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Claire E. Cochran (SBN 222569)
Natalie A. Xifo (SBN 280930)
LAW OFFICES OF CLAIRE COCHRAN, P.C.
100 Pine Street, Suite 1250
San Francisco, CA 94111
Telephone: (415) 580-6019
Facsimile: (415) 745-3301
Attorneys for Plaintiff
NATHAN PETER RUNYON
Pierce Bainbridge Beck Price & Hecht LLP
Andrew E. Calderon (SBN 316673)
acalderon@piercebainbridge.com
355 South Grand Avenue, 44th Floor
Los Angeles, California 90071
Tel: (213) 262-9333
Fax: (213) 279-2008
Christopher N. LaVigne (NY Bar No. 4811121)
(Admitted Pro Hac Vice)
clavigne@piercebainbridge.com
277 Park Avenue, 45th Floor
New York, NY 10172
Tel.: (646) 694-9666
Fax: (646) 968-412
Attorneys for Defendants
PAYWARD, INC. d/b/a KRAKEN and KAISER NG
SUPERIOR COURT OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
{UNLIMITED JURISDICTION]
NATHAN PETER RUNYON, an individual Case No.: CGC-19-581099
Plaintiff, STIPULATED PROTECTIVE ORDER
v. Date Action Filed: November 26, 2019
FAC File: January 6, 2020
PAYWARD, INC., a California Corporation Trial Date:
d/b/a KRAKEN; and KAISER NG an
individual; and DOES 1-50, inclusive
Defendants.
Not Set
RUNYON vy. PAYWARD and NG
STIPULATED PROTECTIVE ORDER
CASE NO. CGC-19-581099Plaintiff, NATHAN PETER RUNYON, (“Plaintiff”) and Defendants, PAY WARD, INC.
d/b/a KRAKEN (“Defendant”) and KAISER NG (“Ng”), (collectively referred to herein as the
“Participating Parties”) hereby stipulate and agree as follows:
Good cause exists for a protective order under California law, including under Code of Civil
Procedure section 2031.060, in that the parties anticipate (a) that certain documents,
communications, and other information produced in discovery will contain private and confidential
information relating to Plaintiff, Defendant, and/or third parties, and (b) that a mechanism is needed
to allow for discovery and disclosure while protecting privacy and other rights under the laws of the
State of California.
DESIGNATION OF CONFIDENTIAL INFORMATION
1. For purposes of this Stipulated Protective Order, the term “Confidential
Information” includes, but is not limited to: information that violates the privacy interests of and/or
confidential information relating to Plaintiff, Defendants and/or employees of any Defendant;
confidential and proprietary information and trade secrets; as well as any other information that the
producing party in good faith reasonably deems to be confidential or is otherwise entitled to
confidential treatment under applicable law.
2. Any party may designate as “Confidential” any pleading, document, testimony, or
other discovery material that contains Confidential Information as described in paragraph 1. No
designation shall be made unless counsel of record for the designating party believes in good faith
that the designated material is in fact Confidential. An inadvertent failure to designate qualified
items or material, if promptly corrected, shall not waive the designating party’s right to secure
protection for such items or material under this Stipulated Protective Order.
3. “Confidential Information” or “Proprietary Information” do not include documents
or other information that is publicly available.
4, A party may designate documents as Confidential by marking them as such, or by
providing written notice to the other parties that certain documents, or groups of documents, are to
be considered Confidential. A party may designate all or part of the oral testimony of any witness
as Confidential either by (a) orally designating the testimony as Confidential during the deposition
or hearing, and requesting the reporter to mark the beginning and end of the testimony so
designated and to separately bind the Confidential portion(s), or (b) by giving written notice to all
counsel of record of the specific pages and lines of the transcripts to be designated Confidential
within fifteen (15) days of service of the transcript by the court reporter.
5. Any party may challenge the designation of documents or testimony as Confidential
by first meeting and conferring with counsel for the producing party in a good faith effort to resolve
the dispute and, if necessary, thereafter by seeking relief from the Court by filing a motion.
Pending a determination by the Court as to the appropriateness of the Confidential designation, all
parties will treat the material in question as Confidential.
