Alex Bear v. Republic Bancorp, Inc.

• Court: District Court, C.D. California
• Decided: November 12, 2024
• Docket: 8:24-cv-00913
• Status: Unknown

Opinion

7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9

10 ALEX BEAR, Case No.: 8:24-cv-00913 SB (RAOx) 11 Plaintiff,

12 v. DISCOVERY MATTER

13 REPUBLIC BANCORP, INC., a Kentucky corporation, REPUBLIC STIPULATED PROTECTIVE 14 BANK & TRUST COMPANY, an ORDER1 unknown entity, CBANK, an Ohio 15 corporation, COMMERCIAL INDUSTRIAL FINANCE, INC., an Complaint Filed: March 15, 2023 16 Ohio corporation, SCOTT Trial Date: None set HAWKINS, an individual, and DOES 17 1 through 10, inclusive, 18 Defendant.

19 20 1. A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 Order does not confer blanket protections on all disclosures or responses to 27 discovery and that the protection it affords from public disclosure and use extends 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 B. GOOD CAUSE STATEMENT 4 In light of the nature of the claims and allegations in this case and the parties’ 5 representations that discovery in this case will involve the production of confidential 6 records (specifically, that Defendant Republic Bank & Trust Company is a Bank, 7 Plaintiff’s allegations involve his job performance, and the production of records may 8 identify clients, and/or other third parties), and in order to expedite the flow of 9 information, to facilitate the prompt resolution of disputes over confidentiality of 10 discovery materials, to adequately protect information the parties are entitled to keep 11 confidential, to ensure that the parties are permitted reasonable necessary uses of such 12 material in connection with this action, to address their handling of such material at 13 the end of the litigation, and to serve the ends of justice, a protective order for such 14 information is justified in this matter. The parties shall not designate any 15 information/documents as confidential without a good faith belief that such 16 information/documents have been maintained in a confidential, non-public manner, 17 and that there is good cause or a compelling reason why it should not be part of the 18 public record of this case. 19 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 20 The parties further acknowledge, as set forth in Section 12.3, below, that this 21 Stipulated Protective Order does not entitle them to file confidential information 22 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 23 and the standards that will be applied when a party seeks permission from the court 24 to file material under seal. 25 There is a strong presumption that the public has a right of access to judicial 26 proceedings and records in civil cases. In connection with non-dispositive motions, 27 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 1 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 2 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 3 require good cause showing), and a specific showing of good cause or compelling 4 reasons with proper evidentiary support and legal justification, must be made with 5 respect to Protected Material that a party seeks to file under seal. The parties’ mere 6 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 7 without the submission of competent evidence by declaration, establishing that the 8 material sought to be filed under seal qualifies as confidential, privileged, or 9 otherwise protectable—constitute good cause. 10 Further, if a party requests sealing related to a dispositive motion or trial, then 11 compelling reasons, not only good cause, for the sealing must be shown, and the 12 relief sought shall be narrowly tailored to serve the specific interest to be protected. 13 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 14 each item or type of information, document, or thing sought to be filed or introduced 15 under seal in connection with a dispositive motion or trial, the party seeking 16 protection must articulate compelling reasons, supported by specific facts and legal 17 justification, for the requested sealing order. Again, competent evidence supporting 18 the application to file documents under seal must be provided by declaration. 19 Any document that is not confidential, privileged, or otherwise protectable in 20 its entirety will not be filed under seal if the confidential portions can be redacted. 21 If documents can be redacted, then a redacted version for public viewing, omitting 22 only the confidential, privileged, or otherwise protectable portions of the document 23 shall be filed. Any application that seeks to file documents under seal in their 24 entirety should include an explanation of why redaction is not feasible. 25 2. DEFINITIONS 26 2.1 Action: Bear v. Republic Bank & Trust Company, et al. Central District 27 2.2 Challenging Party: a Party or Non-Party that challenges the designation 1 of information or items under this Order. 2 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 3 how it is generated, stored or maintained) or tangible things that qualify for 4 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 5 the Good Cause Statement. 6 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 7 their support staff). 8 2.5 Designating Party: a Party or Non-Party that designates information or 9 items that it produces in disclosures or in responses to discovery as 10 “CONFIDENTIAL.” 11 2.6 Disclosure or Discovery Material: all items or information, regardless of 12 the medium or manner in which it is generated, stored, or maintained (including, 13 among other things, testimony, transcripts, and tangible things) that are produced or 14 generated in disclosures or responses to discovery in this matter. 15 2.7 Expert: a person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to serve as 17 an expert witness or as a consultant in this Action. 18 2.8 House Counsel: attorneys who are employees of a party to this Action. 19 House Counsel does not include Outside Counsel of Record or any other outside 20 counsel. 21 2.9 Non-Party: any natural person, partnership, corporation, association or 22 other legal entity not named as a Party to this action. 23 2.10 Outside Counsel of Record: attorneys who are not employees of a party 24 to this Action but are retained to represent or advise a party to this Action and have 25 appeared in this Action on behalf of that party or are affiliated with a law firm that 26 has appeared on behalf of that party, and includes support staff. 27 2.11 Party: any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 support staffs). 3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 2.13 Professional Vendors: persons or entities that provide litigation support 6 services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or medium) 8 and their employees and subcontractors. 9 2.14 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL.” 11 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 12 from a Producing Party. 13 3. SCOPE 14 The protections conferred by this Stipulation and Order cover not only 15 Protected Material (as defined above), but also (1) any information copied or 16 extracted from Protected Material; (2) all copies, excerpts, summaries, or 17 compilations of Protected Material; and (3) any testimony, conversations, or 18 presentations by Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 4. DURATION 22 Even after final disposition of this litigation, the confidentiality obligations 23 imposed by this Order shall remain in effect until a Designating Party agrees 24 otherwise in writing or a court order otherwise directs. Final disposition shall be 25 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 26 or without prejudice; and (2) final judgment herein after the completion and 27 including the time limits for filing any motions or applications for extension of time 1 pursuant to applicable law. 2 5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for Protection. 