City of Torrance v. Hi-Shear Corporation

Filing 394

PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order. #393 *NOTE: CHANGES MADE BY THE COURT.* (es)

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David L. Evans (State Bar No. 155634)
[e-mail]
Thomas P. Schmidt (State Bar No. 157831)
[e-mail]
Jeff Poole (State Bar No. 291783)
[e-mail]
NOTE: CHANGES MADE BY THE COURT
HAMRICK & EVANS, LLP
2600 West Olive Avenue, Suite 1020
Burbank, California 91505
Telephone No.: [phone]
Fax No.: [phone]
Attorneys for Defendant, CounterClaimant, Third-Party Plaintiff and
Third-Party Defendant
HI-SHEAR CORPORATION
UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CITY OF TORRANCE,
v.

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Plaintiff,

PROTECTIVE ORDER

HI-SHEAR CORPORATION, a Delaware
corporation, d/b/a LISI AEROSPACE,
Defendant.

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Case No.: 2:17-cv-07732-DSF-JPR
(Case assigned to Hon. Dale S. Fischer)

HI-SHEAR CORPORATION,
v.

Counter-Claimant,

CITY OF TORRANCE,

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Counter-Defendant.

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Complaint Filed: 10/23/2017

HI-SHEAR CORPORATION,
v.

Trial Date:

Third-Party Plaintiff,

SHERIDAN-GRAY, INC., a California
corporation et al.,
Third-Party Defendants.
AND RELATED COUNTERCLAIMS.
-1[PROPOSED] PROTECTIVE ORDER

None Set

1. A. PURPOSES AND LIMITATIONS 1

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As the parties have represented that discovery in this action is likely to

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involve production of confidential, proprietary, or private information for which

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special protection from public disclosure and from use for any purpose other than

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prosecuting this litigation may be warranted, this Court enters the following

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Protective Order. This Order does not confer blanket protections on all disclosures

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or responses to discovery. The protection it affords from public disclosure and use

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extends only to the limited information or items that are entitled to confidential

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treatment under the applicable legal principles. Further, as set forth in Section 12.3,
below, this Protective Order does not entitle the parties to file confidential

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information under seal. Rather, when the parties seek permission from the court to

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file material under seal, the parties must comply with Civil Local Rule 79-5 and

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with any pertinent orders of the assigned District Judge and Magistrate Judge.

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B. GOOD CAUSE STATEMENT

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In light of the nature of the claims and allegations in this case and the parties’

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representations that discovery in this case will involve the production of confidential

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records, and in order to expedite the flow of information, to facilitate the prompt

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resolution of disputes over confidentiality of discovery materials, to adequately

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

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parties are permitted reasonable necessary uses of such material in connection with

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this action, to address their handling of such material at the end of the litigation, and

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to serve the ends of justice, a protective order for such information is justified in this

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matter. The parties shall not designate any information/documents as confidential

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without a good faith belief that such information/documents have been maintained

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protective order.

This [Proposed] Protective Order is based on Magistrate Judge Chooljian’s model
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in a confidential, non-public manner, and that there is good cause or a compelling

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

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2.

DEFINITIONS

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2.1

Action: The instant action: City of Torrance v. Hi-Shear Corporation

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et al. and Related Cross and Third Party Actions, case number 2:17-cv-07732-DSF-

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JPR, in the United States District Court, Central District of California.

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2.2

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

designation of information or items under this Order.

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2.3

“CONFIDENTIAL” Information or Items: information (regardless of

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

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

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the Good Cause Statement.

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2.4

“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”

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Information or Items: extremely sensitive “CONFIDENTIAL” Information or

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Items, the disclosure of which to another Party or Non-Party would create a

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substantial risk of serious harm that could not be avoided by less restrictive means.

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2.5

Counsel: Outside Counsel of Record, House Counsel, and other

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attorneys working with or at the request of Counsel of Record, irrespective of

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whether such attorneys are counsel of record (as well as their support staff).

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2.6

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” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

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ONLY.”

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2.7

Disclosure or Discovery Material: all items or information, regardless

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

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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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-3[PROPOSED] PROTECTIVE ORDER

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2.8

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

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an expert witness or as a consultant in this Action.

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2.9

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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2.10 Non-Party: any natural person, partnership, limited liability company,
corporation, association, or other legal entity not named as a Party to this action.

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2.11 Outside Counsel of Record: attorneys who are not employees of a
party to this Action but are retained to represent or advise a party to this Action and

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have appeared in this Action on behalf of that party or are affiliated with, or working

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at the request of, a law firm which has appeared on behalf of that party, and includes

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support staff.

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2.12 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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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

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2.14 Professional Vendors: persons or entities that provide litigation

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support 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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2.15 Protected Material: any Disclosure or Discovery Material that is

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designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY.”

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2.16 Receiving Party: a Party that receives Disclosure or Discovery

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Material from a Producing Party.

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-4[PROPOSED] PROTECTIVE ORDER

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3.

SCOPE

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The protections conferred by this Order cover not only Protected Material (as

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

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

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and (3) any deposition testimony, conversations, or presentations by Parties or their

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Counsel that might reveal Protected Material, other than during a court hearing or at

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trial.

