1 CINDY M. RUCKER (SBN 272465) [email protected] 2 MAYNARD, COOPER & GALE, LLP 3 1901 Avenue of the Stars, Suite 1900 Los Angeles, CA 90067 4 Telephone: (323)987-3356 5 Facsimile: (205) 254-1999 6 Attorney for Defendant 7 PRINCIPAL LIFE INSURANCE COMPANY 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 HAMID ZEHTAB, an individual, CASE NO. 8:19-CV-01649-JLS-KES 12 Plaintiff, ORDER RE 13 vs. STIPULATED PROTECTIVE ORDER 14 PRINCIPAL LIFE INSURANCE 15 COMPANY; and DOES 1 through 10 16 inclusive, 17 Defendants. 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public disclosure 22 and from use for any purpose other than prosecuting this litigation may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 24 Stipulated Protective Order. The parties acknowledge that this Order does not confer 25 blanket protections on all disclosures or responses to discovery and that the protection 26 it affords from public disclosure and use extends only to the limited information or 27 items that are entitled to confidential treatment under the applicable legal principles. 28 1 B. GOOD CAUSE STATEMENT 2 The parties anticipate producing certain confidential documents or information 3 in connection with discovery in this matter. Such confidential and proprietary 4 materials and information consist of, among other things, confidential business 5 information, information regarding confidential business practices, or other 6 commercial information, information otherwise generally unavailable to the public, or 7 which may be privileged or otherwise protected from disclosure under state or federal 8 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow 9 of 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 preparation for and in the conduct of trial, to address their handling at the 13 end of the litigation, and serve the ends of justice, a protective order for such 14 information is justified in this matter. It is the intent of the parties that information will 15 not be designated as confidential for tactical reasons and that nothing be so designated 16 without a good faith belief that it has been maintained in a confidential, non-public 17 manner, and there is good cause why it should not be part of the public record of this 18 case. 19 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 20 SEAL 21 The parties further acknowledge, as set forth in Section 12.3, below, that this 22 Stipulated Protective Order does not entitle them to file confidential information under 23 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 24 standards that will be applied when a party seeks permission from the court to file 25 material under seal. 26 There is a strong presumption that the public has a right of access to judicial 27 proceedings and records in civil cases. In connection with non-dispositive motions, 28 good cause must be shown to support a filing under seal. See Kamakana v. City and 1 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 2 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 3

(E.D. Wis. 1999) (even stipulated protective orders require good 4 cause showing), and a specific showing of good cause or compelling reasons with 5 proper evidentiary support and legal justification, must be made with respect to 6 Protected Material that a party seeks to file under seal. The parties’ mere designation 7 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 8 submission of competent evidence by declaration, establishing that the material sought 9 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 10 constitute good cause. 11 Further, if a party requests sealing related to a dispositive motion or trial, then 12 compelling reasons, not only good cause, for the sealing must be shown, and the relief 13 sought shall be narrowly tailored to serve the specific interest to be protected. See 14 Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item 15 or type of information, document, or thing sought to be filed or introduced under seal 16 in connection with a dispositive motion or trial, the party seeking protection must 17 articulate compelling reasons, supported by specific facts and legal justification, for 18 the requested sealing order. Again, competent evidence supporting the application to 19 file documents under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable in its 21 entirety will not be filed under seal if the confidential portions can be redacted. If 22 documents can be redacted, then a redacted version for public viewing, omitting only 23 the confidential, privileged, or otherwise protectable portions of the document, shall 24 be filed. Any application that seeks to file documents under seal in their entirety should 25 include an explanation of why redaction is not feasible. 26 2. DEFINITIONS 27 2.1 Action: Hamid Zehtab v. Principal Life Insurance Company, Case No. 28 8:19-CV-01649-JLS-KES 1 2.2 Challenging Party: a Party or Non-Party that challenges the designation 2 of information or items under this Order. 3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 4 how it is generated, stored or maintained) or tangible things that qualify for protection 5 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 6 Statement. 7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 8 support staff). 9 2.5 Designating Party: a Party or Non-Party that designates information or 10 items that it produces in disclosures or in responses to discovery as 11 “CONFIDENTIAL.” 12 2.6 Disclosure or Discovery Material: all items or information, regardless of 13 the medium or manner in which it is generated, stored, or maintained (including, 14 among other things, testimony, transcripts, and tangible things), that are produced or 15 generated in disclosures or responses to discovery in this matter. 16 2.7 Expert: a person with specialized knowledge or experience in a matter 17 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 18 expert witness or as a consultant in this Action. 19 2.8 House Counsel: attorneys who are employees of a party to this Action. 20 House Counsel does not include Outside Counsel of Record or any other outside 21 counsel. 22 2.9 Non-Party: any natural person, partnership, corporation, association or 23 other legal entity not named as a Party to this action. 