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I JOHN P. BRISCOE (SBN: 273690)
ibriscoe(a),mavallaw.com
2 MAY ALL HURLEY P.C. FILEO/EMDORSED
3 2453 Grand Canal Boulevard
Stockton, California 95207-8253 OCT 1 9 2022
4 Telephone: (209)477-3833
Facsimile: (209) 473-4818 By:. E. Macdonald
5 Deputy Clerk
Attorneys for Plaintiff David Ridge
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7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF SACRAMENTO
9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393
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Plaintiff, NOTICE OF MOTION AND MOTION
II FOR PROTECTIVE ORDER
vs. TERMINATING PLAINTIFF'S
12 DEPOSITION
THE CALIFORNIA HIGHWAY PATROL;
13 and DOES 1-100, inclusive. Date: January 11, 2023
14 Time: 1:30 p.m.
Defendants. Dept.: 53
15 Res.: 2684748
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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Notice is hereby given that on January I I , 2023 1:30 p.m. in Department 53 of the above-
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entitled Court, pursuant to Code of Civil Procedure section 2025.420, Plaintiff David Ridge
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("Ridge") will, and does hereby, move for a protective order, terminating his deposition. This
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motion is made on the grounds that Defendant Califomia Highway Patrol ("Defendant") has
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already deposed Ridge for approximately fourteen hours over a three-day period, and that
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deposing him further is unwarranted and would only cause unwarranted annoyance,
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embarrassment, and oppression, as well as undue burden and expense.
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This motion is made pursuant to Code of Civil Procedure section 2025.420, and is based
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on this Notice, the Memorandum of Points and Authorities, the Declaration of John P. Briscoe
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Notice of Motion and Motion for Protective Order Terminating Plaintiffs Deposition
Page 1 of2
I and exhibits thereto, and on such further evidence as may be submitted upon reply and at
2 hearing.
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4 DATED: October 14, 2022 MAY ALL HURLEY P.C.
5 By_
JOHN P. BRISCOE
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Attomeys for Plaintiff
7 DAVID RIDGE
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Notice of Motion and Motion for Protective Order Terminating Plaintiffs Deposition
Page 2 of2
Ridge V. Califorriia Highway Patrol, et al.
Sacramento County Superior Court Case No. 34-2019-00265393
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PROOF OF SERVICE
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I, the undersigned, certify and declare as follows:
3 I am over the age of eighteen years and not a party to this action. My business address is 2453
Grand Canal Boulevard, Stockton, California 95207 that is located in the county where the mailing
4 and/or delivery below took place.
5 On October 14, 2022,1 served the following document:
6 NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER TERMINATING
PLAINTIFF'S DEPOSITION
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addressed to:
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James F. Curran
9 Deputy Attomey General
P.O. Box 944255
10 Sacramento, CA 94244-2550
James.Curran@doi.ca.gov
11 Christopher Irby
Christopher.irbyfoidoi.ca.gov
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• BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with
13 the business practice at my place of business for collection and processing of correspondence for
mailing with the United States Postal Service. Correspondence so collected and processed is
14 deposited with the United States Postal Service that same day in the ordinary course of business.
On the date specified below, at my place of business at Stockton, Califomia a copy of the document
15 described above was placed for deposit in the United States Postal Service in a sealed envelope,
with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that
16 envelope was placed for collection and mailing on that date following ordinary business practice.
17 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified
below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail
18 address(es) listed above. My business e-mail address is lrilev(a),mavallaw.com. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that the
19 transmission was unsuccessful.
20 I certify and declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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Executed on October 14, 2022, at Lodi, California.
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24 LINDSAY RILEY SHIELDS
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28 PROOF OF SERVICE
\ .
JOHN P. BRISCOE (SBN: 273690) ^
ibriscoe(S),mavallaw.com \ ^ ^ ^
2 MAY ALL HURLEY P.C.
2453 Grand Canal Boulevard
3
Stockton, California 95207-8253
4 Telephone: (209) 477-3833
Facsimile: (209) 473-4818
5
Attorneys for Plaintiff David Ridge
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF SACRAMENTO
9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393
10
Plaintiff, [PROPOSED] ORDER GRANTING
II MOTION FOR PROTECTIVE ORDER
vs. TERMINATING PLAINTIFF'S
12 DEPOSITION
THE CALIFORNIA HIGHWAY PATROL;
13 and DOES 1-100, inclusive, Date: January 11, 2023
14 Time: 1:30 p.m.
Defendants. Dept.: 53
15 Res.: 2684748
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21 Plaintiff David Ridge's Motion for Protective Order Granting Motion for Protective Order
22 Terminating Plaintiffs Deposition came on regularly for hearing on January 11, 2023 at 1:30 p.m.
23 in Department 53 of the above-entitled Court. Appearances by counsel are reflected in the Court's
24 file.
