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1 Michael D. Mortenson, State Bar No. 247758
mmortenson@mortensontaggart.com
2 Craig A. Taggart, State Bar No. 239168
ctaggart@mortensontaggart.com
3
Ravi K. Lally, State Bar No. 225687
4 rlally@mortensontaggart.com
Hannah M. Biemann, State Bar No. 333843
5 hbiemann@mortensontaggart.com
MORTENSON TAGGART ADAMS LLP
6 300 Spectrum Center Drive, Suite 1200
7 Irvine, California 92618
Telephone: (949) 774-2224
8 Facsimile: (949) 774-2545
9 Attorneys for Defendants
FORD MOTOR COMPANY and
10 JIM BURKE FORD
11
Tionna Carvalho, State Bar No. 299010
12 tcarvalho@slpattorney.com
STRATEGIC LEGAL PRACTICES, APC
13 1888 Century Park East, 19th Floor
Los Angeles, California 90067
14 Telephone: (310) 929-4900
15 Facsimile: (310) 943-3838
16 Attorneys for Plaintiff
LALONIE SANDERS
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
18
COUNTY OF KERN
19
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21 LALONIE SANDERS, CASE NO. BCV-23-102679
Honorable Thomas S. Clark
22 Plaintiff, Dept.: 17
23 vs.
24 STIPULATION AND PROTECTIVE
FORD MOTOR COMPANY; JIM BURKE ORDER – CONFIDENTIAL
25 FORD; and DOES 1 through 10, inclusive, DESIGNATION ONLY
26 Defendants.
Action Filed: August 14, 2023
27 Trial Date: September 15, 2025
28
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1 IT IS HEREBY STIPULATED by and between the Parties to Lalonie Sanders v. Ford
2 Motor Company, et al., by and through their respective counsel of record, that in order to facilitate
3 the exchange of information and documents which may be subject to confidentiality limitations
4 on disclosure due to federal laws, state laws, and privacy rights, the Parties stipulate as follows:
5 1. In this Stipulation and Protective Order, the words set forth below shall have the
6 following meanings:
7 a. “Proceeding” means the above-entitled proceeding BCV-23-102679.
8 b. “Court” means the Hon. Thomas S. Clark, or any other judge to which this
9 Proceeding may be assigned, including Court staff participating in such proceedings.
10 c. “Confidential” means any information which is in the possession of a
11 Designating Party who believes in good faith that such information is entitled to confidential
12 treatment under applicable law.
13 d. “Confidential Materials” means any Documents, Testimony or Information
14 as defined below designated as “Confidential” or “Subject to Protective Order” pursuant to the
15 provisions of this Stipulation and Protective Order.
16 e. “Designating Party” means the Party that designates
17 Materials as “Confidential.”
18 f. “Disclose” or “Disclosed” or “Disclosure” means to reveal, divulge, give, or
19 make available Materials, or any part thereof, or any information contained therein.
20 g. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those
21 terms are defined by California Evidence Code Sections 250, 255, and 260, which have been
22 produced in discovery in this Proceeding by any person, and (ii) any copies, reproductions, or
23 summaries of all or any part of the foregoing.
24 h. “Information” means the content of Documents or Testimony.
25 i. “Testimony” means all depositions, declarations or other testimony taken or
26 used in this Proceeding.
27 2. The Designating Party shall have the right to designate as “Confidential” or “Subject
28 to Protective Order” any Documents, Testimony or Information that the Designating Party in good
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1 faith believes to contain non-public information that is entitled to confidential treatment under
2 applicable law, including proprietary or commercially sensitive business information or personally
3 identifiable information (“PII”) of non-parties.
4 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or
5 abridge any right, privilege or protection otherwise available to any Party with respect to the
6 discovery of matters, including but not limited to any Party’s right to assert the attorney-client
7 privilege, the attorney work product doctrine, or other privileges, or any Party’s right to contest any
8 such assertion.
9 4. Any Documents, Testimony or Information to be designated as “Confidential” or
10 “Subject to Protective Order” must be clearly so designated before the Document, Testimony or
11 Information is Disclosed or produced. The parties may agree that the case name and number are to
12 be part of the “Confidential” or “Subject to Protective Order” designation. The ”Confidential” or
13 “Subject to Protective Order” designation should not obscure or interfere with the legibility of the
14 designated Information.
15 a. For Documents (apart from transcripts of depositions or other pretrial or trial
16 proceedings), the Designating Party must affix the legend “Confidential” or “Subject to Protective
17 Order” on each page of any Document containing such designated Confidential Material.
18 b. For Testimony given in depositions the Designating Party may either:
19 i. identify on the record, before the close of the deposition, all
20 “Confidential” Testimony, by specifying all portions of the Testimony that qualify as
21 “Confidential;” or
22 ii. identify more specific portions of the Testimony as to which
23 protection is sought within 30 days following receipt of the deposition transcript. In circumstances
24 where portions of the deposition Testimony are designated for protection, the transcript pages
25 containing “Confidential” Information may be separately bound by the court reporter, who must
26 affix to the top of each page the legend “Confidential” or “Subject to Protective Order” as instructed
27 by the Designating Party.
28 c. For Information produced in some form other than Documents, and for any
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1 other tangible items, including, without limitation, compact discs or DVDs, the Designating Party
2 must affix in a prominent place on the exterior of the container or containers in which the
