Mary Olsen Kelly v. Federal Insurance Company et al

Filing 35

PROTECTIVE ORDER by Magistrate Judge Shashi H. Kewalramani re Stipulation for Protective Order 34 . (see document for details) (hr)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
REBECCA R. WEINREICH, SB# 155684
E-Mail: [e-mail]
2
633 West 5th Street, Suite 4000
3 Los Angeles, California 90071
Telephone: [phone]
4 Facsimile: 213.250.7900
5 LEWIS BRISBOIS BISGAARD & SMITH LLP
MICHAEL K. JOHNSON, SB# 130193
E-Mail: [e-mail]
6
2185 N. California Blvd., Suite 300
7 Walnut Creek, California 94549-2872
Telephone: [phone]
8 Facsimile: 925.478.3260
9 Attorneys for Defendant
FEDERAL INSURANCE COMPANY
10
11

UNITED STATES DISTRICT COURT

12

CENTRAL DISTRICT OF CALIFORNIA

13
14 MARY OLSEN KELLY,

Case No. 5:20-cv-01567-JGB-SHK(x)

Plaintiff,

15

STIPULATED PROTECTIVE
ORDER

v.

16

17 FEDERAL INSURANCE COMPANY AND
DOES 1 TO 100,
18
Defendants.
19
20

DISCOVERY MATTER
[DISCOVERY DOCUMENT:
REFERRED TO MAGISTRATE JUDGE
SHASHI H. KEWALRAMANI]
[DIVERSITY]

21
22

IT IS HEREBY STIPULATED by and between the Parties, Plaintiff MARY

23 OLSEN KELLY, and Defendant FEDERAL INSURANCE COMPANY , by and through
24 their respective counsel of record, that in order to facilitate the exchange of information
25 and documents which may be subject to confidentiality limitations on disclosure due to
26 federal laws, state laws, and privacy rights, the Parties stipulate as follows:
27 I.

LEWIS

PURPOSES AND LIMITATIONS

28

A.

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

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

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proprietary, or private information for which special protection from public

2

disclosure and from use for any purpose other than prosecuting this litigation

3

may be warranted. Accordingly, the parties hereby stipulate to and petition

4

the Court to enter the following Stipulated Protective Order. The parties

5

acknowledge that this Order does not confer blanket protections on all

6

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

7

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

8

are entitled to confidential treatment under the applicable legal principles.

9

The parties further acknowledge, as set forth in Section XIII(C), below, that

10
11

information under seal; Civil Local Rule 79-5 sets forth the procedures that

12

must be followed and the standards that will be applied when a party seeks

13

permission from the Court to file material under seal. The parties further

14

acknowledge the Standing Order of Judge Jesus G. Bernal as to the filing of

15

documents under seal.

16 II.

GOOD CAUSE STATEMENT

17

This action is likely to involve trade secrets, insurance policy underwriting

18

and claims handling information, customer and pricing information, and other

19

valuable research, development, commercial, financial, technical and/or

20

proprietary information for which special protection from public disclosure

21

and from use for any purpose other than prosecution of this action is

22

warranted. Such confidential and proprietary materials and information

23

consist of, among other things, confidential business or financial information,

24

information regarding confidential business practices, or other confidential

25

research, development, or commercial information (including information

26

implicating privacy rights of third parties), information otherwise generally

27

LEWIS

this Stipulated Protective Order does not entitle them to file confidential

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

28

from disclosure under state or federal statutes, court rules, case decisions, or

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

2

STIPULATED PROTECTIVE ORDER

1
2

the prompt resolution of disputes over confidentiality of discovery materials,

3

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

4

to ensure that the parties are permitted reasonable necessary uses of such

5

material in preparation for and in the conduct of trial, to address their

6

handling at the end of the litigation, and serve the ends of justice, a protective

7

order for such information is justified in this matter. It is the intent of the

8

parties that information will not be designated as confidential for tactical

9

reasons and that nothing be so designated without a good faith belief that it

10

has been maintained in a confidential, non-public manner, and there is good

11

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

12 III.

DEFINITIONS

13

A.

Action: This pending federal law suit.

14

B.

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

15

designation of information or items under this Order.