25 Having read and considered the papers and evidence supporting and opposing Plaintiffs
26 motion, haying heard and considered the argument of counsel at the hearing, and good cause
appearing therefor:
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OCT 19
201 [Proposed] Order Granting Motion for Protective Order Terminating Plaintiffs Deposition
1 of 2
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1 IT IS HEREBY ORDERED that Plaintiffs motion is granted as requested. Pursuant to
2 Code of Civil Procedure section 2025.240, Plaintiffs deposition is hereby terminated.
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4 DATED:
Judge of the Superior Court
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[Proposed] Order Granting Motion for Protective Order Terminating Plaintiffs Deposition
Page 2 of 2
Ridge V. California Highway Patrol, et al.
Sacramento County Superior Court Case No. 34-2019-00265393
I
PROOF OF SERVICE
2
I, the undersigned, certify and declare as follows:
3 I am over the age of eighteen years and not a party to this action. My business address is 2453
Grand Canal Boulevard, Stockton, Califomia 95207 that is located in the county where the mailing
4 and/or delivery below took place.
5 On October 14, 2022,1 served the following document:
6 [PROPOSED] ORDER GRANTING MOTION FOR PROTECTIVE ORDER TERMINATING
PLAINTIFF'S DEPOSITION
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addressed to:
8
James F. Curran
9 Deputy Attomey General
P.O. Box 944255
10 Sacramento, CA 94244-2550
James.Curran@doi.ca.gov
II Christopher Irby
Christopher.irbv@doi.ca.gov
12
• BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with
13 the business practice at my place of business for collection and processing of correspondence for
mailing with the United States Postal Service. Correspondence so collected and processed is
14 deposited with the United States Postal Service that same day in the ordinary course of business.
On the date specified below, at my place of business at Stockton, Califomia a copy of the document
15 described above was placed for deposit in the United States Postal Service in a sealed envelope,
with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that
16 envelope was placed for collection and mailing on that date following ordinary business practice.
17 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified
below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail
18 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that the
19 transmission was unsuccessful.
20 I certify and declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
21
Executed on October 14, 2022, at Lodi, California.
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PROOF OF SERVICE - I
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Preview
I JOHN P. BRISCOE (SBN: 273690) ibriscoe(a),mavallaw.com 2 MAY ALL HURLEY P.C. FILEO/EMDORSED 3 2453 Grand Canal Boulevard Stockton, California 95207-8253 OCT 1 9 2022 4 Telephone: (209)477-3833 Facsimile: (209) 473-4818 By:. E. Macdonald 5 Deputy Clerk Attorneys for Plaintiff David Ridge 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SACRAMENTO 9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393 10 Plaintiff, NOTICE OF MOTION AND MOTION II FOR PROTECTIVE ORDER vs. TERMINATING PLAINTIFF'S 12 DEPOSITION THE CALIFORNIA HIGHWAY PATROL; 13 and DOES 1-100, inclusive. Date: January 11, 2023 14 Time: 1:30 p.m. Defendants. Dept.: 53 15 Res.: 2684748 16 17 18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 19 Notice is hereby given that on January I I , 2023 1:30 p.m. in Department 53 of the above- 20 entitled Court, pursuant to Code of Civil Procedure section 2025.420, Plaintiff David Ridge 21 ("Ridge") will, and does hereby, move for a protective order, terminating his deposition. This 22 motion is made on the grounds that Defendant Califomia Highway Patrol ("Defendant") has >3 already deposed Ridge for approximately fourteen hours over a three-day period, and that 7i deposing him further is unwarranted and would only cause unwarranted annoyance, '25 embarrassment, and oppression, as well as undue burden and expense. 26 This motion is made pursuant to Code of Civil Procedure section 2025.420, and is based 27 on this Notice, the Memorandum of Points and Authorities, the Declaration of John P. Briscoe 28 Notice of Motion and Motion for Protective Order Terminating Plaintiffs Deposition Page 1 of2 I and exhibits thereto, and on such further evidence as may be submitted upon reply and at 2 hearing. 3 /// 4 DATED: October 14, 2022 MAY ALL HURLEY P.C. 5 By_ JOHN P. BRISCOE 6 Attomeys for Plaintiff 7 DAVID RIDGE 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Notice of Motion and Motion for Protective Order Terminating Plaintiffs Deposition Page 2 of2 Ridge V. Califorriia Highway Patrol, et al. Sacramento County Superior Court Case No. 34-2019-00265393 I PROOF OF SERVICE 2 I, the undersigned, certify and declare as follows: 3 I am over the age of eighteen years and not a party to this action. My business address is 2453 Grand Canal Boulevard, Stockton, California 95207 that is located in the county where the mailing 4 and/or delivery below took place. 