6. Material designated as Confidential pursuant to this Stipulated Protective Order, the
2
RUNYON v, PAYWARD and NG STIPULATED PROTECTIVE ORDER
CASE NO. CGC-19-581099information contained therein, and any summaries, copies, abstracts, or other documents derived, in
whole or in part from Confidential Information, shall be used only for purposes of this litigation.
The parties recognize and agree that it is not a legitimate or good faith use of the discovery process
to seek, disseminate, or use discovery material for any purpose other than this litigation. The term
“this litigation,” as used herein and in the acknowledgment set forth in Attachment A hereto, refers
only to the above captioned matter, specifically Nathan Peter Runyon v. Payward, Inc. d/b/a
Kraken, and Kaiser Ng (San Francisco Superior Court Case No. CGC-19-581099).
LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL INFORMATION
7. Except as provided below, Confidential Information may be disclosed only to the
following persons:
(a) Counsel of record for any party to this litigation, and the employees of
counsels’ law firms;
(b) Experts and consultants (including independent experts and independent
consultants, their employees and clerical assistants) who are employed,
retained, or otherwise consulted by any counsel of record to assist in any way
in this litigation, provided such person has first agreed to be bound by the
terms of this Stipulated Protective Order by executing the acknowledgment
set forth in Attachment A;
(c) The Court hearing this litigation and its staff,
(d) Court reporters, their staff and professional vendors to whom disclosure is
reasonably necessary for purposes of this litigation;
(e) Witnesses in this action to whom disclosure is reasonably necessary;
@é The author of the document or the original source of the information; and
(g) Mediators.
8. Confidential Information may also be disclosed to any Party.
9. Confidential or Proprietary Information produced during the course of this litigation
shall not be disclosed to any person under paragraphs 7(b), (d) and (e), unless that person has
agreed to be bound by the terms of this Stipulated Protective Order by executing the
acknowledgment set forth in Attachment A. Parties to the lawsuit shall also agree to be bound by
the terms of Attachment A.
10. Any party submitting Confidential or Proprietary Information in conjunction with
motions or other Court proceedings shall comply with California Rule of Court 2.551.
11. Nothing in this Stipulated Protective Order shall preclude use of Confidential
Information at trial nor shall it preclude any party from seeking appropriate protections from the
trial court.
12. Nothing in this Stipulated Protective Order shall prevent any party from seeking
modification of it by the Court in the future. In addition, nothing in this Stipulated Protective Order
shall be deemed a waiver of any party’s right to object to any discovery request on any ground; to
seek an order compelling a response to any discovery request; to object to the use in evidence of
any material covered by the Stipulated Protective Order; or to restrict the designating party’s use of
its own documents.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
LITIGATION
13. If a Receiving Party (“party receiving the documents”) is served with a subpoena or
an order issued in other litigation that would compel disclosure of any information or items
designated in this litigation as “CONFIDENTIAL INFORMATION,” the Receiving Party must so
3
RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER
CASE NO. CGC-19-581099notify the Designating Party (“party that has designated the documents confidential”), in writing by
e-mail, immediately and in no event more than three court days after receiving the subpoena or
order. Such notification must include a copy of the subpoena or court order.
14. The Receiving Party also must immediately inform in writing the Party who caused
the subpoena or order to issue in the other litigation that some or all the material covered by the
subpoena or order is the subject of this Protective Order. In addition, the Receiving Party must
deliver a copy of this Stipulated Protective Order promptly to the Party in the other action that
caused the subpoena or order to issue.
15. The purpose of imposing these duties is to alert the interested parties to the existence
of this Protective Order and to afford the Designating Party in this case an opportunity to try to
protect its confidentiality interests in the court from which the subpoena or order issued. The
Designating Party shall bear the burdens and the expenses of seeking protection in that court of its
confidential material — and nothing in these provisions should be construed as authorizing or
encouraging a Receiving Party in this action to disobey a lawful directive from another court.
DURATION
16. Even after the termination of this litigation, the confidentiality obligations imposed
by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
order otherwise directs.
