1 DAVID R. FISHER, ESQ. (SBN 119773) JEFFREY R. KLEIN, ESQ. (SBN 273310) 2 FISHER & WOLFE, LLP 9401 Wilshire Boulevard, Suite 640 3 Beverly Hills, California 90212-2913 Telephone: (310) 278-4300 4 Facsimile: (310) 278-5430 E-mail: [email protected] 5 Attorneys for Defendants Sky High 6 Investment Company LLC, Morad Ben Neman and Neman Real Estate 7 Investments, LLC

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DISTRICT 10 THE TRAVELERS INDEMNITY CASE NO.: 2:19-cv-08706-JFW (SPx) 11 COMPANY OF CONNECTICUT, a Connecticut Corporation, STIPULATED PROTECTIVE 12 ORDER Plaintiffs, 13 v. 14 SKY HIGH INVESTMENT COMPANY 15 LLC, a California Limited Liability Complaint October 9, 2019 Company, MORAD BEN NEMAN, an Filed: 16 individual, NEMAN REAL ESTATE INVESTMENTS, LLC, a California 17 Limited Liability Company, and DOES 1- 10, 18 Defendants. 19 1. 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 pursuing 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 it 26 affords from public disclosure and use extends only to the limited information or items 27 that are entitled to confidential treatment under the applicable legal principles. 1 2. GOOD CAUSE STATEMENT 2 This Action is likely to involve trade secrets, customer and pricing lists and other 3 valuable research, development, commercial, financial, technical and/or proprietary 4 information for which special protection from public disclosure and from use for any 5 purpose other than prosecution of this Action is warranted. Such confidential and 6 proprietary materials and information consist of, among other things, confidential 7 business or financial information, information regarding confidential business practices, 8 or other confidential research, development, or commercial information (including 9 information implicating privacy rights of third parties), information otherwise generally 10 unavailable to the public, or which may be privileged or otherwise protected from 11 disclosure under state or federal statutes, court rules, case decisions, or common law. 12 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 13 disputes over confidentiality of discovery materials, to adequately protect information 14 the parties are entitled to keep confidential, to ensure that the parties are permitted 15 reasonable necessary uses of such material in preparation for and in the conduct of trial, 16 to address their handling at the end of the litigation, and serve the ends of justice, a 17 protective order for such information is justified in this matter. It is the intent of the 18 parties that information will not be designated as confidential for tactical reasons and 19 that nothing be so designated without a good faith belief that it has been maintained in a 20 confidential, non-public manner, and there is good cause why it should not be part of the 21 public record of this case. 22 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 23 The parties further acknowledge, as set forth in Section 14.3, below, that this 24 Stipulated Protective Order does not entitle them to file confidential information under 25 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 26 standards that will be applied when a party seeks permission from the court to file 27 material under seal. There is a strong presumption that the public has a right of access to 1 motions, good cause must be shown to support a filing under seal. See Kamakana v. City 2 and County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 3 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 4

