1 WOODRUFF, SPRADLIN & SMART, APC CAROLINE A. BYRNE – State Bar No. 196541 2 [email protected] JEANNE L. TOLLISON – State Bar No. 238970 3 [email protected] 555 Anton Boulevard, Suite 1200 4 Costa Mesa, California 92626-7670 Telephone: (714) 558-7000 5 Facsimile: (714) 835-7787 6 Attorneys for Defendant CITY OF GARDEN GROVE, a public entity 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 DIECENIA CHAVEZ and RAFAEL CASE NO.: 8:20-cv-01589 JVS (ADSx) CHAVEZ, Plaintiffs, and as Successors- 12 in-Interest for Decedent RAFAEL BEFORE THE HONORABLE CHAVEZ FRANCO, JAMES V. SELNA 13 COURTROOM 10C Plaintiffs, 14 “DISCOVERY MATTER” v. 15 STIPULATION RE: [PROPOSED] CITY OF GARDEN GROVE, CITY PROTECTIVE ORDER 16 OF WESTMINSTER, and DOES 1 through 10, inclusive, HEARING DATES PENDING: 17 Type: Final Pretrial Conference Defendants. Date: December 20, 2021 18 Time: 11:00 a.m. 19 Type: Trial Date: January 11, 2022 20 Time: 8:30 a.m. 21 22 Plaintiffs DIECENIA CHAVEZ and RAFAEL CHAVEZ and Defendant CITY 23 OF GARDEN GROVE, a public entity, by and through their respective counsel, 24 hereby stipulate and agree as follows: 25 1. PURPOSES AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential, 27 proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 1 Accordingly, the parties hereby stipulate to and petition the Court to enter the 2 following Stipulated Protective Order. The parties acknowledge that this Order does 3 not confer blanket protections on all disclosures or responses to discovery and that the 4 protection it affords from public disclosure and use extends only to the limited 5 information or items that are entitled to confidential treatment under the applicable 6 legal principles. 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 Stipulated Protective Order does not automatically entitle them to file confidential 9 information under seal and that Local Civil Rule 79-5 sets forth the procedures that 10 must be followed and the standards that will be applied when a party seeks permission 11 from the Court to file material under seal. The parties agree that this protective order 12 does not waive the parties’ rights to object to discovery demands or requests for 13 documents and/or information. 14 2. DEFINITIONS 15 2.1 Action: Chavez, et al. v. City of Garden Grove, et al. 8:20-cv-01589- 16 JVS. 17 2.2 Challenging Party: A Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 Cause Statement. This also includes (1) any information copied or extracted from the 23 Confidential information; (2) all copies, excerpts, summaries, abstracts or 24 compilations of Confidential information; and (3) any testimony, conversations, or 25 presentations that might reveal Confidential information. 26 2.4 Counsel: Counsel of record for the parties to this civil litigation and their 27 support staff. 1 items that it produces in disclosures or in responses to discovery as 2 “CONFIDENTIAL.” 3 2.6 Disclosure or Discovery Material: all items or information, regardless 4 of the medium or manner in which it is generated, stored, or maintained (including, 5 among other things, testimony, transcripts, and tangible things), that are produced or 6 generated in disclosures or responses to discovery in this matter. 7 2.7 Expert: a person with specialized knowledge or experience in a matter 8 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 9 expert witness or as a consultant in this Action. 10 2.8 Final Disposition: when this Action has been fully and completely 11 terminated by way of settlement, dismissal, trial and/or appeal. 12 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph 13 2.4) and who are employees of a party to this Action. 14 2.10 Non-Party: any natural person, partnership, corporation, association or 15 other legal entity not named as a Party to this action. 16 2.11 Outside Counsel of Record: attorneys who are not employees of a party 17 to this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm that has 19 appeared on behalf of that party, and includes support staff. 20 2.12 Party: any party to this Action, including all of its officers, directors, 21 boards, departments, divisions, employees, consultants, retained experts, and Outside 22 Counsel of Record (and their support staffs). 23 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.14 Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 1 2.15 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.16 Receiving Party: A Party that receives Disclosure or Discovery Material 4 from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 Protected Material (as defined above), but also (1) any information copied or extracted 8 from Protected Material; (2) all copies, excerpts, abstracts, summaries, or 9 compilations of Protected Material; and (3) any deposition testimony, conversations, 10 or presentations by Parties or their Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial shall be governed by the orders of the trial 12 judge. This Order does not govern the use of Protected Material at trial. 13 4. DURATION 14 Once a trial commences in this Action, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this protective order and that is 16 introduced or admitted as an exhibit at trial becomes public and will be presumptively 17 available to all members of the public, including the press, unless compelling reasons 18 supported by specific factual findings to proceed otherwise are made to the trial judge 19 in advance of the trial. See Kamakana v. City and County of Honolulu,

