Jose Flores v. Bimbo Bakeries USA, Inc.

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9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

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12 JOSE FLORES, an individual, DISCOVERY MATTER

13 Plaintiff, Case No. 2:24-cv-03440-MEMF-RAO

14 vs. [PROPOSED] STIPULATED

PROTECTIVE ORDER1

15 BIMBO BAKERIES USA, INC., a

Delaware corporation; and DOES 1-50,

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inclusive, Judge: Hon. Maame Ewusi-

17 Mensah Frimpong

Defendants.

Courtroom: 8B, 8th Floor

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19 Magistrate: Hon. Rozella A. Oliver

Courtroom: 590, 5th Floor

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21 Trial Date: September 8, 2025

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1 This Stipulated Protective Order is substantially based on the model

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protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

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 disclosure and from use for any purpose other than prosecuting this litigation may

5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

6 enter the following Stipulated Protective Order. The parties acknowledge that this

7 Order does not confer blanket protections on all disclosures or responses to

8 discovery and that the protection it affords from public disclosure and use extends

9 only to the limited information or items that are entitled to confidential treatment

10 under the applicable legal principles.

11 B. GOOD CAUSE STATEMENT

12 This action is likely to involve the exchange of records and information

13 referencing or otherwise reflecting certain business practices, internal procedures,

14 sensitive internal investigations, customer and employee information, and other

15 valuable research, development, commercial, financial, technical and/or proprietary

16 information for which special protection from public disclosure and from use for

17 any purpose other than prosecution of this action is warranted. Such confidential

18 and proprietary materials and information consist of, among other things,

19 confidential business or financial information, information regarding confidential

20 business practices, or other confidential research, development, or commercial

21 information (including information implicating privacy rights of third parties),

22 information otherwise generally unavailable to the public, or which may be

23 privileged or otherwise protected from disclosure under state or federal statutes,

24 court rules, case decisions, or common law. Accordingly, to expedite the flow of

25 information, to facilitate the prompt resolution of disputes over confidentiality of

26 discovery materials, to adequately protect information the parties are entitled to

27 keep confidential, to ensure that the parties are permitted reasonable necessary uses

28 of such material in preparation for and in the conduct of trial, to address their

1 handling at the end of the litigation, and serve the ends of justice, a protective order

2 for such information is justified in this matter. It is the intent of the parties that

3 information will not be designated as confidential for tactical reasons and that

4 nothing be so designated without a good faith belief that it has been maintained in a

5 confidential, non-public manner, and there is good cause why it should not be part

6 of the public record of this case.

7 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING

UNDER SEAL

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The parties further acknowledge, as set forth in Section 12.3, below, that this

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Stipulated Protective Order does not entitle them to file confidential information

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under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

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and the standards that will be applied when a party seeks permission from the court

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to file material under seal.

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There is a strong presumption that the public has a right of access to judicial

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proceedings and records in civil cases. In connection with non-dispositive motions,

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good cause must be shown to support a filing under seal. See Kamakana v. City

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and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen.

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Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony

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Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective

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orders require good cause showing), and a specific showing of good cause or

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compelling reasons with proper evidentiary support and legal justification, must be

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made with respect to Protected Material that a party seeks to file under seal. The

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parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL

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does not—without the submission of competent evidence by declaration,

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establishing that the material sought to be filed under seal qualifies as confidential,

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privileged, or otherwise protectable—constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial,

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then compelling reasons, not only good cause, for the sealing must be shown, and

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1 the relief sought shall be narrowly tailored to serve the specific interest to be

2 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.

3 2010). For each item or type of information, document, or thing sought to be filed

4 or introduced under seal in connection with a dispositive motion or trial, the party

5 seeking protection must articulate compelling reasons, supported by specific facts

6 and legal justification, for the requested sealing order. Again, competent evidence

7 supporting the application to file documents under seal must be provided by

8 declaration.

9 Any document that is not confidential, privileged, or otherwise protectable in

10 its entirety will not be filed under seal if the confidential portions can be redacted.

11 If documents can be redacted, then a redacted version for public viewing, omitting

12 only the confidential, privileged, or otherwise protectable portions of the document

13 shall be filed. Any application that seeks to file documents under seal in their

14 entirety should include an explanation of why redaction is not feasible.

