Legal Document: Koop vs Fire Insurance Exchange, dba Farmers Insurance Group

On August 24, 2020 a 77165PROPO0194d8 was filed involving a dispute between Koop, Gary, and Fire Insurance Exchange, Dba Farmers Insurance Group, Hunsaker, Brian, for 18: Unlimited Insurance Coverage in the District Court of Sonoma County.

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EFS-020
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO.: 218942 FOR COURT USE ONLY
NAME: Stacy M. Tucker
FIRM NAME: MONAHAN TUCKER LAW, P.C.
STREET ADDRESS: 14241 NE Woodinville-Duvall Road, Suite 382
CITY: Woodinville STATE: WA ZIP CODE: 98072
TELEPHONE NO.: 206-486-3553 FAX NO.: 206-339-7155

E-MAIL ADDRESS: smtucker@mtlawpc.com

ATTORNEY FOR (name): Plaintiff, Gary Koop

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SONOMA
STREET ADDRESS: 600 Administrative Drive
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Rosa 95403
BRANCH NAME:
CASE NUMBER:

PLAINTIFF/PETITIONER: GARY KOOP
SCV-266944

DEFENDANT/RESPONDENT: FIRE INSURANCE EXCHANGE JUDICIAL OFFICER:
HON. OSCAR A. PARDO
OTHER:
DEPT:
PROPOSED ORDER (COVER SHEET) 19

NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent
electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed
order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed
order in PDF format are filed.

1. Name of the party submitting the proposed order:
PLAINTIFF, GARY KOOP

2. Title of the proposed order:
PROPOSED ORDER RE PLAINTIFF'S MOTION TO COMPEL FURTHER DOCUMENT PRODUCTION

3. The proceeding to which the proposed order relates is:

a. Description of proceeding: Motion to Compel Further Responses

b. Date and time: June 2, 2023 at 3pm

c. Place: Sonoma County Superior Court, Dept. 19

4. The proposed order was served on the other parties in the case.

Stacy M. Tucker
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)

Page 1 of 2

Form Adopted for Mandatory Use
Judicial Council of California
PROPOSED ORDER (COVER SHEET) Cal. Rules of Court,
rules 2.252, 3.1312
EFS-020 [Rev. February 1, 2017] (Electronic Filing) www.courts.ca.gov
EFS-020
CASE NAME: CASE NUMBER:
SCV-266944

PROOF OF ELECTRONIC SERVICE
PROPOSED ORDER

1. I am at least 18 years old and not a party to this action.

a. My residence or business address is (specify):

b. My electronic service address is (specify):

2. I electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in
an editable word-processing format as follows:

a. On (name of person served) (If the person served is an attorney, the party or parties represented should also be stated.):

b. To (electronic service address of person served):

c. On (date):

Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the
proposed order in an editable word-processing format on additional persons are described in an attachment.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:

(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT)

EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of 2

(Electronic Filing)
1

7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF SONOMA
9

10
GARY KOOP, Case No. SCV-266944
11
Plaintiff, [Assigned to Hon. Oscar A. Pardo]
12
vs. [PROPOSED] ORDER RE. PLAINTIFF’S
Northridge, California 91324

13
KANTOR & KANTOR LLP

MOTION TO COMPEL FURTHER
19839 Nordhoff Street

FIRE INSURANCE EXCHANGE, BRIAN
DOCUMENT PRODUCTION
(818) 886 2525

14 HUNSAKER,

15 Defendants.
16

17 This matter came on for the Court’s consideration upon Plaintiff’s Motion to Compel

18 Defendant Fire Insurance Exchange’s Further Responses to Plaintiff’s Second Set of Requests for

19 Production. After consideration of the Memoranda filed in support of and in opposition to said

20 Motion and upon all the papers and pleadings on file herein, and oral argument on June 2, 2023,

21 and with the format approved by Defendant on June 8, 2023, the Court hereby orders as follows:

22 Plaintiff Gary Koop (“Plaintiff”) filed the original complaint in this action against Fire

23 Insurance Exchange dba Farmers Insurance Group (“Fire”), and Brian Hunsaker (“Hunsaker”,

24 together with Fire, “Defendants”) arising out of insurance dispute (“Complaint”). This matter is on

25 calendar for Plaintiff’s motion to compel further responses to requests for production of

26 documents (“RPODs”) set two against Fire under Code of Civil Procedure (“CCP”) § 2031.310.

