Armida De Castro Henriquez v. Myrna Castro O'Bara et al

Filing 12

STIPULATED PROTECTIVE ORDER AS BETWEEN PLAINTIFF AND DEFENDANT ROCKET MORTGAGE, LLC by Magistrate Judge Maria A. Audero re Stipulation for Protective Order #11 . (See document for further details). (et)

1
2
3
4
5

Gary E. Devlin (SBN 210517)
HINSHAW & CULBERTSON LLP
350 South Grand Avenue
Los Angeles, CA 90071
Telephone: [phone]
Facsimile:
310-909-8001
Attorneys for Defendant
ROCKET MORTGAGE, LLC

6
7
8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10

LOS ANGELES DIVISION

11

ARMIDA DE CASTRO HENRIQUEZ,

Case No. 2:24-CV-03151-AB-MAA

12

Plaintiff,

13

vs.

(Assigned to the Honorable André Birotte Jr.
Ctrm “7B” First Street Courthouse)

14

MYRNA CASTRO O'BARA, an individual;
JOHN O'BARA, an individual; 1013
INVESTMENTS,
INC.,
a
California
corporation; OFRI, INC., a California
corporation; CAMBRIDGE ESCROW, INC., a
California corporation; ESCROW OFFICER
#1, an individual; ESCROW COMPANY #1, a
business entity; JULIE ROZANER, an
individual; PROSPECT MORTGAGE, LLC, a
Delaware limited liability company; LOAN
ORIGINATOR #1, an individual; DANNY
ZOLLER, an individual; NEW AMERICAN
FUNDING, LLC, a California limited liability
company; RACHNA KHANNA, an individual,
ROCKET MORTGATE, LLC, a Michigan
limited liability company; JOHN RUBEN
ZEPEDA,
an
individual;
REDIGER
INVESTMENT MORTGAGE FUND, a
California limited partnership; DENIS
REDIGER,
an
individual;
REDIGER
INVESTMENT CORPORATION, a California
corporation; TRIBUNE INVESTMENTS,
LLC, a Delaware limited liability company;
LAWYERS TITLE COMPANY, a California
corporation; YEFRY J. CALI, an individual;
BALVINDER SINGH, an individual doing
business under the fictitious business names of
Superior Tax & Executive Services and

15
16
17
18
19
20
21
22
23
24
25
26
27
28

STIPULATED PROTECTIVE ORDER AS
BETWEEN PLAINTIFF AND
DEFENDANT ROCKET MORTGAGE,
LLC

Action Filed: 04/17/2024

1
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1
2
3

Superior Tax; S. TESORO MOWRY, an
individual; KELLER WILLIAMS, Inc., a Texas
corporation; Bond Company #1, a business
entity; Bond Company #2, a business entity;
and DOES 1 through 300, inclusive,
Defendants.

4
5
6

1.

PURPOSES AND LIMITATIONS

7

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

8

private information for which special protection from public disclosure and from use for any

9

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

10

stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties

11

acknowledge that this Stipulated Protective Order does not confer blanket protections on all

12

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

13

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

14

the applicable legal principles. The parties further acknowledge, as set forth in Section 13.3 below,

15

that this Stipulated Protective Order does not entitle them to file confidential information under

16

seal; Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be

17

applied when a party seeks permission from the Court to file material under seal.

18
19

2.

GOOD CAUSE STATEMENT

20

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

21

research, development, commercial, financial, technical and/or proprietary information for which

22

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

23

this action is warranted. Such confidential and proprietary materials and information consist of,

24

among other things, confidential business or financial information, information regarding

25

confidential business practices, or other confidential research, development, or commercial

26

information (including information implicating privacy rights of third parties), information

27

otherwise generally unavailable to the public, or which may be privileged or otherwise protected

28

2
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

from disclosure under state or federal statutes, court rules, case decisions, or common law. In

2

particular, such materials include confidential contracts entered into between Defendant Rocket

3

Mortgage, LLC and other parties that are not parties to this case. Accordingly, to expedite the flow

4

of information, to facilitate the prompt resolution of disputes over confidentiality of discovery

5

materials, to adequately protect information the parties are entitled to keep confidential, to ensure

6

that the parties are permitted reasonable necessary uses of such material in preparation for and in

7

the conduct of trial, to address their handling at the end of the litigation, and to serve the ends of

8

justice, a protective order for such information is justified in this matter. It is the intent of the

9

parties that information will not be designated as confidential for tactical reasons and that nothing

10

be so designated without a good faith belief that it has been maintained in a confidential, non-

11

public manner, and there is good cause why it should not be part of the public record of this case.

