Michael Feldman v. Venture Agency Holdings, Inc.
Michael Feldman v. Venture Agency Holdings, Inc.
Trial Court Opinion
1 Guillermo M. Tello, Esq., SBN 277896 Alejandro E. Rosa, Esq., SBN 340410 2 CLARK HILL LLP 555 South Flower Street, 24th Floor 3 Los Angeles, CA 90071 Telephone: (213) 891-9100 4 Facsimile: (213) 488-1178 [email protected] 5 [email protected]
6 Attorneys for Defendants CONIFER HOLDINGS, INC., VSRM INSURANCE 7 AGENCY, INC. (formerly known as VENTURE AGENCY HOLDINGS, INC.), JOHN BURES, ROCHELLE 8 KAPLAN-RUDOLPH, and JAMES PETCOFF
9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11
12 MICHAEL FELDMAN, an individual, Case No. 2:23-CV-08951 13 Plaintiff, 14 STIPULATED PROTECTIVE v. ORDER1 15 VENTURE AGENCY HOLDINGS, 16 INC. dba VSRM Insurance Agency, Inc., a Michigan Corporation; 17 CONIFER HOLDINGS, INC. dba VENTURE AGENCY HOLDINGS, 18 INC. dba CONIFER INSURANCE COMPANY, a Michigan 19 Corporation; JOHN BURES, an Individual; JAMES PETCOFF, and 20 Individual; ROCHELL KAPLAN RUDOLPH, an Individual, 21 Defendants. 22
23 24 25 26 27 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 6 Stipulated Protective Order. The parties acknowledge that this Order does not confer 7 blanket protections on all disclosures or responses to discovery and that the protection 8 it affords from public disclosure and use extends only to the limited information or 9 items that are entitled to confidential treatment under the applicable legal principles. 10 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve materials and information from which special 13 protection from public disclosure and from use for any purpose other than prosecution 14 and defense of this action are warranted. Such confidential materials and information 15 consist of, among other things, confidential business and financial information, 16 confidential information regarding business relationships, confidential information 17 regarding business practices, confidential individual financial information, information 18 otherwise generally unacceptable to the public, or which may be privileged or otherwise 19 protected from disclosure under state or federal statutes, court rules, case decisions, or 20 common law. 21 Accordingly, to expedite the flow of information, to facilitate the prompt 22 resolution of disputes over confidentiality of discovery materials, to adequately protect 23 information the parties are entitled to keep confidential, to ensure that the parties are 24 permitted reasonable necessary uses of such material in preparation for and in the 25 conduct of trial, to address their handling at the end of the litigation, and serve the ends 26 of justice, a protective order for such information is justified in this matter. It is the 27 intent of the parties that information will not be designated as confidential for tactical 1 maintained in a confidential, non-public manner, and there is good cause why it should 2 not be part of the public record of this case. 3 4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 5 The parties further acknowledge, as set forth in Section 12.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information under 7 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 8 standards that will be applied when a party seeks permission from the court to file 9 material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu,
447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 14 Corp.,
307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc., 15
187 F.R.D. 576, 577(E.D. Wis. 1999) (even stipulated protective orders require good 16 cause showing), and a specific showing of good cause or compelling reasons with 17 proper evidentiary support and legal justification, must be made with respect to 18 Protected Material that a party seeks to file under seal. The parties’ mere designation 19 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 20 submission of competent evidence by declaration, establishing that the material sought 21 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 22 constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the relief 25 sought shall be narrowly tailored to serve the specific interest to be protected. See 26 Pintos v. Pacific Creditors Ass’n,
605 F.3d 665, 677-79(9th Cir. 2010). For each item 27 or type of information, document, or thing sought to be filed or introduced under seal 1 articulate compelling reasons, supported by specific facts and legal justification, for the 2 requested sealing order. Again, competent evidence supporting the application to file 3 documents under seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in its 5 entirety will not be filed under seal if the confidential portions can be redacted. If 6 documents can be redacted, then a redacted version for public viewing, omitting only 7 the confidential, privileged, or otherwise protectable portions of the document shall be 8 filed. Any application that seeks to file documents under seal in their entirety should 9 include an explanation of why redaction is not feasible. 10 11 2. DEFINITIONS 12 2.1 Action: Michael Feldman v. Venture Agency Holdings, Inc., et al., Case 13 No. 2:23-CV-08951. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for protection 18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 19 Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless of 26 the medium or manner in which it is generated, stored, or maintained (including, among 27 other things, testimony, transcripts, and tangible things) that are produced or generated 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that has 12 appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 21 their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 /// 27 /// 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Order does not govern the use of Protected Material at trial. 9 10 4. DURATION 11 Once a case proceeds to trial, information that was designated as 12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 13 an exhibit at trial becomes public and will be presumptively available to all members 14 of the public, including the press, unless compelling reasons supported by specific 15 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 16 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 17 documents produced in discovery from “compelling reasons” standard when merits- 18 related documents are part of court record). Accordingly, the terms of this protective 19 order do not extend beyond the commencement of the trial. 20 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under this 24 Order must take care to limit any such designation to specific material that qualifies 25 under the appropriate standards. The Designating Party must designate for protection 26 only those parts of material, documents, items or oral or written communications that 27 qualify so that other portions of the material, documents, items or communications for 1 Order. 