Enrique B. Roque v. Home Depot U.S.A., INC.,

Filing 15

PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver granting Stipulated Protective Order 13 (sbu)

1
2
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6

Michael J. Sexton, CA Bar No. 153435
[e-mail]
Michael E. Olsen, CA Bar No. 307358
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Park Tower, Suite 1500
695 Town Center Drive
Costa Mesa, CA 92626
Telephone: [phone]
Facsimile: 714.754.1298

7 Attorneys for Defendant

HOME DEPOT U.S.A., INC.

8

Gregory P. Wong, CA Bar No. 204502
9 ADEPT EMPLOYMENT LAW, APC
10880 Wilshire Boulevard, Suite 1101
10 Los Angeles, CA 90012
Telephone: [phone]
11 Facsimile: 213.947.4584
[e-mail]
12

Attorneys for Plaintiff
13 Enrique B. Roque
14

UNITED STATES DISTRICT COURT

15

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

16
17 ENRIQUE B. ROQUE, an individual,

Case No. 2:17-CV-02464 PA (RAOx)

18

Assigned to:
Percy Anderson, District Judge
Rozella A. Oliver, Magistrate Judge

19

Plaintiff,
vs.

20 HOME DEPOT U.S.A., INC., a Delaware STIPULATED PROTECTIVE
21
22

corporation.

ORDER

Defendant.

[Filed Concurrently with [Proposed]
Protective Order]

23

Complaint Filed: March 30, 2016
Trial Date:
None Set

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1
STIPULATED PROTECTIVE ORDER

Case No. 2:17-CV-02464 PA (RAOx)

1

IT IS HEREBY STIPULATED by and between Plaintiff ENRIQUE B.

2

ROQUE (hereinafter referred to as “Plaintiff”) and Defendant HOME DEPOT

3

U.S.A., INC. (hereinafter referred to as “Defendant” and/or “Home Depot”), through

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their respective attorneys of record, that a Protective Order be entered by this Court

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as follows:

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This Stipulation and Protective Order shall be applicable to and shall apply to

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the production and exchange of all document requests and documents, interrogatories

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and answers to interrogatories, depositions, request for admissions, and responses to

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requests for admissions, exhibits, and pleadings and all other information exchanged

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and furnished in this Action by the Parties that the parties customarily treat as

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confidential, proprietary, and/or a trade secret as defined by California Civil Code

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Section 3426.1.

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1.

SCOPE

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(a)

The parties acknowledge that discovery may require disclosure of

15

information that is private and personal or confidential and proprietary, specifically

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personnel records, personnel policies, employment offers, competitive analyses,

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income statements, employee, client, or customer personal information (including,

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but not limited to medical, age, and contact information), medical records, and

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financial records and statements, along with other trade secret information as defined

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in California Civil Code Section 3426.1. As a result, the parties agree to enter into a

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Protective Order on the following terms to ensure the continuing confidentiality of

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such information. The parties further acknowledge that this Order does not confer

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blanket protections on all disclosures or responses to discovery and that the

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protection it affords extends only to the limited information or items that are entitled

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under the applicable legal principles to treatment as confidential.

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(b)

This Protective Order shall limit the use or disclosure of documents,

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deposition testimony, and related information which are or which embody or

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disclose any information falling with the scope of Paragraph (1)(a) and designated

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STIPULATED PROTECTIVE ORDER

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hereunder as “Confidential,” and shall apply to:
(i)

2

All such documents, including those produced by third parties,

3

designated as “Confidential” in accordance with the terms of this Protective Order

4

and the applicable legal standards;
(ii)

5

Portions of deposition testimony and transcripts and exhibits

6 thereto which include, refer or relate to any Confidential Information;

(iii)

7

All information, copies, extracts and complete or partial

8 summaries prepared or derived from Confidential Information; and

(iv)

9

Portions of briefs, memoranda or any writing filed with or

10 otherwise supplied to the Court, which include or refer to any such Confidential
11
12

Information.
(c)

Any person designating documents, testimony, or other information as

13 “Confidential” hereunder asserts that he or she believes in good faith that such
14 material is Confidential Information which falls within the scope of Section (1)(a)
15 and is not otherwise available to the public generally. Each party or non-party that
16 designates information or items for protection under this Order must take care to
17 limit any such designation to specific material that qualifies under the appropriate
18 standards. A Designating Party must take care to designate for protection only those
19 parts of material, documents, items, or oral or written communications that qualify so
20 that other portions of the material, documents, items, or communications for which
21 protection is not warranted are not swept unjustifiably within the ambit of this Order.
22

2.