12
13

3.

DEFINITIONS

14

3.1.

Action: This pending federal lawsuit.

15

3.2.

Challenging Party: A Party or Nonparty that challenges the designation of
information or items under this Stipulated Protective Order.

16
17

3.3.

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

18

generated, stored or maintained) or tangible things that qualify for protection under

19

Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

20

Statement.

21

3.4.

support staff).

22
23

3.5.

26

Designating Party: A Party or Nonparty that designates information or items that it
produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

24
25

Counsel: Outside Counsel of Record and In-House Counsel (as well as their

3.6.

Disclosure or Discovery Material: All items or information, regardless of the
medium or manner in which it is generated, stored, or maintained (including, among

27
28

3
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

other things, testimony, transcripts, and tangible things), that is produced or

2

generated in disclosures or responses to discovery in this matter.

3

3.7.

Expert: A person with specialized knowledge or experience in a matter pertinent to

4

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

5

witness or as a consultant in this Action.

6

3.8.

In-House Counsel: Attorneys who are employees of a party to this Action. In-

7

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

8

counsel.

9

3.9.

entity not named as a Party to this action.

10
11

Nonparty: Any natural person, partnership, corporation, association, or other legal

3.10.

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

12

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

13

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

14

which has appeared on behalf of that party, and includes support staff.

15

3.11.

Party: Any party to this Action, including all of its officers, directors, employees,

16

consultants, retained experts, In-House Counsel, and Outside Counsel of Record

17

(and their support staffs).

18

3.12.

Material in this Action.

19
20

Producing Party: A Party or Nonparty that produces Disclosure or Discovery

3.13.

Professional Vendors: Persons or entities that provide litigation support services

21

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

22

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

23

employees and subcontractors.

24

3.14.

“CONFIDENTIAL.”

25
26
27
28

Protected Material: Any Disclosure or Discovery Material that is designated as

3.15.

Receiving Party: A Party that receives Disclosure or Discovery Material from a
Producing Party.

4
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

4.

SCOPE
The protections conferred by this Stipulated Protective Order cover not only Protected

2
3

Material, but also (1) any information copied or extracted from Protected Material; (2) all copies,

4

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

5

or presentations by Parties or their Counsel that might reveal Protected Material. Any use of

6

Protected Material at trial shall be governed by the orders of the trial judge. This Stipulated

7

Protective Order does not govern the use of Protected Material at trial.

8
9

5.

DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this

10
11

Stipulated Protective Order shall remain in effect until a Designating Party agrees otherwise in

12

writing or a court order otherwise directs. Final disposition shall be deemed to be the later of (1)

13

dismissal of all claims and defenses in this Action, with or without prejudice; and (2) final

14

judgment herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or

15

reviews of this Action, including the time limits for filing any motions or applications for extension

16

of time pursuant to applicable law.

17
18
19

6.

DESIGNATING PROTECTED MATERIAL
6.1.

Exercise of Restraint and Care in Designating Material for Protection.

20

Each Party or Nonparty that designates information or items for protection

21

under this Stipulated Protective Order must take care to limit any such designation

22

to specific material that qualifies under the appropriate standards. The Designating

23

Party must designate for protection only those parts of material, documents, items,

24

or oral or written communications that qualify so that other portions of the material,

25

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

26

swept unjustifiably within the ambit of this Stipulated Protective Order.

27
28

Mass, indiscriminate, or routinized designations are prohibited. Designations

5
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

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

2

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

3

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

4

Party to sanctions.

5

6.2.