15 2. DEFINITIONS

16 2.1. Action: Jose Flores v. Bimbo Bakeries USA, Inc., a Delaware

17 corporation; and Does 1-50, inclusive (C.D. Cal. Case No. 2:24-cv-03440-MEMF-

18 RAO).

19 2.2. Challenging Party: A Party or Non-Party that challenges the

20 designation of information or items under this Order.

21 2.3. “CONFIDENTIAL” Information or Items: Information (regardless of

22 how it is generated, stored or maintained) or tangible things that qualify for

23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

24 the Good Cause Statement.

25 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as

26 their support staff).

27 2.5. Designating Party: A Party or Non-Party that designates information

28 or items that it produces in disclosures or in responses to discovery as

1 “CONFIDENTIAL.”

2 2.6. Disclosure or Discovery Material: All items or information, regardless

3 of the medium or manner in which it is generated, stored, or maintained (including,

4 among other things, testimony, transcripts, and tangible things,) that are produced

5 or generated in disclosures or responses to discovery in this matter.

6 2.7. Expert: A person with specialized knowledge or experience in a

7 matter pertinent to the litigation who has been retained by a Party or its counsel to

8 serve as an expert witness or as a consultant in this Action.

9 2.8. House Counsel: Attorneys who are employees of a party to this

10 Action. House Counsel does not include Outside Counsel of Record or any other

11 outside counsel.

12 2.9. Non-Party: Any natural person, partnership, corporation, association,

13 or other legal entity not named as a Party to this action.

14 2.10. Outside Counsel of Record: Attorneys who are not employees of a

15 party to this Action but are retained to represent or advise a party to this Action and

16 have appeared in this Action on behalf of that party or are affiliated with a law firm

17 that has appeared on behalf of that party, and includes support staff.

18 2.11. Party: Any party to this Action, including all of its officers, directors,

19 employees, consultants, retained experts, House Counsel, and Outside Counsel of

20 Record (and their support staffs).

21 2.12. Producing Party: A Party or Non-Party that produces Disclosure or

22 Discovery Material in this Action.

23 2.13. Professional Vendors: Persons or entities that provide litigation

24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

25 demonstrations, and organizing, storing, or retrieving data in any form or medium)

26 and their employees and subcontractors.

27 2.14. Protected Material: Any Disclosure or Discovery Material that is

28 designated as “CONFIDENTIAL.”

1 2.15. Receiving Party: A Party that receives Disclosure or Discovery

2 Material from a Producing Party.

3 3. SCOPE

4 The protections conferred by this Stipulation and Order cover not only

5 Protected Material, (as defined above), but also (1) any information copied or

6 extracted from Protected Material; (2) all copies, excerpts, summaries, or

7 compilations of Protected Material; and (3) any testimony, conversations, or

8 presentations by Parties or their Counsel that might reveal Protected Material.

9 Any use of Protected Material at trial shall be governed by the orders of the

10 trial judge. This Order does not govern the use of Protected Material at trial.

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4. DURATION

12 Once a case proceeds to trial, information that was designated as

13 CONFIDENTIAL or maintained pursuant to this protective order used or

14 introduced as an exhibit at trial becomes public and will be presumptively available

15 to all members of the public, including the press, unless compelling reasons

16 supported by specific factual findings to proceed otherwise are made to the trial

17 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing

18 “good cause” showing for sealing documents produced in discovery from

19 “compelling reasons” standard when merits-related documents are part of court

20 record). Accordingly, the terms of this protective order do not extend beyond the

21 commencement of the trial.

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5. DESIGNATING PROTECTED MATERIAL

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5.1. Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items or oral or written

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communications that qualify so that other portions of the material, documents,

1 items or communications for which protection is not warranted are not swept

2 unjustifiably within the ambit of this Order.

3 Mass, indiscriminate or routinized designations are prohibited. Designations

4 that are shown to be clearly unjustified or that have been made for an improper

5 purpose (e.g., to unnecessarily encumber the case development process or to

6 impose unnecessary expenses and burdens on other parties) may expose the

7 Designating Party to sanctions.

8 If it comes to a Designating Party’s attention that information or items that it

9 designated for protection do not qualify for protection, that Designating Party must

10 promptly notify all other Parties that it is withdrawing the inapplicable designation.