3 Information or item is stored the legend “Confidential” or “Subject to Protective Order.”
4 5. The inadvertent production by any of the undersigned Parties or non-Parties to the
5 Proceedings of any Document, Testimony or Information during discovery in this Proceeding
6 without a “Confidential” or “Subject to Protective Order” designation, shall be without prejudice to
7 any claim that such item is Confidential” and such Party shall not be held to have waived any rights
8 by such inadvertent production. In the event that any Document, Testimony or Information that is
9 subject to a “Confidential” or “Subject to Protective Order” designation is inadvertently produced
10 without such designation, the Party that inadvertently produced the document shall give written
11 notice of such inadvertent production within twenty (20) days of discovery of the inadvertent
12 production, together with a further copy of the subject Document, Testimony or Information
13 designated as “Confidential” (the “Inadvertent Production Notice”). Upon receipt of such
14 Inadvertent Production Notice, the Party that received the inadvertently produced Document,
15 Testimony or Information shall promptly destroy the inadvertently produced Document, Testimony
16 or Information and all copies thereof, or, at the expense of the producing Party, return such together
17 with all copies of such Document, Testimony or Information to counsel for the producing Party and
18 shall retain only the “Confidential” or “Subject to Protective Order” designated Materials. Should
19 the receiving Party choose to destroy such inadvertently produced Document, Testimony or
20 Information, the receiving Party shall notify the producing Party in writing of such destruction
21 within ten (10) days of receipt of written notice of the inadvertent production. This provision is not
22 intended to apply to any inadvertent production of any Information protected by attorney-client or
23 work product privileges. In the event that this provision conflicts with any applicable law
24 regarding waiver of confidentiality through the inadvertent production of Documents, Testimony or
25 Information, such law shall govern.
26 6. In the event that counsel for a Party receiving Documents, Testimony or Information
27 in discovery designated as “Confidential” objects to such designation with respect to any or all of
28 such items, said counsel shall advise counsel for the Designating Party, in writing, of such
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1 objections, by identifying by Bates number to the extent practicable, the specific Documents,
2 Testimony or Information to which each objection pertains, and the specific reasons and support for
3 such objections (the “Designation Objections”). If the parties cannot resolve a challenge without
4 court intervention, counsel for the Designating Party shall have forty-five (45) days from receipt of
5 the written Designation Objections, or thirty (30) days from the parties agreement that the meet and
6 confer process will not resolve their dispute, whichever is earlier, to either (a) agree in writing to
7 de-designate Documents, Testimony or Information pursuant to any or all of the Designation
8 Objections and/or (b) file a motion with the Court seeking to uphold any or all designations on
9 Documents, Testimony or Information addressed by the Designation Objections (the “Designation
10 Motion”). Pending a resolution of the Designation Motion by the Court, any and all existing
11 designations on the Documents, Testimony or Information at issue in such Motion shall remain in
12 place. The Designating Party shall have the burden on any Designation Motion of establishing the
13 applicability of its “Confidential” designation. In the event that the Designation Objections are
14 neither timely agreed to nor timely addressed in the Designation Motion, then such Documents,
15 Testimony or Information shall be de-designated in accordance with the Designation Objection
16 applicable to such material.
17 7. Access to and/or Disclosure of Confidential Materials designated as “Confidential”
18 shall be permitted only to the following persons:
19 a. the Court and its personnel;
20 b. (1) Attorneys of record in the Proceedings and their affiliated attorneys in the
21 same firm, paralegals, clerical and secretarial staff employed by such attorneys who are actively
22 involved in the Proceedings and are not employees of any Party. (2) In-house counsel to the
23 undersigned Parties and the paralegal, clerical and secretarial staff employed by such counsel.
24 Provided, however, that each non-lawyer given access to Confidential Materials shall be advised
25 that such Materials are being Disclosed pursuant to, and are subject to, the terms of this Stipulation
26 and Protective Order and that they may not be Disclosed other than pursuant to its terms,
27 c. those officers, directors, partners, members, employees and agents of all non-
28 designating Parties (e.g. outside vendors) that counsel for such Parties deems necessary to aid
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1 counsel in the prosecution and defense of this Proceeding; provided, however, that prior to the
2 Disclosure of Confidential Materials to any such officer, director, partner, member, employee or
3 agent, counsel for the Party making the Disclosure shall deliver a copy of this Stipulation and
4 Protective Order to such person, shall explain that such person is bound to follow the terms of
5 such Order, and shall secure the signature of such person on a statement in the form attached
6 hereto as Exhibit A;
7 d. court reporters, videographers, and their staff who are not personnel of the
8 court, in this Proceeding (whether at depositions, hearings, or any other proceeding). Should a party
9 invoke Paragraph 4(b) because Protected Documents or Information are used in a deposition,
10 hearing, or other proceeding, all present court reporters, videographers, and their staff who are not
11 personnel of the court shall execute the form attached as Exhibit A to the extent not already
12 executed;
13 e. any deposition, trial or hearing witness in the Proceeding who previously
14 has had access to the Confidential Materials, or was previously an officer, director, partner,
15 member, employee or agent of an entity that has had access to the Confidential Materials, and who
16 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
17 agreed by the Designating Party or ordered by the court. [N]othing in this paragraph shall limit the
18 use of Ford documents in deposition of Ford representatives or employees
19 f. any deposition or non-trial hearing witness in the Proceeding who previously
20 did not have access to the Confidential Materials; provided, however, that each such witness given
21 access to Confidential Materials shall be advised that such Materials are being Disclosed pursuant
22 to, and are subject to, the terms of this Stipulation and Protective Order and that they may not be
23 Disclosed other than pursuant to its terms, and who have signed the “Acknowledgment and
24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
25 by the court. [N]othing in this paragraph shall limit the use of Ford documents in deposition of Ford
26 representatives or employees.
27 g. mock jury participants, provided, however, that prior to the Disclosure
28 of Confidential Materials to any such mock jury participant, counsel for the Party making the
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1 Disclosure shall deliver a copy of this Stipulation and Protective Order to such person, shall explain
2 that such person is bound to follow the terms of such Order, and shall secure the signature of such
3 person on a statement in the form attached hereto as Exhibit A. Mock jury participants may not
4 retain copies of any material designated as “Confidential;”
5 h. non-attorney outside experts or non-attorney expert consultants or attorneys
6 specifically retained to consult as an e-discovery analyst with respect to technical issues pertaining
7 to electronically stored information consulted by the undersigned Parties or their counsel in
8 connection with the Proceeding, whether or not retained to testify at any oral hearing; provided,
9 however, that no disclosure shall be made to any expert or consultant who is currently employed by
10 a competitor of the Designating Party, and that prior to the Disclosure of Confidential Materials to
11 any such expert or expert consultant, counsel for the Party making the Disclosure shall deliver
12 a copy of this Stipulation and Protective Order to such person, shall explain its terms to such
13 person, and shall secure the signature of such person on a statement in the form attached hereto as
14 Exhibit A. It shall be the obligation of counsel, upon learning of any breach or threatened breach
15 of this Stipulation and Protective Order by any such expert or expert consultant, to promptly notify
16 counsel for the Designating Party of such breach or threatened breach; and
17 i. any other person that the Designating Party agrees to in writing.
