Ramiro Figueroa et al v. General Electric Company et al

Filing 27

STIPULATED PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver. The Court Orders that the terms of the parties Stipulated Confidentiality Agreement and Protective Order Regarding Non-Disclosure of Confidential Information shall govern the handling of such documents produced or disclosed by the parties in this case. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. #24 (SEE ORDER FOR FURTHER DETAILS) (gr)

1 DeWITT ALGORRI & ALGORRI
MARK S. ALGORRI, SB# 88859
E-Mail: [e-mail]
2
CAROLYN L. TAN, SB# 269770
E-Mail: [e-mail]
3
25 East Union Street
4 Pasadena, CA 91103
Telephone: [phone]
5 Facsimile: 626.584.3980

2/2/2016
G
R

6 Attorneys for Plaintiffs
RAMIRO FIGUEROA and BERTHA FIGUEROA
7
LEWIS BRISBOIS BISGAARD & SMITH LLP
8 DANA ALDEN FOX, SB# 119761
E-Mail: [e-mail]
9 JASON R. CHERMELA, SB# 204039
E-Mail: [e-mail]
th
10 633 West 5 Street, Suite 4000
Los Angeles, California 90071
11 Telephone: [phone]
Facsimile: 213.250.7900
12
Attorneys for Defendants
13 GENERAL ELECTRIC COMPANY,
THE HOME DEPOT, INC., and HOME
14 DEPOT, U.S.A., INC.
15
16

UNITED STATES DISTRICT COURT

17

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

18
19 RAMIOR FIGUEROA and BERTHA
FIGUEROA,
20
Plaintiff,
21
vs.
22
GENERAL ELECTRIC COMPANY;
23 THE HOME DEPOT, INC.; HOME
DEPOT, U.S.A., INC.; KOKO
24 TASMAJIAN; and DOES 1 through
100, Inclusive,
25
Defendant.
26

Case No. 2:15-cv-06381-ODW(RAOx)
Assigned to Hon. Otis D. Wright II,
District Judge and to Magistrate Judge
Hon. Rozella A. Oliver
STIPULATED PROTECTIVE
ORDER
Judge: Hon. Otis D. Wright II
Crtrm.: 11
Trial Date:

27 ///
28 ///
4823-3743-5948.1

STIPULATED PROTECTIVE ORDER

08/16/2016

1 1.
2

A.

PURPOSES AND LIMITATIONS

3

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

4 proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation may
6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
7 enter the following Stipulated Protective Order. The parties acknowledge that this
8 Order does not confer blanket protections on all disclosures or responses to
9 discovery and that the protection it affords from public disclosure and use extends
10 only to the limited information or items that are entitled to confidential treatment
11 under the applicable legal principles. The parties further acknowledge, as set forth
12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
13 file confidential information under seal; Civil Local Rule 79-5 sets forth the
14 procedures that must be followed and the standards that will be applied when a party
15 seeks permission from the court to file material under seal.
16

B.

GOOD CAUSE STATEMENT

17

This action is likely to involve trade secrets, customer and pricing lists and

18 other valuable research, development, commercial, financial, technical and/or
19 proprietary information, as well as personal medical information, for which special
20 protection from public disclosure and from use for any purpose other than
21 prosecution of this action is warranted. Such confidential and proprietary materials
22 and information consist of, among other things, confidential business or financial
23 information, information regarding confidential business practices, or other
24 confidential research, development, or commercial information (including
25 information implicating privacy rights of third parties), medical records, information
26 otherwise generally unavailable to the public, or which may be privileged or
27 otherwise protected from disclosure under state or federal statutes, court rules, case
28 decisions, or common law. Accordingly, to expedite the flow of information, to
4823-3743-5948.1
2
STIPULATED PROTECTIVE ORDER

1 facilitate the prompt resolution of disputes over confidentiality of discovery
2 materials, to adequately protect information the parties are entitled to keep
3 confidential, to ensure that the parties are permitted reasonable necessary uses of
4 such material in preparation for and in the conduct of trial, to address their handling
5 at the end of the litigation, and serve the ends of justice, a protective order for such
6 information is justified in this matter. It is the intent of the parties that information
7 will not be designated as confidential for tactical reasons and that nothing be so
8 designated without a good faith belief that it has been maintained in a confidential,
9 non-public manner, and there is good cause why it should not be part of the public
10 record of this case.
11 2.