24 2.10 Outside Counsel of Record: attorneys who are not employees of a party 25 to this Action but are retained to represent or advise a party to this Action and have 26 appeared in this Action on behalf of that party or are affiliated with a law firm that has 27 appeared on behalf of that party, and includes support staff. 28 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) and 8 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 Protected 15 Material (as defined above), but also (1) any information copied or extracted from 16 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 17 Material; and (3) any testimony, conversations, or presentations by Parties or their 18 Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the trial 20 judge. This Order does not govern the use of Protected Material at trial. 21 4. DURATION 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 24 as an exhibit at trial becomes public and will be presumptively available to all members 25 of the public, including the press, unless compelling reasons supported by specific 26 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 27 See Kamakana,

(distinguishing “good cause” showing for sealing 28 documents produced in discovery from “compelling reasons” standard when merits- 1 related documents are part of court record). Accordingly, the terms of this protective 2 order do not extend beyond the commencement of the trial. 3 5. DESIGNATED PROTECTED MATERIAL 4 5.1 Exercise of Restraint and Care in Designating Material for Protection. 5 Each Party or Non-Party that designates information or items for protection under this 6 Order must take care to limit any such designation to specific material that qualifies 7 under the appropriate standards. The Designating Party must designate for protection 8 only those parts of material, documents, items or oral or written communications that 9 qualify so that other portions of the material, documents, items or communications for 10 which protection is not warranted are not swept unjustifiably within the ambit of this 11 Order. 12 Mass, indiscriminate or routinized designations are prohibited. Designations that 13 are shown to be clearly unjustified or that have been made for an improper purpose 14 (e.g., to unnecessarily encumber the case development process or to impose 15 unnecessary expenses and burdens on other parties) may expose the Designating Party 16 to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it 18 designated for protection do not qualify for protection, that Designating Party must 19 promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in this 21 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 22 or ordered, Disclosure or Discovery Material that qualifies for protection under this 23 Order must be clearly so designated before the material is disclosed or produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic documents, 26 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 27 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 28 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 1 portion of the material on a page qualifies for protection, the Producing Party also must 2 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 3 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 before 7 the designation, all of the material made available for inspection shall be deemed 8 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 9 copied and produced, the Producing Party must determine which documents, or 10 portions thereof, qualify for protection under this Order. Then, before producing the 11 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 12 to each page that contains Protected Material. If only a portion of the material on a 13 page qualifies for protection, the Producing Party also must clearly identify the 14 protected portion(s) (e.g., by making appropriate markings in the margins). 15 b. For Testimony given in depositions the Designating Party may either: 16 i. identify on the record, before the close of the deposition, all “Confidential” 17 Testimony, by specifying all portions of the Testimony that qualify as “Confidential;” 18 or 19 ii. designate the entirety of the Testimony at the deposition as “Confidential” 20 (before the deposition is concluded) with the right to identify more specific portions of 21 the Testimony as to which protection is sought within 30 days following receipt of the 22 deposition transcript. In circumstances where portions of the deposition Testimony are 23 designated for protection, the transcript pages containing “Confidential” Information 24 may be separately bound by the court reporter, who must affix to the top of each page 25 the legend “Confidential,” as instructed by the Designating Party. 26 (c) for information produced in some form other than documentary and for 27 any other tangible items, that the Producing Party affix in a prominent place on the 28 exterior of the container or containers in which the information is stored the legend 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). 4 5.3 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 8 to assure that the material is treated in accordance with the provisions of this Order. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 designation of confidentiality at any time that is consistent with the Court’s Scheduling 12 Order. 13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 14 resolution process under Local Rule 37-1 et seq. 15 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 16 stipulation pursuant to Local Rule 37-2. 