18 8. Confidential Materials shall be used by the persons receiving them only for the
19 purposes of preparing for, conducting, participating in the conduct of, and/or prosecuting and/or
20 defending this Proceeding, and not for any business or other purpose whatsoever.
21 9. Any Party to the Proceeding (or other person subject to the terms of this Stipulation
22 and Protective Order) may ask the Court, after appropriate notice to the other Parties to the
23 Proceeding, to modify or grant relief from any provision of this Stipulation and Protective Order.
24 10. Entering into, agreeing to, and/or complying with the terms of this Stipulation and
25 Protective Order shall not:
26 a. operate as an admission by any person that any particular Document,
27 Testimony or Information marked “Confidential” or “Subject to Protective Order” contains or
28 reflects trade secrets, proprietary, confidential or competitively sensitive business, commercial,
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1 financial or personal information; or
2 b. prejudice in any way the right of any Party (or any other person subject to the
3 terms of this Stipulation and Protective Order):
4 i. to seek a determination by the Court of whether any particular
5 Confidential Material should be subject to protection as “Confidential” under the terms of this
6 Stipulation and Protective Order; or
7 ii. to seek relief from the Court on appropriate notice to all other Parties
8 to the Proceeding from any provision(s) of this Stipulation and Protective Order, either generally or
9 as to any particular Document, Material or Information.
10 11. Any Party to the Proceeding who has not executed this Stipulation and Protective
11 Order as of the time it is presented to the Court for signature may thereafter become a Party to this
12 Stipulation and Protective Order by its counsel’s signing and dating a copy thereof and filing the
13 same with the Court, and serving copies of such signed and dated copy upon the other Parties to this
14 Stipulation and Protective Order.
15 12. Any Information that may be produced by a non-Party witness in discovery in the
16 Proceeding pursuant to subpoena or otherwise may be designated by such non-Party as “Confidential”
17 or “Subject to Protective Order” under the terms of this Stipulation and Protective Order, and any such
18 designation by a non-Party shall have the same force and effect, and create the same duties and
19 obligations, as if made by one of the undersigned Parties hereto. Any such designation shall also
20 function as a consent by such producing Party to the authority of the Court in the Proceeding to resolve
21 and conclusively determine any motion or other application made by any person or Party with respect
22 to such designation, or any other matter otherwise arising under this Stipulation and Protective Order.
23 13. If any person subject to this Stipulation and Protective Order who has custody of any
24 Confidential Materials receives a subpoena or other process (“Subpoena”) from any government or
25 other person or entity demanding production of Confidential Materials, the recipient of the
26 Subpoena shall promptly give notice of the same by electronic mail transmission, followed by either
27 express mail or overnight delivery to counsel of record for the Designating Party, and shall furnish
28 such counsel with a copy of the Subpoena. Upon receipt of this notice, the Designating Party may,
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1 in its sole discretion and at its own cost, move to quash or limit the Subpoena, otherwise oppose
2 production of the Confidential Materials, and/or seek to obtain confidential treatment of such
3 Confidential Materials from the subpoenaing person or entity to the fullest extent available under
4 law. The recipient of the Subpoena may not produce any Documents, Testimony or Information
5 pursuant to the Subpoena prior to the date specified for production on the Subpoena.
6 14. Nothing in this Stipulation and Protective Order shall be construed to preclude either
7 Party from asserting in good faith that certain Confidential Materials require additional protection.
8 The Parties shall meet and confer to agree upon the terms of such additional protection.
9 15. If, after execution of this Stipulation and Protective Order, any Confidential
10 Materials submitted by a Designating Party under the terms of this Stipulation and Protective Order
11 is Disclosed by a non-Designating Party to any person other than in the manner authorized by this
12 Stipulation and Protective Order, the non-Designating Party responsible for the Disclosure shall
13 bring all pertinent facts relating to the Disclosure of such Confidential Materials to the immediate
14 attention of the Designating Party.
15 16. This Stipulation and Protective Order is entered into without prejudice to the right of
16 any Party to knowingly waive the applicability of this Stipulation and Protective Order to any
17 Confidential Materials designated by that Party. If the Designating Party uses Confidential
18 Materials in a non-Confidential manner, then the Designating Party shall advise that the designation
19 no longer applies.
20 17. Where any Confidential Materials, or Information derived from Confidential
21 Materials, is included in any motion or other proceeding governed by California Rules of Court,
22 Rules 2.550 and 2.551, the party shall follow those rules. With respect to discovery motions or other
23 proceedings not governed by California Rules of Court, Rules 2.550 and 2.551, the following shall
24 apply: If Confidential Materials or Information derived from Confidential Materials are
25 submitted to or otherwise disclosed to the Court in connection with discovery motions and
26 proceedings, the same shall be separately filed under seal with the clerk of the Court in an envelope
27 marked: “CONFIDENTIAL – FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
28 AND WITHOUT ANY FURTHER SEALING ORDER REQUIRED.”
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1 18. The Parties shall meet and confer regarding the procedures for use of Confidential
2 Materials at trial and shall move the Court for entry of an appropriate order.
3 19. Nothing in this Stipulation and Protective Order shall affect the admissibility into
4 evidence of Confidential Materials, or abridge the rights of any person to seek judicial review or to
5 pursue other appropriate judicial action with respect to any ruling made by the Court concerning the
6 issue of the status of Protected Material.
