Isiah Washington v. Sierra Aluminum Company et al

Filing 43


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1 2 3 4 5 6 7 8 Lisa Bloom, Esq. (SBN: 158458) Jivaka Candappa, Esq. (SBN 225919) Alyson Decker, Esq. (SBN: 252384) THE BLOOM FIRM 20700 Ventura Blvd., Suite 301 Woodland Hills, CA 91364 Telephone: (818) 914-7314 Facsimile: (866) 852-5666 Email: Attorneys for Plaintiff ISIAH WASHINGTON 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 ISIAH WASHINGTON, an individual, 13 Plaintiff, 14 v. 15 SIERRA ALUMINUM COMPANY; 16 MANUEL HERNANDEZ, an 17 individual, GUADALUPE SANTOS SANCHEZ, an individual, and DOES 2 18 through 10, inclusive, 19 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) DISCOVERY MATTER CASE NO.: 5:16-cv-00298-DMG (SPx) STIPULATED PROTECTIVE ORDER HON. SHERI PYM Discovery Cut-Off: July 3, 2017 Pre-Trial Conference: October 10, 2017 Trial Date: November 7, 2017 20 21 22 1. INTRODUCTION 23 1.1 24 Discovery in this action is likely to involve production of confidential, PURPOSES AND LIMITATIONS 25 proprietary, or private information for which special protection from public disclosure 26 and from use for any purpose other than prosecuting this litigation may be warranted. 27 Accordingly, the parties hereby stipulate to and petition the Court to enter the 28 following Stipulated Protective Order. The parties acknowledge that this Order does 1 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 not confer blanket protections on all disclosures or responses to discovery and that the 2 protection it affords from public disclosure and use extends only to the limited 3 information or items that are entitled to confidential treatment under the applicable 4 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 5 that this Stipulated Protective Order does not entitle them to file confidential 6 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 7 followed and the standards that will be applied when a party seeks permission from the 8 court to file material under seal. 1.2 9 GOOD CAUSE STATEMENT This action is likely to involve the discovery and disclosure of private 10 11 information relating to the Plaintiff, the Defendants, various employees of Defendant 12 SIERRA ALUMINUM COMPANY (“Sierra Aluminum”), and other Third-Parties. 13 For instance, Plaintiff has served subpoenas on two Third-Party workforce 14 management companies seeking documents relating to all candidates or applicants 15 referred by such companies to Sierra Aluminum, including background checks and 16 documents identifying criminal convictions of the Third-Parties. Such documents and 17 information are protected under the privacy rights of the various Third-Parties 18 applicants and employees. See, e.g., Gehring v. Case Corp., 43 F.3d 340, 342–43 (7th 19 Cir.1994); Miller v. Federal Express Corp., 186 F.R.D. 376, 384 (W.D. Tenn. 1999). 20 Similarly, Defendant seeks the mental examination of the Plaintiff pursuant to Rule 35 21 of the Federal Rules of Civil Procedure. 22 To protect the privacy interests of both Parties and Third-Parties, to expedite the 23 flow of information, to facilitate the prompt resolution of disputes over confidentiality 24 of discovery materials, to adequately protect the confidential information the Parties 25 and Third-Parties, to ensure that the parties are permitted reasonable necessary use of 26 such material in preparation for and in the conduct of trial, to address the handling of 27 such documents at the end of the litigation, and to serve the ends of justice, a 28 protective order for such information is justified in this matter. It is the intent of the 2 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 Parties that information will not be designated as confidential for tactical reasons and 2 that nothing be so designated without a good faith belief that it has been maintained in 3 a confidential, non-public manner, and there is good cause why it should not be part of 4 the public record of this case. 5 6 2. DEFINITIONS 7 2.1 Action: This above-captioned pending federal law suit. 8 2.2 Challenging Party: a Party or Third-Party that challenges the designation 9 of information or items under this Order. 2.3 10 “CONFIDENTIAL” Information or Items: information (regardless of how 11 it is generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 13 Statement. 2.4 14 15 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 16 Designating Party: a Party or Third-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 2.6 19 Disclosure or Discovery Material: all items or information, regardless of 20 the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced or 22 generated in disclosures or responses to discovery in this matter. 2.7 23 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 25 expert witness or as a consultant in this Action. 2.8 26 House Counsel: attorneys who are employees of a Party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside 28 counsel. 3 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 2.9 1 2 Third-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a Party to 3 4 this Action but are retained to represent or advise a party to this Action and have 5 appeared in this Action on behalf of that party or are affiliated with a law firm which 6 has appeared on behalf of that party, and includes support staff 2.11 Party: any party to this Action, including all of its officers, directors, 7 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 2.12 Producing Party: a Party or Third-Party that produces Disclosure or 10 11 Discovery Materials in this Action. 