DEFINITIONS

12

2.1

Action: This pending federal lawsuit.

13

2.2

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

14 of information or items under this Order.
2.3

15

“CONFIDENTIAL” Information or Items: information (regardless of

16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
18 the Good Cause Statement.
2.4

19

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

20 their support staff).
2.5

21

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

22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
2.6

24

Disclosure or Discovery Material: all items or information, regardless

25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery in this matter.
28 ///
4823-3743-5948.1

3

STIPULATED PROTECTIVE ORDER

1

2.7

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

2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4

2.8

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

5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7

2.9

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

8 other legal entity not named as a Party to this action.
9

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

10 to this Action but are retained to represent or advise a party to this Action and have
11 appeared in this Action on behalf of that party or are affiliated with a law firm which
12 has appeared on behalf of that party, and includes support staff.
13

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

14 employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
16

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

17 Discovery Material in this Action.
18

2.13 Professional Vendors: persons or entities that provide litigation support

19 services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium)
21 and their employees and subcontractors.
22

2.14 Protected Material: any Disclosure or Discovery Material that is

23 designated as “CONFIDENTIAL.”
24

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

25 from a Producing Party.
26 3.

SCOPE

27

The protections conferred by this Stipulation and Order cover not only

28 Protected Material (as defined above), but also (1) any information copied or
4823-3743-5948.1
4
STIPULATED PROTECTIVE ORDER

1 extracted from Protected Material; (2) all copies, excerpts, summaries, or
2 compilations of Protected Material; and (3) any testimony, conversations, or
3 presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the

4

5 trial judge. This Order does not govern the use of Protected Material at trial.
6 4.

DURATION

7

Even after final disposition of this litigation, the confidentiality obligations

8 imposed by this Order shall remain in effect until a Designating Party agrees
9 otherwise in writing or a court order otherwise directs. Final disposition shall be
10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
11 or without prejudice; and (2) final judgment herein after the completion and
12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
13 including the time limits for filing any motions or applications for extension of time
14 pursuant to applicable law.
15 5.

DESIGNATING PROTECTED MATERIAL

16

5.1

Exercise of Restraint and Care in Designating Material for Protection.

17 Each Party or Non-Party that designates information or items for protection under
18 this Order must take care to limit any such designation to specific material that
19 qualifies under the appropriate standards. The Designating Party must designate for
20 protection only those parts of material, documents, items, or oral or written
21 communications that qualify so that other portions of the material, documents,
22 items, or communications for which protection is not warranted are not swept
23 unjustifiably within the ambit of this Order.
24

Mass, indiscriminate, or routinized designations are prohibited. Designations

25 that are shown to be clearly unjustified or that have been made for an improper
26 purpose (e.g., to unnecessarily encumber the case development process or to impose
27 unnecessary expenses and burdens on other parties) may expose the Designating
28 Party to sanctions.
4823-3743-5948.1

5

STIPULATED PROTECTIVE ORDER

1

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

2 designated for protection do not qualify for protection that Designating Party must
3 promptly notify all other Parties that it is withdrawing the inapplicable designation.
4

5.2

Manner and Timing of Designations. Except as otherwise provided in

5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
7 under this Order must be clearly so designated before the material is disclosed or
8 produced.
9
10

Designation in conformity with this Order requires:
a.

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

11 documents, but excluding transcripts of depositions or other pretrial or trial
12 proceedings), that the Producing Party affix at a minimum, the legend
13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
14 contains protected material. If only a portion or portions of the material on a page
15 qualifies for protection, the Producing Party also must clearly identify the protected
16 portion(s) (e.g., by making appropriate markings in the margins).
17

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

18 need not designate them for protection until after the inspecting Party has indicated
19 which documents it would like copied and produced. During the inspection and
20 before the designation, all of the material made available for inspection shall be
21 deemed “CONFIDENTIAL.”