7 20. This Stipulation and Protective Order shall continue to be binding after the
8 conclusion of this Proceeding and all subsequent proceedings arising from this Proceeding, except
9 that a Party may seek the written permission of the Designating Party or may move the Court for
10 relief from the provisions of this Stipulation and Protective Order. To the extent permitted by law,
11 the Court shall retain jurisdiction to enforce, modify, or reconsider this Stipulation and Protective
12 Order, even after the Proceeding is terminated.
13 21. Upon written request made within thirty (30) days after the settlement or other
14 termination of the Proceeding, the undersigned Parties shall have thirty (30) days to either (a)
15 promptly return to counsel for each Designating Party all Confidential Materials and all copies
16 thereof (except that counsel for each Party may maintain in its files, in continuing compliance with
17 the terms of this Stipulation and Protective Order, all work product, and one copy of each pleading
18 filed with the Court and one copy of each deposition together with the exhibits marked at the
19 deposition), (b) agree with counsel for the Designating Party upon appropriate methods and
20 certification of destruction or other disposition of such Confidential Materials, or (c) as to any
21 Documents, Testimony or other Information not addressed by sub-paragraphs (a) and (b), file a
22 motion seeking a Court order regarding proper preservation of such Materials. With respect to
23 those materials that this provision allows the Receiving Party to retain after settlement or termination
24 of the Proceeding, exhibits to the retained materials must be returned to the Producing Party or
25 destroyed on or before 5 years after settlement or termination of the Proceeding. The parties agree
26 to meet and confer prior to moving to enforce compliance with this provision. To the extent
27 permitted by law the Court shall retain continuing jurisdiction to review and rule upon the motion
28 referred to in sub-paragraph (c) herein.
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1 22. After this Stipulation and Protective Order has been signed by counsel for all Parties,
2 it shall be presented to the Court for entry. Counsel agree to be bound by the terms set forth herein
3 with regard to any Confidential Materials that have been produced before the Court signs this
4 Stipulation and Protective Order.
5 23. The Parties and all signatories to the Certification attached hereto as Exhibit A agree
6 to be bound by this Stipulation and Protective Order pending its approval and entry by the Court. In
7 the event that the Court modifies this Stipulation and Protective Order, or in the event that the Court
8 enters a different Protective Order, the Parties agree to be bound by this Stipulation and Protective
9 Order until such time as the Court may enter such a different Order. It is the Parties’ intent to be
10 bound by the terms of this Stipulation and Protective Order pending its entry so as to allow for
11 immediate production of Confidential Materials under the terms herein.
12 This Stipulation and Protective Order may be executed in counterparts.
13
DATED: _____________________ BY:
14 Attorneys for Plaintiff
15 LALONIE SANDERS
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DATED: ____April 22, 2024_____ BY:
18
Attorneys for Defendants
19 FORD MOTOR COMPANY and
JIM BURKE FORD
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1 ORDER
2 GOOD CAUSE APPEARING, the Court hereby approves this Stipulation and Protective
3 Order.
4 IT IS SO ORDERED.
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DATED: _____________________
7 HONORABLE THOMAS S. CLARK
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1 EXHIBIT A
2 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS
3 I hereby acknowledge that I, ________________________________ [NAME],
4 ________________________________________ [POSITION AND EMPLOYER], am about to
5 receive Confidential Materials supplied in connection with the Proceeding, BCV-23-102679. I
6 certify that I understand that the Confidential Materials are provided to me subject to the terms and
7 restrictions of the Stipulation and Protective Order filed in this Proceeding. I have been given a copy
8 of the Stipulation and Protective Order; I have read it, and I agree to be bound by its terms.
9 I understand that Confidential Materials, as defined in the Stipulation and Protective Order,
10 including any notes or other records that may be made regarding any such materials, shall not be
11 Disclosed to anyone except as expressly permitted by the Stipulation and Protective Order. I will
12 not copy or use, except solely for the purposes of this Proceeding, any Confidential Materials
13 obtained pursuant to this Protective Order, except as provided therein or otherwise ordered by the
14 Court in the Proceeding.
15 I further understand that I am to retain all copies of all Confidential Materials provided to
16 me in the Proceeding in a secure manner, and that all copies of such Materials are to remain in my
17 personal custody until termination of my participation in this Proceeding, whereupon the copies of
18 such Materials will be returned or certified of destruction or deletion in writing to counsel who
19 provided me with such Materials.
20 I declare under penalty of perjury, under the laws of the State of California, that the foregoing
21 is true and correct. Executed this ____ day of 20__, at _____________.
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DATED: _____________________ BY:
23 Signature
24 Title
25 Address
26
City, State, Zip
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Telephone Number
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1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the age of 18
3 and not a party to the within action. My business address is Strategic Legal Practices, 1888
Century Park East, 19th Floor, Los Angeles, California 90067.
4
On May 7, 2024, I caused to be served the document(s) described as:
5
STIPULATION AND PROTECTIVE ORDER – CONFIDENTIAL DESIGNATION
6 ONLY
7 on the interested parties in this action by sending [ ] the original [or] [] a true copy thereof
[] to interested parties as follows [or] [ ] as stated on the attached service list:
8
MORTENSON TAGGART ADAMS LLP
9 300 Spectrum Center Dr., Suite 1200
Irvine, CA 92618
10 mmortenson@mortensontaggart.com
ctaggart@mortensontaggart.com
11 pjun@mortensontaggart.com
sross@mortensontaggart.com
12 dkeithly@mortensontaggart.com
klaub@mortensontaggart.com
13 hbiemann@mortensontaggart.com
kthurmond@mortensontaggart.com
14 service@mortensontaggart.com
15 [] BY E-MAIL: (BY ELECTRONIC MAIL - CCP § 1010.6(a)(6)) Based on a court
order or an agreement of the parties to accept service by e-mail or electronic
16 transmission, I caused such documents described herein to be sent to the persons at
the e-mail address(es) listed above. The firm did not receive, within a reasonable
17 time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
18
19 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
20
Executed this May 7, 2024, at Los Angeles, California.
