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Agracewicz v. The County of Orange

United States District Court, C.D. California

July 22, 2019

DOROTHY “DEE” AGRACEWICZ, Individually; and on behalf of THE ESTATE OF KEVIN MORRIS, Plaintiff,
v.
THE COUNTY OF ORANGE, a Governmental Entity; and DOES 1-100, inclusive, Defendants. JACK MORRIS, individually and as Successor in Interest to KEVIN MORRIS, deceased, Plaintiff,
v.
THE COUNTY OF ORANGE, a municipal entity, and DOES 1 through 10, inclusive, Defendants.

          Wylie A. Aitken, Esq. Megan G. Demshki, Esq. AITKEN AITKEN COHN Attorneys for Plaintiff DOROTHY “DEE” AGRACEWICZ, Individually; and on behalf of THE ESTATE OF KEVIN MORRIS

          Brian T. Dunn, Esq. Megan R. Gyongyos, Esq. THE COCHRAN FIRM CALIFORNIA Attorneys for Plaintiffs JACK MORRIS, individually and as Successor in Interest to KEVIN MORRIS, deceased

          BEFORE THE HONORABLE JOSEPHINE L. STATON

          [PROPOSED] PROTECTIVE ORDER FOR DEPOSITIONS AND DOCUMENTS

          KAREN E. SCOTT, UNITED STATES MAGISTRATE JUDGE

         GOOD CAUSE APPEARING, and in accordance with the parties' Stipulation re Protective Order for Depositions and Documents (Dkt. 30), IT IS HEREBY ORDERED that Defendant COUNTY OF ORANGE, a public entity, Plaintiff DOROTHY “DEE” AGRACEWICZ, Individually; and on behalf of THE ESTATE OF KEVIN MORRIS, by and through her respective counsel, and Plaintiff JACK MORRIS, individually and as Successor in Interest to KEVIN MORRIS, deceased, by and through his respective counsel, are to abide by the Stipulation re Protective Order for Depositions and Documents concurrently filed herewith.

         PROOF OF SERVICE

         STATE OF CALIFORNIA, COUNTY OF ORANGE

         I am over the age of 18 and not a party to the within action; I am employed by B WOODRUFF, t SPRADLIN MiSM CA T in the County of Orange at Anton

         On July 17, 2019, I served the foregoing document(s) described as [PROPOSED] PROTECTIVE ORDER FOR DEPOSITIONS AND DOCUMENTS

[ ] by placing the true copies thereof enclosed in sealed envelopes addressed as stated on the attached mailing list;
[ ] (BY MAIL) I placed said envelope(s) for collection and mailing, following ordinary business practices, at the business offices of WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached service list, for deposit in the United States Postal Service. I am readily familiar with the practice of WOODRUFF, SPRADLIN & SMART for collection and processing correspondence for mailing with the United States Postal Service, and said envelope(s) will be deposited with the United States Postal Service on said date in the ordinary course of business.
[X] (BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be electronically filed using the Court's Electronic Filing System which constitutes service of the filed document(s) on the individual(s) listed on the attached mailing list.
[ ] (BY OVERNIGHT DELIVERY) I placed said documents in envelope(s) for collection following ordinary business practices, at the business offices of WOODRUFF, SPRADLIN & SMART, and addressed as shown on the attached service list, for collection and delivery to a courier authorized by ____ to receive said documents, with delivery fees provided for. I am readily familiar with the practices of WOODRUFF, SPRADLIN & SMART for collection and processing of documents for overnight delivery, and said envelope(s) will be deposited for receipt by ____ on said date in the ordinary course of business.
[ ] (BY FACSIMILE) I caused the above-referenced document to be transmitted to the interested parties via facsimile transmission to the fax number(s) as ...

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