2 Mass, indiscriminate or routinized designations are prohibited. Designations that 3 are shown to be clearly unjustified or that have been made for an improper purpose 4 (e.g., to unnecessarily encumber the case development process or to impose 5 unnecessary expenses and burdens on other parties) may expose the Designating Party 6 to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise provided in this 11 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 12 or ordered, Disclosure or Discovery Material that qualifies for protection under this 13 Order must be clearly so designated before the material is disclosed or produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic documents, 16 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 17 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 18 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 19 portion of the material on a page qualifies for protection, the Producing Party also must 20 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 21 margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and before 25 the designation, all of the material made available for inspection shall be deemed 26 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 27 copied and produced, the Producing Party must determine which documents, or 1 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 2 each page that contains Protected Material. If only a portion of the material on a page 3 qualifies for protection, the Producing Party also must clearly identify the protected 4 portion(s) (e.g., by making appropriate markings in the margins). 5 (b) for testimony given in depositions that the Designating Party identifies 6 the Disclosure or Discovery Material on the record, before the close of the deposition 7 all protected testimony. 8 (c) for information produced in some form other than documentary and for 9 any other tangible items, that the Producing Party affix in a prominent place on the 10 exterior of the container or containers in which the information is stored the legend 11 “CONFIDENTIAL.” If only a portion or portions of the information warrants 12 protection, the Producing Party, to the extent practicable, shall identify the protected 13 portion(s). 14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 failure to designate qualified information or items does not, standing alone, waive the 16 Designating Party’s right to secure protection under this Order for such material. Upon 17 timely correction of a designation, the Receiving Party must make reasonable efforts to 18 assure that the material is treated in accordance with the provisions of this Order. 19 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 designation of confidentiality at any time that is consistent with the Court’s Scheduling 23 Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process under Local Rule 37.1 et seq. 26 6.3 The burden of persuasion in any such challenge proceeding shall be on the 27 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 1 the Challenging Party to sanctions. Unless the Designating Party has waived or 2 withdrawn the confidentiality designation, all parties shall continue to afford the 3 material in question the level of protection to which it is entitled under the Producing 4 Party’s designation until the Court rules on the challenge. 5 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this Action 9 only for prosecuting, defending or attempting to settle this Action. Such Protected 10 Material may be disclosed only to the categories of persons and under the conditions 11 described in this Order. When the Action has been terminated, a Receiving Party must 12 comply with the provisions of section 13 below (FINAL DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 19 only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 21 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 22 disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) of the 24 Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 (g) the author or recipient of a document containing the information or a 6 custodian or other person who otherwise possessed or knew the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 9 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 10 not be permitted to keep any confidential information unless they sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 12 by the Designating Party or ordered by the court. Pages of transcribed deposition 13 testimony or exhibits to depositions that reveal Protected Material may be separately 14 bound by the court reporter and may not be disclosed to anyone except as permitted 15 under this Stipulated Protective Order; and 16 (i) any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions. 18 19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 20 OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation that 22 compels disclosure of any information or items designated in this Action as 23 “CONFIDENTIAL,” that Party must: 24 (a) promptly notify in writing the Designating Party. Such notification shall 25 include a copy of the subpoena or court order; 26 (b) promptly notify in writing the party who caused the subpoena or order to 27 issue in the other litigation that some or all of the material covered by the subpoena or 1 Stipulated Protective Order; and 2 (c) cooperate with respect to all reasonable procedures sought to be pursued 3 by the Designating Party whose Protected Material may be affected. 4 If the Designating Party timely seeks a protective order, the Party served with 5 the subpoena or court order shall not produce any information designated in this action 6 as “CONFIDENTIAL” before a determination by the court from which the subpoena 7 or order issued, unless the Party has obtained the Designating Party’s permission. The 8 Designating Party shall bear the burden and expense of seeking protection in that court 9 of its confidential material and nothing in these provisions should be construed as 10 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 11 directive from another court. 12 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 14 IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 17 by Non-Parties in connection with this litigation is protected by the remedies and relief 18 provided by this Order. Nothing in these provisions should be construed as prohibiting 19 a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to 21 produce a Non-Party’s confidential information in its possession, and the Party is 22 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 23 information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement with 26 a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the Stipulated 1 specific description of the information requested; and 2 (3) make the information requested available for inspection by the Non- 3 Party, if requested. 4 (c) If the Non-Party fails to seek a protective order from this court within 14 5 days of receiving the notice and accompanying information, the Receiving Party may 6 produce the Non-Party’s confidential information responsive to the discovery request. 