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23
Maureen Sennhauser
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PROOF OF SERVICE
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1 Michael D. Mortenson, State Bar No. 247758 mmortenson@mortensontaggart.com 2 Craig A. Taggart, State Bar No. 239168 ctaggart@mortensontaggart.com 3 Ravi K. Lally, State Bar No. 225687 4 rlally@mortensontaggart.com Hannah M. Biemann, State Bar No. 333843 5 hbiemann@mortensontaggart.com MORTENSON TAGGART ADAMS LLP 6 300 Spectrum Center Drive, Suite 1200 7 Irvine, California 92618 Telephone: (949) 774-2224 8 Facsimile: (949) 774-2545 9 Attorneys for Defendants FORD MOTOR COMPANY and 10 JIM BURKE FORD 11 Tionna Carvalho, State Bar No. 299010 12 tcarvalho@slpattorney.com STRATEGIC LEGAL PRACTICES, APC 13 1888 Century Park East, 19th Floor Los Angeles, California 90067 14 Telephone: (310) 929-4900 15 Facsimile: (310) 943-3838 16 Attorneys for Plaintiff LALONIE SANDERS 17 SUPERIOR COURT OF THE STATE OF CALIFORNIA 18 COUNTY OF KERN 19 20 21 LALONIE SANDERS, CASE NO. BCV-23-102679 Honorable Thomas S. Clark 22 Plaintiff, Dept.: 17 23 vs. 24 STIPULATION AND PROTECTIVE FORD MOTOR COMPANY; JIM BURKE ORDER – CONFIDENTIAL 25 FORD; and DOES 1 through 10, inclusive, DESIGNATION ONLY 26 Defendants. Action Filed: August 14, 2023 27 Trial Date: September 15, 2025 28 MORTENSON TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 IT IS HEREBY STIPULATED by and between the Parties to Lalonie Sanders v. Ford 2 Motor Company, et al., by and through their respective counsel of record, that in order to facilitate 3 the exchange of information and documents which may be subject to confidentiality limitations 4 on disclosure due to federal laws, state laws, and privacy rights, the Parties stipulate as follows: 5 1. In this Stipulation and Protective Order, the words set forth below shall have the 6 following meanings: 7 a. “Proceeding” means the above-entitled proceeding BCV-23-102679. 8 b. “Court” means the Hon. Thomas S. Clark, or any other judge to which this 9 Proceeding may be assigned, including Court staff participating in such proceedings. 10 c. “Confidential” means any information which is in the possession of a 11 Designating Party who believes in good faith that such information is entitled to confidential 12 treatment under applicable law. 13 d. “Confidential Materials” means any Documents, Testimony or Information 14 as defined below designated as “Confidential” or “Subject to Protective Order” pursuant to the 15 provisions of this Stipulation and Protective Order. 16 e. “Designating Party” means the Party that designates 17 Materials as “Confidential.” 18 f. “Disclose” or “Disclosed” or “Disclosure” means to reveal, divulge, give, or 19 make available Materials, or any part thereof, or any information contained therein. 20 g. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those 21 terms are defined by California Evidence Code Sections 250, 255, and 260, which have been 22 produced in discovery in this Proceeding by any person, and (ii) any copies, reproductions, or 23 summaries of all or any part of the foregoing. 24 h. “Information” means the content of Documents or Testimony. 25 i. “Testimony” means all depositions, declarations or other testimony taken or 26 used in this Proceeding. 27 2. The Designating Party shall have the right to designate as “Confidential” or “Subject 28 to Protective Order” any Documents, Testimony or Information that the Designating Party in good MORTENSON -1- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 faith believes to contain non-public information that is entitled to confidential treatment under 2 applicable law, including proprietary or commercially sensitive business information or personally 3 identifiable information (“PII”) of non-parties. 4 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or 5 abridge any right, privilege or protection otherwise available to any Party with respect to the 6 discovery of matters, including but not limited to any Party’s right to assert the attorney-client 7 privilege, the attorney work product doctrine, or other privileges, or any Party’s right to contest any 8 such assertion. 9 4. Any Documents, Testimony or Information to be designated as “Confidential” or 10 “Subject to Protective Order” must be clearly so designated before the Document, Testimony or 11 Information is Disclosed or produced. The parties may agree that the case name and number are to 12 be part of the “Confidential” or “Subject to Protective Order” designation. The ”Confidential” or 13 “Subject to Protective Order” designation should not obscure or interfere with the legibility of the 14 designated Information. 15 a. For Documents (apart from transcripts of depositions or other pretrial or trial 16 proceedings), the Designating Party must affix the legend “Confidential” or “Subject to Protective 17 Order” on each page of any Document containing such designated Confidential Material. 18 b. For Testimony given in depositions the Designating Party may either: 19 i. identify on the record, before the close of the deposition, all 20 “Confidential” Testimony, by specifying all portions of the Testimony that qualify as 21 “Confidential;” or 22 ii. identify more specific portions of the Testimony as to which 23 protection is sought within 30 days following receipt of the deposition transcript. In circumstances 24 where portions of the deposition Testimony are designated for protection, the transcript pages 25 containing “Confidential” Information may be separately bound by the court reporter, who must 26 affix to the top of each page the legend “Confidential” or “Subject to Protective Order” as instructed 27 by the Designating Party. 28 c. For Information produced in some form other than Documents, and for any MORTENSON -2- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 other tangible items, including, without limitation, compact discs or DVDs, the Designating Party 2 must affix in a prominent place on the exterior of the container or containers in which the 3 Information or item is stored the legend “Confidential” or “Subject to Protective Order.” 4 5. The inadvertent production by any of the undersigned Parties or non-Parties to the 5 Proceedings of any Document, Testimony or Information during discovery in this Proceeding 6 without a “Confidential” or “Subject to Protective Order” designation, shall be without prejudice to 7 any claim that such item is Confidential” and such Party shall not be held to have waived any rights 8 by such inadvertent production. In the event that any Document, Testimony or Information that is 9 subject to a “Confidential” or “Subject to Protective Order” designation is inadvertently produced 10 without such designation, the Party that inadvertently produced the document shall give written 11 notice of such inadvertent production within twenty (20) days of discovery of the inadvertent 12 production, together with a further copy of the subject Document, Testimony or Information 13 designated as “Confidential” (the “Inadvertent Production Notice”). Upon receipt of such 14 Inadvertent Production Notice, the Party that received the inadvertently produced Document, 15 Testimony or Information shall promptly destroy the inadvertently produced Document, Testimony 16 or Information and all copies thereof, or, at the expense of the producing Party, return such together 17 with all copies of such Document, Testimony or Information to counsel for the producing Party and 18 shall retain only the “Confidential” or “Subject to Protective Order” designated Materials. Should 19 the receiving Party choose to destroy such inadvertently produced Document, Testimony or 20 Information, the receiving Party shall notify the producing Party in writing of such destruction 21 within ten (10) days of receipt of written notice of the inadvertent production. This provision is not 22 intended to apply to any inadvertent production of any Information protected by attorney-client or 23 work product privileges. In the event that this provision conflicts with any applicable law 24 regarding waiver of confidentiality through the inadvertent production of Documents, Testimony or 25 Information, such law shall govern. 