16

C.

17

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

18

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

19

above in the Good Cause Statement.

20

D.

21

their support staff).

22

E.

23

items that it produces in disclosures or in responses to discovery as

24

“CONFIDENTIAL.”

25

F.

26

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

27

LEWIS

common law. Accordingly, to expedite the flow of information, to facilitate

(including, among other things, testimony, transcripts, and tangible things),

28

that are produced or generated in disclosures or responses to discovery in this

“CONFIDENTIAL” Information or Items: Information (regardless of

Counsel: Outside Counsel of Record and House Counsel (as well as

Designating Party: A Party or Non-Party that designates information or

Disclosure or Discovery Material: All items or information, regardless

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

1

matter.

2

G.

3

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

4

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

5

H.

6

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

7

outside counsel.

8

I.

9

other legal entity not named as a Party to this action.

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

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

Non-Party: Any natural person, partnership, corporation, association, or

10
11

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

12

Action and have appeared in this Action on behalf of that party or are

13

affiliated with a law firm which has appeared on behalf of that party, and

14

includes support staff.

15

K.

16

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

17

their support staffs).

18

L.

19

Discovery Material in this Action.

20

M.

21

support services (e.g., photocopying, videotaping, translating, preparing

22

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

23

form or medium) and their employees and subcontractors.

24

N.

25

designated as “CONFIDENTIAL.”

26

O.

27

LEWIS

J.

Outside Counsel of Record: Attorneys who are not employees of a

Material from a Producing Party.

28

///

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

Producing Party: A Party or Non-Party that produces Disclosure or

Professional Vendors: Persons or entities that provide litigation

Protected Material: Any Disclosure or Discovery Material that is

Receiving Party: A Party that receives Disclosure or Discovery

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ATTORNEYS AT LAW

4834-0205-2059.1

4

STIPULATED PROTECTIVE ORDER

1 IV.

SCOPE

2

A.

3

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

4

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

5

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

6

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

7

B.

8

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

9

trial.

The protections conferred by this Stipulation and Order cover not only

Any use of Protected Material at trial shall be governed by the orders of

10 V.

DURATION

11

Even after final disposition of this litigation, the confidentiality obligations

12

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

13

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

14

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

15

Action, with or without prejudice; and (2) final judgment herein after the

16

completion and exhaustion of all appeals, rehearings, remands, trials, or

17

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

18

applications for extension of time pursuant to applicable law.

19 VI.

DESIGNATING PROTECTED MATERIAL

20

A.

Exercise of Restraint and Care in Designating Material for Protection

21
22

protection under this Order must take care to limit any such designation

23

to specific material that qualifies under the appropriate standards. The

24

Designating Party must designate for protection only those parts of

25

material, documents, items, or oral or written communications that

26

qualify so that other portions of the material, documents, items, or

27

LEWIS

1.

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

communications for which protection is not warranted are not swept

28

unjustifiably within the ambit of this Order.

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& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

1

2.

2

Designations that are shown to be clearly unjustified or that have been

3

made for an improper purpose (e.g., to unnecessarily encumber the case

4

development process or to impose unnecessary expenses and burdens

5

on other parties) may expose the Designating Party to sanctions.

6

3.

7

items that it designated for protection do not qualify for protection, that

8

Designating Party must promptly notify all other Parties that it is

9

withdrawing the inapplicable designation.

10

B.

Mass, indiscriminate, or routinized designations are prohibited.

If it comes to a Designating Party’s attention that information or

Manner and Timing of Designations

11

1.

Except as otherwise provided in this Order (see, e.g., Section

12

B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or

13

Discovery Material that qualifies for protection under this Order must

14

be clearly so designated before the material is disclosed or produced.

15

2.

Designation in conformity with this Order requires the following:

16
17

electronic documents, but excluding transcripts of depositions or

18

other pretrial or trial proceedings), that the Producing Party affix

19

at a minimum, the legend “CONFIDENTIAL” (hereinafter

20

“CONFIDENTIAL legend”), to each page that contains

21

protected material. If only a portion or portions of the material

22

on a page qualifies for protection, the Producing Party also must

23

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

24

appropriate markings in the margins).

