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1 JOHN C. MANLY (State Bar No. 149080)
jmanly@manlystewart.com
2 VINCE W. FINALDI, Esq. (State Bar No. 238279)
vfinaldi@manlystewart.com
3 ALEX E. CUNNY, Esq. (State Bar No. 291567)
acunny@manlystewart.com
4 COURTNEY P. PENDRY (State Bar No. 327382)
cpendry@manlystewart.com
5 MANLY STEWART FINALDI
19100 Von Karman Avenue, Suite 800
6 Irvine, California 92612
Telephone: (949) 252-9990
7 Facsimile: (949) 252-9991
8 Attorneys for Plaintiff, Jane BE Doe
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF MONTEREY
11
MANLY STEWART FINALDI
12 JANE BE DOE, Case No. 21CV000805
19100 Von Karman Avenue, Suite 800
Judge: Thomas W. Wills
Telephone (949) 252-9990
13 Plaintiff, Dept.: 15
Irvine, California 92612
14 v. PLAINTIFF JANE BE DOE’S NOTICE OF
LODGMENT OF EVIDENCE
15 BIG BROTHERS BIG SISTERS OF CONDITIONALLY FILED UNDER SEAL
AMERICA, a California corporation; BIG IN SUPPORT OF PLAINTIFF’S
16 SUPPLEMENTAL BRIEF RE: MOTION
BROTHERS BIG SISTERS OF MONTEREY TO COMPEL FURTHER RESPONSES
17 COUNTY, a California corporation; BOYS & TO REQUEST FOR PRODUCTION, SET
GIRLS CLUBS OF MONTEREY COUNTY, ONE, PURSUANT TO C.C.P.
18 a California corporation; JON DAVID §§2031.010,2031.310, ET SEQ.
WOODY, an individual;
. and DOES 1-50, REDACTED
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inclusive, Date: April 15, 2022
20 Time: 8:30 am
Defendants. Dept: 15
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Action Filed: March 12, 2021
22 Trial Date: None
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PLEASE TAKE NOTICE that the Plaintiff, Jane BE Doe (“Plaintiff”) by and through her
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counsel of record lodges the following documents conditionally under seal with the Court pursuant to
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California Rules of Court, Rule 2.550(a)(3), which provides for discovery motions that, “These rules
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do not apply to discovery motions and records filed or lodged in connection with discovery motions or
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proceedings.” The following exhibit, which has been designated “Confidential” pursuant to the
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PLAINTIFF JANE BE DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER
SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL FURTHER RESPONSES TO
RFP SET ONE - REDACTED
1 Stipulated Protective Order, is being lodged conditionally under seal in support of this Motion:
2 Exhibit 2 to Declaration of Courtney PRIVBBBSA_000019- PRIVBBBSA_000020
3 Pendry, Esq.:
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6 DATED: April 8, 2022 MANLY STEWART FINALDI
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By:
9 COURTNEY P. PENDRY
Attorneys for Plaintiff, Jane BE Doe
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MANLY STEWART FINALDI
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19100 Von Karman Avenue, Suite 800
Telephone (949) 252-9990
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Irvine, California 92612
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PLAINTIFF JANE BE DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER
SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL FURTHER RESPONSES TO
RFP SET ONE
EXHIBIT 2
LODGED CONDITIONALLY UNDER SEAL
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF ORANGE
3
I am employed in the county of Orange, State of California. I am over the age of 18 and
4 not a party to the within action; my business address is 19100 Von Karman Ave., Suite 800,
Irvine, CA 92612.
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On April 8, 2022, I served the foregoing document described as PLAINTIFF JANE BE
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DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER
7 SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL
FURTHER RESPONSES TO RFP SET ONE - REDACTED on the interested parties in this
8 action addressed as follows:
SEE ATTACHED SERVICE LIST
9
BY U.S. MAIL: I served the documents by enclosing them in an envelope and placing the
10 envelope for collection and mailing following our ordinary business practices. I am readily
familiar with this business’s practice of collection and processing of correspondence for mailing.
11 On the same day that correspondence is placed for collection and mailing, it is deposited in the
ordinary course of business with the United States Postal Service in a sealed envelope with
12 postage fully prepaid.