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Any use of Protected Material during a court hearing or at trial shall be

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governed by the orders of the presiding judge. This Order does not govern the use

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of Protected Material during a court hearing or at trial.

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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

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

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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including the time limits for filing any motions or applications for extension of time

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pursuant to applicable law.

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5.

DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

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

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

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that qualifies under the appropriate standards. The Designating Party must designate

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

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

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items, or communications for which protection is not warranted are not swept

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unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Party to sanctions.

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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, then Designating Party must

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

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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), that the Producing Party affix at a

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minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY” to each page that contains protected material. If

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only a portion or portions of the material on a page qualify for protection, the

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Producing Party also must clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins).

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

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

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which documents 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

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

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documents, or portions thereof, qualify for protection under this Order. Then,
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before producing the specified documents, the Producing Party must affix the

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“CONFIDENTIAL”, or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

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ONLY” legend to each page that contains Protected Material. If only a portion or

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portions of the material on a page qualify for protection, the Producing Party also

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

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in the margins).

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(b) for testimony given in depositions that the Designating Party identifies on
the record, before the close of the deposition as protected testimony.
(c) for information produced in some form other than documentary and for
any 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 is stored the legend

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

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ONLY.” If only a portion or portions of the information warrant protection, the

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Producing Party, to the extent practicable, shall identify the 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

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the 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.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

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

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

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Scheduling Order.

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37-1 et seq.
6.3

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

the Designating Party. Frivolous challenges, and those made for an improper
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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties shall

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

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entitled under the Producing Party’s designation until the Court rules on the

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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

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

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

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

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conditions described in this Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of Section 13 below.

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

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

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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

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“CONFIDENTIAL” only to:

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

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

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to disclose the information for this Action;

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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 Action;

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

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disclosure is reasonably necessary for this Action 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) private court reporters and their staff to whom disclosure is reasonably

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necessary for this Action and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A);

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

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

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

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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the

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

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requests that the witness sign the “Acknowledgment and Agreement to Be Bound”

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(Exhibit A); and (2) they will not be permitted to keep any confidential information

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unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),

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unless otherwise agreed by the Designating Party or ordered by the court. Pages of

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transcribed deposition testimony or exhibits to depositions that reveal Protected

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Material may be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Protective Order;

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

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

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appointed by the Court;

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(j) the Receiving Party’s insurance carriers, including Counsel for a Receiving

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Party’s insurance carriers, to whom it is reasonably necessary to disclose the

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information for this Action; and

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(k)

The United States may use documents marked “CONFIDENTIAL” for

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law enforcement purposes and may, notwithstanding any other provision of this

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agreement, disclose such information to law enforcement agencies.

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7.3

Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

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ONLY” Information or Items. Unless otherwise ordered by the court or permitted in

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writing by the Designating Party, a Receiving Party may disclose any information or

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item designated “HIGHLY CONFIDENTIAL” only to:

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

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

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to disclose the information for this Action;

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

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

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(c) the court and its personnel;

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(d) private court reporters and their staff to whom disclosure is reasonably

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necessary for this Action and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A);

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

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

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

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(f) 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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(g) any mediator or settlement officer, and their supporting personnel,

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

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appointed by the Court; and

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(h)

The United States may use documents marked “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” for law enforcement purposes

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and may, notwithstanding any other provision of this agreement, disclose such

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information to law enforcement agencies.

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8.

DOCUMENTS REQUESTED OR DEMANDED BY NON-PARTIES
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If a Party is served with a subpoena, discovery, or a court order issued in

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other litigation that compels disclosure of any information or items designated in

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this Action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY,” that Party must:

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

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include a copy of the subpoena, discovery, or court order unless prohibited by law;

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(b) promptly notify in writing the party who caused the subpoena, discovery,

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

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subpoena, discovery, or order is subject to this Protective Order. Such notification

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shall include a copy of this Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with

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the subpoena, discovery, or court order shall not produce any information

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designated in this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --

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ATTORNEYS’ EYES ONLY” before a determination by the court from which the

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subpoena, discovery, or order issued, unless the Party has obtained the Designating

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Party’s permission, or unless otherwise required by the law or court order. The

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

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

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

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directive from another court.

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(d)

If the United States is served with a request under the Freedom of

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Information Act (“FOIA”), 5 U.S.C. § 552, or the City of Torrance is served with a

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request under the California Public Records Act (“CPRA”), California Government

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Code § 6250 et seq., that seeks documents, ESI, or other material designated as

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Protected Information by another Producing Party, the United States or City of

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Torrance, as applicable, must, within ten days of determining that the request seeks
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Protected Information:

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(i)

notify the Producing Party and provide a copy of the request; and

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(ii)

inform the person responsible for the FOIA or CPRA request of this

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Protective Order and provide them with copy of this Protective Order.
(e)

The United States or City of Torrance, as applicable, shall not produce

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Protected Information in response to any FOIA or CPRA request except in

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compliance with: (i) this Protective Order (e.g., with the consent of the Producing

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Party), (ii) a directive of this Court removing the designation as Protected

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Information, or (iii) a lawful directive of another court.
9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a Non-

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Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such information produced by

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Non-Parties in connection with this litigation is protected by the remedies and relief

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provided by this Order. Nothing in these provisions should be construed as

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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 confidentiality

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agreement with a Non-Party;

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

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

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description of the information requested; and
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(3) make the information requested available for inspection by the
Non-Party, if requested.