25

(b)

26

available for inspection need not designate them for protection

27

LEWIS

(a)

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

until after the inspecting Party has indicated which documents it

28

would like copied and produced. During the inspection and

A Party or Non-Party that makes original documents

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ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

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before the designation, all of the material made available for

2

inspection shall be deemed “CONFIDENTIAL.” After the

3

inspecting Party has identified the documents it wants copied and

4

produced, the Producing Party must determine which documents,

5

or portions thereof, qualify for protection under this Order.

6

Then, before producing the specified documents, the Producing

7

Party must affix the “CONFIDENTIAL legend” to each page

8

that contains Protected Material. If only a portion or portions of

9

the material on a page qualifies for protection, the Producing

10

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

11

making appropriate markings in the margins).

12

(c)

13

Party identify the Disclosure or Discovery Material on the

14

record, before the close of the deposition all protected testimony.

15

(d)

16

for any other tangible items, that the Producing Party affix in a

17

prominent place on the exterior of the container or containers in

18

which the information is stored the legend “CONFIDENTIAL.”

19

If only a portion or portions of the information warrants

20

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

21

identify the protected portion(s).

22

C.

For testimony given in depositions, that the Designating

For information produced in form other than document and

Inadvertent Failure to Designate

23
24

information or items does not, standing alone, waive the Designating

25

Party’s right to secure protection under this Order for such material.

26

Upon timely correction of a designation, the Receiving Party must

27

LEWIS

If timely corrected, an inadvertent failure to designate qualified

make reasonable efforts to assure that the material is treated in

28

accordance with the provisions of this Order.

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& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

1 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2

A.

Timing of Challenges

3

Any party or Non-Party may challenge a designation of confidentiality

4

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

5

B.

Meet and Confer

6

The Challenging Party shall initiate the dispute resolution process

7

under Local Rule 37.1 et seq.

8

C.

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

9

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

10

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

11

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

12

Designating Party has waived or withdrawn the confidentiality designation,

13

all parties shall continue to afford the material in question the level of

14

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

15

the Court rules on the challenge.

16 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
17

A.

Basic Principles

18
19

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

20

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

21

Action. Such Protected Material may be disclosed only to the

22

categories of persons and under the conditions described in this Order.

23

When the Action has been terminated, a Receiving Party must comply

24

with the provisions of Section XIV below.

25

2.

26

Party at a location and in a secure manner that ensures that access is

27

LEWIS

1.

limited to the persons authorized under this Order.

28

B.

A Receiving Party may use Protected Material that is disclosed or

Protected Material must be stored and maintained by a Receiving

Disclosure of “CONFIDENTIAL” Information or Items

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ATTORNEYS AT LAW

4834-0205-2059.1

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STIPULATED PROTECTIVE ORDER

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1.

Unless otherwise ordered by the Court or permitted in writing by

2

the Designating Party, a Receiving Party may disclose any information

3

or item designated “CONFIDENTIAL” only to:
The Receiving Party’s Outside Counsel of Record in this

4

(a)

5

Action, as well as employees of said Outside Counsel of Record

6

to whom it is reasonably necessary to disclose the information

7

for this Action;

8

(b)

9

House Counsel) of the Receiving Party to whom disclosure is

The officers, directors, agents and employees (including

10
11

(c)

12

whom disclosure is reasonably necessary for this Action and who

13

have signed the “Acknowledgment and Agreement to Be Bound”

14

(Exhibit A);

15

(d)

The Court and its personnel;

16

(e)

Court reporters and their staff;

17

(f)

18

Professional Vendors to whom disclosure is reasonably

19

necessary or this Action and who have signed the

20

“Acknowledgment and Agreement to be Bound” attached as

21

Exhibit A hereto;

22

(g)

23

information or a custodian or other person who otherwise

24

possessed or knew the information;

25

(h)

