Subpoena Rec'd 1-12-24 - Records for Grace Elizabeth Schmidt{j$,E C [E [I V E fTh
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g4-RT1NO CITY CLERK - A
$ten Deposfitnon Seriee, LLC
1755 Witttngton Place, Suite 750
Dallas Texas 75234
Telephone (972) 488-5555 - (800) 346-4405 - WD8,Custodian@wdsli
Secure File Upload - littps://securefiles.wdslezal.com/filedro
CITY OF CUPERTINO - HUMAN RESOURCES DIVISION
10300 TORRE AVENUE
CUPERTINO, CA 95014
HUMAN RESOURCES
TELEPHONE: 408-777-3227: 408-777-3109
SUBPOENA FOR RECORDS
RE: Records Regarding: GRACE ELIZABETH SCHMIDT; DOB; 08/19/1964; SS#: XXX-XX-6458
Our Ref. #: 7646LOO3
Please Contact: Jolene Standridge x226
Enclosed please find a subpoena that authorizes the release of records. See Attachment 3 for the records being
requested.
I. PLEASE RELEASE -ALL RECORDS AS NAMED ABOllE, JNCLUDING ALL FILES AND EVERY PIECE OF PAPER -
AS REQUESTED.
2. Please date and sign the attached Declaration/Certification of Records - Tliis Autlienticates tlie provided record.
3. DONOTSTAPLEORPROWDEDOUBLE-SIDEDPAGES,
-4. ALL FEES MUST BE PRE-APPROVED (WE WILL ASK FOR PAGE COUNT PRIOR TO APPROVING FEES). WE
PREFER RF,CORDS SENT IN ELECTRONIC FORMAT WHEN POSSIBLE - VIA PORT AL/CD/EMAIL OR ANY
OTHER ELECTRONIC MEDIA. ANY UNAPPROVED FEES WILL NOT BE PAID AND RECORDS WILL BE
RETURNED. IF NOT AVjuLABLE ELECTRONICALLY, PLEASE MAIL THE RECORDS TO THE ABOVE
ADDRESSi NOT THE ADDRESS ON THE SUBPOENA.
5. Please allow the following authorized copy services:
I. Written Deposition Service, LLC - Rob Glucroft or designated agent:
21021 Ventura Blvd., Ste 410; Woodland Hills, CA 91364
(828) 97 4-8837
Completing this documentation properly and in a timely fashion will al{ow our client to enter the records
in court as evidence, likely, without having the records custodian present at the time of trial, %B
appreciate you producing all records requested, by the due date! Shoukl you liave any questions, please
PLEASE CALL - 1-800-346-4405.
Thank you for your assistance in this matter. Should you have any questions, please call Joleiie Standrtdge x226@
800-346-4405.
Sincerely,
Jolene Standridge x226
ATTORNEY OR PARTY WITHOIIT ATTORNEY ( Name, 8iale Bar number and addreee)
Rob Greeni S+nte Bar #i 216116
8imoii Greengtone Paiiiitier, PC
3780 Kllroy Airport Way, Sultii 540, Long Beacl5 CA 90806
TELEPHONE NO.! (562) 590-3400 FAX NO. (opiibnai)i
E-MAIL ADORfftiS (OptlanaQ:
ATTORNffY FOR (Name}: Plainliff
FOR COURT USE ONLY
tNAME OF COURTi SUPERIOR COURT OF CALIFORNIA, COUNTY OF
STREET ADDRESS: Los Angeles County Superior Courl
MAILING AOORESS: l l I N. Hill Street
Lot Angeln CA 9DD12
BRANCH NAME:CASE NUMBER:
23S?G:V18!il3PLAINTIFF/PETITIONER: GRACE SCHIVImT and ANTHONY SCHMIDI"
DEFENDANT/FIESPONDENT: ARKEMA, INC,, ET Al,
ForPrDoEduPcotsiolTn'oofNBsusuiBnPesOsERNeAcords I
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, If known}:
CUSTODjANOFRECORD5;FOR: CITYOFCUPERTINO.HUMANRESOuRCESDM5>ION:10300TORREAVENUE,
CUPERTINO, CA 9501 4
1, YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described iii item 3, as follows:
To (name of deposition officer): Written Deposition Service, LLC
On (date): 1/22/2024 At (time): 10am
Location (address).' 21021 Ventura Blvd., Ste, 410, Woodland Hills, CA 91364 Ph: (800) 346-4405
Do not release tlie requested records to the depositton officer prior to the date and time stated above. i
a. by delivering a true, legible, and dutIable copy of the bu.qiness records described in item 3, enclosed ir. a sealed inner
Wit)l
tlie addres.i in item I
determined under Evidence Code section 1 563(b)
c. by making the original business re.cords described in item 3.available for Inspection at your business address by the
IXlattorney's representattve and permitting copying at your bustness address under reasonable conditions during
LJnormal business hours
2. The rer;ords are to be produced by the date and tfme shown in item 1 (but not sooner than 20 days affar the jssuance of the
deposition subpoena, or 15 days affer service, whichever date fs later). Reasonable costs of locating records, makjng them
available or copying them, and postage, if any, are recoverable as set forth /n Evidence Code ser;tion 1563(b). The records shall
be accompanied by an affldavit of the custodlan or other qualified witness pursuarit to Evidence Code section 1561.