, 20 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents 21 produced in discovery from “compelling reasons” standard when merits-related 22 documents are part of court record). Accordingly, the terms of this protective order do 23 not extend beyond the commencement of the trial as to the CONFIDENTIAL 24 information and materials introduced or admitted as an exhibit at trial. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for 27 Protection. 1 under this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items or oral or written 4 communications that qualify so that other portions of the material, documents, items 5 or communications for which protection is not warranted are not swept unjustifiably 6 within the ambit of this Order. 7 Mass, indiscriminate or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a 24 similar effect, and that includes the case name and case number (hereinafter 25 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 26 portion of the material on a page qualifies for protection, the Producing Party also 27 must clearly identify the protected portion(s) (e.g., by making appropriate markings in 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and before 4 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 7 portions thereof, qualify for protection under this Order. Then, before producing the 8 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 9 to each page that contains Protected Material. If only a portion of the material on a 10 page qualifies for protection, the Producing Party also must clearly identify the 11 protected portion(s) (e.g., by making appropriate markings in the margins). 12 (b) for testimony given in depositions that the Designating Party identifies the 13 Disclosure or Discovery Material on the record, before the close of the deposition all 14 protected testimony. 15 (c) for information produced in some form other than documentary and for any 16 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 is stored the legend 18 “CONFIDENTIAL.” If only a portion or portions of the information warrants 19 protection, the Producing Party, to the extent practicable, shall identify the protected 20 portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure 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. 24 Upon timely correction of a designation, the Receiving Party must make reasonable 25 efforts to assure that the material is treated in accordance with the provisions of this 26 Order. 27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 1 designation of confidentiality at any time that is consistent with the Court’s 2 Scheduling Order. 3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 4 resolution process under Local Rule 37.1 et seq. 5 6.3 The burden of persuasion in any such challenge proceeding shall be on 6 the Designating Party. Frivolous challenges, and those made for an improper purpose 7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 8 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 9 withdrawn the confidentiality designation, all parties shall continue to afford the 10 material in question the level of protection to which it is entitled under the Producing 11 Party’s designation until the Court rules on the challenge. 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under the 17 conditions described in this Order. When the Action has been terminated, a Receiving 18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 25 only to: 26 (a) the Receiving Party’s Counsel of Record in this Action, as well as 27 employees of said Counsel of Record to whom it is reasonably necessary to disclose 1 (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure 2 is reasonably necessary for this Action and who have signed the “Acknowledgment 3 and Agreement to Be Bound” (Exhibit A); 4 (c) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 7 to whom disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or a 10 custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in the 12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 13 requests that the witness sign the form attached as Exhibit “A” hereto; and (2) they 14 will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit “A”), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may be 18 separately bound by the court reporter and may not be disclosed to anyone except as 19 permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, mutually 21 agreed upon by any of the parties engaged in settlement discussions and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 