11 5.2. Manner and Timing of Designations. Except as otherwise provided in

12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

14 under this Order must be clearly so designated before the material is disclosed or

15 produced.

16 Designation in conformity with this Order requires:

17 (a) For information in documentary form (e.g., paper or electronic

18 documents, but excluding transcripts of depositions or other pretrial or trial

19 proceedings), that the Producing Party affix at a minimum, the legend

20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

21 contains protected material. If only a portion of the material on a page qualifies for

22 protection, the Producing Party also must clearly identify the protected portion(s)

23 (e.g., by making appropriate markings in the margins).

24 A Party or Non-Party that makes original documents available for inspection

25 need not designate them for protection until after the inspecting Party has indicated

26 which documents it would like copied and produced. During the inspection and

27 before the designation, all of the material made available for inspection shall be

28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the

1 documents it wants copied and produced, the Producing Party must determine

2 which documents, or portions thereof, qualify for protection under this Order.

3 Then, before producing the specified documents, the Producing Party must affix the

4 “CONFIDENTIAL legend to each page that contains Protected Material. If only a

5 portion of the material on a page qualifies for protection, the Producing Party also

6 must clearly identify the protected portion(s) (e.g., by making appropriate markings

7 in the margins).

8 (b) For testimony given in depositions, that the Designating Party

9 identifies the Disclosure or Discovery Material on the record, before the close of

10 the deposition all protected testimony.

11 (c) For information produced in some form, other than documentary

12 and for any other tangible items, that the Producing Party affix in a prominent place

13 on the exterior of the container or containers in which the information is stored the

14 legend “CONFIDENTIAL.” If only a portion or portions of the information

15 warrants protection, the Producing Party, to the extent practicable, shall identify the

16 protected portion(s).

17 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent

18 failure to designate qualified information or items does not, standing alone, waive

19 the Designating Party’s right to secure protection under this Order for such

20 material. Upon timely correction of a designation, the Receiving Party must make

21 reasonable efforts to assure that the material is treated in accordance with the

22 provisions of this Order.

23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

24 6.1. Timing of Challenges. Any Party or Non-Party may challenge a

25 designation of confidentiality at any time that is consistent with the Court’s

26 Scheduling Order.

27 6.2. Meet and Confer. The Challenging Party shall initiate the dispute

28 resolution process, under Local Rule 37.1 et seq.

1 6.3. The burden of persuasion in any such challenge proceeding shall be on

2 the Designating Party. Frivolous challenges, and those made for an improper

3 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

4 parties) may expose the Challenging Party to sanctions. Unless the Designating

5 Party has waived or withdrawn the confidentiality designation, all parties shall

6 continue to afford the material in question the level of protection to which it is

7 entitled under the Producing Party’s designation until the Court rules on the

8 challenge.

9 7. ACCESS TO AND USE OF PROTECTED MATERIAL

10 7.1. Basic Principles. A Receiving Party may use Protected Material that is

11 disclosed or produced by another Party or by a Non-Party in connection with this

12 Action only for prosecuting, defending or attempting to settle this Action. Such

13 Protected Material may be disclosed only to the categories of persons and under the

14 conditions described in this Order. When the Action has been terminated, a

15 Receiving Party must comply with the provisions of Section 13 below (FINAL

16 DISPOSITION).

17 Protected Material must be stored and maintained by a Receiving Party at a

18 location and in a secure manner that ensures that access is limited to the persons

19 authorized under this Order.

20 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless

21 otherwise ordered by the Court or permitted in writing by the Designating Party, a

22 Receiving Party may disclose any information or item designated

23 “CONFIDENTIAL” only to:

24 (a) The Receiving Party’s Outside Counsel of Record in this

25 Action, as well as employees of said Outside Counsel of Record to whom it is

26 reasonably necessary to disclose the information for this Action;

27 (b) The officers, directors, and employees (current or former)

28 (including House Counsel) of the Receiving Party to whom disclosure is reasonably

1 necessary for this Action;

2 (c) Experts (as defined in this Order) of the Receiving Party to

3 whom disclosure is reasonably necessary for this Action and who have signed the

4 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

5 (d) The Court and its personnel;

6 (e) Court reporters and their staff;

7 (f) Professional jury or trial consultants, mock jurors, and

8 Professional Vendors to whom disclosure is reasonably necessary for this Action

9 and who have signed the “Acknowledgment and Agreement to be Bound” (Exhibit

10 A);

11 (g) The author or recipient of a document containing the

12 information or a custodian or other person who otherwise possessed or knew the