4 Each Party or Non-Party that designates information or items for protection under 5 this Order must take care to limit any such designation to specific material that 6 qualifies under the appropriate standards. The Designating Party must designate for 7 protection only those parts of material, documents, items or oral or written 8 communications that qualify so that other portions of the material, documents, items 9 or communications for which protection is not warranted are not swept unjustifiably 10 within the ambit of this Order. 11 Mass, indiscriminate or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper 13 purpose (e.g., to unnecessarily encumber the case development process or to impose 14 unnecessary expenses and burdens on other parties) may expose the Designating 15 Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 22 under this Order must be clearly so designated before the material is disclosed or 23 produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 1 contains protected material. If only a portion of the material on a page qualifies for 2 protection, the Producing Party also must clearly identify the protected portion(s) 3 (e.g., by making appropriate markings in the margins). 4 A Party or Non-Party that makes original documents available for inspection 5 need not designate them for protection until after the inspecting Party has indicated 6 which documents it would like copied and produced. During the inspection and 7 before the designation, all of the material made available for inspection shall be 8 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 9 documents it wants copied and produced, the Producing Party must determine which 10 documents, or portions thereof, qualify for protection under this Order. Then, 11 before producing the specified documents, the Producing Party must affix the 12 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 13 portion of the material on a page qualifies for protection, the Producing Party also 14 must clearly identify the protected portion(s) (e.g., by making appropriate markings 15 in the margins). 16 (b) for testimony given in depositions that the Designating Party identifies 17 the Disclosure or Discovery Material on the record, before the close of the 18 deposition all protected testimony. 19 (c) for information produced in some form other than documentary and 20 for any other tangible items, that the Producing Party affix in a prominent place on 21 the exterior of the container or containers in which the information is stored the 22 legend “CONFIDENTIAL.” If only a portion or portions of the information 23 warrants protection, the Producing Party, to the extent practicable, shall identify the 24 protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive 27 Upon timely correction of a designation, the Receiving Party must make reasonable 1 efforts to assure that the material is treated in accordance with the provisions of this 2 Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on 10 the Designating Party. Frivolous challenges, and those made for an improper 11 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 12 parties) may expose the Challenging Party to sanctions. Unless the Designating 13 Party has waived or withdrawn the confidentiality designation, all parties shall 14 continue to afford the material in question the level of protection to which it is 15 entitled under the Producing Party’s designation until the Court rules on the 16 challenge. 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a 23 Receiving Party must comply with the provisions of section 13 below (FINAL 24 DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 5 well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of 8 the Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) the court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 (h) during their depositions, witnesses, and attorneys for witnesses, in the 20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 21 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 22 will not be permitted to keep any confidential information unless they sign the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 24 agreed by the Designating Party or ordered by the court. Pages of transcribed 25 deposition testimony or exhibits to depositions that reveal Protected Material may 26 be separately bound by the court reporter and may not be disclosed to anyone except 27 (i) any mediator or settlement officer, and their supporting personnel, 1 mutually agreed upon by any of the parties engaged in settlement discussions. 2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 3 IN OTHER LITIGATION 4 If a Party is served with a subpoena or a court order issued in other litigation 5 that compels disclosure of any information or items designated in this Action as 6 “CONFIDENTIAL,” that Party must: 7 (a) promptly notify in writing the Designating Party. Such notification 8 shall include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or order 10 to issue in the other litigation that some or all of the material covered by the 11 subpoena or order is subject to this Protective Order. Such notification shall include 12 a copy of this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be 14 pursued by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with 16 the subpoena or court order shall not produce any information designated in this 17 action as “CONFIDENTIAL” before a determination by the court from which the 18 subpoena or order issued, unless the Party has obtained the Designating Party’s 19 permission. The Designating Party shall bear the burden and expense of seeking 20 protection in that court of its confidential material and nothing in these provisions 21 should be construed as authorizing or encouraging a Receiving Party in this Action 22 to disobey a lawful directive from another court. 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 remedies and relief provided by this Order. Nothing in these provisions should be 1 construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, to 3 produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated 10 Protective Order in this Action, the relevant discovery request(s), and a reasonably 11 specific description of the information requested; and 12 (3) make the information requested available for inspection by the 13 Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court within 15 14 days of receiving the notice and accompanying information, the Receiving Party 16 may produce the Non-Party’s confidential information responsive to the discovery 17 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 18 not produce any information in its possession or control that is subject to the 19 confidentiality agreement with the Non-Party before a determination by the court. 20 Absent a court order to the contrary, the Non-Party shall bear the burden and 21 expense of seeking protection in this court of its Protected Material. 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 1 and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 9 procedure may be established in an e-discovery order that provides for production 10 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 11 (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 13 product protection, the parties may incorporate their agreement in the stipulated 14 protective order submitted to the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order, no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material 25 may only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material at issue. If a Party’s request to file Protected Material 27 in the public record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 , || 14. VIOLATION > Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 || 1T ISSO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: November 8, 2024 8 9 || s/Kevin H. Ngai Thomas F. Nowland 10 || Kevin H. Ngai Daniel A. Brodnax 11 |) Law Offices of Thomas F. Nowland Attorneys for Plaintiff 12 || ALEX BEAR 13 14 || DATED: November 8, 2024 15 16 || /s/ Hannah Sweiss Hannah Sweiss 17 || Serineh Terzyan _ Jasmine Sadeghant 18 |) Fisher & Phil Ips LLP Attorneys for Defendants 19 || REPUBLIC BANK & TRUST COMPANY and SCOTT HAWKINS 20 21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 92 DATED: 11/12/2024 23 Re 24 Bhan hr. © ~ HON. ROZELLA A. OLIVER 25 || United States Magistrate Judge 26 27 28 14

EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of ___________ Bear v. Republic Bank & Trust Company, et al. 8 Central District of California Case No. 8:24-cv-00913 SB (RAOx). I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and I understand 10 and acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 Signature: __________________________________ 27 1 PROOF OF SERVICE 5 (CCP §§1013(a) and 2015.5) I, the undersigned, am at least 18 years old and not a party to this action. I am 3 employed in the County of Los Angeles with the law offices of Fisher & Ehullips LLP and its business address is 21600 Oxnard Street, Suite 650, Woodland Hills, 4 || California 91367. 5 On November 8, 2024, I served the following document(s) PULATED oped ORDER on the person(s) listed below by placing the original 6 a true copy thereof enclosed in sealed envelope(s) addressed as follows: 7 || Thomas F. Nowland Attomey for Plaintiff Daniel A. Brodnax ALEX BEAR 8 || Kevin H. Ngai Law Offices of Thomas F. Nowland 9 || 20241 SW Birch Street, Suite 203 Newport Beach, California 92660 10 || Telephone: OY 221-0005 Facsimile: (949) 221-0003 1 || E-Mail: tom@nowlandlaw.com dbrodnax@nowlandlaw.com 12 khngai@nowlandlaw.com 13 [by ELECTRONIC SUBMISSION] - I served the above listed document(s) described via the United States District Court’s Electronic Filing Program on 14 the designated recipients via electronic transmission through the CM/ECF system on the Court’s website. The Court’s CM/ECF system will generate a I5 otice of Electronic Filing (NEF) to the fling party, the assigned judge, and any registered users in the case. The NEF will constitute service of the 16 document(s). Registration as a CM/ECF user constitutes consent to electronic 7 service through the court’s transmission facilities. I declare under penalty of perjury, under the laws of the State of California, 18 || that the foregoing is true and correct. 19 Executed November 8, 2024, at Woodland Hills, California. 20 Adriana Preciado By: _/s/ Adriana Preciado print Name —“ieOS~<‘<—<;7;737;] □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ 21 22 23 24 25 26 27 28