2.13 Professional Vendors: persons or entities that provide litigation support 12 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 15 their employees and subcontractors. 2.14 Protected Material: any Disclosure or Discovery Material that is 16 17 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 18 19 from a Producing Party. 20 21 3. SCOPE The protections conferred by this Stipulation and Order cover not only 22 23 Protected Material (as defined above), but also (1) any information copied or extracted 24 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 25 Protected Material; and (3) any testimony, conversations, or presentations by Parties or 26 their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial 27 28 judge. This Order does not govern the use of Protected Material at trial. 4 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 4. DURATION 2 Even after final disposition of this litigation, the confidentiality obligations 3 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 4 in writing or a court order otherwise directs. Final disposition shall be deemed to be 5 the later of (1) dismissal of all claims and defenses in this Action, with or without 6 prejudice; and (2) final judgment herein after the completion and exhaustion of all 7 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 8 for filing any motions or applications for extension of time pursuant to applicable law. 9 10 5. DESIGNATING PROTECTED MATERIAL 5.1 11 Exercise of Restraint and Care in Designating Material for Protection. 12 Each Party or Third-Party that designates information or items for protection under this 13 Order must take care to limit any such designation to specific material that qualifies 14 under the appropriate standards. The Designating Party must designate for protection 15 only those parts of material, documents, items, or oral or written communications that 16 qualify so that other portions of the material, documents, items, or communications for 17 which protection is not warranted are not swept unjustifiably within the ambit of this 18 Order. Mass, indiscriminate, or routinized designations are prohibited. Designations 19 20 that are shown to be clearly unjustified or that have been made for an improper 21 purpose (e.g., to unnecessarily encumber the case development process or to impose 22 unnecessary expenses and burdens on other parties) may expose the Designating 23 Party to sanctions. If it comes to a Designating Party’s attention that information or items that it 24 25 designated for protection do not qualify for protection, which Designating Party must 26 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5.2 27 28 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 stipulated 5 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 or ordered, Disclosure or Discovery Material that qualifies for protection under this 2 Order must be clearly so designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, 5 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 6 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 7 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 8 portion or portions of the material on a page qualifies for protection, the Producing 9 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 10 markings in the margins). 11 A Party or Non-Party that makes original documents available for inspection 12 need not designate them for protection until after the inspecting Party has indicated 13 which documents it would like copied and produced. During the inspection and before 14 the designation, all of the material made available for inspection shall be deemed 15 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 16 copied and produced, the Producing Party must determine which documents, or 17 portions thereof, qualify for protection under this Order. Then, before producing the 18 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 19 each page that contains Protected Material. If only a portion or portions of the material on a page qualifies for protection, 20 21 the Producing Party also must clearly identify the protected portion(s) (e.g., by making 22 appropriate markings in the margins). (b) for testimony given in depositions that the Designating Party identify the 23 24 Disclosure or Discovery Material on the record, before the close of the deposition all 25 protected testimony. (c) for information produced in some form other than documentary and for any 26 27 other tangible items, that the Producing Party affix in a prominent place on the exterior 28 of the container or containers in which the information is stored the legend 6 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 “CONFIDENTIAL.” If only a portion or portions of the information warrants 2 protection, the Producing Party, to the extent practicable, shall identify the protected 3 portion(s). 5.3 4 Inadvertent Failures to Designate. If timely corrected, an inadvertent 5 failure to designate qualified information or items does not, standing alone, waive the 6 Designating Party’s right to secure protection under this Order for such material. Upon 7 timely correction of a designation, the Receiving Party must make reasonable efforts to 8 assure that the material is treated in accordance with the provisions of this Order. 