13 information;

14 (h) During their depositions, witnesses, and attorneys for witnesses,

15 in the Action to whom disclosure is reasonably necessary provided: (1) the

16 deposing party requests that the witness sign the form attached as Exhibit A hereto;

17 and (2) they will not be permitted to keep any confidential information unless they

18 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

19 otherwise agreed by the Designating Party or ordered by the Court. Pages of

20 transcribed deposition testimony or exhibits to depositions that reveal Protected

21 Material may be separately bound by the court reporter and may not be disclosed to

22 anyone except as permitted under this Stipulated Protective Order; and

23 (i) Any mediator or settlement officer, and their supporting

24 personnel, mutually agreed upon by any of the parties engaged in settlement

25 discussions.

26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation

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1 that compels disclosure of any information or items designated in this Action as

2 “CONFIDENTIAL,” that Party must:

3 (a) Promptly notify in writing the Designating Party. Such

4 notification shall include a copy of the subpoena or court order;

5 (b) Promptly notify in writing the party who caused the subpoena or

6 order to issue in the other litigation that some or all of the material covered by the

7 subpoena or order is subject to this Protective Order. Such notification shall

8 include a copy of this Protective Order; and

9 (c) Cooperate with respect to all reasonable procedures sought to be

10 pursued by the Designating Party whose Protected Material may be affected.

11 If the Designating Party timely seeks a protective order, the Party served with

12 the subpoena or court order shall not produce any information designated in this

13 action as “CONFIDENTIAL” before a determination by the Court from which the

14 subpoena or order issued, unless the Party has obtained the Designating Party’s

15 permission. The Designating Party shall bear the burden and expense of seeking

16 protection in that court of its confidential material and nothing in these provisions

17 should be construed as authorizing or encouraging a Receiving Party in this Action

18 to disobey a lawful directive from another court.

19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

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(a) The terms of this Order are applicable to information produced by a

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Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

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produced by Non-Parties in connection with this litigation is protected by the

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remedies and relief provided by this Order. Nothing in these provisions should be

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construed as prohibiting a Non-Party from seeking additional protections.

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(b) In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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1 confidential information, then the Party shall:

2 (1) Promptly notify in writing the Requesting Party and the Non-

3 Party that some or all of the information requested is subject to a confidentiality

4 agreement with a Non-Party;

5 (2) Promptly provide the Non-Party with a copy of the Stipulated

6 Protective Order in this Action, the relevant discovery request(s), and a reasonably

7 specific description of the information requested; and

8 (3) Make the information requested available for inspection by the

9 Non-Party, if requested.

10 (c) If the Non-Party fails to seek a protective order from this Court within

11 fourteen (14) days after receiving the notice and accompanying information, the

12 Receiving Party may produce the Non-Party’s confidential information responsive

13 to the discovery request. If the Non-Party timely seeks a protective order, the

14 Receiving Party shall not produce any information in its possession or control that

15 is subject to the confidentiality agreement with the Non-Party before a

16 determination by the Court. Absent a court order to the contrary, the Non-Party

17 shall bear the burden and expense of seeking protection in this Court of its

18 Protected Material.

19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

21 Protected Material to any person or in any circumstance not authorized under this

22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

23 writing the Designating Party of the unauthorized disclosures, (b) use its best

24 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the

25 person or persons to whom unauthorized disclosures were made of all the terms of

26 this Order, and (d) request such person or persons to execute the “Acknowledgment

27 and Agreement to be Bound” (that is attached hereto as Exhibit A).

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1] 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

5 PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other

protection, the obligations of the Receiving Parties are those set forth in Federal

° Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

° whatever procedure may be established in an e-discovery order that provides for

production without prior privilege review. Pursuant to Federal Rule of Evidence

502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

of a communication or information covered by the attorney-client privilege or work

1 product protection, the parties may incorporate their agreement in the Stipulated

Protective Order submitted to the Court.

3 12. MISCELLANEOUS

14 12.1. Right to Further Relief. Nothing in this Order abridges the right of any

15 || Person to seek its modification by the Court in the future.