26

witnesses, in the Action to whom disclosure is reasonably

27

LEWIS

reasonably necessary for this Action;

necessary provided: (i) the deposing party requests that the

28

witness sign the “Acknowledgment and Agreement to Be

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

Professional jury or trial consultants, mock jurors, and

The author or recipient of a document containing the

During their depositions, witnesses, and attorneys for

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STIPULATED PROTECTIVE ORDER

1

Bound;” and (ii) they will not be permitted to keep any

2

confidential information unless they sign the “Acknowledgment

3

and Agreement to Be Bound,” unless otherwise agreed by the

4

Designating Party or ordered by the Court. Pages of transcribed

5

deposition testimony or exhibits to depositions that reveal

6

Protected Material may be separately bound by the court reporter

7

and may not be disclosed to anyone except as permitted under

8

this Stipulated Protective Order; and

9

(i)

Any mediator or settlement officer, and their supporting

10

personnel, mutually agreed upon by any of the parties engaged in

11

settlement discussions.

12 IX.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

13

PRODUCED IN OTHER LITIGATION

14

A.

15

litigation that compels disclosure of any information or items designated in

16

this Action as “CONFIDENTIAL,” that Party must:

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

17

1.

Promptly notify in writing the Designating Party. Such

18

notification shall include a copy of the subpoena or court order;

19

2.

20

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

21

covered by the subpoena or order is subject to this Protective Order.

22

Such notification shall include a copy of this Stipulated Protective

23

Order; and

24

3.

25

pursued by the Designating Party whose Protected Material may be

26

affected.

Promptly notify in writing the party who caused the subpoena or

Cooperate with respect to all reasonable procedures sought to be

27

LEWIS

B.

If the Designating Party timely seeks a protective order, the Party

28

served with the subpoena or court order shall not produce any information

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STIPULATED PROTECTIVE ORDER

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designated in this action as “CONFIDENTIAL” before a determination by the

2

Court from which the subpoena or order issued, unless the Party has obtained

3

the Designating Party’s permission. The Designating Party shall bear the

4

burden and expense of seeking protection in that court of its confidential

5

material and nothing in these provisions should be construed as authorizing or

6

encouraging a Receiving Party in this Action to disobey a lawful directive

7

from another court.

8 X.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

9

PRODUCED IN THIS LITIGATION

10

A.

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

11

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

12

information produced by Non-Parties in connection with this litigation is

13

protected by the remedies and relief provided by this Order. Nothing in these

14

provisions should be construed as prohibiting a Non-Party from seeking

15

additional protections.

16

B.

17

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

18

Party is subject to an agreement with the Non-Party not to produce the Non-

19

Party’s confidential information, then the Party shall:

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

20
21

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

22

confidentiality agreement with a Non-Party;

23

2.

24

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

25

reasonably specific description of the information requested; and

26

3.

27

LEWIS

1.

Non-Party, if requested.

28

C.

Promptly notify in writing the Requesting Party and the Non-

Promptly provide the Non-Party with a copy of the Stipulated

Make the information requested available for inspection by the

If the Non-Party fails to seek a protective order from this court within

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STIPULATED PROTECTIVE ORDER

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14 days of receiving the notice and accompanying information, the Receiving

2

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

3

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

4

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

5

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

6

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

7

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

8

its Protected Material.

9 XI.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

10

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

11

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

12

this Stipulated Protective Order, the Receiving Party must immediately (1)

13

notify in writing the Designating Party of the unauthorized disclosures, (2)

14

use its best efforts to retrieve all unauthorized copies of the Protected

15

Material, (3) inform the person or persons to whom unauthorized disclosures

16

were made of all the terms of this Order, and (4) request such person or

17

persons to execute the “Acknowledgment and Agreement to be Bound” that is

18

attached hereto as Exhibit A.

19 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20
21

A. When a Producing Party gives notice to Receiving Parties that certain

22

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

23

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

24

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

25

to modify whatever procedure may be established in an e-discovery order that

26

provides for production without prior privilege review. Pursuant to Federal

27

LEWIS

PROTECTED MATERIAL

Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on

28

the effect of disclosure of a communication or information covered by the

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STIPULATED PROTECTIVE ORDER

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attorney-client privilege or work product protection, the parties may

2

incorporate their agreement in the Stipulated Protective Order submitted to

3

the Court.

4 XIII. MISCELLANEOUS
5

A.

Right to Further Relief

6

Nothing in this Order abridges the right of any person to seek its

7

modification by the Court in the future.

