, by and through their Guardian
Ad Litem, VERONICA T. HEBERT

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: _9/11/2013_

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________________/s/__________________
Victor B. Kenton, Magistrate
United States District Court

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951896.1

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

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

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District of California on __________, 2013 in the case of Gabrielle Alberici, et al. v.

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County of Los Angeles, et al. Case No. CV 12-10511-JFW (VBK). I agree to comply

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

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

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

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ATTORNEYS AT LAW
COSTA MESA

I, _____________________, of _____________________, declare under

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WOODRUFF, SPRADLIN
& SMART

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

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Order to any person or entity except in strict compliance with the provisions of this

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Order.

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

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action.

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Date: _________________

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City and State where sworn and signed: _________________________________

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Printed name: ______________________________

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Signature: __________________________________

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951896.1

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PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF ORANGE

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I am over the age of 18 and not a party to the within action; I am employed by
WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 Anton
Boulevard, Suite 1200, Costa Mesa, CA 92626-7670.

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On September 9, 2013, I served the foregoing document(s) described as
STIPULATION AND [PROPOSED] PROTECTIVE ORDER FOR
DEFENDANTS' PERSONNEL RECORDS

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

by placing the true copies thereof enclosed in sealed envelopes addressed as
stated on the attached mailing list;

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(BY MAIL) I placed said envelope(s) for collection and mailing, following
ordinary business practices, at the business offices of WOODRUFF,
SPRADLIN & SMART, and addressed as shown on the attached service list,
for deposit in the United States Postal Service. I am readily familiar with the
practice of WOODRUFF, SPRADLIN & SMART for collection and processing
correspondence for mailing with the United States Postal Service, and said
envelope(s) will be deposited with the United States Postal Service on said date
in the ordinary course of business.



(BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be
electronically filed using the Court’s Electronic Filing System which constitutes
service of the filed document(s) on the individual(s) listed on the attached
mailing list.



(BY OVERNIGHT DELIVERY) I placed said documents in envelope(s) for
collection following ordinary business practices, at the business offices of
WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached
service list, for collection and delivery to a courier authorized by
________________________ to receive said documents, with delivery fees
provided for. I am readily familiar with the practices of WOODRUFF,
SPRADLIN & SMART for collection and processing of documents for
overnight delivery, and said envelope(s) will be deposited for receipt by
________________________ on said date in the ordinary course of business.



(BY FACSIMILE) I caused the above-referenced document to be transmitted
to the interested parties via facsimile transmission to the fax number(s) as stated
on the attached service list.



(BY PERSONAL SERVICE) I delivered such envelope(s) by hand to the
offices of the addressee(s).



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(Federal) I declare that I am employed in the office of a member of the bar of
this court at whose direction the service was made. I declare under
penalty of perjury that the above is true and correct.

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Executed on September 9, 2013, at Costa Mesa, California.

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ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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s/ Diane Castillo
DIANE CASTILLO

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951896.1

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GABRIELLE ALBERICI, et al. v. COUNTY OF LOS ANGELES, et al.

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ASSIGNED TO HONORABLE JOHN F. WALTER
REFERRED TO MAGISTRATE JUDGE VICTOR B. KENTON

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USDC, WESTERN DIVISION
CASE NO: CV 12-10511 JFW (VBK)

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SERVICE LIST

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ATTORNEYS AT LAW
COSTA MESA

WOODRUFF, SPRADLIN
& SMART

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Vincent W. Davis, Esq.
Danielle K. Little, Esq.
Law Offices of Vincent W. Davis
& Associates
150 N. Santa Anita Avenue, Suite 200
Arcadia, CA 91006
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Avi Burkwitz, Esq.
Chanel Call, Esq.
Diana Ratcliff, Esq.
Peterson, Bradford Burkwitz
100 North First Street Suite 300
Burbank, CA 91502
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

Attorneys for Plaintiffs
GABRIELLE ALBERICI,
NICHOLAS GROSS, JOHN A., a
Minor, and GREGORY A., A Minor,
by and through their Guardian Ad
Litem VERONICA T. HEBERT

Attorneys for Defendant
COUNTY OF LOS ANGELES

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951896.1

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