27 The motion is GRANTED in part and DENIED in part.

1
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 I. Governing Law

2 Regarding the RPODs, a demand for production may request access to “documents,

3 tangible things, land or other property, and electronically stored information in the possession,

4 custody, or control” of another party. A party to whom a document demand is directed must

5 respond to each item in the demand with an agreement to comply, a representation of inability to

6 comply, or an objection. CCP § 2031.210(a). If only part of an item or category demanded is

7 objectionable, the response must contain an agreement to comply with the remainder, or a

8 representation of the inability to comply. CCP § 2031.240(c)(1). If a responding party is not able

9 to comply with a particular request, that party “shall affirm that a diligent search and a reasonable

10 inquiry has been made in an effort to comply with that demand.” CCP § 2031.230. “This statement

11 shall also specify whether the inability to comply is because the particular item or category has

12 never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been, or is no
Northridge, California 91324

13 longer, in the possession, custody, or control of the responding party” and “[t]he statement shall
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 set forth the name and address of any natural person or organization known or believed by that

15 party to have possession, custody, or control of that item or category of item.” Id. CCP §

16 2031.240(c)(1) provides that when asserting claims of privilege or attorney work product

17 protection, the objecting party must provide “sufficient factual information” to enable other parties

18 to evaluate the merits of the claim, “including, if necessary, a privilege log.”

19 Upon receipt of a response to a request for production, the propounding party may move

20 within 45 days for an order compelling further response if the propounding party deems that a

21 statement of compliance with the demand is incomplete; a representation of inability to comply is

22 inadequate, incomplete, or evasive; or an objection in the response is without merit or too general.

23 CCP § 2031.310(a). Failure to move within 45 days is jurisdictional, and serving indistinguishable

24 requests after the expiration does not grant the court jurisdiction over the duplicative

25 request. Career Colleges, Magna Institute, Inc. v. Superior Court (1989) 207 Cal.App.3d 490,

26 492.

27 A motion to compel further responses to a request for production of documents must “set

28 forth specific facts showing ‘good cause’ justifying the discovery sought by the demand.” CCP

2
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 §2031.310(b)(1). Absent a claim of privilege or attorney work product, the party who seeks to

2 compel production has met his burden of showing ‘good cause’ simply by showing that the

3 requested documents are relevant to the case, i.e., that it is itself admissible in evidence or appears

4 reasonably calculated to lead to the discovery of admissible evidence under CCP § 2017.010. See

5 also Kirkland v. Sup. Ct. (2002) 95 Cal.App.4th 92, 98. Once good cause is shown, the burden

6 shifts to the responding party to justify its objections. See Coy, 58 Cal.2d at 220–221. It is

7 insufficient to claim that a requested document is within the possession of another person if the

8 party has control over that document. Clark v. Superior Court of State In and For San Mateo

9 County (1960) 177 Cal.App.2d 577, 579. “The protections of the attorney-client privilege and the

10 work product doctrine may be waived by disclosure of privileged communications or work

11 product to a party outside the attorney-client relationship if the disclosure is inconsistent with

12 goals of maintaining confidentiality or safeguarding the attorney's work product.” City of
Northridge, California 91324

13 Petaluma v. Superior Court (2016) 248 Cal.App.4th 1023, 1033.
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 The scope of discovery is one of reason, logic and common sense. Lipton v. Superior

15 Court (1996) 48 Cal.App.4th 1599, 1612. The right to discovery is generally liberally

16 construed. Williams v. Superior Court (2017) 3 Cal.5th 531, 540. “California law provides parties

