Luis Morales-Garcia et al v. Higuera Farms, Inc. et al

Filing 54

JOINT STIPULATION AND PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth: re Stipulation for Protective Order 52 . (sbou)

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Michael C. Saqui, Esq., SBN: 147853
Jennifer M. Schermerhorn, Esq., SBN: 225070
Anthony C. Oceguera, Esq., SBN: 259117
Gregory L. Blueford, Esq., SBN: 302628
Rebecca A. Hause-Schultz, Esq., SBN: 292252
DOWLING AARON INCORPORATED
1410 Rocky Ridge Drive, Suite 330
Roseville, California 95661
NOTE: CHANGES MADE BY THE COURT
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants, HIGUERA FARMS, INC., LA CUESTA FARMING
COMPANY, INC. and BIG F COMPANY, INC.
Dawson Morton, SBN 320811
R. Erandi Zamora, SBN 281929
Emma Irene Scott, SBN 314021
CALIFORNIA RURAL LEGAL ASSISTANCE FOUNDATION
2210 K Street, Suite 201
Sacramento, CA 95816
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
NOTE: CHANGES MADE BY THE COURT
[e-mail]
Randy Renick, SBN 179652
Cornelia Dai, SBN 207435
HADSELL STORMER & RENICK, LLP
128 North Fair Oaks Avenue, Suite 204
Pasadena, California 91103-3645
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
CAPTION CONTINUED ON THE NEXT PAGE
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Joint Stipulation and Protective Order

Case No. 2:18-cv-05118-SVW-JPR

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IN THE UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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LUIS MORALES-GARCIA, BENITO
PEREZ-REYES, CESAR JIMENEZMENDOZA, GABRIELA RENDONVASQUEZ, and JUANA VELASCOTORRES, on behalf of themselves and
all others similarly situated,

JOINT STIPULATION AND
PROTECTIVE ORDER

Plaintiffs,

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Case No. 2:18-cv-05118-SVW-JPR
CLASS ACTION

Complaint Filed: June 8, 2018
Trial: July 9, 2019

v.

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HIGUERA FARMS, INC., LA
CUESTA FARMING COMPANY,
INC., BIG F COMPANY, INC., and
DOES 1-10,
Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiffs LUIS

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MORALES-GARCIA,

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MENDOZA, GABRIELA RENDON-VASQUEZ, and JUANA VELASCO-

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TORRES (“Plaintiffs”) and Defendants HIGUERA FARMS, INC., LA CUESTA

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FARMING COMPANY, INC., and BIG F COMPANY, INC. (“Defendants”) to

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enter this Stipulated Protective Order as follows:

BENITO

PEREZ-REYES,

CESAR

JIMENEZ-

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1.

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Disclosure and discovery activity in this action are likely to involve

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

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

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prosecuting this litigation may be warranted. Accordingly, the parties hereby

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stipulate to and petition the court to enter the following Stipulated Protective Order.

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The parties acknowledge that this Order does not confer blanket protections on all

PURPOSES AND LIMITATIONS

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disclosures or responses to discovery and that the protection it affords from public

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disclosure and use extends only to the limited information or items that are entitled

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to confidential treatment under the applicable legal principles. The parties further

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acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

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Order does not entitle them to file confidential information under seal; Civil Local

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Rule 79-5 sets forth the procedures that must be followed and the standards that

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will be applied when a party seeks permission from the court to file material under

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seal.

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2.
2.1

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DEFINITIONS

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

2.2

“CONFIDENTIAL” Information or Items: information (regardless of how it

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

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protection under Federal Rule of Civil Procedure 26(c).

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2.3

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Counsel (without qualifier): Outside Counsel of Record and House Counsel
(as well as their support staff).

2.4

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

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that it produces in disclosures or in responses to discovery as

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“CONFIDENTIAL.”

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2.5

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

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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

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produced or generated in disclosures or responses to discovery in this matter.

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2.6

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

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

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serve as an expert witness or as a consultant in this action.

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2.7

House Counsel: attorneys who are employees of a party to this action. House
Counsel does not include Outside Counsel of Record or any other outside
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counsel.
2.8

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

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

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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 a

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law firm which has appeared on behalf of that party.

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

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

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(and their support staffs).
2.11 Producing Party:

a Party or Non-Party that produces Disclosure or

Discovery Material in this action.

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2.12 Professional Vendors: persons or entities that provide litigation support

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

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

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medium) and their employees and subcontractors.

