Lina Noory v. Camden Development, Inc.

Opinion

i 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 LINA NOORY, I] , Case No. 2:20-cv-01767-AB-GJS Plaintiff, 12 Vv. STIPULATED PROTECTIVE 13 ORDER! CAMDEN DEVELOPMENT, INC.; 14 and DOES 1-5, 15 Defendants. 16 17 l. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may 21 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 22 enter the following Stipulated Protective Order. The parties acknowledge that this 23 Order does not confer blanket protections on all disclosures or responses to 24 discovery and that the protection it affords from public disclosure and use extends 25 26 27 4g || | This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures.

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 This action is likely to involve medical, business and financial 5 || documentation, for which protection from public disclosure and from use for any 6 || purpose other than prosecution of this action is warranted. Such medical, 7 || employment and financial materials and information consist of, among other things, 8 || personal medical records, confidential business or financial information, information 9 || regarding confidential business practices, or other confidential research, 10 |} development, or commercial information (including information implicating privacy 11 || rights of third parties), information otherwise generally unavailable to the public, or 12 which may be privileged or otherwise protected from disclosure under state or 13 || federal statutes, court rules, case decisions, or common law. Accordingly, to 14 || expedite the flow of information, to facilitate the prompt resolution of disputes over 15 || confidentiality of discovery materials, to adequately protect information the parties 16 || are entitled to keep confidential, to ensure that the parties are permitted reasonable 17 || necessary uses of such material in preparation for and in the conduct of trial, to 18 || address their handling at the end of the litigation, and serve the ends of Justice, a 19 |] protective order for such information is justified in this matter. It is the intent of the 20 || parties that information will not be designated as confidential for tactical reasons 21 |! and that nothing be so designated without a good faith belief that it has been 22 || maintained in a confidential, non-public manner, and there is good cause why it 23 || should not be part of the public record of this case. 24 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 25 The parties further acknowledge, as set forth in Section 12.3, below, that this 26 || Stipulated Protective Order does not entitle them to file confidential information 27 |i under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 28

1 || and the standards that will be applied when a party seeks permission from the court 2 || to file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 || proceedings and records in civil cases. In connection with non-dispositive motions, 5 || good cause must be shown to support a filing under seal. See Kamakana v. City and 6 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 7 || Corp., 307 F.3d 1206, 1210-11 (th Cir. 2002), Makar-Welbon v. Sony Electrics, 8 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 9 || require good cause showing), and a specific showing of good cause or compelling 10 || reasons with proper evidentiary support and legal justification, must be made with 11 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 12 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 13 || without the submission of competent evidence by declaration, establishing that the 14 || material sought to be filed under seal qualifies as confidential, privileged, or 15 || otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 || compelling reasons, not only good cause, for the sealing must be shown, and the 18 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 19 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 20 || each item or type of information, document, or thing sought to be filed or introduced 21 || under seal in connection with a dispositive motion or trial, the party seeking 22 || protection must articulate compelling reasons, supported by specific facts and legal 23 || justification, for the requested sealing order. Again, competent evidence supporting 24 || the application to file documents under seal must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in 26 || its entirety will not be filed under seal if the confidential portions can be redacted. 27 || If documents can be redacted, then a redacted version for public viewing, omitting 28 || only the confidential, privileged, or otherwise protectable portions of the document,

1 |i shall be filed, Any application that seeks to file documents under seal in their 2 || entirety should include an explanation of why redaction is not feasible. 3 2. DEFINITIONS 4 2.1 Action: Lina Noory v. Camden Development, Inc., Case No. 2:20-cv- 5 || 01767-AB-GJS. 6 2.2 Challenging Party: a Party or Non-Party that challenges the 7 || designation of information or items under this Order. 8 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 9 || how it is generated, stored or maintained) or tangible things that qualify for 10 |} protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 || the Good Cause Statement. 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 13 |) their support staff). 14 2.5 Designating Party: a Party or Non-Party that designates information or 15 || items that it produces in disclosures or in responses to discovery as 16 || “CONFIDENTIAL.” 17 2.6 Disclosure or Discovery Material: all items or information, regardless 18 || of the medium or manner in which it is generated, stored, or maintained (including, 19 || among other things, testimony, transcripts, and tangible things), that are produced or 20 || generated in disclosures or responses to discovery in this matter. 21 2.7. Expert: a person with specialized knowledge or experience in a matter 22 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 23 || an expert witness or as a consultant in this Action. 24 2.8 House Counsel: attorneys who are employees of a party to this Action. 25 || House Counsel does not include Outside Counsel of Record or any other outside 26 || counsel. 27 2.9 Non-Party: any natural person, partnership, corporation, association or 28 || other legal entity not named as a Party to this action.