17 with expansive discovery rights.” Lopez v. Watchtower Bible & Tract Society of N.Y., Inc. (2016)

18 246 Cal.App.4th 566, 590-591. Specifically, the Code provides that “any party may obtain

19 discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the

20 pending action or to the determination of any motion made in that action, if the matter either is

21 itself admissible in evidence or appears reasonably calculated to lead to the discovery of

22 admissible evidence.” CCP § 2017.010; see also, Garamendi v. Golden Eagle Ins. Co. (2004) 116

23 Cal.App.4th 694, 712, fn. 8. (“For discovery purposes, information is relevant if it ‘might

24 reasonably assist a party in evaluating the case, preparing for trial, or facilitating

25 settlement…”) See Lopez, supra, 246 Cal.App.4th at 590-591, citing Garamendi, supra, 116

26 Cal.App.4th at 712, fn. 8. “Admissibility is not the test and information[,] unless privileged, is

27 discoverable if it might reasonably lead to admissible evidence.” Id. “These rules are applied

3
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 liberally in favor of discovery, and (contrary to popular belief), fishing expeditions are permissible

2 in some cases.” Id.

3 California’s constitution establishes privacy rights for her citizens, but those rights are not

4 boundless or inviolate. The privacy privilege is not absolute, but qualified. Palay v. Sup. Ct.

5 (County of Los Angeles) (1993) 18 Cal.App.4th 919, 933. The balancing test in applying the

6 privacy privilege is aptly described in Valley Bank of Nevada v. Superior Court (1975) 15 Cal.3d

7 652, 658, and requires the analysis of four factors: 1) the purpose of the information sought; 2) the

8 effect the disclosure will have on the affected persons and parties; 3) the nature of the objections

9 urged by the party resisting disclosure; and 4) whether less obtrusive means exist for obtaining the

10 requested information. The constitutional right of privacy does not provide absolute protection

11 against disclosure of personal information; rather it must be balanced against the countervailing

12 public interests in disclosure. Williams v. Superior Court (2017) 3 Cal.5th 531, 552. While some
Northridge, California 91324

13 instances of disclosure may require a compelling state interest be shown, other less private
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 information does not require the same showing. Id. at 556. The seriousness of the prospective

15 invasion of privacy must be established by the party asserting the privacy interest. Ibid. Financial

16 affairs are among the matters where the right to privacy applies. Cobb v. Superior Court (1979) 99

17 Cal.App.3d 543, 552.

18 Generally, failure to assert a discovery objection in a response waives that objection

19 later. Stadish v. Superior Court (1999) 71 Cal.App.4th 1130, 1140. When a party serves response

20 after a motion to compel is filed, the court maintains jurisdiction within its discretion to determine

21 whether the requested sanctions are appropriate. Sinaiko Healthcare Consulting, Inc. v. Pacific

22 Healthcare Consultants (2007) 148 Cal.App.4th 390, 410-411.

23 CCP § 2031.310(h) (relating to requests for production of documents) provides that a

24 monetary sanction “shall” be imposed against the party losing a motion to compel further

25 responses unless the court finds “substantial justification” for that party’s position or other

26 circumstances making sanctions “unjust.” For the court to order sanctions against an attorney, the

27 Court must find that the attorney advised their client to engage in discovery misconduct. Kwan

28 Software Engineering, Inc. v. Hennings (2020) 58 Cal.App.5th 57, 81. Additionally, the motion

4
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 must advise the attorney that joint and several liability against the attorney is sought for the

2 sanctions. Blumenthal v. Superior Court (1980) 103 Cal.App.3d 317, 319.