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2.13 Protected Material: any Disclosure or Discovery Material that is designated
as “CONFIDENTIAL.”
2.14 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

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The protections conferred by this Stipulation and Order cover not only

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

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

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material

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However, the protections conferred by this Stipulation and Order do not cover the

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following information: (a) any information that is in the public domain at the time

SCOPE

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

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disclosure to a Receiving Party as a result of publication not involving a violation

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of this Order, including becoming part of the public record through trial or

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otherwise; and (b) any information known to the Receiving Party prior to the

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disclosure or obtained by the Receiving Party after the disclosure from a source

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who obtained the information lawfully and under no obligation of confidentiality to

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the Designating Party. Any use of Protected Material at trial shall be governed by a

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separate agreement or order.

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4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees

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otherwise in writing or a court order otherwise directs. Final disposition shall be

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

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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.
5.1

DESIGNATING PROTECTED MATERIAL

Exercise of Restraint and Care in Designating Material for Protection. Each

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

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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

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designate for protection only those parts of material, documents, items, or

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oral or written communications that qualify – so that other portions of the

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material, documents, items, or communications for which protection is not

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warranted are not swept unjustifiably within the ambit of this Order. Mass,

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indiscriminate, or routinized designations are prohibited. Designations that

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are shown to be clearly unjustified or that have been made for an improper
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purpose (e.g., to unnecessarily encumber or retard the case development

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process or to impose unnecessary expenses and burdens on other parties)

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expose the Designating Party to sanctions. If it comes to a Designating

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Party’s attention that information or items that it designated for protection do

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not qualify for protection, that Designating Party must promptly notify all

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other Parties that it is withdrawing the mistaken designation.

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Manner and Timing of Designations. Except as otherwise provided in this

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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

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protection under this Order must be clearly so designated before the material

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is disclosed or produced.

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Designation in conformity with this Order requires:

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

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

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

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protected material. If only a portion or portions of the material on a page qualifies

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for protection, the Producing Party also must clearly identify the protected

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portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-

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Party that makes original documents or materials available for inspection need not

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designate them for protection until after the inspecting Party has indicated which

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material it would like copied and produced. During the inspection and before the

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

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

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

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

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

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

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of the material on a page qualifies for protection, the Producing Party also must
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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 deposition or in other discovery-related

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

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the deposition, hearing, or other proceeding, all protected testimony.

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

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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 or item is stored the

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

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

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protected portion(s).

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

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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

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material. Upon timely correction of a designation, the Receiving Party must

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make reasonable efforts to assure that the material is treated in accordance

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with the provisions of this Order.

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6.

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6.1

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

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

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Party’s confidentiality designation is necessary to avoid foreseeable,

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substantial unfairness, unnecessary economic burdens, or a significant

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disruption or delay of the litigation, a Party does not waive its right to

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challenge a confidentiality designation by electing not to mount a challenge

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promptly after the original designation is disclosed.

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute resolution

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

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describing the basis for each challenge. To avoid ambiguity as to whether a
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challenge has been made, the written notice must recite that the challenge to

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confidentiality is being made in accordance with this specific paragraph of

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the Protective Order and Local Rule 37. The parties shall attempt to resolve

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each challenge in good faith and must begin the process by conferring

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directly (in voice to voice dialogue; other forms of communication are not

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sufficient) within 10 days of the date of service of notice. In conferring, the

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Challenging Party must explain the basis for its belief that the confidentiality

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designation was not proper and must give the Designating Party an

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opportunity to review the designated material, to reconsider the

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circumstances, and, if no change in designation is offered, to explain the

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basis for the chosen designation. A Challenging Party may proceed to the

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next stage of the challenge process only if it has engaged in this meet and

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confer process first or establishes that the Designating Party is unwilling to

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participate in the meet and confer process in a timely manner.

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6.3

Judicial Intervention. If the Parties cannot resolve a challenge without court

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intervention, the Designating Party shall file and serve a motion to retain

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confidentiality under Civil Local Rule 37 (and in compliance with Civil

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Local Rule 79-5, if applicable) within 21 days of the initial notice of

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challenge or within 14 days of the parties agreeing that the meet and confer

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process will not resolve their dispute, whichever is earlier. Each such motion

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must be accompanied by a competent declaration affirming that the movant

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has complied with the meet and confer requirements imposed in the

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preceding paragraph and Local Rule 37. Failure by the Designating Party to

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make such a motion including the required declaration within 21 days (or 14

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days, if applicable) shall automatically waive the confidentiality designation

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for each challenged designation. In addition, the Challenging Party may file a

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motion challenging a confidentiality designation at any time consistent with

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the court’s scheduling order if there is good cause for doing so, including a
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challenge to the designation of a deposition transcript or any portions

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thereof. Any motion brought pursuant to this provision must be accompanied

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by a competent declaration affirming that the movant has complied with the

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meet and confer requirements imposed by the preceding paragraph and Local

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Rule 37. The burden of persuasion in any such challenge proceeding shall be

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on the Designating Party. Frivolous challenges, and those made for an

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improper purpose (e.g., to harass or impose unnecessary expenses and

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burdens on other parties) may expose the Challenging Party to sanctions.

