Marcus Alexander Murchinson v. City of Sierra Madre ( 2024 )

1 || Michael L. Wroniak, Esq. (State Bar No. 210413) Robin M. Nagele (State Bar No. 323209) COLLINS + COLLINS LLP 3 || 750 The City Drive, Suite 400 4 Orange, CA 92868 (714) 823-4100 - FAX (714) 823-4101 5S Email: mwroniak@ccllp.law 6 Email: rnagele@ccllp.law 7 Attorneys for Defendants 8 CITY OF SIERRA MADRE, OFFICER SHAW, and GRANT CADZOW 9 || James Do Kim (SBN 231038) 10 LAW OFFICES OF DO KIM, APLC 3435 Wilshire Boulevard, Suite 2700 11 || Los Angeles, CA 90010 v (213) 251-5440 Email: dkim@dokimlaw.com 13 14 Attorney for Plaintiff MARCUS ALEXANDER MURCHINSON 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 18 || MARCUS ALEXANDER CASE NO. 2:22-—cv—08099 DMG(AGRx) 19 MURCHINSON, Assigned to Hon. Dolly M. Gee in Ctrm. 8( Magistrate Judge Alicia G. Rosenberg 20 Plaintiff, 1 STIPULATED PROTECTIVE ORDER VS. 22 33 CITY OF SIERRA MADRE; OFFICER SHAW; GRANT Complaint Filed: 11/04/2022 24 || CADZOW; and DOES | through 10, | Trial Date: 04/22/2025 25 Defendants. 26 27 /// 28 /// || °°" \ 1 1. A. PURPOSES AND LIMITATIONS! 2 Discovery in this action is likely to involve production of confidential 3 || proprietary, or private information for which special protection from public □□□□□□□□□ 4 ||and from use for any purpose other than prosecuting this litigation may be warranted 5 || Accordingly, the parties hereby stipulate to and petition the Court to enter the followin; 6 Stipulated Protective Order. The parties acknowledge that this Order does not confe 7 blanket protections on all disclosures or responses to discovery and that the □□□□□□□□□□ 8 ||it affords from public disclosure and use extends only to the limited information o 9 ||items that are entitled to confidential treatment under the applicable legal principles 10 || The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulatec 11 || Protective Order does not entitle them to file confidential information under seal; Civi 12 || Local Rule 79-5 sets forth the procedures that must be followed and the standards tha 13 || will be applied when a party seeks permission from the court to file material unde 14 || seal. 15 B. GOOD CAUSE STATEMENT 16 This action arises from the September 6, 2021 arrest of Plaintiff by officers of th 17 || Sierra Madre Police Department. Plaintiff alleges causes of action for negligence and 18 || intentional infliction of emotional distress. He further alleges causes of action for false 19 || arrest and imprisonment, false evidence, and supervisory liability pursuant to 42 U.S.C. 20 || § 1983. 21 As explained below, this action is likely to involve confidential materials 22 || protected by California Evidence Code section 1040, the official information privilege, 23 || or other state or federal statutes, court rules, case decisions, or common law prohibiting 24 || or limiting dissemination and disclosure. Additionally, this action may involve other 25 || proprietary information concerning police practices and security protocols for which 26 || Special protection from public disclosure and from use for any purpose other than 27 28 || | This stipulated protective order is substantially based on the model protective order published and used throughout th Central District. || °°" 1 || prosecution of this action is warranted. 2 In terms of discovery, Defendants anticipate that a protective order will be 3 ||necessary in connection with the following items of evidence: 1) personnel and 4 ||administrative records of peace officers; 2) law enforcement investigative records 5 || which reveal the identify of third-party witnesses; and 3) such other evidence for which 6 || dissemination should be limited for use in this action only. 7 Accordingly, to expedite the flow of information, to facilitate the prompt 8 resolution of disputes over confidentiality of discovery materials, to adequately protect 9 || information the parties are entitled to keep confidential, to ensure that the parties are 10 || permitted reasonable necessary uses of such material in preparation for and in the 11 || conduct of trial, to address their handling at the end of the litigation, and serve the ends 12 || of justice, a protective order for such information 1s justified in this matter. It is the 13 || intent of the parties that information will not be designated as confidential for tactical 14 || reasons and that nothing be so designated without a good faith belief that it has been 15 || maintained in a confidential, non-public manner, and there is good cause why it should 16 || not be part of the public record of this case. 17 |} 2. DEFINITIONS 18 2.1 Action: Marcus Alexander Murchinson v. City of Sierra Madre, et al. 19 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 20 || information or items under this Order. 21 13 “CONFIDENTIAL” Information or Items: information (regardless of how 22 it is generated, stored or maintained) or tangible things that qualify for protection under 23 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 24 || Statement. 