DESIGNATION OF DOCUMENTS AND DEPOSITIONS

23

(a)

Designation of a document as “Confidential” shall be made by stamping

24

or writing CONFIDENTIAL on the document(s). Alternatively, the parties may

25

designate documents as “Confidential” by producing the documents with a letter

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designating the documents by Bates number as “Confidential.” The parties shall

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make all reasonable effort to designate as “Confidential” only those documents that

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they reasonably believe constitute personnel records, personnel policies, employment

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STIPULATED PROTECTIVE ORDER

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offers, competitive analyses, income statements, employee, client or customer

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personal information, medical records, financial records and statements, and trade

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secret information as defined in California Civil Code Section 3426.1. The failure to

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designate documents as “Confidential” at the time of production shall not constitute

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a waiver of the protection of this Order and any party may, at any time up to 30 days

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before the date of discovery cut-off in this action, designate any documents or

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information produced as “Confidential” that have not as yet been so designated.

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Stamping the legend “Confidential” on the cover of any multi-page document shall

9

designate all pages of the document as confidential, unless otherwise indicated by the

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Designating Party, but only if the entire document is produced in a bound or

11

otherwise intact manner.

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(b)

Designation of a deposition or other pretrial testimony, or portions

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thereof, as “Confidential” shall be made by a statement on the record by counsel for

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the party or other person making the claim of confidentiality at the time of such

15

testimony. The portions of depositions so designated as “Confidential” shall be

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taken only in the presence of persons qualified to receive such information pursuant

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to the terms of this Protective Order: the parties and their attorneys and staff, the

18

court reporter, videographer, the deponent, and the deponent’s attorney. Failure of

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any other person to comply with a request to leave the deposition room will

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constitute sufficient justification for the witness to refuse to answer any question

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calling for disclosure of Confidential Information so long as persons are in

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attendance who are not entitled by this Protective Order to have access to such

23

information.

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Confidential Information, instruct the court reporter to segregate such portions of the

25

deposition in a separate transcript designated as “Confidential.” Portions of such

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deposition transcripts shall be clearly marked as “Confidential” on the cover or on

27

each page, as appropriate.

The parties may, but need not in order to designate material as

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(c)

Any party may designate documents produced or portions of
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STIPULATED PROTECTIVE ORDER

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depositions taken as containing Confidential Information even if not initially marked

2 as “Confidential” in accordance with the terms of this Protective Order by so
3 advising counsel for each other party in writing and by reproducing said documents
4 with the required confidential designation.

Thereafter, each such document or

5 transcript shall be treated in accordance with the terms of this Protective Order;
6 provided, however, that there shall be no liability for any disclosure or use of such
7 documents or transcripts, or the Confidential Information contained therein, which
8 occurred prior to actual receipt of such written notice. Any person who receives
9 actual notice of any such designation of previously produced documents or
10 deposition transcripts as containing Confidential Information shall thereafter treat
11 such information as if it had been designated as “Confidential” at the time he, she, or
12 it first received it in connection with this matter.
13

(d)

Inadvertent failure to designate Confidential Information shall not be

14 construed as a waiver, in whole or in part, and may be corrected by the producing
15 party by designating documents produced or portions of depositions taken as
16 containing Confidential Information, even if not initially marked as “Confidential,”
17 in accordance with the terms of this Protective Order and, specifically, Paragraph
18 2(c) above.
19

3.

INFORMATION

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LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL

(a)

No Confidential Information shall be disclosed by anyone receiving

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such information to anyone other than those persons designated herein. In no event

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shall Confidential Information be used, either directly or indirectly, by anyone

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receiving such information for any business, commercial or competitive purpose or

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for any purpose whatsoever other than the direct furtherance of the litigation of this

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action in accordance with the provisions of this Protective Order.