After the inspecting Party has identified the

22 documents it wants copied and produced, the Producing Party must determine which
23 documents, or portions thereof, qualify for protection under this Order. Then,
24 before producing the specified documents, the Producing Party must affix the
25 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
26 portion or portions of the material on a page qualifies for protection, the Producing
27 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
28 markings in the margins).
4823-3743-5948.1

6

STIPULATED PROTECTIVE ORDER

b.

1

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.
c.

4

for information produced in some form other than documentary and for

5 any other tangible items, that the Producing Party affix in a prominent place on the
6 exterior of the container or containers in which the information is stored the legend
7 “CONFIDENTIAL.” If only a portion or portions of the information warrants
8 protection, the Producing Party, to the extent practicable, shall identify the protected
9 portion(s).
5.3

10

Inadvertent Failures to Designate. If timely corrected, an inadvertent

11 failure to designate qualified information or items does not, standing alone, waive
12 the Designating Party’s right to secure protection under this Order for such material.
13 Upon timely correction of a designation, the Receiving Party must make reasonable
14 efforts to assure that the material is treated in accordance with the provisions of this
15 Order.
16 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

17

6.1

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

18 designation of confidentiality at any time that is consistent with the Court’s
19 Scheduling Order.
6.2

20

Meet and Confer. The Challenging Party shall initiate the dispute

21 resolution process under Local Rule 37.1 et seq.
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
4823-3743-5948.1

7

STIPULATED PROTECTIVE ORDER

1

6.3

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

2 the Designating Party.

Frivolous challenges, and those made for an improper

3 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
4 parties) may expose the Challenging Party to sanctions. Unless the Designating
5 Party has waived or withdrawn the confidentiality designation, all parties shall
6 continue to afford the material in question the level of protection to which it is
7 entitled under the Producing Party’s designation until the Court rules on the
8 challenge.
9 7.
10

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

11 disclosed or produced by another Party or by a Non-Party in connection with this
12 Action only for prosecuting, defending, or attempting to settle this Action. Such
13 Protected Material may be disclosed only to the categories of persons and under the
14 conditions described in this Order.

When the Action has been terminated, a

15 Receiving Party must comply with the provisions of section 13 below (FINAL
16 DISPOSITION).
17

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

18 location and in a secure manner that ensures that access is limited to the persons
19 authorized under this Order.
20

7.2

Disclosure of “CONFIDENTIAL” Information or Items.

Unless

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

Party

may

disclose

any

information

or

item

designated

23 “CONFIDENTIAL” only to:
24

a.

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

25 as employees of said Outside Counsel of Record to whom it is reasonably necessary
26 to disclose the information for this Action;
27

b.

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

28 Receiving Party to whom disclosure is reasonably necessary for this Action;
4823-3743-5948.1
8
STIPULATED PROTECTIVE ORDER

1

c.

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

2 disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4

d.

the court and its personnel;

5

e.

court reporters and their staff;

6

f.

professional jury or trial consultants, mock jurors, and Professional

7 Vendors to whom disclosure is reasonably necessary for this Action and who have
8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9

g.

the author or recipient of a document containing the information or a

10 custodian or other person who otherwise possessed or knew the information;
11

h.

during their depositions, witnesses, and attorneys for witnesses, in the

12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
13 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
14 not be permitted to keep any confidential information unless they sign the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
16 agreed by the Designating Party or ordered by the court. Pages of transcribed
17 deposition testimony or exhibits to depositions that reveal Protected Material may
18 be separately bound by the court reporter and may not be disclosed to anyone except
19 as permitted under this Stipulated Protective Order; and
20

i.

any mediator or settlement officer, and their supporting personnel,

21 mutually agreed upon by any of the parties engaged in settlement discussions.
22 8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

23

IN OTHER LITIGATION

24

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

25 that compels disclosure of any information or items designated in this Action as
26 “CONFIDENTIAL,” that Party must:
27

a.

promptly notify in writing the Designating Party. Such notification

28 shall include a copy of the subpoena or court order;
4823-3743-5948.1
9

STIPULATED PROTECTIVE ORDER

b.

1

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

2 to issue in the other litigation that some or all of the material covered by the
3 subpoena or order is subject to this Protective Order. Such notification shall include
4 a copy of this Stipulated Protective Order; and
c.