FINAL DISPOSITION
17. Unless otherwise ordered or agreed in writing by the Producing Party, within sixty
days after the final termination of this action, each Receiving Party must return all Protected
Material to the Producing Party. As used in this subdivision, “all Protected Material” includes all
copies, abstracts, compilations, summaries or any other form of reproducing or capturing any of the
Protected Material. With permission in writing from the Designating Party, the Receiving Party
may destroy some or all of the Protected Material instead of returning it. Whether the Protected
Material is returned or destroyed, the Receiving Party must submit a written certification to the
Producing Party (and, if not the same person or entity, to the Designating Party) by the sixty-day
deadline that all the Protected Material that was returned or destroyed and that affirms that the
Receiving Party has not retained any copies, abstracts, compilations, summaries or other forms of
reproducing or capturing any of the Protected Material.
IT IS SO STIPULATED
Dated: March 9, 2020 LAW OFFICES OF CLAIRE COCHRAN
CLAIRE COCHRAN
NATALIE A. XIFO
Attorneys for Plaintiff
NATHAN PETER RUNYON
RUNYON v, PAYWARD and NG STIPULATED PROTECTIVE ORDER
CASE NO. CGC-19-581099Dated: March 9, 2020 Pierce Bainbridge Beck Price & Hecht LLP
Aulus Getad)
CHRISTOPHER N. LAVIGNE
ANDREW E. CALDERON
Attorneys for Defendants
PAYWARD, INC. d/b/a KRAKEN and
KAISER NG
[PROPOSED] ORDER
GOOD CAUSE APPEARING for this Protective Order and pursuant to stipulation of the parties,
| Dated: Se ert
JUDGE OF THE SUPERIOR COURT
IT IS SO ORDERED.
>
RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER
CASE NO. CGC-19-58109924
25
Modification
Provided that nothing in this order determines that any document marked “confidential” qualifies
for sealing under CRC 2.550 or relieves any party from following the procedure in CRC 2.55 1.
ORDER
GOOD CAUSE APPEARING for this Protective Order, IT IS SO ORDERED.
“MAR =4 2021 Fb be P Soh ,
° ETHAN P. SCHULMAN
Judge of the Superior Court
DATED:
STIPULATION AND PROTECTIVE ORDER-ATTACHMENT A
AGREEMENT TO COMPLY WITH STIPULATED PROTECTIVE ORDER FOR
CONFIDENTIAL INFORMATION
I, [print or type full address
J, declare under penalty of perjury that I have read and
understand the Court's Stipulated Protective Order for CONFIDENTIAL INFORMATION in the
case of Nathan Peter Runyon v. Payward Inc, d/b/a Kraken and Kaiser Ng, San Francisco Superior
Court Case No. CGC 19-581099 (“Protective Order”). I agree to abide by all terms of the Order.
In addition, I specifically understand and agree to the following:
1, I will not disclose the CONFIDENTIAL INFORMATION to any other person or for
any purpose other than this litigation except in compliance with the Protective Order.
2. I understand that I have no power to authorize any other person to review the
CONFIDENTIAL INFORMATION.
3. I agree not to make copies of the CONFIDENTIAL INFORMATION.
4, I agree to return the CONFIDENTIAL INFORMATION to the counsel for the party
that produced it in compliance with Section 17 of the Protective Order.
5. I understand that if I violate any of the terms of the Protective Order, then I may be
subject to sanctions or possible contempt.
AGREED:
City and State where sworn and signed:
| Dated:
SIGNATURE
RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER
| CASE NO. CGC-19-581099THE LAW OFFICES OF
CLAIRE COCHRAN
March 4, 2021
Via Email, discovery302@sftc.org
Runyon vy Payward - CGC-19-581099 - 7/12/2021
Attention: Department 302, Presiding Justice, The Honorable Ethan P. Schulman
Re: Stipulated Protective Order, Filed and Local Fee Paid on 03/09/2020
Dear Honorable Judge Schulman,
Please find attached herein, the following for your consideration:
1. Stipulated Protective Order
We filed the above-mentioned order on March 09, 2020 however, due to the confusion
that resulted from the COVID-19 lockdown, a hard copy was never provided to department 302
for review.