23 7.3. Counsel making the disclosure to any qualified person described herein 24 shall retain the original executed copy of the Nondisclosure Agreement until sixty (60) 25 days after this litigation has become final, including any appellate review, and 26 monitoring of an injunction. Counsel for the Receiving Party shall maintain all signed 27 Nondisclosure Agreements and shall produce the original signature page upon 1 purported unauthorized disclosure of Confidential Information, upon noticed motion 2 of contempt filed by the Designating Party, counsel for the Receiving Party may be 3 required to file the signed Nondisclosure Agreements, as well as a list of the disclosed 4 materials, in camera with the Court having jurisdiction of the Stipulation. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 6 IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification shall 11 include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order to 13 issue in the other litigation that some or all of the material covered by the subpoena or 14 order is subject to this Protective Order. Such notification shall include a copy of this 15 Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued by 17 the Designating Party whose Protected Material may be affected. 18 The Party served with the subpoena or court order shall not produce any 19 information designated in this action as “CONFIDENTIAL”, unless the Party has 20 obtained the Designating Party’s permission or an order from the court from which the 21 subpoena or order issued. Nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 23 directive from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a Non- 27 Party in this Action and designated as “CONFIDENTIAL.” Such information 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a 9 confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a 12 reasonably specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 16 days of receiving the notice and accompanying information, the Receiving Party may 17 produce the Non-Party’s confidential information responsive to the discovery request. 18 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 19 any information in its possession or control that is subject to the confidentiality 20 agreement with the Non-Party before a determination by the court. Absent a court 21 order to the contrary, the Non-Party shall bear the burden and expense of seeking 22 protection in this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 1 persons to whom unauthorized disclosures were made of all the terms of this Order, 2 and (d) request such person or persons to execute the “Acknowledgment and 3 Agreement to Be Bound” that is attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other protection, 8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 may be established in an e-discovery order that provides for production without prior 11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 parties reach an agreement on the effect of disclosure of a communication or 13 information covered by the attorney-client privilege or work product protection, the 14 parties may incorporate their agreement in the stipulated protective order submitted to 15 the court. 16 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 18 person to seek its modification by the Court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 Protective Order, no Party waives any right it otherwise would have to object to 21 disclosing or producing any information or item on any ground not addressed in this 22 Stipulated Protective Order. Similarly, no Party waives any right to object on any 23 ground to use in evidence of any of the material covered by this Protective Order. 24 12.3 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 26 only be filed under seal pursuant to a court order authorizing the sealing of the 27 specific Protected Material at issue. If a Party’s request to file Protected Material 1 the public record unless otherwise instructed by the court. 2 13. FINAL DISPOSITION 3 After the FINAL DISPOSITION of this Action, as defined in paragraph 2.8, 4 within 30 days of a written request by the Designating Party, each Receiving Party 5 must return all Protected Material to the Producing Party. As used in this subdivision, 6 “all Protected Material” includes all copies, abstracts, compilations, summaries, and 7 any other format reproducing or capturing any of the Protected Material. The 8 Receiving Party must submit a written certification to the Producing Party (and, if not 9 the same person or entity, to the Designating Party) by the 30-day deadline that (1) 10 identifies (by category, where appropriate) all the Protected Material that was returned 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. 14 14. VIOLATION 15 Any violation of this Order may be punished by appropriate measures 16 including, without limitation, contempt proceedings and/or monetary sanctions. 