17 6.4 The burden of persuasion in any such challenge proceeding shall be on 18 the Designating Party. Frivolous challenges, and those made for an improper purpose 19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 20 expose 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 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending or attempting to settle this Action. Such 28 Protected Material may be disclosed only to the categories of persons and under the 1 conditions described in this Order. When the Action has been terminated, a Receiving 2 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 9 only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 12 disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its 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); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 28 not be permitted to keep any confidential information unless they sign the 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 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 9 OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation that 11 compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification shall 14 include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the subpoena or 17 order is subject to this Protective Order. Such notification shall include a copy of this 18 Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 the subpoena or court order shall not produce any information designated in this action 23 as “CONFIDENTIAL” before a determination by the court from which the subpoena 24 or order issued, unless the Party has obtained the Designating Party’s permission. The 25 Designating Party shall bear the burden and expense of seeking protection in that court 26 of its confidential material and nothing in these provisions should be construed as 27 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 28 directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the remedies 6 and relief provided by this Order. Nothing in these provisions should be construed as 7 prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the 19 Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery request. 23 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 24 any information in its possession or control that is subject to the confidentiality 25 agreement with the Non-Party before a determination by the court. Absent a court order 26 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 27 in this court of its Protected Material. 28 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) 8 request such person or persons to execute the “Acknowledgment and Agreement to Be 9 Bound” that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 Stipulated Protective Order. Similarly, no Party waives any right to object on any 1 ground to use in evidence of any of the material covered by this Protective Order. 2 12.3 Filing Protected Material. A Party that seeks to file under seal any 3 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 4 only be filed under seal pursuant to a court order authorizing the sealing of the specific 5 Protected Material at issue. If a Party’s request to file Protected Material under seal is 6 denied by the court, then the Receiving Party may file the information in the public 7 record unless otherwise instructed by the court. 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 4, within 60 10 days of a written request by the Designating Party, each Receiving Party must return 11 all Protected Material to the Producing Party or destroy such material. As used in this 12 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 summaries, and any other format reproducing or capturing any of the Protected 14 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 15 must submit a written certification to the Producing Party (and, if not the same person 16 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 17 category, where appropriate) all the Protected Material that was returned or destroyed 18 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 19 compilations, summaries or any other format reproducing or capturing any of the 20 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 21 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 22 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 23 attorney work product, and consultant and expert work product, even if such materials 24 contain Protected Material. Any such archival copies that contain or constitute 25 Protected Material remain subject to this Protective Order as set forth in Section 4 26 (DURATION). 27 28 1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 We hereby attest that concurrence in the filing of this stipulation was obtained 6 by each of the below identified signatories. 7 DATED: April 29, 2020 MAYNARD COOPER AND GALE LLP 8 9 /s/ Cindy M. Rucker 10 Cindy M. Rucker Attorneys for Defendant 11 PRINCIPAL LIFE INSURANCE COMPANY 12 13 DATED: April 29, 2020 MCKENNON LAW GROUP 14 15 /s/ Robert J. McKennon Robert J. McKennon 16 Attorneys for Plaintiff HAMID ZEHTAB 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 DATED: April 30, 2020 21 HON. KAREN E. SCOTT UNITED STATES DISTRICT JUDGE 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ______________________________ [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 was 7 issued by the United States District Court for the Central District of California on [date] 8 in the case of Hamid Zehtab v Principal Life Insurance Company, Case No. 8:19-CV- 9 01649-JLS-KES. I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order and I understand and acknowledge that failure to so comply could expose 11 me to sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not 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 of 14 this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the 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. I 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: PROOF OF SERVICE 2 STATE OF CALIFORNIA ) 3 || COUNTY OF SAN FRANCISCO ) 4 5 I am employed in the County of San Francisco, State of California. I am over the age of 21 and not a party to the within action. My business address is Maynard, 6 Cooper & Gale, LLP, 600 Montgomery Street, Suite 2600, San Francisco, CA 94111. 7 ||On the date indicated below, I served the foregoing document described as: 8 9 STIPULATED PROTECTIVE ORDER 10 || [X] BY CM/ECF ELECTRONIC SERVICE: The interested party(ies) set forth below are registered CM/ECF users with the Court, and have consented to service through the Court’s automatic transmission of a notice of filing. 12 Robert J. McKennon 13 [email protected] 14 || Andrea Soliz 15 28 @mckennonlawgroup.com McKennon Law Group PC 16 20321 SW Birch Street Suite 200 7 Newport Beach, CA 92660 (949) 387-9595 18 || Fax: (949) 385-5165 19 woe Attorneys for Plaintiff 20 || HAMID ZEHTAB 21 22 I declare that I am employed in the office of a member who has been admitted 73 || to the bar of this Court at whose direction the service was made. I declare under penalty of perjury under the laws of the State of California that the foregoing is true 24 || and correct. 25 ps Executed April 29, 2020 in San Francisco, California: 26 a LA 27 a □ 2 ee 28 Sam Roberson