1 2.10 Outside Counsel of Record: attorneys who are not employees of a 2 || party to this Action but are retained to represent or advise a party to this Action and 3 || have appeared in this Action on behalf of that party or are affiliated with a law firm 4 || that has appeared on behalf of that party, and includes support staff. 5 2.11 Party: any party to this Action, including all of its officers, directors, 6 || employees, consultants, retained experts, and Outside Counsel of Record (and their 7 || support staffs). 8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 9 || Discovery Material in this Action. 10 2.13 Professional Vendors: persons or entities that provide litigation 11 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 || and their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is 15 || designated as “CONFIDENTIAL.” 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery 17 || Material from a Producing Party. ig || 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 50 Protected Material (as defined above), but also (1) any information copied or

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

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

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

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

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

26 4, DURATION 7 FINAL DISPOSITION of the action is defined as the conclusion of any 38 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

1 || has run. Except as set forth below, the terms of this protective order apply through 2 || FINAL DISPOSITION of the action. The parties may stipulate that the they will be 3 || contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 4 || but will have to file a separate action for enforcement of the agreement once all 5 || proceedings in this case are complete. 6 Once a case proceeds to trial, information that was designated as 7 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 8 || as an exhibit at trial becomes public and will be presumptively available to all 9 || members of the public, including the press, unless compelling reasons supported by 10 || specific factual findings to proceed otherwise are made to the trial judge in advance 11 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 12 || showing for sealing documents produced in discovery from “compelling reasons” 13 || standard when merits-related documents are part of court record). Accordingly, for 14 || such materials, the terms of this protective order do not extend beyond the 15 || commencement of the trial. 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 || Each Party or Non-Party that designates information or items for protection under 19 |} this Order must take care to limit any such designation to specific material that 20 || qualifies under the appropriate standards. The Designating Party must designate for 21 || protection only those parts of material, documents, items or oral or written 22 || communications that qualify so that other portions of the material, documents, items 23 || or communications for which protection is not warranted are not swept unjustifiably 24 || within the ambit of this Order. 25 Mass, indiscriminate or routinized designations are prohibited. Designations 26 || that are shown to be clearly unjustified or that have been made for an improper 27 || purpose (e.g., to unnecessarily encumber the case development process or to impose 28

1 || unnecessary expenses and burdens on other parties) may expose the Designating 2 || Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 || designated for protection do not qualify for protection, that Designating Party must 5 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 || under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 || documents, but excluding transcripts of depositions or other pretrial or trial 14 || proceedings), that the Producing Party affix at a minimum, the legend 15 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that i6 || contains protected material. If only a portion of the material on a page qualifies for 17 || protection, the Producing Party also must clearly identify the protected portion(s) 18 || (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 || need not designate them for protection until after the inspecting Party has indicated 21 || which documents it would like copied and produced. During the inspection and 22 || before the designation, all of the material made available for inspection shall be 23 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 || documents it wants copied and produced, the Producing Party must determine which 25 || documents, or portions thereof, qualify for protection under this Order. Then, 26 || before producing the specified documents, the Producing Party must affix the 27 || “CONFIDENTIAL legend” to each page that contains Protected Material, If only a 28 || portion of the material on a page qualifies for protection, the Producing Party also

1 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 2 || in the margins). 3 (b) for testimony given in depositions that the Designating Party identifies 4 || the Disclosure or Discovery Material on the record, before the close of the 5 || deposition all protected testimony. 6 (c) for information produced in some form other than documentary and 7 || for any other tangible items, that the Producing Party affix in a prominent place on 8 || the exterior of the container or containers in which the information is stored the 9 || legend “CONFIDENTIAL.” If only a portion or portions of the information 10 |} warrants protection, the Producing Party, to the extent practicable, shall identify the 11 || protected portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 || failure to designate qualified information or items does not, standing alone, waive 14 || the Designating Party’s right to secure protection under this Order for such material. 15 || Upon timely correction of a designation, the Receiving Party must make reasonable 16 || efforts to assure that the material is treated in accordance with the provisions of this 17 || Order. 18 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 20 || designation of confidentiality at any time that is consistent with the Court’s 21 || Scheduling Order. 22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 23 || resolution process under Local Rule 37.1 et seq. 24 6.3. The burden of persuasion in any such challenge proceeding shall be on 25 || the Designating Party. Frivolous challenges, and those made for an improper 26 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 27 || parties) may expose the Challenging Party to sanctions. Unless the Designating 28 || Party has waived or withdrawn the confidentiality designation, all parties shall