Manner and Timing of Designations.
Except as otherwise provided in this Stipulated Protective Order (see, e.g.,

6
7

Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure or Discovery

8

Material that qualifies for protection under this Stipulated Protective Order must be

9

clearly so designated before the material is disclosed or produced.
Designation in conformity with this Stipulated Protective Order requires the

10
11

following:

12

(a)

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

13

but excluding transcripts of depositions or other pretrial or trial

14

proceedings), that the Producing Party affix at a minimum, the legend

15

“CONFIDENTIAL” to each page that contains protected material. If only a

16

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

17

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

18

making appropriate markings in the margins).

19

A Party or Nonparty that makes original documents available for

20

inspection need not designate them for protection until after the inspecting

21

Party has indicated which documents it would like copied and produced.

22

During the inspection and before the designation, all of the material made

23

available for inspection shall be deemed “CONFIDENTIAL.” After the

24

inspecting Party has identified the documents it wants copied and produced,

25

the Producing Party must determine which documents, or portions thereof,

26

qualify for protection under this Stipulated Protective Order. Then, before

27

producing the specified documents, the Producing Party must affix the

28

6
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

legend “CONFIDENTIAL” to each page that contains Protected Material. If

2

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

3

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

4

by making appropriate markings in the margins).
(b)

5

For testimony given in depositions, that the Designating Party identify the

6

Disclosure or Discovery Material on the record, before the close of the

7

deposition, all protected testimony.
(c)

8

For information produced in nondocumentary form, and for any other
tangible items, that the Producing Party affix in a prominent place on the

9
10

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

11

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

12

warrants protection, the Producing Party, to the extent practicable, shall

13

identify the protected portion(s).
6.3.

14

Inadvertent Failure to Designate.
If timely corrected, an inadvertent failure to designate qualified information

15
16

or items does not, standing alone, waive the Designating Party’s right to secure

17

protection under this Stipulated Protective Order for such material. Upon timely

18

correction of a designation, the Receiving Party must make reasonable efforts to

19

assure that the material is treated in accordance with the provisions of this

20

Stipulated Protective Order.

21
22
23

7.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
7.1.

Any Party or Nonparty may challenge a designation of confidentiality at any

24

time that is consistent with the Court’s Scheduling Order.

25
26
27
28

Timing of Challenges.

7.2.

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

7
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

shall comply with Local Rule 37.1 et seq., and with Section 4 of Judge Audero’s

2

Procedures (“Mandatory Telephonic Conference for Discovery Disputes”).1
7.3.

3

Burden of Persuasion.

4

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

5

Designating Party. Frivolous challenges, and those made for an improper purpose

6

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

7

expose the Challenging Party to sanctions. Unless the Designating Party has waived

8

or withdrawn the confidentiality designation, all parties shall continue to afford the

9

material in question the level of protection to which it is entitled under the
Producing Party’s designation until the Court rules on the challenge.

10
11
12

8.

ACCESS TO AND USE OF PROTECTED MATERIALS
8.1.

13

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

14
15

by another Party or by a Nonparty in connection with this Action only for

16

prosecuting, defending, or attempting to settle this Action. Such Protected Material

17

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

18

described in this Stipulated Protective Order. When the Action reaches a final

19

disposition, a Receiving Party must comply with the provisions of Section 14 below.
Protected Material must be stored and maintained by a Receiving Party at a

20
21

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

22

authorized under this Stipulated Protective Order.
8.2.

23

Disclosure of “CONFIDENTIAL” Information or Items.
Unless otherwise ordered by the Court or permitted in writing by the

24

Designating Party, a Receiving Party may disclose any information or item

25
26
27
28

1

Judge Audero’s Procedures are available at

https://www.cacd.uscourts.gov/honorable-maria-audero.

8

STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

designated “CONFIDENTIAL” only to:

2

(a)

The Receiving Party’s Outside Counsel of Record, as well as employees of

3

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

4

disclose the information for this Action;

5

(b)

Receiving Party to whom disclosure is reasonably necessary for this Action;

6
7

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

(c)

Experts of the Receiving Party to whom disclosure is reasonably necessary

8

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

9

to Be Bound” (Exhibit A);

10

(d)

The Court and its personnel;

11

(e)

Court reporters and their staff;

12

(f)

Professional jury or trial consultants, mock jurors, and Professional Vendors

13

to whom disclosure is reasonably necessary or this Action and who have

14

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

15

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

16

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

17

(g)