(E.D. Wis. 1999) (even stipulated protective orders require good 5 cause showing), and a specific showing of good cause or compelling reasons with proper 6 evidentiary support and legal justification, must be made with respect to Protected 7 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure 8 or Discovery Material as CONFIDENTIAL does not— without the submission of 9 competent evidence by declaration, establishing that the material sought to be filed under 10 seal qualifies as confidential, privileged, or otherwise protectable—constitute good 11 cause. 12 Further, if a party requests sealing related to a dispositive motion or trial, the 13 compelling reasons, not only good cause, for the sealing must be shown, and the relief 14 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 15 v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item or type 16 of information, document, or thing sought to be filed or introduced under seal, the party 17 seeking protection must articulate compelling reasons, supported by specific facts and 18 legal justification, for the requested sealing order. Again, competent evidence supporting 19 the application to 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 be 24 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 4. DEFINITIONS 27 4.1. Action: this pending federal lawsuit. 1 information or items under this Order. 2 4.3. “CONFIDENTIAL” Information or Items: information (regardless of how 3 it is generated, stored or maintained) or tangible things that qualify for protection under 4 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 5 Statement. 6 4.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 7 support staff). 8 4.5. Designating Party: a Party or Non-Party that designates information or 9 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 10 4.6. Disclosure or Discovery Material: all items or information, regardless of 11 the medium or manner in which it is generated, stored, or maintained (including, among 12 other things, testimony, transcripts, and tangible things), that are produced or generated 13 in disclosures or responses to discovery in this matter. 14 4.7. Expert: a person with specialized knowledge or experience in a matter 15 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 16 expert witness or as a consultant in this Action. 17 4.8. House Counsel: attorneys who are employees of a party to this Action. 18 House Counsel does not include Outside Counsel of Record or any other outside counsel. 19 4.9. Non-Party: any natural person, partnership, corporation, association, or 20 other legal entity not named as a Party to this Action. 21 4.10. Outside Counsel of Record: attorneys who are not employees of a party to 22 this Action but are retained to represent or advise a party to this Action and have 23 appeared in this Action on behalf of that party or are affiliated with a law firm that has 24 appeared on behalf of that party or are affiliated with a law firm that has appeared on 25 behalf of that party, and includes support staff. 26 4.11. Party: any party to this Action, including all of its officers, directors, 27 employees, consultants, retained experts, and Outside Counsel of Record (and their 1 4.12. Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 4.13. Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 6 their employees and subcontractors. 7 4.14. Protected Material: any Disclosure or Discovery Material that is designated 8 as “CONFIDENTIAL.” 9 4.15. Receiving Party: a Party that receives Disclosure or Discovery Material 10 from a Producing Party. 11 5. SCOPE 12 The protections conferred by this Stipulation and Order cover not only Protected 13 Material (as defined above), but also (1) any information copied or extracted from 14 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 15 Material; and (3) any testimony, conversations, or presentations by Parties or their 16 Counsel that might reveal Protected Material. 17 Any use of Protected Material at trial shall be governed by the orders of the trial 18 judge and other applicable authorities. This Order does not govern the use of Protected 19 Material at trial. 20 6. DURATION 21 Once a case proceeds to trial, information that was designated as 22 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 23 an exhibit at trial becomes public and will be presumptively available to all members of 24 the public, including the press, unless compelling reasons supported by specific factual 25 findings to proceed otherwise are made to the trial judge in advance of the trial. See 26 Kamakana,