3 II. Motion

4 In March of 2021, Plaintiff served RPODs set one which included the requests for all

5 documents demonstrating all insurance policy reformation requests (RPOD ¶ 23) and any approval

6 of those requests (RPOD ¶ 24) between January 1, 2010 and “present”. Fire served objections,

7 including that the requests were overly broad, burdensome not likely to lead to the discovery of

8 admissible evidence, and that it was “privileged proprietary and confidential”. See Tucker

9 Declaration, Exhibit 1. The parties met and conferred and agreed to Fire’s production of broad

10 statistical evidence, which included just a statistical table inserted to an email between counsel. Id.

11 at Exhibit 2. On December 22, 2022, Plaintiff served RPODs Set Two. Fire served responses on

12 January 17, 2023. The parties met and conferred regarding the deficiencies that Plaintiff alleged in
Northridge, California 91324

13 the responses. The instant motion to compel was filed March 22, 2023.
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 A. RPOD No. 37

15 RPOD ¶ 37 requests all documents from Fire’s internal reformation Sharepoint database

16 regarding the 199 claims for reformation from the Sonoma area stemming from the October 2017

17 Tubbs Fire. Fire contends that this seeks documents that would have fallen under a previous

18 document request, and it is therefore precluded since more than 45 days have lapsed since the

19 responses to RPOD ¶¶ 23 and 24 were provided. Plaintiff asserts that this request is adequately

20 distinct due to the narrower scope of the current request, and that Fire previously has not produced

21 the documents requested. Fire asserted the previous category was overbroad, and therefore the

22 parties agreed to the production of broad form statistical data as a response to the prior request.

23 Here, good cause is obvious. Fire makes no persuasive assertions to the contrary. Plaintiff’s claims

24 regarding failure to reform would be influenced by a pattern and practice of encouraging the

25 denial of claims. This makes the information requested likely to lead to admissible evidence. The

26 primary contention is that Plaintiff, by making a broad request two years ago, and not moving to

27 compel at that time, has waived rights to any documents which may be responsive to the original

28 request.

5
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 First, the general purpose of discovery is to take the game element out of trial preparation

2 while retaining the adversarial nature of the trial itself, essentially to eliminate surprise at

3 trial. Emerson Electric Co. v. Superior Court (1997) 16 Cal.4th 1101, 1107. By way of analogy,

4 the prohibition against making the same request in discovery does not implicate the exact same

5 request made under a different code section. Carter v. Superior Court (1990) 218 Cal.App.3d 994,

6 997. This clearly shows that the discovery act is intended to be interpreted liberally in favor of

7 disclosures. See also, Williams v. Superior Court (2017) 3 Cal.5th 531, 540 (The right to

8 discovery is “liberally construed”.) Here, Plaintiff’s request falls under the same code section, but

9 the request is substantially different in that it implicates a very narrow band of documents

10 that might have fallen under the original request. However, Fire did not previously provide these

11 responsive documents, despite now averring that the documents exist and are sufficiently

12 responsive to preclude Plaintiff’s supposedly redundant request.
Northridge, California 91324

13 Fire’s reliance on Professional Career Colleges, Magna Institute, Inc. v. Superior
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 Court (1989) 207 Cal.App.3d 490, is unavailing, as that case is quite distinguishable. There,

15 Plaintiff sought the same information in the second set of interrogatories as was requested in the

16 first. Id. at 492. “The sole change was that it now sought the name, as well as the address, of each

17 student, and specified that the persons about whom information was sought had been enrolled in

18 the private security program ‘at Professional Career Colleges.’” Ibid. The court there noted that,

19 “it is evident that the first question, although it asked only for addresses, would necessarily have

20 elicited names as well.” Ibid. Neither party argued that the requests were different. Ibid.

21 Here, Plaintiff argues that the second request is substantially different, and the Court

22 agrees. The scope of discovery is one of reason, logic and common sense. Lipton v. Superior

23 Court (1996) 48 Cal.App.4th 1599, 1612. Plaintiff has, through other discovery methods,

24 uncovered the ease with which Defendant could have produced this subset of documents in

25 response to RPOD ¶¶ 23 and 24. RPOD ¶¶ 23 and 24 requested incredibly broad sections of

26 documents, and Defendant objected at the time that such production was overly burdensome. The

27 parties agreed to a particular production that allowed Fire to meet some portion of the request.