16 12.2. Right to Assert Other Objections. By stipulating to the entry of this

7 Protective Order, no Party waives any right it otherwise would have to object to

18 disclosing or producing any information or item on any ground not addressed in

19 this Stipulated Protective Order. Similarly, no Party waives any right to object on

29 || any ground to use in evidence of any of the material covered by this Protective

Order.

12.3. Filing Protected Material. A Party that seeks to file under seal any

33 Protected Material must comply with Local Civil Rule 79-5. Protected Material

34 || May only be filed under seal pursuant to a court order authorizing the sealing of the

5 specific Protected Material at issue. If a Party’s request to file Protected Material

under seal is denied by the Court, then the Receiving Party may file the information

in the public record unless otherwise instructed by the Court.

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~ Case No. □□□□□□□□□□□□□□□□□□□□□□ □□□□□□□□□□□□□□□□□□□□□ =| SST IPULATED PROTECTIVE ORDER |

1 13. FINAL DISPOSITION

2 After the final disposition of this Action, as defined in paragraph 4, within 60

3 days of a written request by the Designating Party, each Receiving Party must

4 return all Protected Material to the Producing Party or destroy such material. As

5 used in this subdivision, “all Protected Material” includes all copies, abstracts,

6 compilations, summaries, and any other format reproducing or capturing any of the

7 Protected Material. Whether the Protected Material is returned or destroyed, the

8 Receiving Party must submit a written certification to the Producing Party (and, if

9 not the same person or entity, to the Designating Party) by the 60-day deadline that

10 (1) identifies (by category, where appropriate) all the Protected Material that was

11 returned or destroyed and (2) affirms that the Receiving Party has not retained any

12 copies, abstracts, compilations, summaries or any other format reproducing or

13 capturing any of the Protected Material. Notwithstanding this provision, Counsel

14 are entitled to retain an archival copy of all pleadings, motion papers, trial,

15 deposition, and hearing transcripts, legal memoranda, correspondence, deposition

16 and trial exhibits, expert reports, attorney work product, and consultant and expert

17 work product, even if such materials contain Protected Material. Any such archival

18 copies that contain or constitute Protected Material remain subject to this Protective

19 Order as set forth in Section 4 (DURATION).

20 //

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27 //

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1] 14. VIOLATION

2 Any violation of this Order may be punished by appropriate measures

3 | including, without limitation, contempt proceedings and/or monetary sanctions.

4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5 | DATED: _September 11 , 2024 JML LAW

6

7 BY: Avena Fare

ADRIANA GARRIDO

9 Attorneys for Plaintiff JOSE

FLORES

10 DATED: September 12 _, 2024 GBG LLP

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12 BY: ( os

13 ELIZABETH A. BROWN

14 Attorneys for Defendant BIMBO

BAKERIES USA, INC.

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16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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18 | paTep: 9/12/2024

19 .

21 HON. ROZELLA A. OLIVER

3 United States Magistrate Judge

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Case No. 2:24-cv-03440-MEMF-RAO -15- STIPULATED PROTECTIVE ORDER

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

5 penalty of perjury that I have read in its entirety and understand the Stipulated

6 Protective Order that was issued by the United States District Court for the Central

7 District of California on __________________ [date] in the case of Jose Flores v.

8 Bimbo Bakeries USA, Inc., a Delaware corporation; and Does 1-50, inclusive

9 (C.D. Cal. Case No. 2:24-cv-03440-MEMF-RAO). I agree to comply with and to

10 be bound by all the terms of this Stipulated Protective Order, and I understand and

11 acknowledge that failure to so comply could expose me to sanctions and

12 punishment in the nature of contempt. I solemnly promise that I will not disclose in

13 any manner any information or item that is subject to this Order to any person or

14 entity except in strict compliance with the provisions of this Stipulated Protective

15 Order.

16 I further agree to submit to the jurisdiction of the United States District Court

17 for the Central District of California for enforcing the terms of this Stipulated

18 Protective Order, even if such enforcement proceedings occur after termination of

19 this action. I hereby appoint _______________________ [print or type full name]

20 of _______________________________________ [print or type address and

21 telephone number] as my California agent for service of process in connection with

22 this action or any proceedings related to enforcement of this Stipulated Protective

23 Order.

24 Date: _____________________________

25 City and State Where Sworn and Signed: _____________________________

26 Signature: _____________________________

27 Printed Name: _____________________________

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