Aside from this technical issue, our filing was accepted by the court and we paid the local
fee of $20. We hope you will accept for review and consideration, our order today.
Dated: March 04, 2021 Respectfully submitted,
LAW OFFICES OF CLAIRE COCHRAN
Vaal bolo
Attorney for Plaintiff,
Nathan Peter Runyon
-1-
100 Pine Street, Suite 1250, San Francisco, California 94111 | 415-580-6019 | www.clairecochranlegal.com | info@clairecochranlegal.com
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Claire E. Cochran (SBN 222569) Natalie A. Xifo (SBN 280930) LAW OFFICES OF CLAIRE COCHRAN, P.C. 100 Pine Street, Suite 1250 San Francisco, CA 94111 Telephone: (415) 580-6019 Facsimile: (415) 745-3301 Attorneys for Plaintiff NATHAN PETER RUNYON Pierce Bainbridge Beck Price & Hecht LLP Andrew E. Calderon (SBN 316673) acalderon@piercebainbridge.com 355 South Grand Avenue, 44th Floor Los Angeles, California 90071 Tel: (213) 262-9333 Fax: (213) 279-2008 Christopher N. LaVigne (NY Bar No. 4811121) (Admitted Pro Hac Vice) clavigne@piercebainbridge.com 277 Park Avenue, 45th Floor New York, NY 10172 Tel.: (646) 694-9666 Fax: (646) 968-412 Attorneys for Defendants PAYWARD, INC. d/b/a KRAKEN and KAISER NG SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO {UNLIMITED JURISDICTION] NATHAN PETER RUNYON, an individual Case No.: CGC-19-581099 Plaintiff, STIPULATED PROTECTIVE ORDER v. Date Action Filed: November 26, 2019 FAC File: January 6, 2020 PAYWARD, INC., a California Corporation Trial Date: d/b/a KRAKEN; and KAISER NG an individual; and DOES 1-50, inclusive Defendants. Not Set RUNYON vy. PAYWARD and NG STIPULATED PROTECTIVE ORDER CASE NO. CGC-19-581099Plaintiff, NATHAN PETER RUNYON, (“Plaintiff”) and Defendants, PAY WARD, INC. d/b/a KRAKEN (“Defendant”) and KAISER NG (“Ng”), (collectively referred to herein as the “Participating Parties”) hereby stipulate and agree as follows: Good cause exists for a protective order under California law, including under Code of Civil Procedure section 2031.060, in that the parties anticipate (a) that certain documents, communications, and other information produced in discovery will contain private and confidential information relating to Plaintiff, Defendant, and/or third parties, and (b) that a mechanism is needed to allow for discovery and disclosure while protecting privacy and other rights under the laws of the State of California. DESIGNATION OF CONFIDENTIAL INFORMATION 1. For purposes of this Stipulated Protective Order, the term “Confidential Information” includes, but is not limited to: information that violates the privacy interests of and/or confidential information relating to Plaintiff, Defendants and/or employees of any Defendant; confidential and proprietary information and trade secrets; as well as any other information that the producing party in good faith reasonably deems to be confidential or is otherwise entitled to confidential treatment under applicable law. 2. Any party may designate as “Confidential” any pleading, document, testimony, or other discovery material that contains Confidential Information as described in paragraph 1. No designation shall be made unless counsel of record for the designating party believes in good faith that the designated material is in fact Confidential. An inadvertent failure to designate qualified items or material, if promptly corrected, shall not waive the designating party’s right to secure protection for such items or material under this Stipulated Protective Order. 3. “Confidential Information” or “Proprietary Information” do not include documents or other information that is publicly available. 4, A party may designate documents as Confidential by marking them as such, or by providing written notice to the other parties that certain documents, or groups of documents, are to be considered Confidential. A party may designate all or part of the oral testimony of any witness as Confidential either by (a) orally designating the testimony as Confidential during the deposition or hearing, and requesting the reporter to mark the beginning and end of the testimony so designated and to separately bind the Confidential portion(s), or (b) by giving written notice to all counsel of record of the specific pages and lines of the transcripts to be designated Confidential within fifteen (15) days of service of the transcript by the court reporter. 5. Any party may challenge the designation of documents or testimony as Confidential by first meeting and conferring with counsel for the producing party in a good faith effort to resolve the dispute and, if necessary, thereafter by seeking relief from the Court by filing a motion. Pending a determination by the Court as to the appropriateness of the Confidential designation, all parties will treat the material in question as Confidential. 