3. The records to be produced are described as fo[lows:
G Continued on Attachment 3.
4. IFYOu HAVE BEEN SERVED WITH THIS SUBPOENA AS A CUSTODIAN OF CONSUMER OR
EMPLOYEE RECORDS UNDER CODE OF CML PROCEDURE SECTION '1985.3 0R i985.8 AND A MOTION TO QUASH OR
AN OEIJECTION HAS BEEN SERVED ON YOU, A COURT ORDER OR AGREEMENT OF THE PART)ES, WITNES8ES, AND
CONSUMER OR EMPLOYEE AFFECTED MUST BE OBT AINED BEFORE YOU ARE REQUIRED TO PRODUCE: CONSUMER
OR EMPLOYEE RECORDS.
DISOBEDIENCE OF THIS SUBPOENA MAY BE PuNlSHED AS CONTEMPT BY THIS COURT. YOU WiLL ALSO BE LIABLE FOR THE
SUM OF FIVE HuNDFlED DOL.LARS AND ALL DAMAGEf RESuLTlNG FROM YOUR FAILLIRE TO OBEY.
Date issued:
pob (,reen
iTYPE OR PRINT NAMS)
Form Adopled For Mendelory Use
liidlclal Councll of CallTomla
/S/ Rob Green
iSIGNATuRE OF PERSON IS8U1NG SuBPOENA)
Attorrrey for Plaintiff
(TITLE)
[Pyoof QT ggrvli.a sea rmetse)
DEPOSITION SUEIPOENA FOR PRODUCTION
OF BUSINESS RECORDS
Code oT CMI Procedure 2€l20.3tO, 2020.440
Government Code 88097.1
wmiv.tourls.tta.gov
iPLAINTIFF/PETITIONER: GRACE SCHMIDT and ANTHONY SCHIViIDT I
i
I, DEFENDANT/RESPONDENT: ARKEMA, INC., ET AL l'
II
CASE NUMBER:
23STCV18513
PROOF OF SERVICE FOR DEPOSITION SLIBPOENA FOR
PRODUCTiON OF BuSiNESS RECORDS
1. I served this Deposition Subpoena forPmduction ofBusiness Recoms by personally delivering a copy to the person served
as follows:
a Person served (name):
b. Address where served:
c Date of delivery:
d Time of delivery:
e. (1) D Witness fees were paid.
Amount............... $
(;) D Copying fees were paid.
Amount................. $-
f Fee for service..
2. I received this subpoena for seWce m (date):
3: Person serving:
a Not a registered California process server.
b. California sheriff or marshal.
c D Registered California process server.
d. C J Employee or independent contractor of a registered California process server,
B l) Exempt from registration under Business and Professions Code section 22350(b).
f D Registered professional photocopier.
, l) Exempt from reistration under Business and Professions section 22451.
h Name, address, telephone number, and, if app(icable, county of registration and number:
I declare under penalty of perjuiy under the laws of the State of
California that the foregoing is true and correct.