25 1.4 Counsel: Counsel of Record and House Counsel (as well as their 26 || support staff). 97 /// 2g || /// || °°" 1 1.5 Designating Party: a Party or Non-Party that designates information or 2 ||items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 1.6 Disclosure or Discovery Material: all items or information, regardless of 5 || the medium or manner in which it is generated, stored, or maintained (including, □□□□ 6 || other things, testimony, transcripts, and tangible things), that are produced or generated 7 ||in disclosures or responses to discovery in this matter, 8 17 Expert: a person with specialized knowledge or experience in a matter 9 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 10 || expert witness or as a consultant in this Action. 11 1.8 House Counsel: attorneys who are employees of a party to this Action. 12 || House Counsel does not include Outside Counsel of Record or any other outside 13 |} counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association, or 15 || other legal entity not named as a Party to this action. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 || employees, consultants, retained experts, and Outside Counsel of Record (and their 18 || Support staffs). 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 || Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation support 22 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and 24 || their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 || designated as “CONFIDENTIAL.” 27 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 28 || from a Producing Party. || °°" 1 |/3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 || Material (as defined above), but also (1) any information copied or extracted from 4 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 || Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 ||judge. This Order does not govern the use of Protected Material at trial. 9 DURATION 10 Once a case proceeds to trial, all of the information that was designated as 11 || confidential or maintained pursuant to this protective order becomes public and will be 12 || presumptively available to all members of the public, including the press, unless 13 || compelling reasons supported by specific factual findings to proceed otherwise are 14 || made to the trial judge in advance of the trial. See Kamakana v. City and County of 15 || Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 16 || Showing for sealing documents produced in discovery from “compelling reasons” 17 || standard when merits-related documents are part of court record). Accordingly, the 18 || terms of this protective order do not extend beyond the commencement of the trial. 19 |}5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. 21 || Each Party or Non-Party that designates information or items for protection under this 22 || Order must take care to limit any such designation to specific material that qualifies 23 || under the appropriate standards. The Designating Party must designate for protection 24 || only those parts of material, documents, items or oral or written communications that 25 || qualify so that other portions of the material, documents, items or communications for 26 || which protection is not warranted are not swept unjustifiably within the ambit of this 27 || Order. 28 || /// || °°" 1 Mass, indiscriminate or routinized designations are prohibited. Designations that 2 shown to be clearly unjustified or that have been made for an improper purpose 3 |/(e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating Party 5 to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in this 10 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated o: 11 || ordered, Disclosure or Discovery Material that qualifies for protection under this Order 12 || must be clearly so designated before the material is disclosed or produced. 13 Designation in conformity with this Order requires: 14 (a) for information in documentary form (e.g., paper or electronic documents, 15 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the 16 || Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 17 || “CONFIDENTIAL legend’), to each page that contains protected material. If only a 18 || portion of the material on a page qualifies for protection, the Producing Party also must 19 || clearly identify the protected portion(s) (e.g., by making appropriate markings in the 20 || margins). 21 A Party or Non-Party that makes original documents available for inspection 22 ||need not designate them for protection until after the inspecting Party has indicated 23 || which documents it would like copied and produced. During the inspection and before 24 || the designation, all of the material made available for inspection shall be deemed 25 || “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 26 || copied and produced, the Producing Party must determine which documents, or 27 || portions thereof, qualify for protection under this Order. Then, before producing the 28 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to || °°" ‘ 1 || each page that contains Protected Material. If only a portion of the material on a page 2 || qualifies for protection, the Producing Party also must clearly identify the protected 3 || portion(s) (e.g., by making appropriate markings in the margins). 