26 6. In the event that counsel for a Party receiving Documents, Testimony or Information 27 in discovery designated as “Confidential” objects to such designation with respect to any or all of 28 such items, said counsel shall advise counsel for the Designating Party, in writing, of such MORTENSON -3- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 objections, by identifying by Bates number to the extent practicable, the specific Documents, 2 Testimony or Information to which each objection pertains, and the specific reasons and support for 3 such objections (the “Designation Objections”). If the parties cannot resolve a challenge without 4 court intervention, counsel for the Designating Party shall have forty-five (45) days from receipt of 5 the written Designation Objections, or thirty (30) days from the parties agreement that the meet and 6 confer process will not resolve their dispute, whichever is earlier, to either (a) agree in writing to 7 de-designate Documents, Testimony or Information pursuant to any or all of the Designation 8 Objections and/or (b) file a motion with the Court seeking to uphold any or all designations on 9 Documents, Testimony or Information addressed by the Designation Objections (the “Designation 10 Motion”). Pending a resolution of the Designation Motion by the Court, any and all existing 11 designations on the Documents, Testimony or Information at issue in such Motion shall remain in 12 place. The Designating Party shall have the burden on any Designation Motion of establishing the 13 applicability of its “Confidential” designation. In the event that the Designation Objections are 14 neither timely agreed to nor timely addressed in the Designation Motion, then such Documents, 15 Testimony or Information shall be de-designated in accordance with the Designation Objection 16 applicable to such material. 17 7. Access to and/or Disclosure of Confidential Materials designated as “Confidential” 18 shall be permitted only to the following persons: 19 a. the Court and its personnel; 20 b. (1) Attorneys of record in the Proceedings and their affiliated attorneys in the 21 same firm, paralegals, clerical and secretarial staff employed by such attorneys who are actively 22 involved in the Proceedings and are not employees of any Party. (2) In-house counsel to the 23 undersigned Parties and the paralegal, clerical and secretarial staff employed by such counsel. 24 Provided, however, that each non-lawyer given access to Confidential Materials shall be advised 25 that such Materials are being Disclosed pursuant to, and are subject to, the terms of this Stipulation 26 and Protective Order and that they may not be Disclosed other than pursuant to its terms, 27 c. those officers, directors, partners, members, employees and agents of all non- 28 designating Parties (e.g. outside vendors) that counsel for such Parties deems necessary to aid MORTENSON -4- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 counsel in the prosecution and defense of this Proceeding; provided, however, that prior to the 2 Disclosure of Confidential Materials to any such officer, director, partner, member, employee or 3 agent, counsel for the Party making the Disclosure shall deliver a copy of this Stipulation and 4 Protective Order to such person, shall explain that such person is bound to follow the terms of 5 such Order, and shall secure the signature of such person on a statement in the form attached 6 hereto as Exhibit A; 7 d. court reporters, videographers, and their staff who are not personnel of the 8 court, in this Proceeding (whether at depositions, hearings, or any other proceeding). Should a party 9 invoke Paragraph 4(b) because Protected Documents or Information are used in a deposition, 10 hearing, or other proceeding, all present court reporters, videographers, and their staff who are not 11 personnel of the court shall execute the form attached as Exhibit A to the extent not already 12 executed; 13 e. any deposition, trial or hearing witness in the Proceeding who previously 14 has had access to the Confidential Materials, or was previously an officer, director, partner, 15 member, employee or agent of an entity that has had access to the Confidential Materials, and who 16 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 17 agreed by the Designating Party or ordered by the court. [N]othing in this paragraph shall limit the 18 use of Ford documents in deposition of Ford representatives or employees 19 f. any deposition or non-trial hearing witness in the Proceeding who previously 20 did not have access to the Confidential Materials; provided, however, that each such witness given 21 access to Confidential Materials shall be advised that such Materials are being Disclosed pursuant 22 to, and are subject to, the terms of this Stipulation and Protective Order and that they may not be 23 Disclosed other than pursuant to its terms, and who have signed the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 25 by the court. [N]othing in this paragraph shall limit the use of Ford documents in deposition of Ford 26 representatives or employees. 27 g. mock jury participants, provided, however, that prior to the Disclosure 28 of Confidential Materials to any such mock jury participant, counsel for the Party making the MORTENSON -5- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 Disclosure shall deliver a copy of this Stipulation and Protective Order to such person, shall explain 2 that such person is bound to follow the terms of such Order, and shall secure the signature of such 3 person on a statement in the form attached hereto as Exhibit A. Mock jury participants may not 4 retain copies of any material designated as “Confidential;” 5 h. non-attorney outside experts or non-attorney expert consultants or attorneys 6 specifically retained to consult as an e-discovery analyst with respect to technical issues pertaining 7 to electronically stored information consulted by the undersigned Parties or their counsel in 8 connection with the Proceeding, whether or not retained to testify at any oral hearing; provided, 9 however, that no disclosure shall be made to any expert or consultant who is currently employed by 10 a competitor of the Designating Party, and that prior to the Disclosure of Confidential Materials to 11 any such expert or expert consultant, counsel for the Party making the Disclosure shall deliver 12 a copy of this Stipulation and Protective Order to such person, shall explain its terms to such 13 person, and shall secure the signature of such person on a statement in the form attached hereto as 14 Exhibit A. It shall be the obligation of counsel, upon learning of any breach or threatened breach 15 of this Stipulation and Protective Order by any such expert or expert consultant, to promptly notify 16 counsel for the Designating Party of such breach or threatened breach; and 17 i. any other person that the Designating Party agrees to in writing. 