5

cooperate with respect to all reasonable procedures sought to be

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

7

8 the subpoena or court order shall not produce any information designated in this
9 action as “CONFIDENTIAL” before a determination by the court from which the
10 subpoena or order issued, unless the Party has obtained the Designating Party’s
11 permission. The Designating Party shall bear the burden and expense of seeking
12 protection in that court of its confidential material and nothing in these provisions
13 should be construed as authorizing or encouraging a Receiving Party in this Action
14 to disobey a lawful directive from another court.
15 9.

A

NON-PARTY’S

PROTECTED

16

PRODUCED IN THIS LITIGATION

17

a.

MATERIAL

SOUGHT

TO

BE

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

18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
19 produced by Non-Parties in connection with this litigation is protected by the
20 remedies and relief provided by this Order. Nothing in these provisions should be
21 construed as prohibiting a Non-Party from seeking additional protections.
22

b.

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

23 produce a Non-Party’s confidential information in its possession, and the Party is
24 subject to an agreement with the Non-Party not to produce the Non-Party’s
25 confidential information, then the Party shall:
(1)

26

promptly notify in writing the Requesting Party and the Non-

27 Party that some or all of the information requested is subject to a confidentiality
28 agreement with a Non-Party;
4823-3743-5948.1

10

STIPULATED PROTECTIVE ORDER

(2)

1

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

2 Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 specific description of the information requested; and
(3)

4

make the information requested available for inspection by the

5 Non-Party, if requested.
c.

6

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

7 14 days of receiving the notice and accompanying information, the Receiving Party
8 may produce the Non-Party’s confidential information responsive to the discovery
9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
10 not produce any information in its possession or control that is subject to the
11 confidentiality agreement with the Non-Party before a determination by the court.
12 Absent a court order to the contrary, the Non-Party shall bear the burden and
13 expense of seeking protection in this court of its Protected Material.
14 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15

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 (a) notify in
18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
20 persons to whom unauthorized disclosures were made of all the terms of this Order,
21 and (d) request such person or persons to execute the “Acknowledgment and
22 Agreement to Be Bound” that is attached hereto as Exhibit A.
23 11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24

PROTECTED MATERIAL

25

When a Producing Party gives notice to Receiving Parties that certain

26 inadvertently produced material is subject to a claim of privilege or other protection,
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28 Procedure 26(b)(5)(B).
4823-3743-5948.1

This provision is not intended to modify whatever
11
STIPULATED PROTECTIVE ORDER

1 procedure may be established in an e-discovery order that provides for production
2 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
3 (e), insofar as the parties reach an agreement on the effect of disclosure of a
4 communication or information covered by the attorney-client privilege or work
5 product protection, the parties may incorporate their agreement in the stipulated
6 protective order submitted to the court.
7 12.

MISCELLANEOUS

8

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

9 person to seek its modification by the Court in the future.
10

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

11 Protective Order no Party waives any right it otherwise would have to object to
12 disclosing or producing any information or item on any ground not addressed in this
13 Stipulated Protective Order. Similarly, no Party waives any right to object on any
14 ground to use in evidence of any of the material covered by this Protective Order.
15

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

16 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
17 only be filed under seal pursuant to a court order authorizing the sealing of the
18 specific Protected Material at issue. If a Party's request to file Protected Material
19 under seal is denied by the court, then the Receiving Party may file the information
20 in the public record unless otherwise instructed by the court.
21 13.

FINAL DISPOSITION

22

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

23 60 days of a written request by the Designating Party, each Receiving Party must
24 return all Protected Material to the Producing Party or destroy such material. As
25 used in this subdivision, “all Protected Material” includes all copies, abstracts,
26 compilations, summaries, and any other format reproducing or capturing any of the
27 Protected Material. Whether the Protected Material is returned or destroyed, the
28 Receiving Party must submit a written certification to the Producing Party (and, if
4823-3743-5948.1
12
STIPULATED PROTECTIVE ORDER

1 not the same person or entity, to the Designating Party) by the 60 day deadline that
2 (1) identifies (by category, where appropriate) all the Protected Material that was
3 returned or destroyed and (2) affirms that the Receiving Party has not retained any
4 copies, abstracts, compilations, summaries or any other format reproducing or
5 capturing any of the Protected Material. Notwithstanding this provision, Counsel
6 are entitled to retain an archival copy of all pleadings, motion papers, trial,
7 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
8 and trial exhibits, expert reports, attorney work product, and consultant and expert
9 work product, even if such materials contain Protected Material. Any such archival
10 copies that contain or constitute Protected Material remain subject to this Protective
11 Order as set forth in Section 4 indefinitely.
12

14.