1 || continue to afford the material in question the level of protection to which it is 2 || entitled under the Producing Party’s designation until the Court rules on the 3 || challenge. 4 ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 || disclosed or produced by another Party or by a Non-Party in connection with this 7 || Action only for prosecuting, defending or attempting to settle this Action. Such 8 || Protected Material may be disclosed only to the categories of persons and under the 9 |} conditions described in this Order. When the Action has been terminated, a 10 || Receiving Party must comply with the provisions of section 13 below (FINAL 11 || DISPOSITION). 12 Protected Material must be stored and maintained by a Receiving Party at a 13 || location and in a secure manner that ensures that access is limited to the persons 14 || authorized under this Order. 15 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless 16 || otherwise ordered by the court or permitted in writing by the Designating Party, a 17 || Receiving Party may disclose any information or item designated 18 || “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 20 || well as employees of said Outside Counsel of Record to whom it is reasonably 21 || necessary to disclose the information for this Action, 22 (b) the officers, directors, and employees (including House Counsel) of 23 || the Receiving Party to whom disclosure is reasonably necessary for this Action, 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 || disclosure is reasonably necessary for this Action and who have signed the 26 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 (e) court reporters and their staff;

1 (£) professional jury or trial consultants, mock jurors, and Professional 2 || Vendors to whom disclosure is reasonably necessary for this Action and who have 3 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (gz) the author or recipient of a document containing the information or a § || custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 9 || not be permitted to keep any confidential information unless they sign the 10 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 || agreed by the Designating Party or ordered by the court. Pages of transcribed 12 || deposition testimony or exhibits to depositions that reveal Protected Material may 13 || be separately bound by the court reporter and may not be disclosed to anyone except 14 || as permitted under this Stipulated Protective Order; and 15 (i) any mediator or settlement officer, and their supporting personnel, 16 || mutually agreed upon by any of the parties engaged in settlement discussions. 17 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 18 OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 || that compels disclosure of any information or items designated in this Action as 21 || “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification 23 || shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order 25 || to issue in the other litigation that some or all of the material covered by the 26 || subpoena or order is subject to this Protective Order. Such notification shall include 27 || acopy of this Stipulated Protective Order; and 28 (c) cooperate with respect to all reasonable procedures sought to be

1 || pursued by the Designating Party whose Protected Material may be affected. 2 If the Designating Party timely seeks a protective order, the Party served with 3 || the subpoena or court order shall not produce any information designated in this 4 || action as “CONFIDENTIAL” before a determination by the court from which the 5 || subpoena or order issued, unless the Party has obtained the Designating Party’s 6 || permission. The Designating Party shall bear the burden and expense of seeking 7 || protection in that court of its confidential material and nothing in these provisions 8 || should be construed as authorizing or encouraging a Receiving Party in this Action 9 {| to disobey a lawful directive from another court. LO |] 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE il PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 14 |} produced by Non-Parties in connection with this litigation is protected by the 15 || remedies and relief provided by this Order. Nothing in these provisions should be 16 || construed as prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 || produce a Non-Party’s confidential information in its possession, and the Party is 19 || subject to an agreement with the Non-Party not to produce the Non-Party’s 20 || confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non-Party 22 || that some or all of the information requested is subject to a confidentiality 23 || agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 || specific description of the information requested; and 27 (3) make the information requested available for inspection by the 28 || Non-Party, if requested.

1 (c) If the Non-Party fails to seek a protective order from this court within 2 || 14 days of receiving the notice and accompanying information, the Receiving Party 3 || may produce the Non-Party’s confidential information responsive to the discovery 4 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 || not produce any information in its possession or control that is subject to the 6 || confidentiality agreement with the Non-Party before a determination by the court. 7 || Absent a court order to the contrary, the Non-Party shall bear the burden and 8 || expense of seeking protection in this court of its Protected Material. 9 || 10. 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 this 12 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 || persons to whom unauthorized disclosures were made of all the terms of this Order, 16 || and (d) request such person or persons to execute the “Acknowledgment and 17 || Agreement to Be Bound” that is attached hereto as Exhibit A. 18 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 || inadvertently produced material is subject to a claim of privilege or other protection, 22 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 24 || procedure may be established in an e-discovery order that provides for production 25 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 26 || (e), insofar as the parties reach an agreement on the effect of disclosure of a 27 || communication or information covered by the attorney-client privilege or work 28 || product protection, the parties may incorporate their agreement in the stipulated