4 (b) for testimony given in depositions that the Designating Party identifies the 5 || Disclosure or Discovery Material on the record, before the close of the deposition all 6 || protected testimony. 7 (c) for information produced in some form other than documentary and for 8 || any other tangible items, that the Producing Party affix in a prominent place on the 9 exterior of the container or containers in which the information is stored the legend 10 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 11 || protection, the Producing Party, to the extent practicable, shall identify the protected 12 || portion(s). 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 14 || to designate qualified information or items does not, standing alone, waive the 15 || Designating Party’s right to secure protection under this Order for such material. Upon 16 || timely correction of a designation, the Receiving Party must make reasonable efforts to 17 || assure that the material 1s treated in accordance with the provisions of this Order. 18 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 20 || designation of confidentiality at any time that is consistent with the Court’s Scheduling 21 || Order. 22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 23 || resolution process under Local Rule 37.1 et seq. 24 6.3. The burden of persuasion in any such challenge proceeding shall be on the 25 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 26 || to harass or impose unnecessary expenses and burdens on other parties) may expose the 27 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 28 || the confidentiality designation, all parties shall continue to afford the material in || °°" 1 || question the level of protection to which it is entitled under the Producing Party’s 2 designation until the Court rules on the challenge. 3 ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected Material that is 5 || disclosed or produced by another Party or by a Non-Party in connection with this 6 || Action only for prosecuting, defending or attempting to settle this Action. Such 7 Protected Material may be disclosed only to the categories of persons and under the 8 || conditions described in this Order. When the Action has been terminated, a Receiving 9 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 || location and in a secure manner that ensures that access is limited to the persons 12 || authorized under this Order. 13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 14 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party 15 || may disclose any information or item designated “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 || well as employees of said Outside Counsel of Record to whom it is reasonably 18 || necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of ths 20 || Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 || disclosure is reasonably necessary for this Action and who have signed the 23 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the court and its personnel; 25 (ec) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 || Vendors to whom disclosure is reasonably necessary for this Action and who have 28 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); || °°" 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in the 4 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 8 by the Designating Party or ordered by the court. Pages of transcribed deposition 9 || testimony or exhibits to depositions that reveal Protected Material may be separately 10 || bound by the court reporter and may not be disclosed to anyone except as permitted 11 || under this Stipulated Protective Order; 12 (1) any mediator or settlement officer, and their supporting personnel, 13 || mutually agreed upon by any of the parties engaged in settlement discussions; and 14 (j) the parties. 15 |/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 16 |} OTHER LIGITATION 17 If a Party is served with a subpoena or a court order issued in other litigation that 18 || compels disclosure of any information or items designated in this Action as 19 || “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification shall 21 include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order to 23 issue in the other litigation that some or all of the material covered by the subpoena or 24 || order is subject to this Protective Order. Such notification shall include a copy of this 25 || Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued by 27 || the Designating Party whose Protected Material may be affected. 