17 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 19 20 DATED: February 2, 2021 CARRILLO LAW FIRM, LLP 21 22 By:/s/ J. Miguel Flores ___________________ MICHAEL S. CARRILLO 23 J. MIGUEL FLORES 24 Attorneys for Plaintiffs 25 26 27 1 DATED: February 2, 2021 WOODRUFF, SPRADLIN & SMART, APC 2 3 By:/s/ Jeanne L. Tollison___________________ CAROLINE A. BYRNE 4 JEANNE L. TOLLISON 5 Attorneys for Defendant CITY OF GARDEN GROVE, a public entity 6 7 8 Pursuant to local 5-4.3.4, I, Jeanne L. Tollison, attest that J. Miguel Flores 9 concurs with the content of this joint stipulation and has authorized the filing of the 10 same. 11 DATED: February 2, 2021 WOODRUFF, SPRADLIN & SMART, APC 12 13 By:/s/ Jeanne L. Tollison___________________ CAROLINE A. BYRNE 14 JEANNE L. TOLLISON 15 Attorneys for Defendant CITY OF GARDEN GROVE, a public entity 16 17 18 19 PURSUANT TO STIPULATION, IT IS SO ORDERED 20 21 22 DATED: February _5__, 2021 ______/s_/_ A__u_tu_m__n_ D__. _S_p_a_et_h__________ 23 Autumn D. Spaeth, Magistrate United States District Court 24 25 26 27 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 6 penalty of perjury that I have read in its entirety and understand the Stipulated 7 Protective Order that was issued by the United States District Court for the Central 8 District of California on _____________ in the case of Chavez, et al. v. City of 9 Garden Grove, et al., United States District Court Case No. 8:20-cv-01589JVS. I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 12 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 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print or 19 type full name] of _______________________________________ [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated 23 24 Protective Order. 25 Date: ______________________________________ 26 City and State where sworn and signed: _________________________________ 27 Printed name: _______________________________ Signature: _________________________________ 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF ORANGE 3 I am over the age of 18 and not a party to the within action; I am employed by WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 Anton 4 || Boulevard, Suite 1200, Costa Mesa, CA 92626-7670. 5 On February 4, 2021, I served the toregoine. document(s) described as: ‘ STIPULATION RE: [PROPOSED] PROTECTIVE ORDER Ll by placing the true copies thereof enclosed in sealed envelopes addressed as 7 stated on the attached mailing list; 8 1} O (BY MAIL) I placed said envelope(s) for collection and mailing. following ordinary business practices, at the business offices of OODRUFF, 9 SPRADLIN & SMART, and addressed as shown on the attached service list, for deposit in the United States Postal Service. I am readily familiar with the 10 practice of WOODRUFF, SPRADLIN & SMART for collection and processing correspondence for mailing with the United States Postal Service, and sai 11 envelope(s) will be deposited with the United States Postal Service on said date in the ordinary course of business. (BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be 13 electronically filed using the Court’s Electronic Piling ystem which constitutes service of the filed document(s) on the individual(s) listed on the attached «14 mailing list. §15|/0 (wy OVERNIGHT DELIVERY) I placed said documents in envelope(s) for collection tollowing ordinary business practices, at the business offices of 16 WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached service list, for collection and delivery to a courier authorized by 17 __ to receive said documents, with delivery fees provided for. I am readily familiar with the practices of WOODRUFF, 18 PRADLIN & SMART for collection and processing of documents for overnight delivery, and said envelope(s) will be deposited for receipt by 19 on said date in the ordinary course of business. 20 |} (BY FACSIMILE) I caused the above-referenced document to be transmitted to the interested parties via facsimile transmission to the fax number(s) as stated 21 on the attached service list. 22 (BY PERSONAL SERVICE) I delivered such envelope(s) by hand to the 53 offices of the addressee(s). (Federal) I declare that I am employed in the office of a member of the bar of 24 this court at whose direction the service was made. I declare under 35 penalty of perjury that the above is true and correct.

Executed on February 4, 2021, at Costa Mesa, California.

27 /s/ Diane Castillo DIANE CASTILLO 28 1z=0

1 DIECENIA CHAVEZ, et al. v. CITY OF GARDEN GROVE, et al. 2 USDC, CENTRAL DISTRICT OF CALIFORNIA CASE NO. 8:20-cv-01589 JVS (ADSx) 3 BEFORE THE HONORABLE 4 JAMES V. SELNA COURTROOM 10C 5 SERVICE LIST 6 7 Luis A. Carrillo, Esq. Attorneys for Plaintiffs Michael S. Carrillo, Esq. DIECENIA CHAVEZ and RAFAEL 8 CARRILLO LAW FIRM, LLP CHAVEZ, Plaintiffs, and as 1499 Huntington Drive, Suite 402 Successors-in-Interest for Decedent 9 South Pasadena, CA 91030 RAFAEL CHAVEZ FRANCO Telephone: (626) 799-9375 10 Facsimile: (626) 799-9380 Email: [email protected] 11 [email protected] 12 13 14 15 12/10/20 16 17 18 19 20 21 22 23 24 25 26 27