(distinguishing “good cause” showing for sealing 27 documents produced in discovery from “compelling reasons” standard when merits- 1 order do not extend beyond the commencement of the trial. 2 7. DESIGNATING PROTECTED MATERIAL 3 7.1. Exercise of Restraint and Care in Designating Material for Protection. Each 4 Party or Non-Party that designates information or items for protection under this Order 5 must take care to limit any such designation to specific material that qualifies under the 6 appropriate standards. The Designating Party must designate for protection only those 7 parts of material, documents, items, or oral or written communications that qualify so 8 that other portions of the material, documents, items, or communications for which 9 protection is not warranted are not swept unjustifiably within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations that 11 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 12 to unnecessarily encumber or retard the case development process or to impose 13 unnecessary expenses and burdens on other parties) expose the Designating Party to 14 sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the mistaken designation. 18 7.2. Manner and Timing of Designations. Except as otherwise provided in this 19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 20 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 21 must be clearly so designated before the material is disclosed or produced. 22 Designation in conformity with this Order requires: 23 (a) for information in documentary form (e.g., paper or electronic 24 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 25 that the Producing Party affix the legend “CONFIDENTIAL” to each page that contains 26 protected material. If only a portion or portions of the material on a page qualifies for 27 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 1 A Party or Non-Party that makes original documents or materials available for 2 inspection need not designate them for protection until after the inspecting Party has 3 indicated which material it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for inspection shall be deemed 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or portions 7 thereof, qualify for protection under this Order. Then, before producing the specified 8 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 9 that contains Protected Material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly identify the protected 11 portion(s) (e.g., by making appropriate markings in the margins). 12 (b) for testimony given in deposition or in other pretrial or trial proceedings, 13 that the Designating Party identify on the record, before the close of the deposition, 14 hearing, or other proceeding, all protected testimony. 15 (c) for information produced in some form other than documentary and for 16 any other tangible items, that the Producing Party affix in a prominent place on the 17 exterior of the container or containers in which the information or item is stored the 18 legend “CONFIDENTIAL.” If only a portion or portions of the information or item 19 warrant protection, the Producing Party, to the extent practicable, shall identify the 20 protected portion(s). 21 7.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 22 to designate qualified information or items does not, standing alone, waive the 23 Designating Party’s right to secure protection under this Order for such material. Upon 24 timely correction of a designation, the Receiving Party must make reasonable efforts to 25 assure that the material is treated in accordance with the provisions of this Order. 26 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 27 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 1 8.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution 2 process under Local Rule 37-1 et seq. 3 8.3. Joint Stipulation. Any challenge submitted to the Court shall be via a joint 4 stipulation pursuant to Local Rule 37-2. 5 8.4. The burden of persuasion in any such challenge proceeding shall be on the 6 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 7 to harass or impose unnecessary expenses and burdens on other parties) may expose the 8 Challenging Party to sanctions. Unless the Designating Party has waived the 9 confidentiality designation by failing to file a motion to retain confidentiality as 10 described above, all parties shall continue to afford the material in question the level of 11 protection to which it is entitled under the Producing Party’s designation until the court 12 rules on the challenge. 13 9. ACCESS TO AND USE OF PROTECTED MATERIAL 14 9.1. Basic Principles. A Receiving Party may use Protected Material that is 15 disclosed or produced by another Party or by a Non-Party in connection with this Action 16 only for prosecuting, defending, or attempting to settle this Action. Such Protected 17 Material may be disclosed only to the categories of persons and under the conditions 18 described in this Order. When the Action has been terminated, a Receiving Party must 19 comply with the provisions of section 15 below (FINAL DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Order. 23 9.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 24 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 25 may disclose any information or item designated “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 27 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 1 (b) the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff, 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 10 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information. 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 16 not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 18 by the Designating Party or ordered by the court. Pages of transcribed deposition 19 testimony or exhibits to depositions that reveal Protected Material may be separately 20 bound by the court reporter and may not be disclosed to anyone except as permitted 21 under this Stipulated Protective Order; and 22 (i) any mediators or settlement officers and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 25 OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation that 27 compels disclosure of any information or items designated in this Action as 1 (a) promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to issue 4 in the other litigation that some or all of the material covered by the subpoena or order 5 is subject to this Protective Order. Such notification shall include a copy of this 6 Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued by 8 the Designating Party whose Protected Material may be affected. If the Designating 9 Party timely seeks a protective order, the Party served with the subpoena or court order 10 shall not produce any information designated in this Action as “CONFIDENTIAL” 11 before a determination by the court from which the subpoena or order issued, unless the 12 Party has obtained the Designating Party’s permission. The Designating Party shall bear 13 the burden and expense of seeking protection in that court of its confidential material – 14 and nothing in these provisions should be construed as authorizing or encouraging a 15 Receiving Party in this Action to disobey a lawful directive from another court. 16 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 17 IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a Non-Party 19 in this Action and designated as “CONFIDENTIAL.” Such information produced by 20 Non-Parties in connection with this litigation is protected by the remedies and relief 21 provided by this Order. Nothing in these provisions should be construed as prohibiting a 22 Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery request, to produce a 24 Non-Party’s confidential information in its possession, and the Party is subject to an 25 agreement with the Non-Party not to produce the Non-Party’s confidential information, 26 then the Party shall: 27 (1) promptly notify in writing the Requesting Party and the Non-Party that 1 Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective 2 Order in this litigation, the relevant discovery request(s), and a reasonably specific 3 description of the information requested; and 4 (3) make the information requested available for inspection by the Non- 5 Party. 6 (c) If the Non-Party fails to object or seek a protective order from this court within 7 14 days of receiving the notice and accompanying information, the Receiving Party may 8 produce the Non-Party’s confidential information responsive to the discovery request. If 9 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 10 information in its possession or control that is subject to the confidentiality agreement 11 with the Non-Party before a determination by the court. Absent a court order to the 12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 13 court of its Protected Material. 14 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 19 all unauthorized copies of the Protected Material, (c) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 21 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 22 that is attached hereto as Exhibit A. 23 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, the 27 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 1 established in an e-discovery order that provides for production without prior privilege 2 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 3 an agreement on the effect of disclosure of a communication or information covered by 4 the attorney-client privilege or work product protection, the parties may incorporate their 5 agreement in the stipulated protective order submitted to the court. 6 14. MISCELLANEOUS 7 14.1. Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the court in the future. 9 14.2. Right to Assert Other Objections. By stipulating to the entry of this 10 Protective Order no Party waives any right it otherwise would have to object to 11 disclosing or producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 13 to use in evidence of any of the material covered by this Protective Order. 14 14.3. Filing Protected Material. A Party that seeks to file under seal any Protected 15 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 16 under seal pursuant to a court order authorizing the sealing of the specific Protected 17 Material. If a Party’s request to file Protected material under seal is denied by the court, 18 then the Receiving Party may file the information in the public record unless otherwise 19 instructed by the court. 20 15. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 6, within 60 22 days of a written request by the Designating Party, each Receiving Party must return all 23 Protected Material to the Producing Party or destroy such material. As used in this 24 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected Material. 26 Whether the Protected Material is returned or destroyed, the Receiving Party must 27 submit a written certification to the Producing Party (and, if not the same person or 1 where appropriate) all the Protected Material that was returned or destroyed and (2) 2 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 3 summaries or any other format reproducing or capturing any of the Protected Material. 4 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 5 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 6 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 7 consultant and expert work product, even if such materials contain Protected Material. 8 Any such archival copies that contain or constitute Protected Material remain subject to 9 this Protective Order as set forth in Section 6 (DURATION). 10 16. VIOLATION 11 Any violation of this Order may be punished by appropriate measures including, 12 without limitation, contempt proceedings and/or monetary sanctions. 13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 Dated: June 17, 2020 CLYDE & CO US LLP 15