28 Assuming no bad faith on the part of Fire, it still defies the purpose of the discovery act to allow

6
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 Fire to aver both that RPOD ¶¶ 23 and 24 were too broad, and that they now have no obligation to

2 respond to RPOD ¶ 37. RPOD ¶ 37 is not the same request. As such, the Court has jurisdiction to

3 order production. At oral argument on June 2, 2023, the Court agreed that Defendant could redact

4 any identifying information of each insured, including names and insurance policy numbers.

5 Plaintiff’s motion to compel as to RPOD ¶ 37 is GRANTED.

6 B. RPOD No. 38

7 RPOD ¶ 38 requests documents explaining or referencing the relevance of the ratio

8 between premiums collected versus claims paid in the compensation structure of Fire’s employees.

9 Fire objects asserting a number of boilerplate objections and privacy rights of its employees.

10 Good cause is met. The heart of Plaintiff’s Complaint is that Fire, through its employees, denied

11 his request for reformation. This request clearly is designed to produce evidence that Fire

12 incentivized its employees to deny such requests through salary and bonus structures. This is
Northridge, California 91324

13 certainly relevant.
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 While Fire asserts generalized claims of privacy issues, they elucidate no factual pattern

15 wherein the privacy of their employees on an individual scale is at all implicated by their

16 generalized corporate policies. The assertion of a privacy objection is unsupported by any factual

17 showing. Fire has not shown that this information impinges on the privacy rights of individuals.

18 To the degree responsive documents are entwined with compensation information about

19 individuals, the privacy interest of these individuals has not been overcome by Plaintiff. The Court

20 orders that information redacted before production.

21 Fire also asserts that such compensation structure is a trade secret. Fire offers no evidence

22 or explanation to support this contention, but given the subject matter, this would raise the Court’s

23 concerns. However, Fire has not attempted to produce any form of privilege log, and Plaintiff has

24 offered to stipulate to a protective order. Here, the Court intends to order production, but the

25 parties are in the best position to collaborate on the terms of the protective order. The parties are

26 ORDERED to meet and confer in good faith within 30 days of notice of this order. Either after the

27 expiration of this period, or within 30 days of entry of the protective order, Fire shall produce the

7
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 responsive documents. Under these conditions, Plaintiff’s motion to compel is GRANTED as to

2 RPOD ¶ 38.

3 C. RPOD No. 39

4 There does not appear to be a display of relevance to the individual compensation of

5 Schmitz here. Schmitz oversees a department that deals with all requests for reformation of

6 policies. The alleged failure to reform Plaintiff’s particular policy is only one of 199 requests

7 reviewed by Schmitz for the Tubbs fire and therefore the request is not reasonably calculated to

8 lead to admissible evidence. In this way, Plaintiff has failed to demonstrate good cause.

9 Even if the Court’s analysis were to proceed to the objection regarding privacy, here too Plaintiff’s

10 attempt to compel would fail. The rights of individuals to privacy applies to financial information.

11 Schmitz has a right to privacy as to his financial information and situation, of which his salary is a

12 part. See Cobb v. Superior Court (1979) 99 Cal.App.3d 543, 552. Meanwhile, the evidence as to
Northridge, California 91324

13 Schmitz’s compensation has not been displayed to even meet the basic requirement of good cause,
KANTOR & KANTOR LLP
19839 Nordhoff Street

(818) 886 2525

14 much less public interest as required to overcome Schmitz’s privacy rights. As such, Plaintiff has

15 not overcome the privacy objection asserted by Fire.

16 As to RPOD ¶ 39, Plaintiff’s request is DENIED.

17 III. Conclusion

18 Based on the foregoing, Plaintiff’s motion to compel is GRANTED as to RPOD ¶¶ 37 and

19 38, and DENIED as to RPOD ¶ 39. The parties shall meet and confer regarding a protective order

20 as to RPOD ¶ 38.