Date:
(For California or marshaJ use only)
I certify that the foregoing is true and correct.
Date:
{SIGNATURE)
(SIGNATURE)
SllaPa) @EV. Januay 12012)
DEPOS(TION SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
Page 2
Grace Sc}imidt and Anthony Schmidt vs, Arkema, Inc., et al
Court Cause No,: 23STCV18513
Attachment 3
Records Pertaining to: GRACE ELIZABETH SCHMIDT
DOB: 08/19/1964
CUSTODIANOF RECORDS FOR:
CITYOFCUPERTINO -HUMAN RESOURCES DIVISION
10300 TORREA VENUE
CUPERTmO, C4 95014
RECORDS REQUESTED:
ANY AND ALL EMPLOYMENT AND PAYROLL RECORDS INCLUDING BUT NOT LIMITED
TO THE EMPLOYMENT FILE 40MPENSATION RECORDS, !1:MPLOYMENT APPLICATION
RE'UMES TRAINING ugcox.r.js, ATTENDANCE OR TIME RECORDS PERFORMANC
EVALUATIONS INCIDENT OR ACCIDENT REPORTS, INSURANCE RECbRDS WORKERS
REPORTS MEDICAL HENEFITS OR OTHER BENEFITS THAT MAY HAVE BEEN PAID OR
AVAILABLE TO THE INDIVIDUAL 40IK AND RETIREMENT PLANS REPRIMANDS
HH5By, 4yHBHH3oHs 7y7pHyn 7cOyHs,scoq;,,poHDy;H,,,,gv5g;usUcH
MAGNETIC FORM AND ANY OTHER THING IN POSSESSIONT CUSTODY OR CONTROL OF
SAID WITNESS PENT AINING TO GRACE ELIZABETH SCHMID
'i'ir.Rll'NTEN
[)agpos.tyxo%
SEIR !C:E
Custodian Certification
RECORDS PERT AINING TO: GRACE ELIZABETH SCHMIDT
RECORDS REQUESTED FROM: CITY OF CUPERTINO - HUMAN RESOURCES DIVISION
RECORDS REQUESTED: ANY AND ALL EMPLOYMENT AND PAYROLL RECORDS, INCLUD'JNG BUT NOT
LJ)MITED TO, THE EMPLOYMENT FILE, COMPENSATION RECORDS, EMPLOYMENT APPLICATIONS,
RESUMES, TRAINING RECORDS, ATTENDANCE OR TIME RECORDS, PERFORMANCE EVALUATIONS,
mCIDENT OR ACCIDENT REPORTS, INSURANCE RECORDS, WORKERS AND/OR UNEMPLOYMENT
COMPENSATION, LISTING OF SALARY FOR EACH YEAR, WAGE AND PAYROLL FILES, W-2 FORMS, 1099
FORMS, DISCIPLINARY RECORDS, SICK TIME REPORTS, MEmCAL BENEFITS OR OTHER BENEFITS THAT
MAY HAVli: BEEN P,AID OR AVAILABLE TO THE mDffiDUAL, 401K AND RETIREMENT PLANS,
REPRIMANDS, NOTICES, RESIGNATIONS, TERMmATION RECORDS, CORRESPONDENCE, EVERY SUCH
RECORD, INCLUDING BUT NOT IIMITED TO, THOSE EXlSTmG IN ELECTRONIC OR MAGNETIC FORM,
AND ANY OTHER THING IN POSSESSION, CUSTODY OR CONTROL OF SAID WITNESS PERT AINmG TO
CERTIFICATION OF CUSTODIAN OF RECORDS
"Please initial the appropriate blankAND sign tliis fi>rm below.
CERTIFICATION OF RECORDS COPIED (Custodian's initials0!te0rl,1,al records aVal.labie at thl,Tlie copies of the records submitted herewith are true and accurate copies
time, To the best of my knowledge, the records were made at or near the time of occurrence of the matters set fortli
by, or from information transmitted by, a person with knowledge of those matters. The record was kept in the course
of the regularly conducted business activity, and was made by the regularly conducted activity as a regular practice.