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

18

Action to whom disclosure is reasonably necessary provided: (i) the

19

deposing party requests that the witness sign the “Acknowledgment and

20

Agreement to Be Bound” (Exhibit A); and (ii) the witness will not be

21

permitted to keep any confidential information unless they sign the

22

“Acknowledgment and Agreement to Be Bound,” unless otherwise agreed

23

by the Designating Party or ordered by the Court. Pages of transcribed

24

deposition testimony or exhibits to depositions that reveal Protected Material

25

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

26

anyone except as permitted under this Stipulated Protective Order; and (i)

27

Any mediator or settlement officer, and their supporting personnel, mutually

28

9
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

agreed upon by any of the parties engaged in settlement discussions.

1
2
3

9.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER

4

LITIGATION

5

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

6

disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party

7

must:
(a)

8

Promptly notify in writing the Designating Party. Such notification shall include a
copy of the subpoena or court order;

9
(b)

10

Promptly notify in writing the party who caused the subpoena or order to issue in

11

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

12

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

13

of this Stipulated Protective Order; and
(c)

14

Cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Protected Material may be affected.

15
16
17

10.

A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN

18

THIS LITIGATION

19

10.1. Application.

20

The terms of this Stipulated Protective Order are applicable to information

21

produced by a Nonparty in this Action and designated as “CONFIDENTIAL.” Such

22

information produced by Nonparties in connection with this litigation is protected

23

by the remedies and relief provided by this Stipulated Protective Order. Nothing in

24

these provisions should be construed as prohibiting a Nonparty from seeking

25

additional protections.

26
27
28

10.2. Notification.
In the event that a Party is required, by a valid discovery request, to produce

10
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

a Nonparty’s confidential information in its possession, and the Party is subject to

2

an agreement with the Nonparty not to produce the Nonparty’s confidential

3

information, then the Party shall:

4

(a)

Promptly notify in writing the Requesting Party and the Nonparty that some

5

or all of the information requested is subject to a confidentiality agreement

6

with a Nonparty;
(b)

7

Promptly provide the Nonparty with a copy of the Stipulated Protective

8

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

9

specific description of the information requested; and
(c)

10

Make the information requested available for inspection by the Nonparty, if
requested.

11
10.3.

12

Conditions of Production.
If the Nonparty fails to seek a protective order from this Court within

13
14

fourteen (14) days after receiving the notice and accompanying information, the

15

Receiving Party may produce the Nonparty’s confidential information responsive to

16

the discovery request. If the Nonparty timely seeks a protective order, the Receiving

17

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

18

the confidentiality agreement with the Nonparty before a determination by the

19

Court. Absent a court order to the contrary, the Nonparty shall bear the burden and

20

expense of seeking protection in this Court of its Protected Material.

21
22
23

11.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

24

Material to any person or in any circumstance not authorized under this Stipulated Protective

25

Order, the Receiving Party immediately must (1) notify in writing the Designating Party of the

26

unauthorized disclosures, (2) use its best efforts to retrieve all unauthorized copies of the Protected

27

Material, (3) inform the person or persons to whom unauthorized disclosures were made of all the

28

11
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

terms of this Stipulated Protective Order, and (4) request such person or persons to execute the

2

“Acknowledgment and Agreement to be Bound” (Exhibit A).

3
4

12.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

5

PROTECTED MATERIAL

6

When a Producing Party gives notice to Receiving Parties that certain inadvertently

7

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

8

Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision

9

is not intended to modify whatever procedure may be established in an e-discovery order that

10

provides for production without prior privilege review. Pursuant to Federal Rule of Evidence

11

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

12

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

13

the parties may incorporate their agreement in the Stipulated Protective Order submitted to the

14

Court.

15
16
17

13.

MISCELLANEOUS
13.1.

Nothing in this Stipulated Protective Order abridges the right of any person

18

to seek its modification by the Court in the future.

19
20

Right to Further Relief.

13.2. Right to Assert Other Objections.
By stipulating to the entry of this Stipulated Protective Order, no Party

21
22

waives any right it otherwise would have to object to disclosing or producing any

23

information or item on any ground not addressed in this Stipulated Protective Order.