21 The motion being granted, Fire’s request for sanctions is DENIED.

22 Plaintiff shall submit a written order to the Court consistent with this tentative ruling and in

23 compliance with Rule of Court 3.1312(a) and (b).

26
Dated: _____________________________
27 Hon. Oscar A. Pardo
28 Judge, Superior Court of California

8
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL
1 PROOF OF SERVICE

2 I, Carolyn Spencer, declare as follows:
3
I am employed in the County of Rohnert Park, State of California. I am over the age of 18
4 and not a party to the within action; my business address is 14241 NE Woodinville-Duvall Road,
Suite 382, Woodinville, WA 98072.
5
On June 9, 2023, I served the foregoing document described as NOTICE OF
6 ASSOCIAITON OF COUNSEL in this action by serving a true copy thereof addressed as
follows:
7
Christopher R. Wagner, Esq. cwagner@grsm.com
8
David Jones, Esq. djones@grsm.com
9 Steven Inouye, Esq. sinouye@grsm.com
Victoria Hirsch, Esq. vhirsch@grsm.com
10 GORDON REES SCULLY MANSUKHANI, LLP ilopez@grsm.com (assistant)
633 West Fifth Street, 52nd floor jodell@grsm.com (assistant)
11
Los Angeles, CA 90071
12
Attorneys for Defendant Fire
Northridge, California 91324

13 Insurance Exchange, dba Farmers
KANTOR & KANTOR LLP
19839 Nordhoff Street

Insurance Group
(818) 886 2525

15 Albert M. T. Finch, III, Esq. tfinch@fgppr.com
Jason Deng, Esq. jdeng@fgppr.com
16 FORAN GLENNON kokasaki@fgppr.com (assistant)
1741 Technology Drive, Suite 250
17 San Jose, CA 95110
18
Attorneys for Defendant Brian
19 Hunsaker

20
[X] BY E-MAIL SERVICE: I caused a copy of the document(s) to be sent from e-mail address
21 cspencer@kantorlaw.net to the persons at the e-mail addresses listed above. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication that the
22 transmission was unsuccessful.
23
[x] STATE: I declare under penalty of perjury under the Laws of the State of California that the
24
foregoing is true and correct.
25
I declare under penalty of perjury under the laws of the State of California that the above is
26 true and correct. Executed on June 9, 2023, Rohnert Park, California.

27
/s/Carolyn Spencer
28 Carolyn Spencer

9
[PROPOSED] ORDER RE: PLAINTIFF’S MOTION TO COMPEL

Case Info

Judge

DeMeo, Bradford Track Judge’s New Case

Case No.

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Document Filed Date

June 09, 2023

Case Filing Date

August 24, 2020

County

Parties

Finch, Albert Morris, III Attorney for the Defendant
Fire Insurance Exchange, dba Farmers Insurance Group Defendant
Hunsaker, Brian Defendant
Kantor, Glenn Robert Attorney for the Plaintiff
Koop, Gary Plaintiff
Schwartz, Peter Attorney for the Defendant
Christopher Wagner Attorneys for Defendants
David Jones Attorneys for Defendants
Steven Inouye Attorneys for Defendants
Victoria Hirsch Attorneys for Defendants
Jason Deng Attorneys for Defendants
Margaret Drugan Attorneys for Defendants
Stacy Monahan Attorney
Stacy Tucker Attorney
Lisa Kantor Attorneys for Plaintiffs
Steven Soltman Attorney
Alan Jampol Attorneys for Defendants
Paul Donsbach Attorneys for Defendants
Robert Yap Attorneys for Defendants
Stefanie Schiff Attorneys for Defendants
Barry Zoller Attorneys for Defendants
Margret Parke Attorneys for Defendants
Julia Donoho Attorney
Reginaldo Villarreal Attorney
Enrique Adler Attorney

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