28 || /// || °°" 1 If the Designating Party timely seeks a protective order, the Party served with the 2 ||subpoena or court order shall not produce any information designated in this action as 3 || “CONFIDENTIAL” before a determination by the court from which the subpoena or 4 order issued, unless the Party has obtained the Designating Party’s permission. The 5 || Designating Party shall bear the burden and expense of seeking protection in that court 6 || of its confidential material and nothing in these provisions should be construed as 7 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 8 || directive from another court. 9 1/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 10 || IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- 12 || Party in this Action and designated as “CONFIDENTIAL.” Such information produced 13 || by Non-Parties in connection with this litigation is protected by the remedies and relief 14 || provided by this Order. Nothing in these provisions should be construed as prohibiting 15 ||a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to produce < 17 || Non-Party’s confidential information in its possession, and the Party is subject to an 18 || agreement with the Non-Party not to produce the Non-Party’s confidential information, 19 || then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party that 21 || some or all of the information requested is subject to a confidentiality agreement with a 22 || Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 || specific description of the information requested; and 26 (3) make the information requested available for inspection by the Non- 27 || Party, if requested. 2g |] /// || °°" 10 1 (c) If the Non-Party fails to seek a protective order from this court within 14 day: 2 |lof receiving the notice and accompanying information, the Receiving Party may 3 || produce the Non-Party’s confidential information responsive to the discovery request. I 4 ||the Non-Party timely seeks a protective order, the Receiving Party shall not produce 5 any information in its possession or control that is subject to the confidentiality 6 agreement with the Non-Party before a determination by the court. Absent a court ordet 7 ||to the contrary, the Non-Party shall bear the burden and expense of seeking protection 8 ||in this court of its Protected Material. 9 |}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 || Protected Material to any person or in any circumstance not authorized under this 12 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 13 || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 14 || all unauthorized copies of the Protected Material, (c) inform the person or persons to 15 || whom unauthorized disclosures were made of all the terms of this Order, and (d) 16 || request such person or persons to execute the “Acknowledgment and Agreement to Be 17 || Bound” that is attached hereto as Exhibit A. 18 |}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 || PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, th 22 || obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 || may be established in an e-discovery order that provides for production without prior 25 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 26 || parties reach an agreement on the effect of disclosure of a communication or 27 || information covered by the attorney-client privilege or work product protection, the 28 || parties may incorporate their agreement in the stipulated protective order submitted to || °°" iH 1 || the court. 2 {}12. MISCELLANEOUS 3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 4 person to seek its modification by the Court in the future. 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 || Protective Order, no Party waives any right it otherwise would have to object to 7 || disclosing or producing any information or item on any ground not addressed in this 8 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 9 || ground to use in evidence of any of the material covered by this Protective Order, 10 12.3 Filing Protected Material. A Party that seeks to file under seal any 11 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may 12 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 13 || Protected Material at issue. If a Party’s request to file Protected Material under seal is 14 || denied by the court, then the Receiving Party may file the information in the public 15 || record unless otherwise instructed by the court. 16 FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 4, within 60 18 || days of a written request by the Designating Party, each Receiving Party must return all 19 || Protected Material to the Producing Party or destroy such material. As used in this 20 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 21 ||summaries, and any other format reproducing or capturing any of the Protected 22 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party 23 || must submit a written certification to the Producing Party (and, if not the same person 24 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 25 || category, where appropriate) all the Protected Material that was returned or destroyed 26 || and (2) affirms that the Receiving Party has not retained any copies, abstracts, 27 || compilations, summaries or any other format reproducing or capturing any of the 28 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an || °°" ||archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 2 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 3 || work product, and consultant and expert work product, even if such materials contain 4 ||Protected Material. Any such archival copies that contain or constitute Protected 5 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION) 6 ||14. VIOLATION 7 || Any violation of this Order may be punished by appropriate measures including, 8 || without limitation, contempt proceedings and/or monetary sanctions. 