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(b)

Confidential Information shall not be disclosed by any person who has

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received such information through discovery in this action to any other person,
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STIPULATED PROTECTIVE ORDER

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except to:

2

(i)

The parties;

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(ii)

Attorneys of record for the parties and their firms’ associates,

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clerks and other employees involved in the conduct of this litigation, and any court

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reporters, videographers, or interpreters engaged to assist the parties in discovery;
(iii)

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Home Depot’s, its subsidiaries’, or its affiliates’ in-house

(iv)

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Non-party experts and consultants engaged by counsel for the

counsel;

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purpose of preparing or assisting in this litigation, and those experts’ respective

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clerks and employees involved in assisting them in this litigation, to the extent

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deemed necessary by counsel;
(v)

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The Court, its officers, Court reporters and similar personnel,

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provided further that Confidential Information lodged with the Court under seal is

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subject to further evaluation by the Court;
(vi)

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Any person as to which it is apparent from the face of a document

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was either an author, recipient, had knowledge of the contents therein, or was

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otherwise entitled to view the Confidential Information prior to the intended

18

disclosure in this action; and

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(vii) Any other potential witnesses whose testimony may be used in

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connection with the present case who has complied with Paragraph 3(c) immediately

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below.
(viii) Any mediator or other third-party neutral the parties agree to use.

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23

(c)

Before any person described in Paragraphs 3(b)(iv) and (vii) receives or

24 is shown any document or information which has been designated as Confidential,
25 such person shall be given a copy of this Protective Order and shall agree in writing,
26 in the form of the Acknowledgment and Agreement attached hereto as Exhibit A, to
27 be bound by the terms hereof.

The original of each such Acknowledgment and

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28 Agreement shall be maintained by counsel and, if a witness appears at deposition or

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STIPULATED PROTECTIVE ORDER

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at trial and represents that he or she previously executed an Acknowledgment, it

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shall be produced for inspection by opposing counsel upon request. Any counsel

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may require the other counsel to provide a copy of the Acknowledgment and

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Agreement signed by a witness at a deposition before the witness is deposed with

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regard to any Confidential Information.

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7

(d)

Nothing in this Protective Order shall be construed to require execution

of the written Acknowledgment and Agreement referred to in Paragraph 3(c) above,

8 or to prevent disclosure of Confidential Information, by the party producing and
9
10

designating such Confidential Information, or by any employee of such party.
(e)

The substance or content of Confidential Information, as well as all

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notes and memoranda relating thereto, shall not be disclosed to anyone other than as

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set forth in Paragraphs 3(b)(i)-(vii) above.

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4.

FILING DOCUMENTS UNDER SEAL

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(a)

If a Party wishes to submit a document to the Court which the other

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Party has designated as Confidential or which contains Confidential Information and

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which has not been successfully challenged under Paragraph 5 below, the submitting

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Party shall notify the Designating Party, in writing, of both the exact material which

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the Party intends to submit to the Court and the reason(s) and legal ground(s) for

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submitting the material under seal at least 30 days prior to the date on which the

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Party intends to make the submission, so as to provide the Designating Party

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sufficient time to determine whether it needs to bring a motion ordering that the

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material be filed under seal. Any such motion must comply with the procedures set

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forth in Local Rule 79-5 and must also comply with Federal Rule of Civil Procedure

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26(c)(1). The written application and proposed order shall be presented to the judge

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along with the document intended to be submitted for filing under seal. The original

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and judge’s copy of the document shall be sealed in separate envelopes with a copy

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of the title page attached to the front of each envelope. If only a portion of the

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document is sealable, then both the copy lodged with the Clerk and the judge’s copy

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STIPULATED PROTECTIVE ORDER

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shall have the sealable portions identified by notation or highlighting of the text.

2

The Application and Order to Seal, along with the material to be placed under

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seal, shall not be electronically filed but shall be filed manually in the manner

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prescribed by Local Rule 79-5.

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electronically filed, identifying all materials being manually filed.

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(b)

A Notice of Manual Filing shall also be

Any party requesting that a record be filed under seal must comply with

7 Local Rule 79-5. The Parties agree and recognize that Confidential Information or
8 any paper containing Confidential Information cannot be filed under seal based
9 solely upon this stipulated Protective Order.
10

5.

CHALLENGE TO CONFIDENTIALITY DESIGNATION

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Any party that wishes to challenge the designation of a document or other

12

information as “Confidential” must identify the documents or information for which

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it is challenging the designation within 30 days after their production.

14

Designating Party may, for good cause shown, bring a motion before the Court

15

requesting that the Court confirm the designation of any document or information as

16

“Confidential.” The party asserting the designation as “Confidential” shall have the

17

burden of establishing good cause for the designation. However, the Court shall be

18

authorized to award the moving party attorneys’ fees as a sanction if the challenge to

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the “Confidential” designation was made in bad faith or was frivolous.