9 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 11 Timing of Challenges. Any Party or Third-Party may challenge a 12 designation of confidentiality at any time that is consistent with the Court’s Scheduling 13 Order. 6.2 14 Meet and Confer. The Challenging Party shall initiate the dispute 15 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 et 16 seq. 6.3 17 The burden of persuasion in any such challenge proceeding shall be on the 18 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 19 to harass or impose unnecessary expenses and burdens on other parties) may expose 20 the Challenging Party to sanctions. Unless the Designating Party has waived or 21 withdrawn the confidentiality designation, all parties shall continue to afford the 22 material in question the level of protection to which it is entitled under the Producing 23 Party’s designation until the Court rules on the challenge. 24 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 26 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Third-Party in connection with this 28 Action only for prosecuting, defending, or attempting to settle this Action. Such 7 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions prescribed in this Order. When the Action has been terminated, a Receiving 3 Party must comply with the provision of section 13 below (FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a 4 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7.2 7 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 8 ordered by the court or permitted in writing by the Designating Party, a Receiving 9 Party may disclose any information or item designated “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 11 employees of said Outside Counsel of Record to whom it is reasonably necessary to 12 disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the 13 14 Receiving Party to whom disclosure is reasonably necessary for this Action; (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 15 16 is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the Court, the jury, and the Court’s personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a 23 24 custodian or other person who otherwise possessed or knew the information; (h) during their depositions, witnesses ,and attorneys for witnesses, in the 25 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 28 not be permitted to keep any confidential information unless they sign the 8 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 2 by the Designating Party or ordered by the court. Pages of transcribed deposition 3 testimony or exhibits to depositions that reveal Protected Material may be separately 4 bound by the court reporter and may not be disclosed to anyone except as permitted 5 under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 6 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 10 OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that 12 compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 14 15 include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to 16 17 issue in the other litigation that some or all of the material covered by the subpoena or 18 order is subject to this Protective Order. Such notification shall include a copy of this 19 Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by 20 21 the Designating Party whose Protected Material may be affected. If the Designating 22 Party timely seeks a protective order, the Party served with the subpoena or court order 23 shall not produce any information designated in this action as “CONFIDENTIAL” 24 before a determination by the court from which the subpoena or order issued, unless 25 the Party has obtained the Designating Party’s permission. The Designating Party shall 26 bear the burden and expense of seeking protection in that court of its confidential 27 material and nothing in these provisions should be construed as authorizing or 28 encouraging a Receiving Party in this Action to disobey a lawful directive from 9 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 another court. 2 3 9. A THIRD-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a 6 Third-Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Third Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Third-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to produce 10 11 a Third-Party’s confidential information in its possession, and the Party is subject to an 12 agreement with the Third-Party not to produce the Third-Party’s confidential 13 information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Third-Party 14 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Third-Party; (2) promptly provide the Third-Party with a copy of the Stipulated 17 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and (3) make the information requested available for inspection by the 20 21 Third-Party, if requested. (c) If the Third-Party fails to seek a protective order from this court within 22 23 14 days of receiving the notice and accompanying information, the Receiving Party 24 may produce the Third-Party’s confidential information responsive to the discovery 25 request. If the Third-Party timely seeks a protective order, the Receiving Party shall 26 not produce any information in its possession or control that is subject to the 27 confidentiality agreement with the Third-Party before a determination by the court. 