18 8. Confidential Materials shall be used by the persons receiving them only for the 19 purposes of preparing for, conducting, participating in the conduct of, and/or prosecuting and/or 20 defending this Proceeding, and not for any business or other purpose whatsoever. 21 9. Any Party to the Proceeding (or other person subject to the terms of this Stipulation 22 and Protective Order) may ask the Court, after appropriate notice to the other Parties to the 23 Proceeding, to modify or grant relief from any provision of this Stipulation and Protective Order. 24 10. Entering into, agreeing to, and/or complying with the terms of this Stipulation and 25 Protective Order shall not: 26 a. operate as an admission by any person that any particular Document, 27 Testimony or Information marked “Confidential” or “Subject to Protective Order” contains or 28 reflects trade secrets, proprietary, confidential or competitively sensitive business, commercial, MORTENSON -6- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 financial or personal information; or 2 b. prejudice in any way the right of any Party (or any other person subject to the 3 terms of this Stipulation and Protective Order): 4 i. to seek a determination by the Court of whether any particular 5 Confidential Material should be subject to protection as “Confidential” under the terms of this 6 Stipulation and Protective Order; or 7 ii. to seek relief from the Court on appropriate notice to all other Parties 8 to the Proceeding from any provision(s) of this Stipulation and Protective Order, either generally or 9 as to any particular Document, Material or Information. 10 11. Any Party to the Proceeding who has not executed this Stipulation and Protective 11 Order as of the time it is presented to the Court for signature may thereafter become a Party to this 12 Stipulation and Protective Order by its counsel’s signing and dating a copy thereof and filing the 13 same with the Court, and serving copies of such signed and dated copy upon the other Parties to this 14 Stipulation and Protective Order. 15 12. Any Information that may be produced by a non-Party witness in discovery in the 16 Proceeding pursuant to subpoena or otherwise may be designated by such non-Party as “Confidential” 17 or “Subject to Protective Order” under the terms of this Stipulation and Protective Order, and any such 18 designation by a non-Party shall have the same force and effect, and create the same duties and 19 obligations, as if made by one of the undersigned Parties hereto. Any such designation shall also 20 function as a consent by such producing Party to the authority of the Court in the Proceeding to resolve 21 and conclusively determine any motion or other application made by any person or Party with respect 22 to such designation, or any other matter otherwise arising under this Stipulation and Protective Order. 23 13. If any person subject to this Stipulation and Protective Order who has custody of any 24 Confidential Materials receives a subpoena or other process (“Subpoena”) from any government or 25 other person or entity demanding production of Confidential Materials, the recipient of the 26 Subpoena shall promptly give notice of the same by electronic mail transmission, followed by either 27 express mail or overnight delivery to counsel of record for the Designating Party, and shall furnish 28 such counsel with a copy of the Subpoena. Upon receipt of this notice, the Designating Party may, MORTENSON -7- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 in its sole discretion and at its own cost, move to quash or limit the Subpoena, otherwise oppose 2 production of the Confidential Materials, and/or seek to obtain confidential treatment of such 3 Confidential Materials from the subpoenaing person or entity to the fullest extent available under 4 law. The recipient of the Subpoena may not produce any Documents, Testimony or Information 5 pursuant to the Subpoena prior to the date specified for production on the Subpoena. 6 14. Nothing in this Stipulation and Protective Order shall be construed to preclude either 7 Party from asserting in good faith that certain Confidential Materials require additional protection. 8 The Parties shall meet and confer to agree upon the terms of such additional protection. 9 15. If, after execution of this Stipulation and Protective Order, any Confidential 10 Materials submitted by a Designating Party under the terms of this Stipulation and Protective Order 11 is Disclosed by a non-Designating Party to any person other than in the manner authorized by this 12 Stipulation and Protective Order, the non-Designating Party responsible for the Disclosure shall 13 bring all pertinent facts relating to the Disclosure of such Confidential Materials to the immediate 14 attention of the Designating Party. 15 16. This Stipulation and Protective Order is entered into without prejudice to the right of 16 any Party to knowingly waive the applicability of this Stipulation and Protective Order to any 17 Confidential Materials designated by that Party. If the Designating Party uses Confidential 18 Materials in a non-Confidential manner, then the Designating Party shall advise that the designation 19 no longer applies. 20 17. Where any Confidential Materials, or Information derived from Confidential 21 Materials, is included in any motion or other proceeding governed by California Rules of Court, 22 Rules 2.550 and 2.551, the party shall follow those rules. With respect to discovery motions or other 23 proceedings not governed by California Rules of Court, Rules 2.550 and 2.551, the following shall 24 apply: If Confidential Materials or Information derived from Confidential Materials are 25 submitted to or otherwise disclosed to the Court in connection with discovery motions and 26 proceedings, the same shall be separately filed under seal with the clerk of the Court in an envelope 27 marked: “CONFIDENTIAL – FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER 28 AND WITHOUT ANY FURTHER SEALING ORDER REQUIRED.” MORTENSON -8- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 18. The Parties shall meet and confer regarding the procedures for use of Confidential 2 Materials at trial and shall move the Court for entry of an appropriate order. 3 19. Nothing in this Stipulation and Protective Order shall affect the admissibility into 4 evidence of Confidential Materials, or abridge the rights of any person to seek judicial review or to 5 pursue other appropriate judicial action with respect to any ruling made by the Court concerning the 6 issue of the status of Protected Material. 