No documents have been intentionally witlilield ii'i order to avoid their being copied. If we have only part of the
records, sucli records as are available are provided.
to us for identification; the described records do not exist. No copies or records are transmitted because we do not
liave records.
CERTIFICATION OF LOST RECORDS (Custodian's initials
A thorough search has been made for the documents described in the requl based on the information provided
to us for identification, no such records were found. No copies are transmitted because we do not have such records.
It appears the records were lost unintentionally, and not due to bad faith.
aFl";"re"c'ordXCgrIi; gFtheDrEeqsuTesRt OweYreEgsHoEyCeda""spasrt(oCfuosu1rondo'ramnalsc'onu'r'sfeal:ms and in accordance with
our records retention and destruction polices. It is our policy to destroy records evei'y ears. No copies or
records are transmitted because we do not have records. Records were destroyed as part of our normal business, and
not due to bad faith.
I understand this certification is done under penalty of making a false statement, and if I falsely ceitify, I may be
subject to criminal penalties.
Print Name:Dated:
Signature:Phone #:
Order No. 76461.003
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Brake Barnumber, end address).'
Rob Green; State Bar# 216116
Siinon Greenstoiie Panatler, PC
3780 :Kllroy Airport Way, Siiite 540, Long Bench, CA 90806
TELEPHONE: (562) 590-3400 FAX NO. (Optional)
A'nORNEY FOR (Name) Plnintiff
FOR COURT USE ONLY
NAME OF couti'r: SUPERIOR COURT OF CALIFORNIA, COUNTY OF
STREET AODRF_S8: L.os Angeles County Superkua Couri
MAILING AODR5SS: }If N. Hill Sltael
Lot Angeleii CA 'XH112
BRANCH NAMEi
l'
I
PLAINTIFF/PETITONER: GRACE SCHMIDT and ANTHONY SCHMIDT
DEFENDANT/RESPONDENT: ARKEMA, INC., ET AL
CA8E NUMBER:
23STCV18513
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Clv. Porc., % 1985.3, 1985,8)
(RECOR[)S ONLY - NO PERSONAL APPEARANCE IS NECESSARY)
NOTI(E TO CONSUMER OFI EMPLOYEE:
To GRACE ELIZABETH SCHMIDT through attorney of record and all other counsel: (See List)
1. PLEASE TAKE NOTICE THAT REQUESTING PARTY: Simon Gi'eenstone Panatier, PC
SEEKS YOu# RECORDS FOR EXAMINATION by the parties tO thiS aCtiOn On (SpeCif7 date): 1/22/2024
The records are described in the subpoena directed to witness (specify name and address of person or entity from whom records are
sought.' CUSTODIAN OF RECORDS FOR: CITY OF CUPERTINO - HUMAN RESOURCES DIVISION' 10300 TORRE
AVENUE, CUPERTINO, CA 95014
A COP!/ of the subpoena is attached.
2. IF YOU OBJECT to the production of these records, YOU MUST DO ONE OF THE FOLLOWING BEFORE THE DATE
SPECIFIED. IN ITEM a. OR b. BELOW:
a. If you are a party to the above-entltled action, you must file a motion pursuant to Code of CMI Procedure section i987.1 to
quash or modify the subpoena and give notice of that motion to the witness and the deposition officer named In the subpoena at
least five days before the date set for production of the records.
b. If you are not a party to this action, you must serve on )he requesting party and on the witness, before the date set for
production of the records, a written otJection that states the specific grounds on which production of such records should be
prohibited. You may use the form below to object and state the grounds for your objection. You must complete the Proof of Service
on the reverse side indicating whether you personally served or mailed the obJection. The obJection should not be filed with the
court. WARNiNG: IF YOUR OBJECTION IS NOT RECEIVED BEFORE THE DATE SPECIFIED IN ITEM "I, YOUR RECORDS MAY
BE PRODUCED AND MAY BE AVAILABLE TO ALL PARTIES.