16 By: /s/Yevgenia Altman Wiener 17 Alexander E. Potente Yevgenia Altman Wiener 18 Attorneys for Plaintiff The Travelers Indemnity Company of Connecticut 19 20 Dated: June 17, 2020 FISHER & WOLFE LLP 21

22 By: /s/ 23 David R. Fisher Attorneys for Defendants Sky High Investments 24 Company, LLC, Morad Ben Neman, and Neman Real Estate Investments, LLC 25

26

27 PURSUANT TO STIPULATION, IT IS SO ORDERED 1

2

3 Dated: June 22, 2020 ___ Hon. Sheri Pym 4 United States Magistrate Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EXHIBIT A 1

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury that I have read in 5 its entirety and understand the Stipulated Protective Order that was issued by the United 6 States District Court for the Central District of California on [date] in the case of The 7 Travelers Indemnity Company of Connecticut v. Sky High Investment Company, LLC, 8 Morad Ben Neman and Neman Real Estate Investments, LLC, USDC Case No. 2:19-cv- 9 08706-JFW (SPx). 10 I agree to comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so comply could 12 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 13 that I will not disclose in any manner any information or item that is subject to this 14 Stipulated Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for 17 the Central District of California for the purpose of enforcing the terms of this Stipulated 18 Protective Order, even if such enforcement proceedings occur after termination of this 19 Action. 20 21 Date: 22 City and State where sworn and signed: 23 Print Name: 24 Signature:

25 26 27 PROOF OF SERVICE 1 STATE OF CALIFORNIA ) 2 ) SS. COUNTY OF LOS ANGELES ) 3 I am employed in the County of Los Angeles, State of California. I am over the age 4 of 18 years and not a party to the within action; my business address is 9401 Wilshire Boulevard, Suite 640, Beverly Hills, California 90212. 5 On June 19, 2020, I served the foregoing document(s) described as: on the 6 interested parties in this action as follows: [PROPOSED] STIPULATED PROTECTIVE ORDER 7 BY CM/ECF NOTICE OF ELECTRONIC FILING. By causing such 8 document(s) listed above to be served through this Court’s electronic transmission facilities via the Notice of Electronic Filing (NEF) and hyperlink, to the parties and/or 9 counsel who are determined this date to be registered CM/ECF Users set forth in the service listed obtained from this Court on the Electronic Mail Notice List. 10 Electronic Mail Notice List. The following is the list of parties who are currently 11 on the list to receive email notice/service for this case.

12 Alexander E. Potente, Esq. Attorneys for Plaintiffs [email protected] The Travelers Indemnity Company 13 of Connecticut Yevgenia Altman Wiener, Esq. 14 [email protected]

15

16 I declare that I am employed in the office of a member of this bar of this court at 17 whose direction the service was made.

18

19 Executed on June 19, 2020, at Beverly Hills, California.

20

21 LINDA F. COLLINS 22

23

24 25 26 27