X BY E-MAIL OR ELECTRONIC TRANSMISSION I caused the documents to be sent to
19100 Von Karman Avenue, Suite 800
MANLY, STEWART & FINALDI
13 the persons on the e-mail addresses as listed below. I did not receive, within a reasonable time
Telephone: (949) 252-9990
ATTORNEYS AT LAW
14 after the transmission, any electronic message or other indication that the transmission was
Irvine, CA 92612
unsuccessful.
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BY FACSIMILE TRANSMISSION: The facsimile machine I used complied with
16 California Rules of Court 2.301 and no error was reported by the machine. Pursuant to rule
2.306(h), I caused the machine to print a record of the transmission, a copy of which is attached
17 to this proof of service.
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BY OVERNIGHT DELIVERY: I caused the above-referenced document(s) to be
19 delivered via overnight delivery, for delivery to the above address(es).
20 _____(State) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
21 _____(Federal) I declare that I am employed in the office of a member of the bar of this court
22 at whose direction, the service was made.
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Executed on April 8, 2022, Irvine, California.
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___________________________
25 Sadaf Anwar
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1 SERVICE LIST
2 Alison M. Crane, Esq., Partner
3 Tara A. Murray, Esq.
Bledsoe, Diestel, Treppa & Crane LLP
4 180 Sansome, 5th Floor
San Francisco, CA 94104
5 T: 415-981-5411
F: 415-981-0352
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acrane@bledsoelaw.com
7 tmurray@bledsoelaw.com
calendar@bledsoelaw.com
8 Counsel for Defendants Big Brothers Big Sisters of America
9 PAUL CALEO
pcaleo@grsm.com
10 MARK HEISEY
mheisey@grsm.com
11 GORDON REES SCULLY MANSUKHANI, LLP
1111 Broadway, Suite 1700
12 Oakland, CA 94607
Telephone: (510) 463-8600
19100 Von Karman Avenue, Suite 800
MANLY, STEWART & FINALDI
13 Facsimile: (510) 984-1721
Telephone: (949) 252-9990
Attorneys for Defendant
ATTORNEYS AT LAW
14 BOYS & GIRLS CLUB OF MONTEREY COUNTY
Irvine, CA 92612
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1 JOHN C. MANLY (State Bar No. 149080) jmanly@manlystewart.com 2 VINCE W. FINALDI, Esq. (State Bar No. 238279) vfinaldi@manlystewart.com 3 ALEX E. CUNNY, Esq. (State Bar No. 291567) acunny@manlystewart.com 4 COURTNEY P. PENDRY (State Bar No. 327382) cpendry@manlystewart.com 5 MANLY STEWART FINALDI 19100 Von Karman Avenue, Suite 800 6 Irvine, California 92612 Telephone: (949) 252-9990 7 Facsimile: (949) 252-9991 8 Attorneys for Plaintiff, Jane BE Doe 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF MONTEREY 11 MANLY STEWART FINALDI 12 JANE BE DOE, Case No. 21CV000805 19100 Von Karman Avenue, Suite 800 Judge: Thomas W. Wills Telephone (949) 252-9990 13 Plaintiff, Dept.: 15 Irvine, California 92612 14 v. PLAINTIFF JANE BE DOE’S NOTICE OF LODGMENT OF EVIDENCE 15 BIG BROTHERS BIG SISTERS OF CONDITIONALLY FILED UNDER SEAL AMERICA, a California corporation; BIG IN SUPPORT OF PLAINTIFF’S 16 SUPPLEMENTAL BRIEF RE: MOTION BROTHERS BIG SISTERS OF MONTEREY TO COMPEL FURTHER RESPONSES 17 COUNTY, a California corporation; BOYS & TO REQUEST FOR PRODUCTION, SET GIRLS CLUBS OF MONTEREY COUNTY, ONE, PURSUANT TO C.C.P. 18 a California corporation; JON DAVID §§2031.010,2031.310, ET SEQ. WOODY, an individual; . and DOES 1-50, REDACTED 19 inclusive, Date: April 15, 2022 20 Time: 8:30 am Defendants. Dept: 15 21 Action Filed: March 12, 2021 22 Trial Date: None 23 PLEASE TAKE NOTICE that the Plaintiff, Jane BE Doe (“Plaintiff”) by and through her 24 counsel of record lodges the following documents conditionally under seal with the Court pursuant to 25 California Rules of Court, Rule 2.550(a)(3), which provides for discovery motions