8

B.

9

Right to Assert Other Objections
By stipulating to the entry of this Protective Order, no Party waives any

10

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

11

information or item on any ground not addressed in this Stipulated

12

Protective Order. Similarly, no Party waives any right to object on any

13

ground to use in evidence of any of the material covered by this

14

Protective Order.

15

C.

Filing Protected Material

16

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

17

comply with Civil Local Rule 79-5. Protected Material may only be

18

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

19

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

20

Protected Material under seal is denied by the Court, then the

21

Receiving Party may file the information in the public record unless

22

otherwise instructed by the Court.

23 XIV. FINAL DISPOSITION
24
25

sixty (60) days of a written request by the Designating Party, each Receiving

26

Party must return all Protected Material to the Producing Party or destroy

27

LEWIS

A.

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

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

28

all copies, abstracts, compilations, summaries, and any other format

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STIPULATED PROTECTIVE ORDER

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reproducing or capturing any of the Protected Material. Whether the

2

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

3

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

4

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

5

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

6

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

7

abstracts, compilations, summaries or any other format reproducing or

8

capturing any of the Protected Material. Notwithstanding this provision,

9

Counsel are entitled to retain an archival copy of all pleadings, motion papers,

10

trial, deposition, and hearing transcripts, legal memoranda, correspondence,

11

deposition and trial exhibits, expert reports, attorney work product, and

12

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

13

Material. Any such archival copies that contain or constitute Protected

14

Material remain subject to this Protective Order as set forth in Section V.

15

B.

16

measures including, without limitation, contempt proceedings and/or

17

monetary sanctions.

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

18
19
20
21
22
23
24
25
26
27

LEWIS

28

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STIPULATED PROTECTIVE ORDER

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2
3 DATED: March 29, 2021
4

THE BUCKLIN LAW FIRM
By:

5
6

/s/ Stephen L. Bucklin
Stephen L. Bucklin, Esq.
Attorneys for Plaintiff
MARY OLSEN KELLY

7
8
9

DATED: March 29, 2021

LEWIS BRISBOIS BISGAARD & SMITH LLP
By: /s/ Michael K. Johnson
Rebecca R. Weinreich, Esq.
Michael K. Johnson, Esq.
Attorneys for Defendant
FEDERALINSURANCECOMPANY

10
11
12
13
14
15

Attestation Regarding Signatures

16
17

I, Michael K. Johnson, attest that all other signatories listed, and on whose

18 behalf this filing is submitted, concur in the filing’s content and have authorized the
19 filing.
20
21 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
23 Dated:

March 30, 2021
HONORABLE SHASHI H. KEWALRAMANI
United States Magistrate Judge

24
25
26
27

LEWIS

28

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STIPULATED PROTECTIVE ORDER

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2

CERTIFICATE OF SERVICE
Mary Olsen Kelly v. Federal Insurance Company, et al.
USDC-CD, Eastern Division, Case No. 5:20-cv-01567-JGB-SHK

3 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
At the time of service, I was over 18 years of age and not a party to the action.
My business address is 2020 W. El Camino Avenue, Suite 300, Sacramento, California
5 95833. I am employed in the office of a member of the bar of this Court at whose
direction the service was made.
6
On March 29, 2021, I served the following document: STIPULATED
7 PROTECTIVE ORDER
4

8

I served the document on the following person at the following address
(including a fax number and email address, if applicable):

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Stephen Loomis Bucklin, Esq.
THE BUCKLIN LAW FIRM
967 ½ W. 8th Street
San Pedro, CA 90731
Attorneys for Plaintiff Mary Olsen Kelly

Tel: [phone]
Email: [e-mail]

The document was served by the following means:

14  (BY ELECTRONIC TRANSMISSION ONLY) Note that during the
pandemic, this office will be working remotely, not
15 Coronavirus (COVID-19)usual, and is therefore using only electronic mail.able
to send physical mail as
No
electronic message or other indication that the transmission was unsuccessful was
16 received within a reasonable time after the transmission.
17
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
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19 Dated: March 29, 2021
20

Sandra Hayes

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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4834-0205-2059.1

CERTIFICATE OF SERVICE