5 On October 14, 2022,1 served the following document: 6 NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER TERMINATING PLAINTIFF'S DEPOSITION 7 addressed to: 8 James F. Curran 9 Deputy Attomey General P.O. Box 944255 10 Sacramento, CA 94244-2550 James.Curran@doi.ca.gov 11 Christopher Irby Christopher.irbyfoidoi.ca.gov 12 • BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with 13 the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is 14 deposited with the United States Postal Service that same day in the ordinary course of business. On the date specified below, at my place of business at Stockton, Califomia a copy of the document 15 described above was placed for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that 16 envelope was placed for collection and mailing on that date following ordinary business practice. 17 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail 18 address(es) listed above. My business e-mail address is lrilev(a),mavallaw.com. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 19 transmission was unsuccessful. 20 I certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 21 Executed on October 14, 2022, at Lodi, California. 22 23 24 LINDSAY RILEY SHIELDS 25 26 27 28 PROOF OF SERVICE \ . JOHN P. BRISCOE (SBN: 273690) ^ ibriscoe(S),mavallaw.com \ ^ ^ ^ 2 MAY ALL HURLEY P.C. 2453 Grand Canal Boulevard 3 Stockton, California 95207-8253 4 Telephone: (209) 477-3833 Facsimile: (209) 473-4818 5 Attorneys for Plaintiff David Ridge 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SACRAMENTO 9 DAVID RIDGE, an individual. Case No.: 34-2019-00265393 10 Plaintiff, [PROPOSED] ORDER GRANTING II MOTION FOR PROTECTIVE ORDER vs. TERMINATING PLAINTIFF'S 12 DEPOSITION THE CALIFORNIA HIGHWAY PATROL; 13 and DOES 1-100, inclusive, Date: January 11, 2023 14 Time: 1:30 p.m. Defendants. Dept.: 53 15 Res.: 2684748 16 17 18 19 20 21 Plaintiff David Ridge's Motion for Protective Order Granting Motion for Protective Order 22 Terminating Plaintiffs Deposition came on regularly for hearing on January 11, 2023 at 1:30 p.m. 23 in Department 53 of the above-entitled Court. Appearances by counsel are reflected in the Court's 24 file. 25 Having read and considered the papers and evidence supporting and opposing Plaintiffs 26 motion, haying heard and considered the argument of counsel at the hearing, and good cause appearing therefor: 28 OCT 19 201 [Proposed] Order Granting Motion for Protective Order Terminating Plaintiffs Deposition 1 of 2 80 1 IT IS HEREBY ORDERED that Plaintiffs motion is granted as requested. Pursuant to 2 Code of Civil Procedure section 2025.240, Plaintiffs deposition is hereby terminated. 3 4 DATED: Judge of the Superior Court 5 6 7 8 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [Proposed] Order Granting Motion for Protective Order Terminating Plaintiffs Deposition Page 2 of 2 Ridge V. California Highway Patrol, et al. Sacramento County Superior Court Case No. 34-2019-00265393 I PROOF OF SERVICE 2 I, the undersigned, certify and declare as follows: 3 I am over the age of eighteen years and not a party to this action. My business address is 2453 Grand Canal Boulevard, Stockton, Califomia 95207 that is located in the county where the mailing 4 and/or delivery below took place. 5 On October 14, 2022,1 served the following document: 6 [PROPOSED] ORDER GRANTING MOTION FOR PROTECTIVE ORDER TERMINATING PLAINTIFF'S DEPOSITION 7 addressed to: 8 James F. Curran 9 Deputy Attomey General P.O. Box 944255 10 Sacramento, CA 94244-2550 James.Curran@doi.ca.gov II Christopher Irby Christopher.irbv@doi.ca.gov 12 • BUSINESS PRACTICE TO ENTRUST DEPOSIT TO OTHERS: I am readily familiar with 13 the business practice at my place of business for collection and processing of correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is 14 deposited with the United States Postal Service that same day in the ordinary course of business. On the date specified below, at my place of business at Stockton, Califomia a copy of the document 15 described above was placed for deposit in the United States Postal Service in a sealed envelope, with postage fully prepaid addressed to the individuals and/or entities mentioned above; and that 16 envelope was placed for collection and mailing on that date following ordinary business practice. 17 0 BY EMAIL: In accordance with Code of Civil Procedure, Section 1010.6, on the date specified below, I caused a copy of the document(s) described above to be sent to the person(s) at the e-mail 18 address(es) listed above. My business e-mail address is lrilev@mavallaw.com. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 19 transmission was unsuccessful. 20 I certify and declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 21 Executed on October 14, 2022, at Lodi, California. 22 23 24 LINDS 25 26 27 PROOF OF SERVICE - I 28