Any violation of this Order may be punished by any and all appropriate

13 measures including, without limitation, contempt proceedings and/or monetary
14 sanctions.
15
16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
17
18 DATED: 12/28/15
19
20
21

/s/ Carolyn Tan
Attorneys for Plaintiff

22
23

DATED: 1/7/16

24
25

/s/ Jason R. Chermela
26 Attorneys for Defendant
27
28
4823-3743-5948.1

13

STIPULATED PROTECTIVE ORDER

1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3
4 DATED: February 2, 2016
5
6 Rozella A. Oliver
7
8
9 ________________________________
United States Magistrate Judge
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4823-3743-5948.1

14

STIPULATED PROTECTIVE ORDER

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 I have read in its
6 entirety and understand the Stipulated Protective Order that was issued by the
7 United States District Court for the Central District of California on [date] in the
8 case of RAMIOR FIGUEROA and BERTHA FIGUEROA vs. GENERAL ELECTRIC
9 COMPANY; THE HOME DEPOT, INC.; HOME DEPOT, U.S.A., INC.; KOKO
10 TASMAJIAN; and DOES 1 through 100, Inclusive, CASE NO. CV15-0638111 ODW(RAOx). I agree to comply with and to be bound by all the terms of this
12 Stipulated Protective Order and I understand and acknowledge that failure to so
13 comply could expose me to sanctions and punishment in the nature of contempt. I
14 solemnly promise that I will not disclose in any manner any information or item that
15 is subject to this Stipulated Protective Order to any person or entity except in strict
16 compliance with the provisions of this Order.
17

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

18 for the Central District of California for the purpose of enforcing the terms of this
19 Stipulated Protective Order, even if such enforcement proceedings occur after
20 termination of this action. I hereby appoint
21 ________________________________________ [print or type full name] of
22 ___________________________ [print or type full address and telephone number]
23 as my California agent for service of process in connection with this action or any
24 proceedings related to enforcement of this Stipulated Protective Order.
25
26
27
28
4823-3743-5948.1

15

STIPULATED PROTECTIVE ORDER

1

FEDERAL COURT PROOF OF SERVICE

2

Ramiro Figueroa, et al. v. General Electric Company, et al.
Case No. 2:15-cv-06381-ODW(RAOx)

3

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

4

At the time of service, I was over 18 years of age and not a party to the action.
5 My business address is 633 West 5th Street, Suite 4000, Los Angeles, CA 90071. I
am employed in the office of a member of the bar of this Court at whose direction
6 the service was made.
7

On January 26, 2016, I served the following document(s): STIPULATED
PROTECTIVE ORDER

8

I served the documents on the following persons at the following addresses
9 (including fax numbers and e-mail addresses, if applicable):
10

Mark S. Algorri, Esq.
Carolyn L. Tan, Esq.
DeWITT ALGORRI & ALGORRI
25 East Union Street
Pasadena, CA 91103

12
13
14
15

[phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs

Gregory F. Johnsen, Esq.
LAW OFFICES OF GREGORY F.
JOHNSEN
15335 Morrison St., Ste. 100
Sherman Oaks, CA 91403

11

[e-mail]
Attorneys for Intervener
State Farm Fire and Casualty Conpany

16
17

The documents were served by the following means:

18 [x

(BY COURT’S CM/ECF SYSTEM)
Pursuant to Local Rule, I
electronically filed the documents with the Clerk of the Court using the
CM/ECF system, which sent notification of that filing to the persons listed
above.

19
20

I declare under penalty of perjury under the laws of the United States of
21 America and the State of California that the foregoing is true and correct.
22

Executed on January 26, 2016, at Los Angeles, California.

23
24

Nancy L. Alfaro

25
26
27
28
4823-3743-5948.1

16

STIPULATED PROTECTIVE ORDER