Stipulation and Order

Cal. Super. - 6th Dist.January 21, 2021

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RAYMUNDO G. S. MENDOZA STATE BAR NO. 124822 P.O.BOX 161 CARMEL VALLEY, CALIFORNIA 93924 Telephone: (408) 219-7847 Attorney Jane Doe SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA JANE DOE, Petitioner, GLENN BARRY GONZALEZ Respondent, ---------------- No. 21CH009819 STIPULATION AND PROPOSED ORDER SEALING CIVIL HARASSMENT RESTRAINING ORDER The petitioner filed A Request for Civil Harassment Restraining Order against Glenn Barry Gonzalez. On March 16th 2021 the Honorable Erik Johnson granted the Civil Harassment Retraining Order. The Order was subsequently served on the Respondent. The Petitioner was unaware she could file the aforementioned Request and Order under Jane Doe status to protect her privacy. (See Penal Code Section 293) The aforementioned Request and Order contain information supporting the order as well as identifying information of the Petitioner, which is currently public information. The Respondent's attorney Mr. Wes Schroeder was contacted. He agreed to have the aforementioned request and order sealed until further hearing of this court as well as Envelope: 6574703 FILED County of Santa Clara Superior Court of CA Clerk of The Court 21CH009819 By: knguyen 06/07/2021 IQ La.) referring to the Petitioner as “Jane Doe” in a1] filture court proceedings. The sealing of the records will also benefit his client in the criminal case now pending the Superior Coufl of Santa Clara County: Docket No: C2014715. The sealing order will lessen public exposure of his client prior t0 trial. THEREFORE, the Petitioner respectfully request this court pursuant to the stipulation of the parties grant the sealing order of the Request and Order for Civil Harassment Restraining Order. 0*“ “ / Dated; May 11, 2021 MK RAYMUNDO MENDOZA Attorney for Jane Doe Petitionel. Dated: 2 "' I 3 "2-017 / //@ WES‘SEHR/OEéE/R Attorney for Gléu Barry Gonzalez RespondentM Based upon the lation 0f the parties, THIS COURT HEREBY ORDERS: the Civil Harassment Restraining Reque Order records be sealed AND the Petitioner be referred to “Jane Doe” in fiJture court proceedings un 1 onable notice to the parties and a further hearing 0f the matter before this court, If the request to seal records comes under the purview of California Rules of Court, rules 2.550 and 2.551 as it appear to, the order must conform to the requirements of rule 2.550 (d) and (e). The parties may submit a (proposed) order conforming with the required findings and factual basis in accordance with the Dated:6_7_2021 cited rules. Alternatively, if the parties merely wish to limit the order t0 redaction of the petitioner‘s name on previous filings and to require that future submissions identify the petitioner as "Jane Doe," such proposed order may be submitted without the need for said findings. ganta Clara Superior Court oJudgle oft déWSigned: 6/7/2021 11.08 AM W OQ KOOOQQUI-RUJNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OOQONUI-bUJNr-‘OKOOOQQUI-hUJNr-O PROOF OF SERVICE I am a citizen of the United States. My business address is 96 North Third Street, Suite 620, San Jose, CA 951 12. I am employed in the County 0f Santa Clara, Where this mailing occurs. I am over the age of 18 years, and not a party to the Within cause. On the date set forth below, I served the attached document(s) described as: STIPULATION AND PROPOSED ORDER SEALING CIVIL HARASSMENT RESTRAINING ORDER on the following person(s) in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: Wesley Schroeder, Esq. 181 Devine Street San Jose, CA 951 10 408-277-0377 Fax: 408-277-0567 Email: wesleyschroeder@sbcglobalnet [ ] (BY MAIL) I am readily familiar With my firm's practice for collection and processing 0f correspondence for mailing With the United States Postal Service, t0 Wit, that correspondence Will be deposited With the United States Postal Service this same day in the ordinary course 0f business. I sealed said envelope and placed it for collection and mailing on June 3, 2021, following ordinary business practices. [ ] (BY PERSONAL SERVICE) I caused such envelope(s) t0 be delivered by hand this date t0 the offices 0f the addressee(s). [ ] (BY FACSIMILE) I caused such document(s) to be delivered Via facsimile this date t0 the offices 0f the addressee(s). [ ] (BY OVERNIGHT MAIL) I enclosed the documents in an envelope 01‘ package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed above. I placed the envelope 0r package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. [xx] (BY EMAIL OR ELECTRONIC TRANSMISSION) I caused the documents t0 be sent to the persons at the electronic service addresses listed above. I declare under penalty of perjury under the laws 0f the State of California that the foregoing is true and correct. Executed on June 3, 2021, at San Jose, California. warmWe 1 PROOF 0F SERVICE