6. Material designated as Confidential pursuant to this Stipulated Protective Order, the 2 RUNYON v, PAYWARD and NG STIPULATED PROTECTIVE ORDER CASE NO. CGC-19-581099information contained therein, and any summaries, copies, abstracts, or other documents derived, in whole or in part from Confidential Information, shall be used only for purposes of this litigation. The parties recognize and agree that it is not a legitimate or good faith use of the discovery process to seek, disseminate, or use discovery material for any purpose other than this litigation. The term “this litigation,” as used herein and in the acknowledgment set forth in Attachment A hereto, refers only to the above captioned matter, specifically Nathan Peter Runyon v. Payward, Inc. d/b/a Kraken, and Kaiser Ng (San Francisco Superior Court Case No. CGC-19-581099). LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL INFORMATION 7. Except as provided below, Confidential Information may be disclosed only to the following persons: (a) Counsel of record for any party to this litigation, and the employees of counsels’ law firms; (b) Experts and consultants (including independent experts and independent consultants, their employees and clerical assistants) who are employed, retained, or otherwise consulted by any counsel of record to assist in any way in this litigation, provided such person has first agreed to be bound by the terms of this Stipulated Protective Order by executing the acknowledgment set forth in Attachment A; (c) The Court hearing this litigation and its staff, (d) Court reporters, their staff and professional vendors to whom disclosure is reasonably necessary for purposes of this litigation; (e) Witnesses in this action to whom disclosure is reasonably necessary; @é The author of the document or the original source of the information; and (g) Mediators. 8. Confidential Information may also be disclosed to any Party. 9. Confidential or Proprietary Information produced during the course of this litigation shall not be disclosed to any person under paragraphs 7(b), (d) and (e), unless that person has agreed to be bound by the terms of this Stipulated Protective Order by executing the acknowledgment set forth in Attachment A. Parties to the lawsuit shall also agree to be bound by the terms of Attachment A. 10. Any party submitting Confidential or Proprietary Information in conjunction with motions or other Court proceedings shall comply with California Rule of Court 2.551. 11. Nothing in this Stipulated Protective Order shall preclude use of Confidential Information at trial nor shall it preclude any party from seeking appropriate protections from the trial court. 12. Nothing in this Stipulated Protective Order shall prevent any party from seeking modification of it by the Court in the future. In addition, nothing in this Stipulated Protective Order shall be deemed a waiver of any party’s right to object to any discovery request on any ground; to seek an order compelling a response to any discovery request; to object to the use in evidence of any material covered by the Stipulated Protective Order; or to restrict the designating party’s use of its own documents. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 13. If a Receiving Party (“party receiving the documents”) is served with a subpoena or an order issued in other litigation that would compel disclosure of any information or items designated in this litigation as “CONFIDENTIAL INFORMATION,” the Receiving Party must so 3 RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER CASE NO. CGC-19-581099notify the Designating Party (“party that has designated the documents confidential”), in writing by e-mail, immediately and in no event more than three court days after receiving the subpoena or order. Such notification must include a copy of the subpoena or court order. 14. The Receiving Party also must immediately inform in writing the Party who caused the subpoena or order to issue in the other litigation that some or all the material covered by the subpoena or order is the subject of this Protective Order. In addition, the Receiving Party must deliver a copy of this Stipulated Protective Order promptly to the Party in the other action that caused the subpoena or order to issue. 