7 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 8 any information in its possession or control that is subject to the confidentiality 9 agreement with the Non-Party before a determination by the court. Absent a court order 10 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 11 in this court of its Protected Material. 12 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 17 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 18 all unauthorized copies of the Protected Material, (c) inform the person or persons to 19 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 20 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 21 that is attached hereto as Exhibit A. 22 23 11. 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, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 1 may be established in an e-discovery order that provides for production without prior 2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 parties reach an agreement on the effect of disclosure of a communication or 4 information covered by the attorney-client privilege or work product protection, the 5 parties may incorporate their agreement in the stipulated protective order submitted to 6 the court. 7 8 12. MISCELLANEOUS 9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 10 person to seek its modification by the Court in the future. 11 12.2 Right to Assert Other Objections. By stipulating to the entry of this 12 Protective Order, no Party waives any right it otherwise would have to object to 13 disclosing or producing any information or item on any ground not addressed in this 14 Stipulated Protective Order. Similarly, no Party waives any right to object on any 15 ground to use in evidence of any of the material covered by this Protective Order. 16 12.3 Filing Protected Material. A Party that seeks to file under seal any 17 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 18 only be filed under seal pursuant to a court order authorizing the sealing of the specific 19 Protected Material at issue. If a Party’s request to file Protected Material under seal is 20 denied by the court, then the Receiving Party may file the information in the public 21 record unless otherwise instructed by the court. 22 23 13. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in paragraph 4, within 60 25 days of a written request by the Designating Party, each Receiving Party must return 26 all Protected Material to the Producing Party or destroy such material. As used in this 27 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 1 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 2 must submit a written certification to the Producing Party (and, if not the same person 3 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 4 category, where appropriate) all the Protected Material that was returned or destroyed 5 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 6 compilations, summaries or any other format reproducing or capturing any of the 7 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 8 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 9 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 10 work product, and consultant and expert work product, even if such materials contain 11 Protected Material. Any such archival copies that contain or constitute Protected 12 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 1 || 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures includin, 3 |) without limitation, contempt proceedings and/or monetary sanctions. 4 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || DATED: June 17, 2025 8 9 |) /s/ Zachary Cantor, Esq. Zachary Cantor, Esq. 10 |) CANTOR LAW Attorneys for Plaintiff 11 || Michael Feldman 12 13 |} DATED: June 17, 2025 14 15 || /s/ Alejandro E. Rosa, Esq. Guillermo M. Tello, Esq. 16 || Alejandro E. Rosa, Esq. CLARK HILL LLP 17 || Attorneys for Defendants Conifer Holdings, Inc., VSRM Insurance Agency, Inc. 18 (formerly known as Venture Agency Holdings, ne.), 19 ohn Bures, Rochelle Kaplan-Rudolph, and James Petcoff.
20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 DATED: 6/18/2025 23 Rayel Cs, a. OC. 25 || HON. ROZELLA A. OLIVER 56 United States Magistrate Judge 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 that 6 I have read in its entirety and understand the Stipulated Protective Order that was issued 7 by the United States District Court for the Central District of California on [date] in the 8 case of ___________ [insert formal name of the case and the number and initials 9 assigned to it by the court]. I agree to comply with and to be bound by all the terms 10 of this Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that is 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 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 Order, 17 even if such enforcement proceedings occur after termination of this action. I hereby 18 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 this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ PROOF OF SERVICE Feldman v. Venture A gency Holdings, Inc., et al. 5 Case No. 2:23—CV—08951 Iam employed in the County of Los Angeles, State of California. Iam over th 3 age of 18 years and not a party to the within action; my business address is 555 Sout 4 Flower Street, 24"" Floor, Los Angeles, California 90071. On June 17, 2025, I served the following document(s) described as 5 || STIPULATED PROTECTIVE ORDER on the interested parties in this action a ‘ follows: Zac ay vantor, Esq. Attorneys for Plainti 7 CANTOR LAW MICHAEL FELDMAN 1112 Montana Avenue, Suite C 8 Santa Monica, CA 90403 zacha cantorlawyers.com Tel. 310.393.6620 [email protected] 9 Fax 310.393.6680 10 |) [X] BY [ECF E-MAIL OR ELECTRONIC TRANSMISSION: — B electronically mailing a true and correct through Clark Hill LLP’s electroni mail system from [email protected] to the email addresses set forth above. did not receive, within a reasonable time after the transmission, any electroni 12 message or other indication that the transmission was unsuccessful. 7 BY U.S. MAIL: I enclosed the documents in a sealed envelope or packag addressed to the above-named persons at the addresses exhibited therewith. I ar 14 readily familiar with Clark Hill's practice of collection and processin correspondence for mailing. Under that practice, documents are deposited wit Id the U.S. Postal Service on the same day which is stated in the proof of □□□□□□□ with postage fully prepaid at Los Anglees, California in the ordinary course o 16 business. [am aware that on motion of party served, service is presumed invali if the postal cancellation date or postage meter date is more than one day afte 17 the date stated in this proof of service. 18 I declare under penalty of perjury under the laws of the state of California, the 19 the above is true and correct.
50 Executed on June 17, 2025, at Los Angeles, California.
oe 22 Diane Vo 23 24 25 26 27 28
Reference
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