7 20. This Stipulation and Protective Order shall continue to be binding after the 8 conclusion of this Proceeding and all subsequent proceedings arising from this Proceeding, except 9 that a Party may seek the written permission of the Designating Party or may move the Court for 10 relief from the provisions of this Stipulation and Protective Order. To the extent permitted by law, 11 the Court shall retain jurisdiction to enforce, modify, or reconsider this Stipulation and Protective 12 Order, even after the Proceeding is terminated. 13 21. Upon written request made within thirty (30) days after the settlement or other 14 termination of the Proceeding, the undersigned Parties shall have thirty (30) days to either (a) 15 promptly return to counsel for each Designating Party all Confidential Materials and all copies 16 thereof (except that counsel for each Party may maintain in its files, in continuing compliance with 17 the terms of this Stipulation and Protective Order, all work product, and one copy of each pleading 18 filed with the Court and one copy of each deposition together with the exhibits marked at the 19 deposition), (b) agree with counsel for the Designating Party upon appropriate methods and 20 certification of destruction or other disposition of such Confidential Materials, or (c) as to any 21 Documents, Testimony or other Information not addressed by sub-paragraphs (a) and (b), file a 22 motion seeking a Court order regarding proper preservation of such Materials. With respect to 23 those materials that this provision allows the Receiving Party to retain after settlement or termination 24 of the Proceeding, exhibits to the retained materials must be returned to the Producing Party or 25 destroyed on or before 5 years after settlement or termination of the Proceeding. The parties agree 26 to meet and confer prior to moving to enforce compliance with this provision. To the extent 27 permitted by law the Court shall retain continuing jurisdiction to review and rule upon the motion 28 referred to in sub-paragraph (c) herein. MORTENSON -9- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 22. After this Stipulation and Protective Order has been signed by counsel for all Parties, 2 it shall be presented to the Court for entry. Counsel agree to be bound by the terms set forth herein 3 with regard to any Confidential Materials that have been produced before the Court signs this 4 Stipulation and Protective Order. 5 23. The Parties and all signatories to the Certification attached hereto as Exhibit A agree 6 to be bound by this Stipulation and Protective Order pending its approval and entry by the Court. In 7 the event that the Court modifies this Stipulation and Protective Order, or in the event that the Court 8 enters a different Protective Order, the Parties agree to be bound by this Stipulation and Protective 9 Order until such time as the Court may enter such a different Order. It is the Parties’ intent to be 10 bound by the terms of this Stipulation and Protective Order pending its entry so as to allow for 11 immediate production of Confidential Materials under the terms herein. 12 This Stipulation and Protective Order may be executed in counterparts. 13 DATED: _____________________ BY: 14 Attorneys for Plaintiff 15 LALONIE SANDERS 16 17 DATED: ____April 22, 2024_____ BY: 18 Attorneys for Defendants 19 FORD MOTOR COMPANY and JIM BURKE FORD 20 21 22 23 24 25 26 27 28 MORTENSON -10- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 ORDER 2 GOOD CAUSE APPEARING, the Court hereby approves this Stipulation and Protective 3 Order. 4 IT IS SO ORDERED. 5 6 DATED: _____________________ 7 HONORABLE THOMAS S. CLARK 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MORTENSON -11- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 EXHIBIT A 2 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS 3 I hereby acknowledge that I, ________________________________ [NAME], 4 ________________________________________ [POSITION AND EMPLOYER], am about to 5 receive Confidential Materials supplied in connection with the Proceeding, BCV-23-102679. I 6 certify that I understand that the Confidential Materials are provided to me subject to the terms and 7 restrictions of the Stipulation and Protective Order filed in this Proceeding. I have been given a copy 8 of the Stipulation and Protective Order; I have read it, and I agree to be bound by its terms. 9 I understand that Confidential Materials, as defined in the Stipulation and Protective Order, 10 including any notes or other records that may be made regarding any such materials, shall not be 11 Disclosed to anyone except as expressly permitted by the Stipulation and Protective Order. I will 12 not copy or use, except solely for the purposes of this Proceeding, any Confidential Materials 13 obtained pursuant to this Protective Order, except as provided therein or otherwise ordered by the 14 Court in the Proceeding. 15 I further understand that I am to retain all copies of all Confidential Materials provided to 16 me in the Proceeding in a secure manner, and that all copies of such Materials are to remain in my 17 personal custody until termination of my participation in this Proceeding, whereupon the copies of 18 such Materials will be returned or certified of destruction or deletion in writing to counsel who 19 provided me with such Materials. 20 I declare under penalty of perjury, under the laws of the State of California, that the foregoing 21 is true and correct. Executed this ____ day of 20__, at _____________. 22 DATED: _____________________ BY: 23 Signature 24 Title 25 Address 26 City, State, Zip 27 Telephone Number 28 MORTENSON -12- TAGGART STIPULATION AND PROTECTIVE ORDER ADAMS LLP 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 3 and not a party to the within action. My business address is Strategic Legal Practices, 1888 Century Park East, 19th Floor, Los Angeles, California 90067. 4 On May 7, 2024, I caused to be served the document(s) described as: 5 STIPULATION AND PROTECTIVE ORDER – CONFIDENTIAL DESIGNATION 6 ONLY 7 on the interested parties in this action by sending [ ] the original [or] [] a true copy thereof [] to interested parties as follows [or] [ ] as stated on the attached service list: 8 MORTENSON TAGGART ADAMS LLP 9 300 Spectrum Center Dr., Suite 1200 Irvine, CA 92618 10 mmortenson@mortensontaggart.com ctaggart@mortensontaggart.com 11 pjun@mortensontaggart.com sross@mortensontaggart.com 12 dkeithly@mortensontaggart.com klaub@mortensontaggart.com 13 hbiemann@mortensontaggart.com kthurmond@mortensontaggart.com 14 service@mortensontaggart.com 15 [] BY E-MAIL: (BY ELECTRONIC MAIL - CCP § 1010.6(a)(6)) Based on a court order or an agreement of the parties to accept service by e-mail or electronic 16 transmission, I caused such documents described herein to be sent to the persons at the e-mail address(es) listed above. The firm did not receive, within a reasonable 17 time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 18 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 20 Executed this May 7, 2024, at Los Angeles, California. 21 22 23 Maureen Sennhauser 24 25 26 27 28 PROOF OF SERVICE