15. The purpose of imposing these duties is to alert the interested parties to the existence of this Protective Order and to afford the Designating Party in this case an opportunity to try to protect its confidentiality interests in the court from which the subpoena or order issued. The Designating Party shall bear the burdens and the expenses of seeking protection in that court of its confidential material — and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from another court. DURATION 16. Even after the termination of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise directs. FINAL DISPOSITION 17. Unless otherwise ordered or agreed in writing by the Producing Party, within sixty days after the final termination of this action, each Receiving Party must return all Protected Material to the Producing Party. As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries or any other form of reproducing or capturing any of the Protected Material. With permission in writing from the Designating Party, the Receiving Party may destroy some or all of the Protected Material instead of returning it. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the sixty-day deadline that all the Protected Material that was returned or destroyed and that affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or other forms of reproducing or capturing any of the Protected Material. IT IS SO STIPULATED Dated: March 9, 2020 LAW OFFICES OF CLAIRE COCHRAN CLAIRE COCHRAN NATALIE A. XIFO Attorneys for Plaintiff NATHAN PETER RUNYON RUNYON v, PAYWARD and NG STIPULATED PROTECTIVE ORDER CASE NO. CGC-19-581099Dated: March 9, 2020 Pierce Bainbridge Beck Price & Hecht LLP Aulus Getad) CHRISTOPHER N. LAVIGNE ANDREW E. CALDERON Attorneys for Defendants PAYWARD, INC. d/b/a KRAKEN and KAISER NG [PROPOSED] ORDER GOOD CAUSE APPEARING for this Protective Order and pursuant to stipulation of the parties, | Dated: Se ert JUDGE OF THE SUPERIOR COURT IT IS SO ORDERED. > RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER CASE NO. CGC-19-58109924 25 Modification Provided that nothing in this order determines that any document marked “confidential” qualifies for sealing under CRC 2.550 or relieves any party from following the procedure in CRC 2.55 1. ORDER GOOD CAUSE APPEARING for this Protective Order, IT IS SO ORDERED. “MAR =4 2021 Fb be P Soh , ° ETHAN P. SCHULMAN Judge of the Superior Court DATED: STIPULATION AND PROTECTIVE ORDER-ATTACHMENT A AGREEMENT TO COMPLY WITH STIPULATED PROTECTIVE ORDER FOR CONFIDENTIAL INFORMATION I, [print or type full address J, declare under penalty of perjury that I have read and understand the Court's Stipulated Protective Order for CONFIDENTIAL INFORMATION in the case of Nathan Peter Runyon v. Payward Inc, d/b/a Kraken and Kaiser Ng, San Francisco Superior Court Case No. CGC 19-581099 (“Protective Order”). I agree to abide by all terms of the Order. In addition, I specifically understand and agree to the following: 1, I will not disclose the CONFIDENTIAL INFORMATION to any other person or for any purpose other than this litigation except in compliance with the Protective Order. 2. I understand that I have no power to authorize any other person to review the CONFIDENTIAL INFORMATION. 3. I agree not to make copies of the CONFIDENTIAL INFORMATION. 4, I agree to return the CONFIDENTIAL INFORMATION to the counsel for the party that produced it in compliance with Section 17 of the Protective Order. 5. I understand that if I violate any of the terms of the Protective Order, then I may be subject to sanctions or possible contempt. AGREED: City and State where sworn and signed: | Dated: SIGNATURE RUNYON v. PAYWARD and NG STIPULATED PROTECTIVE ORDER | CASE NO. CGC-19-581099THE LAW OFFICES OF CLAIRE COCHRAN March 4, 2021 Via Email, discovery302@sftc.org Runyon vy Payward - CGC-19-581099 - 7/12/2021 Attention: Department 302, Presiding Justice, The Honorable Ethan P. Schulman Re: Stipulated Protective Order, Filed and Local Fee Paid on 03/09/2020 Dear Honorable Judge Schulman, Please find attached herein, the following for your consideration: 1. Stipulated Protective Order We filed the above-mentioned order on March 09, 2020 however, due to the confusion that resulted from the COVID-19 lockdown, a hard copy was never provided to department 302 for review. Aside from this technical issue, our filing was accepted by the court and we paid the local fee of $20. We hope you will accept for review and consideration, our order today. Dated: March 04, 2021 Respectfully submitted, LAW OFFICES OF CLAIRE COCHRAN Vaal bolo Attorney for Plaintiff, Nathan Peter Runyon -1- 100 Pine Street, Suite 1250, San Francisco, California 94111 | 415-580-6019 | www.clairecochranlegal.com | info@clairecochranlegal.com