3. YOU OR YOUR ATTORNEY MAY CONTACT THE UNDERSIGNED to determine whether an agreement can be reached in
Wriling tO cancel Or limit the SCOpe Of the subpoenai If nO SuCh agreement IS reaChedl and if }Ou are mat OtherWiSe represented by
an attorney in this action, YOU SHOULD CONSULT AN ATTORNEY TO ADVISE YOU OF YOUR RIGHTS OF PRIVACY,
Date: 12/5/2023
Rob Green
iTYPE OR F'RINT NAME)
/s/Rob Green
lAlaNA'l'UHE u: peout:stiva PAR'rV X Ait'ORNeY)
OEIJECTION BY NON-PARTY TO PRODUCTION OF RECORDS
1.
2.
[1 lobjecttotheproductionofallofmyrecordsspecifiedinthesubpoena.
€ I object only to the production of fhe following specified records:
3. The specific grounds for my objection are as follows:
Date:
(TYPE OR PRINT NAME)ISIGN ATURE) [ IR(:QUE8T1NG PARTYi iATTORNEY
IProoT or seivlce on revera)
Form adapted For Msndalory Use
Judicisl Council of Calllornla
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Clv. Proc 1985.3, 1985.6)
Code of Clvil Ptocedute
982 ia)( l 5.2) Rev. Jaiiuary T, 2000
Page * of 2
niarliir H "l(srirs 1 I
':::::;,:'.:::;.:'.",::::,:a,":..",".'HONysCIlMrDT lICASE NUMB::STcv 18513
PROOF OF OF SERVICE OF NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
Code Clv. Proc., §§ 1985.3,1986.6)
[1 PersonalService [J Mall
1. A( the time of service I was at least 18 years of age and not a party to this legal action.
2. lservedacopyofkheNoticetoConsumerorEmployeeandObjeckionasTollows(checkeitheraorb):
a. € Personal servlt,e. I personally delivered the Notice to ConsumerorEmployee and Objection as follows:
(1) Name of person served: (3) Date served:
(2) Mdress where served: (4) Time served:
b. [J Mail. I deposited the Notice to ConsumerorEmployee and Objection In the United States mail, in a sealed
envelope with postage fully prepaid. The envelope was addressed as follows:
(1) Name of person served: See List (3) Date of mailing: 12/5/2023
(2) Address: See List (4) Place of mailing (city and state):
(5) I am a resident of or employed in the county where the Notice to Consumer or Employee and Objecfion was mailed.
c. My residence or business address is (specify): Written Deposition Service, LLC, 21021 Ventura B}vd., Ste 410,
Woodland Hills, CA 91364
d. My phone number is (specify): (800) 346-4405
I declare under penalty of perjury under the laws of the Stale of California that the foregoing is true and correct.
Date: I2/5/2023
RobertGlucroft ? %
(Type or Print Name of Person Who Served) (Slgnature ofPerson Who served)
PROOF OF SERVICE OF OBJECTION TO PRODUCTION OF RECORDS
(Code Clv. Proc. § § 1985,3, 1 985.8)
Personal Service Mail
1. At the time of service I was at least 18 years of age and not a party to this legal action.
2. I served a copy of the Objectlon to Production of Records as follows (cornplete either a orb).'
a. ON THE REQUESTING PARTY
(1) 0 Personalservice.IpersonallydeliveredtheObject/onfoProduct/onofRecomsasfollows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) 0 Mait. I deposited the Objectlon to Production of Records in the United States mail, In a sealed envelope with
postage fully prepaid. The envelope was addressed as follows:
(i) Name of person served: (iii) Date of mailing:
(li) Address:
(v) I am a resident of or employed in the county where the Objection to Pr'o2icPtiaocneo'ffr';rcao:'d's Eajf", manadilesda, fe"
b. ON THE WITNESS
(1 ) g Personal service. I personally delivered the Objection to Production of Records as follows:
(i) Name of person served: (iii) Date served:
(ii) Address where served: (iv) Time served:
(2) Mail.ldeposltedtheObject;onfo/:'roducffonofRet.ordsin(heUnitedStatesmall,Inasealedenvelopewlthposiage
fully prepaid. The envelope was addressed as follows:
(i) Name of person served:(iii) Date of mailing:
(ii) Address:
(v) I am a resident of or employed In the county where the Objection to Pro('dv;jc'ffoanceofoRf %aor'J !caisfym&asilfead.'a)
3. My residence or business address Is (specify):
4. My phone number is (specify):
I declare under penalty of pedury under the laws of the State of California that the foregoing is true and correct.