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Unless the Designating Party has waived the confidentiality designation by

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

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shall continue to afford the material in question the level of protection to

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which it is entitled under the Producing Party’s designation until the court

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rules on the challenge.

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7.

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7.1

ACCESS TO AND USE OF PROTECTED MATERIAL

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

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

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this case only for prosecuting, defending, or attempting to settle this

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litigation. Such Protected Material may be disclosed only to the categories of

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persons and under the conditions described in this Order. When the litigation

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has been terminated, a Receiving Party must comply with the provisions of

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section 13 below (FINAL DISPOSITION). Protected Material must be stored

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and maintained by a Receiving Party at a location and in a secure manner

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that ensures that access is limited to the persons authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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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 officers, directors, and employees (including House Counsel) of the
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Joint Stipulation and Protective Order

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

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

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

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disclosure is reasonably necessary for this litigation and who have signed the

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

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(c) the court and its personnel;

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

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

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this litigation;

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

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reasonably necessary unless otherwise agreed by the Designating Party or ordered

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

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that reveal Protected Material must be separately bound by the court reporter and

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may not be disclosed to anyone except as permitted under this Stipulated Protective

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Order; and

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(f) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information.
8.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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PRODUCED IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:

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(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order unless prohibited by law;

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

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

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

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this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued

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by the Designating Party whose Protected Material may be affected. If the

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Designating Party timely seeks a protective order, the Party served with the

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

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

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

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

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

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

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to disobey a lawful directive from another court.
9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

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confidential information, then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-Party

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

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confidentiality agreement with a Non-Party;

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

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

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and a reasonably specific description of the information requested; and

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

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

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within 21 days of receiving the notice and accompanying information, the

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

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

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Receiving Party shall not produce any information in its possession or control that

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is subject to the confidentiality agreement with the Non-Party before a

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determination by the court. Absent a court order to the contrary, the Non-Party

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shall bear the burden and expense of seeking protection in this court of its Protected

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Material.

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10.

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

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disclosed Protected Material to any person or in any circumstance not authorized

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under this Stipulated Protective Order, the Receiving Party must immediately (a)

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notify in writing the Designating Party of the unauthorized disclosures, (b) use its

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best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

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the person or persons to whom unauthorized disclosures were made of all the terms

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of this Order, and (d) request such person or persons to execute the

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“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

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A.

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11.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

INADVERTENT

PRODUCTION

OF

PRIVILEGED

OR

OTHERWISE PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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protection, the obligations of the Receiving Parties are those set forth in Federal

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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

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

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production without prior privilege review. Pursuant to Federal Rule of Evidence
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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

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

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product protection, the parties may incorporate their agreement in the stipulated

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protective order submitted to the court provided the Court so allows.

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12.

MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of any
person to seek its modification by the court in the future.

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

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

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to disclosing or producing any information or item on any ground not

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addressed in this Stipulated Protective Order. Similarly, no Party waives any

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

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covered by this Protective Order.

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12.3

Filing Protected Material. Without written permission from the Designating

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Party a Party may file in the public record in this action any Protected

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Material only after proceeding pursuant to Local Rule 75-5.2.2(b) of the

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Central District of California. Protected Material may be filed in the public

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case file as set forth in Local Rule 75-5.2.2(b)(ii).

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13.

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

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

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Producing Party or destroy such material. As used in this subdivision, “all Protected

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Material” includes all copies, abstracts, compilations, summaries, and any other

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format reproducing or capturing any of the Protected Material. Whether the

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Protected Material is returned or destroyed, the Receiving Party must submit a

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written certification to the Producing Party (and, if not the same person or entity, to

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the Designating Party) by the 60 day deadline that (1) identifies (by category,

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where appropriate) all the Protected Material that was returned or destroyed and (2)

FINAL DISPOSITION

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affirms that the Receiving Party has not retained any copies, abstracts,

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compilations, summaries or any other format reproducing or capturing any of the

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Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

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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

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such 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 (DURATION).