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interested parties or other persons shall attempt to resolve such disagreements before

The

The

21 submitting them to the Court pursuant to Local Rule 37-1. Pending resolution of any
22 dispute concerning such designation, all parties and persons governed by this
23 Protective Order shall treat all documents and information previously designated as
24 “Confidential” as protected from further disclosure by this Protective Order.
25

6.

SURVIVAL OF ORDER - RETURN OF DOCUMENTS

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(a)

The provisions of this Order shall continue in effect until otherwise

27

ordered by the Court, or after notice and an opportunity to be heard is afforded to the

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parties to this action. The final determination or settlement of this action shall not

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STIPULATED PROTECTIVE ORDER

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relieve any person who has received Confidential Information or agreed to be bound

2

by the terms of this Protective Order of his, her, or its obligations under this

3 stipulation and Order.

The Court shall retain jurisdiction after such final

4 determination or settlement to enforce the provisions of this Order.

Upon

5 completion of the litigation, all documents (including copies of documents)
6 containing Confidential Information shall be destroyed or returned to counsel for the
7 producing party, except that (a) documents on which any person has made notations
8

may be destroyed and not returned, and (b) the parties’ respective attorneys of record

9

may retain one copy of each such document for use in connection with any disputes

10

which may arise under the Court’s retention of jurisdiction as provided for herein.

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Within ninety days (90) of the conclusion of this litigation, the attorneys for the

12

receiving party shall provide the attorneys for the producing party a certificate

13

representing that such return or destruction was made.

14

(b)

Except as provided in Paragraphs 4 or 6 hereof, documents or things

15 containing the other party’s Confidential Information shall at all times be in the
16 physical possession of those persons qualifying under Paragraph 3 hereunder, or kept
17 by counsel of record at the premises regularly maintained by such counsel of record
18 as and for their respective law offices.
19

7.

USE OF DOCUMENTS AT TRIAL

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This Stipulation and Protective Order, except as provided in Paragraph 4, shall

21

not apply to information designated or marked Confidential hereunder which is used

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at any evidentiary hearing or trial in this action. The parties hereby reserve their

23

rights to use, or seek to limit the disclosure of, confidential information at any such

24

hearing or trial.

25

8.

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Nothing in this Protective Order shall limit the use by any party, person or

27

entity of his, her, or its own document or information for legitimate business

28

purposes unrelated to this litigation, even if such documents or information have

USE OF OWN DOCUMENTS BY PRODUCING PARTY

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STIPULATED PROTECTIVE ORDER

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been designated as “Confidential.”

2

9.

APPLICATIONS TO COURT

3

(a)

This Protective Order shall not preclude or limit any party’s right to

4

oppose or object to discovery on any ground which would be otherwise available.

5

This Protective Order shall not preclude or limit any party’s right to seek in camera

6

review or to seek further and additional protection against or limitation upon

7

production or dissemination of information produced in response to discovery,

8

including documents and their contents.

9

(b)

Any person to or by whom disclosure or inspection is made in violation

10

of this Protective Order, and who has knowledge of this Protective Order, shall be

11

bound by the terms hereof.

12

(c)

The parties hereto, and all other persons who receive Confidential

13

Information pursuant hereto, agree that any party or other person injured by a

14

violation of this Order does not have an adequate remedy at law and that an

15

injunction against such violation is an appropriate remedy. In the event any person

16

shall violate or threaten to violate any terms of this Order, the parties agree that the

17

aggrieved party may immediately apply to obtain injunctive relief against any such

18

person. In the event the aggrieved party shall do so, the responding person subject to

19

the provisions of this Order shall not employ as a defense thereto the claim that the

20

aggrieved party has an adequate remedy at law. Any persons subject to the terms of

21

this Order agree that the Court shall retain jurisdiction over it and them for the

22

purposes of enforcing this Order, including but not limited to issuing an injunction.

23

In addition to injunctive relief, as specified herein, the Court may impose monetary

24

and/or issue sanctions, as well as other relief deemed appropriate under the

25

circumstances for a violation of this Protective Order.