24

Similarly, no Party waives any right to object on any ground to use in evidence of

25

any of the material covered by this Stipulated Protective Order.

26
27
28

13.3.

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

12
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

with Local Rule 79-5. Protected Material may only be filed under seal pursuant to a

2

court order authorizing the sealing of the specific Protected Material at issue. If a

3

Party's request to file Protected Material under seal is denied by the Court, then the

4

Receiving Party may file the information in the public record unless otherwise

5

instructed by the Court.

6
7

14.

FINAL DISPOSITION

8

After the final disposition of this Action, within sixty (60) days of a written request by the

9

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

10

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

11

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

12

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

13

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

14

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

15

all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party

16

has not retained any copies, abstracts, compilations, summaries or any other format reproducing or

17

capturing any of the Protected Material. Notwithstanding this provision, Counsel is entitled to

18

retain an archival copy of all pleadings; motion papers; trial, deposition, and hearing transcripts;

19

legal memoranda; correspondence; deposition and trial exhibits; expert reports; attorney work

20

product; and consultant and expert work product, even if such materials contain Protected Material.

21

Any such archival copies that contain or constitute Protected Material remain subject to this

22

Stipulated Protective Order as set forth in Section 5.

23
24
25
26

15.

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

including, without limitation, contempt proceedings and/or monetary sanctions.

27
28

13
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2
3

Dated:

May 8, 2024

/s/Jeffery A. Slott
Attorney(s) for Plaintiff(s)

Dated:

May 8, 2024

/s/Gary E. Devlin
Attorney(s) for Defendant(s)

4
5
6
7
8

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Dated:

May 8, 2024
Maria A. Audero
United States Magistrate Judge

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

14
STIPULATED PROTECTIVE ORDER
93260\321114718.v1

1

CERTIFICATE OF SERVICE

2

Armida De Casto Henriquez v. Rocket Mortgage, LLC, et al.
USDC Case No. 2:24-CV-03151-AB-MAA

3

4 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES:
5
6
7

I am a citizen of the United States and employed in Los Angeles, California, at the office of
a member of the bar of this Court at whose direction this service was made. I am over the age of
18 and not a party to the within actions; my business address is 350 S. Grand Avenue, Suite 3600,
Los Angeles, CA 90071.
On May 8, 2024, I served the document(s) entitled, STIPULATED PROTECTIVE

8 ORDER, on the interested parties in this action by placing trust copies thereof enclosed in a sealed
9
10
11
12

envelope(s) addressed as stated below:

VIA CM/ECF
Jeffrey A. Slott
LAW OFFICES OF JEFFREY A. SLOTT
15760 Ventura Boulevard, Suite 700
Encino, CA 91436
Email: [e-mail]

VIA U.S. MAIL
John R. Zepeda
1050 Woodward Avenue
Detroit, MI 48226

13
14

Attorneys for Plaintiff ARMIDA De
CASTRO HENRIQUEZ

15
(BY MAIL):

I deposited such envelope in the mail at Los Angeles, California with

16 postage fully prepaid. I am readily familiar with this firm’s practice of collection and processing
correspondence for mailing. Under that practice it would be placed for collection and mailing, and
17 deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Los
Angeles, California, in the ordinary course of business. I am aware that on motion of party served,

18 service is presumed invalid if postal cancellation date or postage meter date is more than 1 day
after date of deposit for mailing in affidavit.
19
(VIA OVERNIGHT MAIL):

I deposit such envelope to be placed for collection and

20 handling via UPS following our ordinary business practices. I am readily familiar with this
business’ practice for collecting and processing correspondence for UPS. On the same day that
21 material is placed for collection, it is picked by UPS at Los Angeles, California.
22
23

(BY ELECTRONIC MAIL):
addresses as indicated below.
(BY CM/ECF SERVICE):

By transmitting a true copy thereof to the electronic mail
I caused such document(s) to be delivered electronically via

24 CM/ECF as noted herein.
25
I declare under penalty of perjury under the laws of the United States that the above true
26
27
28

and correct and was executed on May 8, 2024, at Los Angeles, California.
/s/Robin Mojica
Robin Mojica

1
CERTIFICATE OF SERVICE
93260\321114718.v1