Date:
(TYPE OR PRINT NAME OF PERSON WHO 8ERVED (SIGNATURE OF PERSON WHO SERVED)
SUB1'4)!I IRIII. litllll!ty 1, 200ii
NOTICE TO CONSUMER OR EMPLOYEE AND OBJECTION
(Code Clv. Proc I 985.3 1986.6
(lvrlr-v *l'HsAKl l
Grace Schmidt andAnthony 8chmidt & Arkema, Inc., et at
Court: 23STCV18513
Order#: 76461
ATTORNEYS OF RECORD
Edward R Hugo
Hugo Parker, LLP
240 Stockton st., sth Floor
San Francisco, CA 94108
415-808-0300;Fax:415-80 8-0333
Attorney For: Defendant
Farah S Nicol
Polsinelli, LLP
2049 Cenhiry Park East, Ste 2900
Los Angeles, CA 90067
310-556-1801; Fax: 310-556-1802
Attorney For: Defendant
Gabriel A Jackson
Goldberg Segalla LLP
611 Gateway Blvd., Ste. 120 Soutli
San Francisco, CA 94080
415-432-6600; Fax:
Attorney For: Defendant
leffrey M Goldman
Troutman Pepper Hamilton Sanders ALP
Two California P]aza
350 South Grand Avenue, Suite 3400
Los Angeles, CA 90071
213-928-9800; Fax:
Attoriiey For: Defendant
Jeremy D. Milbrodt
PrindIe, Goetz, Bames & Reinholtz, LLP
One World Trade Center
Suite 1100
Long Beach, CA 9083 I
562-436-3946; Fax: 562-495-0564
Attorney For: Defendant
Kelley S Olah
Bames & Thoi'nburg LLP
2029 Century Park East, Suite 300
Los Angeles, CA 90067
310-284-3880; Fax: 310-284-3894
Attoiney For: Defendant
Kendra E Bray
WFBM,LLP
I9900 MacArthur Blvd.
Suite 1150
Irvine, CA 92612
714-634-2522; Fax: 714-634-0686
Attorney For: Defendant
76461
Kimberly L Rivera
Foley & Mansfield, P.L.L.P.
187 W Huntington Drive, Suite 2]0
Monrovia, CA 91016
213-283-2100; Fax: 213-283-2101
Attorney For: Defendant
Lindsay Weiss
Maruiing Gross + Massenburg LLP
444 S Flower Street, Ste 4100
Los Angeles, CA 90071
213-622-7300; Fax: 213-622-7313
Attorney For: Defendant
Michael L Fox
Duane Morris LLP
One Market Plaza
Spear Tower, Ste. 2200
San Francisco, CA 94105-1127
; Fax:
Attorney For: Defendant
Nicolas P. Martin
Wilson, Elser, Moskowitz, Edelman & Dicker, LLP
655 Market st., Ste. 900
San Francisco, CA 94105
415-433-0990; Fax: 415-434-1370
Attorney For: Defendant
RObert A Rich
Gordon & Rees Scully Mansukhani, LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071
2]3-576-5000;Fax:2]3-680-4470
Attorney For: Defendant
Ryan B Cosgrove
Nelson Mullins Riley & Scarborough LLP
19191 S. Vermont Ave, Ste. 900
Tonance, CA 90502
424-221-7400; Fax: 424-221-7499
Attorney For: Defendant
Shawn M Ridley
Ridley Master
19000 Cj Farrell Street, Suite 280
San Mateo, CA 94403
650-365-7715; Fax: 650-364-5297
Attorney For: Defendant
Tina Van Darn
Manning Gross + Massenburg L.LP
400 Spectium Center Drive, Suite 1450
Irvine, CA 92618
949-892-4700; Fax: 949-892-4701
Attorney For: Defendant
76461
William L Coggshall
Gordon Rees Scully Mansuk)iani, LLP
101 W. Broadway, Suite 2000
San Diego, CA 92101
619-696-6700; Fax: 619-696-7124
Attorney For: Defendant
76461
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