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(c) If a Non-Party represented by counsel fails to commence the process

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called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the

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notice and accompanying information or fails contemporaneously to notify the

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Receiving Party that it has done so, the Receiving Party may produce the Non-

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Party’s confidential information responsive to the discovery request. If an

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unrepresented Non-Party fails to seek a protective order from this court within 14

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days of receiving the notice and accompanying information, the Receiving Party
may produce the Non-Party’s confidential information responsive to the discovery

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

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

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

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unless otherwise required by the law or court order. Absent a court order to the

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contrary, the Non-Party shall bear the burden and expense of seeking protection in

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this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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whom unauthorized disclosures were made of all the terms of this Order, and (d)

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request such person or persons to execute the “Acknowledgment and Agreement to

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Be Bound” (Exhibit A).

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL

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

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procedure may be established in an e-discovery order that provides for production

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without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

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(e), insofar as the parties reach an agreement on the effect of disclosure of a

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communication or information covered by the attorney-client privilege or work

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product protection, the parties may incorporate their agreement into this Protective

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Order provided the Court so allows.
12.

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

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MISCELLANEOUS

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

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12.2 Right to Assert Other Objections. No Party waives any right it

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otherwise would have to object to disclosing or producing any information or item

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on any ground not addressed in this Protective Order. Similarly, no Party waives

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any right to object on any ground to use in evidence of any of the material covered

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by this Protective Order.

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

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Protected Material must comply with Civil Local Rule 79-5 and with any pertinent

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orders of the assigned District Judge and Magistrate Judge. Protected Material may

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

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specific Protected Material at issue. If a Party’s request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information

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in the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

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

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

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all Protected Material to the Producing Party or destroy such material. As used in
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this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

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summaries, and any other format reproducing or capturing any of the Protected

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Material. Whether the Protected Material is returned or destroyed, the Receiving

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Party must submit a written certification to the Producing Party (and, if not the same

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person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

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(by category, where appropriate) all the Protected Material that was returned or

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destroyed and (2) affirms that the Receiving Party has not retained any copies,

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abstracts, compilations, summaries or any other format reproducing or capturing any

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of the Protected Material. Notwithstanding this provision, Counsel are entitled to
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

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reports, attorney work product, and consultant and expert work product, even if such

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

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constitute Protected Material remain subject to this Protective Order as set forth in

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Section 4.

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

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measures including, without limitation, contempt proceedings and/or monetary

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sanctions.

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IT IS SO ORDERED.
DATED: January 6, 2021

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_________________________
Honorable Jean P. Rosenbluth
United States Magistrate Judge

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-15[PROPOSED] PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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_________________ [print or type full address], declare under penalty of perjury

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

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

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_________________________ in the case of City of Torrance v. Hi-Shear

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Corporation et al. and Related Cross and Third Party Actions, case number 2:17-

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cv-07732-DSF-JPR, in the United States District Court, Central District of

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HAMRICK & EVANS, LLP

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California.

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Protective Order and I understand and acknowledge that failure to so comply could

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expose me to sanctions and punishment in the nature of contempt. I solemnly

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promise that I will not disclose in any manner any information or item that is subject

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

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provisions of this Order.

_____________________________

[print

or

type

full

name],

of

I agree to comply with and to be bound by all the terms of this

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

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this action. I hereby appoint __________________________ [print or type full

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name] of _______________________________________ [print or type full address

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

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with this action or any proceedings related to enforcement of this Protective Order.

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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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-16[PROPOSED] PROTECTIVE ORDER

CERTIFICATE OF SERVICE

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I certify and state that I am now and at all times herein mentioned was, a
citizen of the United States, over the age of eighteen (18) years, a resident of the
County of Los Angeles, and not a party to the within action or cause. My business
address is Hamrick & Evans, LLP, 2600 West Olive Avenue, Suite 1020, Burbank,
California 91505.
I hereby certify that I am employed in the office of a member of the bar of
this court at whose direction the service was made.
I further certify that on January 5, 2021, I caused to be served the copies of
the attached:
[PROPOSED] PROTECTIVE ORDER

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on the parties in said action as follows:


HAMRICK & EVANS, LLP

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

BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically
filed the document(s) with the Clerk of the Court by using the CM/ECF
system. Participants in the case who are registered CM/ECF users will be
served by the CM/ECF system. Participants in the case who are not
registered CM/ECF users will be serve by mail or by any other means
permitted by the court rules.
(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.
Executed on January 5, 2021, at Burbank, California.

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/s/ Heather Martindale
Heather Martindale

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-17-

[PROPOSED] PROTECTIVE ORDER