that, “These rules 26 do not apply to discovery motions and records filed or lodged in connection with discovery motions or 27 proceedings.” The following exhibit, which has been designated “Confidential” pursuant to the 28 PLAINTIFF JANE BE DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL FURTHER RESPONSES TO RFP SET ONE - REDACTED 1 Stipulated Protective Order, is being lodged conditionally under seal in support of this Motion: 2 Exhibit 2 to Declaration of Courtney PRIVBBBSA_000019- PRIVBBBSA_000020 3 Pendry, Esq.: 4 5 6 DATED: April 8, 2022 MANLY STEWART FINALDI 7 8 By: 9 COURTNEY P. PENDRY Attorneys for Plaintiff, Jane BE Doe 10 11 MANLY STEWART FINALDI 12 19100 Von Karman Avenue, Suite 800 Telephone (949) 252-9990 13 Irvine, California 92612 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF JANE BE DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL FURTHER RESPONSES TO RFP SET ONE EXHIBIT 2 LODGED CONDITIONALLY UNDER SEAL 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF ORANGE 3 I am employed in the county of Orange, State of California. I am over the age of 18 and 4 not a party to the within action; my business address is 19100 Von Karman Ave., Suite 800, Irvine, CA 92612. 5 On April 8, 2022, I served the foregoing document described as PLAINTIFF JANE BE 6 DOE’S NOTICE OF LODGMENT OF EVIDENCE CONDITIONALLY FILED UNDER 7 SEAL ISO PLAINTIFF’S SUPPLEMENTAL BRIEF RE: MOTION TO COMPEL FURTHER RESPONSES TO RFP SET ONE - REDACTED on the interested parties in this 8 action addressed as follows: SEE ATTACHED SERVICE LIST 9 BY U.S. MAIL: I served the documents by enclosing them in an envelope and placing the 10 envelope for collection and mailing following our ordinary business practices. I am readily familiar with this business’s practice of collection and processing of correspondence for mailing. 11 On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in a sealed envelope with 12 postage fully prepaid. X BY E-MAIL OR ELECTRONIC TRANSMISSION I caused the documents to be sent to 19100 Von Karman Avenue, Suite 800 MANLY, STEWART & FINALDI 13 the persons on the e-mail addresses as listed below. I did not receive, within a reasonable time Telephone: (949) 252-9990 ATTORNEYS AT LAW 14 after the transmission, any electronic message or other indication that the transmission was Irvine, CA 92612 unsuccessful. 15 BY FACSIMILE TRANSMISSION: The facsimile machine I used complied with 16 California Rules of Court 2.301 and no error was reported by the machine. Pursuant to rule 2.306(h), I caused the machine to print a record of the transmission, a copy of which is attached 17 to this proof of service. 18 BY OVERNIGHT DELIVERY: I caused the above-referenced document(s) to be 19 delivered via overnight delivery, for delivery to the above address(es). 20 _____(State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 21 _____(Federal) I declare that I am employed in the office of a member of the bar of this court 22 at whose direction, the service was made. 23 Executed on April 8, 2022, Irvine, California. 24 ___________________________ 25 Sadaf Anwar 26 27 28 1 SERVICE LIST 2 Alison M. Crane, Esq., Partner 3 Tara A. Murray, Esq. Bledsoe, Diestel, Treppa & Crane LLP 4 180 Sansome, 5th Floor San Francisco, CA 94104 5 T: 415-981-5411 F: 415-981-0352 6 acrane@bledsoelaw.com 7 tmurray@bledsoelaw.com calendar@bledsoelaw.com 8 Counsel for Defendants Big Brothers Big Sisters of America 9 PAUL CALEO pcaleo@grsm.com 10 MARK HEISEY mheisey@grsm.com 11 GORDON REES SCULLY MANSUKHANI, LLP 1111 Broadway, Suite 1700 12 Oakland, CA 94607 Telephone: (510) 463-8600 19100 Von Karman Avenue, Suite 800 MANLY, STEWART & FINALDI 13 Facsimile: (510) 984-1721 Telephone: (949) 252-9990 Attorneys for Defendant ATTORNEYS AT LAW 14 BOYS & GIRLS CLUB OF MONTEREY COUNTY Irvine, CA 92612 15 16 17 18 19 20 21 22 23 24 25 26 27 28