9 ||ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 |} DATED: August 20, 2024 COLLINS + COLLINS LLP i By: Koln MN agkh— 12 ROBIN M. NAGELE B MICHAEL L. WRONIAK Attorneys for Defendants 14 CITY OF SIERRA MADRE, OFFICER 1 SHAW, and GRANT CADZOW 16 || DATED: August 20, 2024 LAW OFFICES OF DO KIM, APLC 17 18 By: __/s/JamesDoKim JAMES DO KIM 19 Attorney for Plaintiff MARCUS ALEXANDER MURCHINSON 21 22 || FOR GOOD CAUSE SHOWN, IT IS ORDERED. 23 24 ||DATED: August 30, 2024 25 lini M Keeinberg, 26 7 HON. ALICIA G. ROSENBERG United States Magistrate Judge 28 79° 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury tha 5 ||I have read in its entirety and understand the Stipulated Protective Order that was 6 ||issued by the United States District Court for the Central District of California on in 7 ||the case of Marcus Alexander Murchinson v. City of Sierra Madre, et al. 8 ||(2:22—cv—08099 DMG(AGRx). I agree to comply with and to be bound by all the 9 ||terms of this Stipulated Protective Order and I understand and acknowledge that 10 || failure to so comply could expose me to sanctions and punishment in the nature of 11 |} contempt. I solemnly promise that I will not disclose in any manner any information 12 || or item that is subject to this Stipulated Protective Order to any person or entity 13 || except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 || for the Central District of California for enforcing the terms of this Stipulated 16 || Protective Order, even if such enforcement proceedings occur after termination of 17 || this action. I hereby appoint [print or type full 18 || name] of [print or type full address 19 || and telephone number] as my California agent for service of process in connection 20 || with this action or any proceedings related to enforcement of this Stipulated 21 || Protective Order. 22 || Date: 23 || City and State where sworn and signed: 24 25 || Printed name: 26 27 || Signature: 28 || °°" 1 PROOF OF SERVICE (CCP §§ 1013(a) and 2015.5; FRCP 5) State of California, ) 2 ) ss. County of Los Angeles. ) 3 Tam employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business 4 address is 790 E. Colorado Boulevard, Suite 600, Pasadena, California 91101. On this date, I served the foregoing document described as STIPULATED PROTECTIVE ORDER on the interested 5 parties in this action by placing same in a sealed envelope, addressed as follows: 6 SEE ATTACHED SERVICE LIST 7 O (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Pasadena, California to be served on the parties as indicated on the attached service list. [am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, 1t would be deposited with the U.S. Postal Service 8 on that same day with postage thereon fully prepaid at Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day 9 after date of deposit for mailing in affidavit. 10 (BY CERTIFIED MAIL) - I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in Pasadena, California. 11 Ol FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to recetve documents with delivery fees provided for. 12 (BY ELECTRONIC FILING AND/OR SERVICE) — I served a true copy, with all exhibits, electronically on the designated 13 recipients listed on the attached service list through the Court’s ECM/CF electronic service and filing system. 14 Ol (ELECTRONIC SERVICE PER CODE CIV. PROC., § 1010.6) — By prior consent or request or as required by rules of court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)). 15 (BY PERSONAL SERVICE) - [ caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s). 16 Executed on August 20, 2024 at Pasadena, California. - [declare that | am employed in the office of a member of the bar of this court at whose direction the service was 17 FEDERAL) - [ declare that I ployed in the office of ber of the bar of thi hose direction th i made. 18 19 Ddeuo Parker Debbie Parker 20 dparker@ccllp.law 21 22 23 24 25 26 27 28 °° Blvd., Suite 600, 15 1 MARCUS ALEXANDER MURCHINSON vy. CITY OF SIERRA MADRE, et al. United States District Court-Central District of California Case Number: 2:22-cv-08099-DMG-JEM 2 CCLLP File Number: 23866 SERVICE LIST 3 4 James Do Kim, Esq. LAW OFFICES OF DO KIM, APLC 3435 Wilshire Boulevard, Suite 2700 5 Los Angeles, CA 90010 T: (213) 251-5440 6 dkim@dokimlaw.com ATTORNEYS FOR PLAINTIFF MARCUS ALEXANDER 7 MURCHINSON 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 23866 SOLLINS 600, 16