1 || protective order submitted to the court, 2 || 12. MISCELLANEOUS 3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 4 || person to seek its modification by the Court in the future. 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 || Protective Order, no Party waives any right it otherwise would have to object to 7 || disclosing or producing any information or item on any ground not addressed in this 8 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 9 |} ground to use in evidence of any of the material covered by this Protective Order. 10 12.3. Filing Protected Material. A Party that seeks to file under seal any 11 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 12 || may only be filed under seal pursuant to a court order authorizing the sealing of the 13 || specific Protected Material at issue. If a Party’s request to file Protected Material 14 || under seal is denied by the court, then the Receiving Party may file the information 15 || in the public record unless otherwise instructed by the court. 16 || 13. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 4, within 60 i8 || days of a written request by the Designating Party, each Receiving Party must return 19 |] all Protected Material to the Producing Party or destroy such material. As used in 20 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 21 || summaries, and any other format reproducing or capturing any of the Protected 22 |! Material. Whether the Protected Material is returned or destroyed, the Receiving 23 || Party must submit a written certification to the Producing Party (and, if not the same 24 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 25 || (by category, where appropriate) all the Protected Material that was returned or 26 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 27 || abstracts, compilations, summaries or any other format reproducing or capturing any 28 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to

|| retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 || reports, attorney work product, and consultant and expert work product, even if such 4 || materials contain Protected Material. Any such archival copies that contain or 5 || constitute Protected Material remain subject to this Protective Order as set forth in 6 |! Section 4 (DURATION). 7 8 9 10 {1 12 13 i4 15 16 17 18 19 20 21 22 23 24 25 26 27 28 aa

1 |} 14. VIOLATION 2 || Any violation of this Order may be punished by appropriate measures including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 | DATED 9/18/2020 7 g /s/ Hani Ganji 9 Attorneys for Plaintiff

10 ll DATED: 9/18/2020 12 13 /s/ Lisa A. Satter 4 Attorneys for Defendant

15 16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 || DATED: September 21, 2020 19 20 /s/ 21 United States Mavisnate ludge 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4], [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that 7 || was issued by the United States District Court for the Central District of California 8 || on [date] in the case of [insert formal name of the case and the 9 || number and initials assigned to it by the court]. I agree to comply with and to be 10 || bound by all the terms of this Stipulated Protective Order and I understand and 11 || acknowledge that failure to so comply could expose me to sanctions and punishment {2 |} in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 || any information or item that is subject to this Stipulated Protective Order to any 14 || person or entity except in strict compliance with the provisions of this 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 |} | 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 26 || Printed name: 27 28 {| Signature:

2 I am employed in the aforesaid county; I am over the age of eighteen years 3 and not a party to the within entitled action; my business address is: 23326 Hawthorne Boulevard, Suite 320, Torrance, California 90505. 4 5 On September 18, 2020, I served the within [Proposed] Stipulated Protective Order on the interested parties in said action by placing [X] a true and correct copy 6 or [] the original thereof enclosed in a sealed envelope, and addressed as set forth 7 on the attached Service List and delivered by one or more of the means set forth below: 8 9 [] [VIA MAIL] By depositing said envelope with postage thereon fully prepaid in the United States mail at Torrance, California. I am "readily familiar" with 10 the firm's practice of collection and processing correspondence for mailing. 11 Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Torrance, California, in the 12 ordinary course of business. I am aware that on motion of the party served, 13 service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 14 15 [x] [EMAIL] I caused the above referenced document(s) to be delivered to the email address(es) set forth on the attached Service List. 16 17 [] [FACSIMILE] , I caused the above referenced document(s) to be delivered to the facsimile telephone number(s) on attached service list. 18 19 [] [OVERNIGHT DELIVERY] I caused the above referenced document(s) to be delivered vi FEDERAL EXPRESS to the addressee(s) set forth on the 20 attached Service List. 21 Executed on September 18, 2020, at Torrance, California. 22 [X] (FEDERAL) I declare that I am employed in the office of a member of the bar 23 of this court at whose direction the service was made. 24 25 /s/ Maria Nixon 26 MARIA NIXON 27 28 2 Counsel Representing: 3 Ramin Kermani-Nejad, Esq. Attorneys for Plaintiff, LINA rk@kermanillp.com NOORY 4 Mohamad Ahmad, Esq. ma@kermanillp.com 5 Hani Ganji, Esq. hg@kermanillp.com 6 Kermani, LLP 2719 Wilshire Boulevard, Suite 200 7 Santa Monica, CA 90403 Tel: 424/253-4254 8 Fax: 888/959-8749 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28