28 Absent a court order to the contrary, the Third-Party shall bear the burden and expense 10 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 of seeking protection in this court of its Protected Material. 2 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 4 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 7 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 8 all unauthorized copies of the Protected Material, (c) inform the person or persons to 9 whom unauthorized disclosures were made of all the terms of this Order, and (d) 10 request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 13 11.INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other protection, 17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 19 may be established in an e-discovery order that provides for production without prior 20 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 21 parties reach an agreement on the effect of disclosure of a communication or 22 information covered by the attorney-client privilege or work product protection, the 23 parties may incorporate their agreement in the stipulated protective order submitted to 24 the court. 25 26 12. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 27 28 person to seek its modification by the Court in the future. 11 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 8 only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party's request to file Protected Material 10 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 4, within 60 14 15 days of a written request by the Designating Party, each Receiving Party must return 16 all Protected Material to the Producing Party or destroy such material. As used in this 17 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected 19 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 20 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 21 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 22 work product, and consultant and expert work product, even if such materials contain 23 Protected Material. Any such archival copies that contain or constitute Protected 24 Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). 26 27 14. Any willful violation of this Order may be punished by civil or criminal 28 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 12 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) 1 authorities, or other appropriate action at the discretion of the Court. 2 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 5 Dated: June 19, 2017 6 By:_____________________________________ 7 8 THE BLOOM FIRM Attorneys for Plaintiff Dated: June 14, 2017 9 GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP 10 By:___s/ Gary E. Scalabrini_____________ Gary E. Scalabrini Attorneys for Plaintiff 11 12 Signature Certification 13 Pursuant to Local Rule 5-4.3.4(2)(i), I attest that all other signatories listed, and 14 15 on whose behalf the filing is submitted, concur in the filing’s content and have 16 authorized the filing. 17 18 Dated: June 19, 2017 THE BLOOM FIRM 19 By:_____________________________________ 20 Attorneys for Plaintiff 21 22 23 24 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25 26 DATED: June 19, 2017 27 28 __________________________________ HON. SHERI PYM United States Magistrate Judge 13 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 I, ____________________________________________________ [full name], 4 of _______________________________________________________ [full address], 5 6 7 8 9 declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the United States District Court for the Central District of California on [date] in the case of Washington v. Sierra Aluminum Company, et al., United States District Court Case No. 5:16-cv-00298-DMG (SPx) . I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the provisions 14 of this Order. I further agree to submit to the jurisdiction of the United States District Court for 15 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________________ 19 [full name] of _________________________________________________________ 20 [full address and telephone number] as my California agent for service of process in 21 22 connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. 23 24 25 26 Date: _________________ City and State where signed: _________________________________ Printed name: _____________________________________________ Signature: _________________________________________________ 27 28 14 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX) CERTIFICATE OF SERVICE 1 2 I hereby certify that on June 15, 2017, I electronically filed STIPULATED 3 4 5 PROTECTIVE ORDER; and this certificate of service using the CM/ECF System which will send notification of such filing to the following: 6 7 8 9 10 11 12 13 14 15 Gary Scalabrini, Esq. GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP Attorneys for Defendant David Prager, Esq. GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP Attorneys for Defendant Jerry Griffin, Esq. GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP Attorneys for Defendant 16 19 Robert Wennagel, Esq. 990 Knox Street Torrance, CA 90502 Attorneys for AppleOne Employment Services 20 DATED: June 19, 2017 17 18 /s/ Alyson Decker 21 Alyson Decker, Esq. THE BLOOM FIRM 20700 Ventura Blvd., Suite 301 Woodland Hills, CA 91436 Phone: (818) 914-7306 Fax: (866) 852-5666 E-Mail: 22 23 24 25 26 27 28 15 THE BLOOM FIRM STIPULATED PROTECTIVE ORDER 1905708.1 CASE NO. 2:16-CV-00298-DMG (SPX)

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