26

(d)

If any deponent required under the terms of this Protective Order to

27 execute the written Acknowledgment and Agreement described in Paragraph 3(c)
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above refuses to do so, the parties may complete the deposition on other matters
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STIPULATED PROTECTIVE ORDER

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and/or adjourn it and move the Court for any appropriate relief, including (without

2

limitation) relief from this Protective Order as to that deponent, or an order that the

3

deponent shall execute the written agreement described in Paragraph 3(c) above, or

4

an order that deponent shall be bound by the terms of this Protective Order. Any

5

non-party whose Confidential Information is the subject of such a motion shall be

6

given notice thereof.

7

10.

AGREEMENT TO COOPERATE

8

The parties hereto and their respective attorneys of record agree that, when one

9

party’s attorney requests a deponent to sign the written Acknowledgment and

10

Agreement described in Paragraph 3(c) above, the other party’s attorney will join in

11

such request, unless that attorney has a good faith basis for refusing to join in such a

12

request; provided, however, that this requirement shall not apply with respect to any

13

deponent who is represented at his or her deposition by an attorney of record for any

14

party hereto (including any member or associate of their respective law firms). An

15

attorney’s request to sign such Acknowledgment pursuant to this Paragraph shall not

16

be construed to constitute legal advice to the deponent, but shall and may be stated to

17

be simply a request to facilitate discovery in this action.

18

11.

NO ADMISSIONS

19

Neither entering into this Stipulation for Protective Order, nor receiving any

20

documents or other information designated as “Confidential” shall be construed as an

21

agreement or admission: (1) that any document or information designated as

22

“Confidential” is in fact Confidential Information; (2) as to the correctness or truth of

23

any allegation made or position taken relative to any matter designated as

24

“Confidential”; or (3) as to the authenticity, competency, relevancy or materiality of

25

any information or document designated as “Confidential.”

26

///

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///

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///

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STIPULATED PROTECTIVE ORDER

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12.

1

NO WAIVER OF PRIVILEGES OR OBJECTIONS TO
ADMISSIBILITY

2
3

Nothing in this Protective Order shall be construed as requiring disclosure of

4

Confidential Information, including, but not limited to, materials subject to

5

protection under the attorney-client privilege and/or attorney work product doctrine,

6

the trade secrets privilege, or under any other applicable privileges or rights of

7

privacy, or requiring disclosure of Confidential Information that is otherwise beyond

8

the scope of permissible discovery. Further, nothing in this Protective Order shall be

9

construed as a waiver by a party of any objections that might be raised as to the

10

admissibility at trial of any evidentiary materials.

11

13.

DISCLOSURE IN VIOLATION OF ORDER

12

If any Confidential Information is disclosed to any person other than in the

13

manner authorized by this Protective Order, the party responsible for the disclosure

14

must immediately, in writing, notify the opposing party and the Designating Party of

15 all pertinent facts relating to such disclosure, and without prejudice to the rights and
16 remedies of the Designating Party, make every effort to prevent further unauthorized
17 disclosure.
18

14.

MODIFICATION - FURTHER AGREEMENTS

19

Nothing contained herein shall preclude any party from seeking from a Court

20

modification, or relief from any aspect, of this Stipulated Protective Order upon

21

proper notice, nor shall anything contained herein be construed as to preclude the

22

parties from entering into other written agreements designed to protect Confidential

23

Information.

24
25

///

26

///

27

///

28

///

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STIPULATED PROTECTIVE ORDER

Case No. 2:17-CV-02464 PA (RAOx)

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15.

COUNTERPARTS

2

This Stipulation for Protective Order may be executed in counterparts, each of

3

which shall be deemed an original and which together shall constitute one

4

instrument.

5
6

DATED: June 1, 2017

7

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

8
9

By: /s/ MICHAEL E. OLSEN________
Michael J. Sexton
Michael E. Olsen
Attorneys for Defendant HOME DEPOT
U.S.A., INC.

10
11
12

DATED: June 1, 2017

ADEPT EMPLOYMENT LAW, APC

13
14
15

By: /s/ GREGORY P. WONG_________
Gregory P. Wong
Attorneys for Plaintiff Enrique B. Roque

16
17
18
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2

EXHIBIT A - ACKNOWLEDGEMENT AND AGREEMENT FOR
PROTECTIVE ORDER

3

I, ________________________________________, hereby certify that:

4

1.

My present address is _____________________________.

5

2.

My present employer is ___________________________.

6

3.

My present occupation or job description is _____________________.

7

4.

I have received a copy of the Protective Order in the above-captioned

8 case and agree to be bound by the terms of the Protective Order.
9

5.