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: February 11, 2019 CALIFORNIA RURAL LEGAL ASSISTANCE
FOUNDATION
HADSELL STORMER & RENICK, LLP

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By:

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/s/ Dawson M. Morton
Dawson M. Morton
R. Erandi Zamora
Emma Scott
Attorneys for Plaintiffs

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DATED: February 11, 2019

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By:

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DOWLING AARON INCORPORATED
/s/ Rebecca A. Hause-Schultz
Michael C. Saqui
Jennifer M. Schermerhorn
Anthony C. Oceguera
Gregory L. Blueford
Rebecca A. Hause-Schultz
Attorneys for Defendants
HIGUERA FARMS, INC., LA CUESTA
FARMING COMPANY, INC. and BIG F
COMPANY, INC.

IT IS SO ORDERED.
Dated: February 13, 2019

_____________________________
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Hon. Magistrate Judge

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ATTESTATION

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I, Rebecca A. Hause-Schultz, attest that I have obtained the concurrence of
Dawson M. Morton, counsel for Plaintiffs; for the filing of this Joint Stipulation
and Protective Order. I declare under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct.
Executed this 11th day of February, 2019, at Roseville, California.

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DOWLING AARON INCORPORATED

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By:

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/s/ Rebecca A. Hause-Schultz
Michael C. Saqui
Jennifer M. Schermerhorn
Anthony C. Oceguera
Gregory L. Blueford
Rebecca A. Hause-Schultz
Attorneys for Defendants
HIGUERA FARMS, INC., LA CUESTA
FARMING COMPANY, INC. and BIG F
COMPANY, INC.

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Joint Stipulation and Protective Order

Case No. 2:18-cv-05118-SVW-JPR

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EXHIBIT A

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CERTIFICATION REGARDING CONFIDENTIAL DISCOVERY MATERIAL

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I, the undersigned, acknowledge I received Confidential Materials in

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connection with Morales-Garcia, et al., v. Higuera Farms, Inc., et al. (Case No.

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2:18-cv-05118-SVW-JPR).

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I certify that the Confidential Materials are provided to me subject to the

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terms and restrictions of the Stipulation and Protective Order filed in this

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Proceeding. I have been given a copy of the Stipulation and Protective Order; I

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have read it, and I agree to be bound by its terms.

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I understand that Confidential Materials, as defined in the Stipulation and

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Protective Order, including any notes or other records that may be made regarding

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any such materials, shall not be Disclosed to anyone except as expressly permitted

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by the Stipulation and Protective Order. I will not copy or use, except solely for

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the purposes of this Proceeding, any Confidential Materials obtained pursuant to

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this Protective Order, except as provided therein or otherwise ordered by the Court

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in the Proceeding.

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I further understand that I am to retain all copies of all Confidential

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Materials provided to me in the Proceeding in a secure manner, and that all copies

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of such materials are to remain in my personal custody until termination of my

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participation in this Proceeding, whereupon the copies of such Materials will be

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returned to counsel who provided me with such Materials.

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I declare under penalty of perjury, under the laws of the State of California,
that the foregoing is true and correct.

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Joint Stipulation and Protective Order

Case No. 2:18-cv-05118-SVW-JPR

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Dated: _______________
_________________________________
Print Name

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_________________________________
Signature

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Joint Stipulation and Protective Order

Case No. 2:18-cv-05118-SVW-JPR

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PROOF OF SERVICE
I am employed in the County of Placer, State of California. I am over the age of
eighteen years and not a party to the within action. My business address is 1410
Rocky Ridge Drive, Suite 330, Roseville, California 95661.
On the date set forth below, I served a copy (copies) of the following
document(s) entitled:

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JOINT STIPULATION TO AND PROTECTIVE ORDER

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to be served on the interested party(ies) or its/their attorney(s) of record in this

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action as follows:

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Attorneys for Plaintiffs
Dawson M. Morton, SBN 320811
R. Erandi Zamora, SBN 281929
Emma Irene Scott, SBN 314021
CALIFORNIA RURAL LEGAL
ASSISTANCE FOUNDATION
2210 K Street, Suite 201
Sacramento, CA 95816
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

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X

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X

Randy Renick, SBN 179652
Cornelia Dai, SBN 207435
HADSELL STORMER & RENICK, LLP
128 North Fair Oaks Avenue, Suite 204
Pasadena, California 91103-3645
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

BY ELECTRONIC FILING, I served each of the above referenced
documents by Efiling, in accordance with the rules governing the
electronic filing of documents in the United States District Court for the
Central District of California, as to the above-listed parties.
FEDERAL: I declare that I am employed in the office of a member of
the bar of this Court at whose direction the service was made. I declare
under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.

Executed on February 11, 2019, at Roseville, California.

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By:
Jeanne Rosenberg

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Joint Stipulation and Protective Order

Case No. 2:18-cv-05118-SVW-JPR