I have carefully read and understand the provisions of the Protective

10 Order.
11

6.

I will hold in confidence and not disclose to anyone not qualified under

12 the Protective Order, any Confidential Information or any portion or substance
13 thereof provided to me in the course of this litigation.
14

7.

I will return all materials containing Confidential Information or any

15 portions or copies, summaries, abstracts or indices thereof, which come into my
16 possession, and documents or things that I prepared relating thereto and containing
17 such Confidential Information, to counsel for the party by whom I am retained or
18 employed, or to counsel by whom I am retained or employed, when my services in
19 this matter have been concluded.
20

8.

I understand that if I violate the provisions of this Protective Order, I

21 may be subject to sanctions by the Court, among other things.
22

9.

I hereby submit to the jurisdiction of the United States District Court for

23 the Central District of California for the purpose of enforcement of this Protective
24 Order against me.
25

I declare under penalty of perjury under the laws of the State of California and

26 the United States of America that the foregoing is true and correct.
27
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28 Dated:_________________

Signature:_________________________________
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STIPULATED PROTECTIVE ORDER

Case No. 2:17-CV-02464 PA (RAOx)

1
2
3

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

4
5 ENRIQUE B. ROQUE, an individual,

Plaintiff,

6
7

vs.

Case No. 2:17-CV-02464 PA (RAOx)
Assigned to:
Percy Anderson, District Judge
Rozella A. Oliver, Magistrate Judge

8 HOME DEPOT U.S.A., INC., a Delaware PROTECTIVE ORDER

corporation.

9

Defendant.

[Filed Concurrently with [Proposed]
Protective Order]

10

Complaint Filed: March 30, 2016
Trial Date:
None Set

11
12
13
14

ORDER

15
16
17
18
19
20
21

GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED
THAT the provisions of the concurrently filed stipulation between the parties
Plaintiff ENRIQUE B. ROQUE and Defendant HOME DEPOT U.S.A., Inc.
regarding the use and protection of Confidential Information (the “Stipulated
Protective Order”) shall be entered as the Order of the Court and be binding upon the
parties.

22
23
24 DATED: June 2, 2017
25

ROZELLA A. OLVER
UNITED STATES MAGISTRATE JUDGE

26

23992504.1

27
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STIPULATED PROTECTIVE ORDER

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CERTIFICATE OF SERVICE
Enrique B. Roque v. Home Depot U.S.A., Inc.

1
2

I am and was at all times herein mentioned over the age of 18 years and not a
party to the action in which this service is made. At all times herein mentioned I
4 have been employed in the County of Orange in the office of a member of the bar of
this court at whose direction the service was made. My business address is 695
Town Center Drive, Suite 1500, Costa Mesa, CA 92626.
5
3

6

On June 2, 2017, I served the following document(s):
STIPULATED PROTECTIVE ORDER

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8 by placing
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(the original)

(a true copy thereof) in a sealed envelope addressed

as follows:
Attorneys for Plaintiff
ENRIQUE B. ROQUE

Gregory P. Wong
ADEPT EMPLOYMENT LAW, APC
10880 Wilshire Blvd., Suite 1101
11 Los Angeles, CA 90012
Tel. [phone]
12 Fax [phone]
[e-mail]
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BY CM/ECF SYSTEM: I caused the above-referenced document(s) to be
sent by electronic transmittal to the Clerk’s Office using the CM/ECF System
for filing which generated a Notice of Electronic Filing to the CM/ECF
registrants in this case.
BY MAIL: I placed the envelope for collection and mailing, following our
ordinary business practices. I am readily familiar with the practice of
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.’s practice for collecting and
processing correspondence for mailing. On the same day that correspondence
is placed for collection and mailing, it is deposited in the ordinary course of
business with the United States Postal Service, in a sealed envelope with
postage fully prepaid.
BY MESSENGER SERVICE: I served the documents by placing them in an
envelope or package addressed to the persons at the addresses on the attached
service list and providing them to a professional messenger service for service.

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I declare that I am employed in the office of a member of the Bar of this Court

23 at whose direction the service was made. I declare under penalty of perjury under
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the laws of the United States of America that the above is true and correct.
Executed on June 2, 2017, at Costa Mesa, California.

26 Diane Vo
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Signature

Type or Print Name

~1876677.DOCX

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CERTIFICATE OF SERVICE