The opinion
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8 UNITED STATES DISTRICT COURT
9 FOR THE EASTERN DISTRICT OF CALIFORNIA
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RAMON QUESADA, Case No. 2:23-cv-311-DAD-CSK
Plaintiff, ORDER GRANTING MODIFIED
13 STIPULATED PROTECTIVE ORDER
14 (ECF No. 106)
MARTEN TRANSPORT, LTD et al.,
Defendants.
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17 The Court has reviewed the parties’ stipulated protective order below (ECF No. 106),
18 || and finds it comports with the relevant authorities and the Court’s Local Rule. See L.R.
19 || 141.1. The Court APPROVES the protective order, subject to the following clarification. The
20 || Court’s Local Rules indicate that once an action is closed, it “will not retain jurisdiction over
21 || enforcement of the terms of any protective order filed in that action.” L.R. 141.1(f); see MD
22 || Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 (E.D. Cal. Feb. 3, 2017) (noting that
23 || courts in the district generally do not retain jurisdiction for disputes concerning protective
24 || orders after closure of the case). Thus, the Court will not retain jurisdiction over this
25 || protective order once the case is closed.
26 Dated: June 24, 2024
27 Cina Spo
GHI 500 KIM
28 sues UNITED STATES MAGISTRATE JUDGE
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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RAMON QUESADA, Ca se No. 2:23-cv-00311-DAD-CSK
10 Plaintiff,
v. STIPULATED PROTECTIVE
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ORDER
MARTEN TRANSPORT, LTD.,1
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MARTEN TRANSPORT SERVICES,
13 LTD., ANN BAUER, TABETHA2
Trial Date: 5/12/2025
CRANDALL, JEFFREY GREILING, and
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DOES 1 to 100, inclusive, Second Amended Complaint Filed:
15 1/10/2024
Defendants.
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A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public disclosure
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and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the parties hereby stipulate to and petition the Court to enter the following
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Stipulated Protective Order. The parties acknowledge that this Order does not confer
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blanket protections on all disclosures or responses to discovery and that the protection
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it affords from public disclosure and use extends only to the limited information or items
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that are entitled to confidential treatment under the applicable legal principles. The
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1 To the best of Defendant Marten Transport, Ltd.’s knowledge, there is no corporate entity known
1 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
2 Protective Order does not entitle them to file confidential information under seal; Civil
3 Local Rule 141 sets forth the procedures that must be followed and the standards that
4 will be applied when a party seeks permission from the court to file material under seal.
5 B. GOOD CAUSE STATEMENT
6 This action is likely to involve information or documents that contain proprietary,
7 confidential business, financial, trade secret, and/or commercially sensitive
8 information, individualized personal information of Plaintiff, including Plaintiff’s
9 personnel file, compensation and benefits information, and medical records and medical
10 information, and personal, private, or sensitive information of non-parties, for which
11 special protection from public disclosure and from use for any purpose other than
12 prosecution of this action is warranted. Such confidential and proprietary materials
13 and information consist of, among other things, confidential business or financial
14 information, information regarding confidential business practices, or other confidential
15 business and personnel information (including information implicating privacy rights
16 of third parties), plaintiffs personal text messages, and financial documents such as tax
17 forms, information otherwise generally unavailable to the public (including insurance
18 policies), or which may be privileged or otherwise protected from disclosure under state
19 or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite
20 the flow of information, to facilitate the prompt resolution of disputes over
21 confidentiality of discovery materials, to adequately protect information the parties are
22 entitled to keep confidential, to ensure that the parties are permitted reasonable
23 necessary uses of such material in preparation for and in the conduct of trial, to address
24 their handling at the end of the litigation, and serve the ends of justice, a protective order
25 for such information is justified in this matter. It is the intent of the parties that
26 information will not be designated as confidential for tactical reasons and that nothing
27 be so designated without a good faith belief that it has been maintained in a confidential,
1 non-public manner, and there is good cause why it should not be part of the public
2 record of this case.
3 2. DEFINITIONS
4 2.1 Action: the above-entitled proceeding, captioned as Ramon Quesada v.
5 Marten Transport, Ltd., Marten Transport Services, Ltd., Ann Bauer, Tabetha Crandall,
6 and Jeffrey Greiling, Case No. 2:23-cv-00311-DAD-CSK, pending in the United States
7 District Court for the Eastern District of California.
8 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
9 information or items under this Order.
10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
11 it is generated, stored or maintained) or tangible things that qualify for protection under
12 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
13 Statement.
14 2.4 Counsel: Outside Counsel of Record (as well as their support staff).
15 2.5 Designating Party: a Party or Non-Party that designates information or
16 items that it produces in disclosures or in responses to discovery as
17 “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: all items or information, regardless of
19 the medium or manner in which it is generated, stored, or maintained (including, among
20 other things, testimony, transcripts, and tangible things), that are produced or generated
21 in disclosures or responses to discovery in this matter.
22 2.7 Expert: a person with specialized knowledge or experience in a matter
23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
24 expert witness or as a consultant in this Action.
25 2.8 Non-Party: any natural person, partnership, corporation, association, or
26 other legal entity not named as a Party to this action.
27 2.9 Outside Counsel of Record: attorneys who are not employees of a party to
1 appeared in this Action on behalf of that party or are affiliated with a law firm which
2 has appeared on behalf of that party, and includes support staff.
3 2.10 Party: any party to this Action, including all of its officers, directors,
4 employees, consultants, retained experts, and Outside Counsel of Record (and their
5 support staffs).
6 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
7 Discovery Material in this Action.
8 2.12 Professional Vendors: persons or entities that provide litigation support
9 services (e.g., photocopying, videotaping, translating, preparing exhibits or
10 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
11 their employees and subcontractors.
12 2.13 Protected Material: any Disclosure or Discovery Material that is
13 designated as “CONFIDENTIAL.”
14 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
15 from a Producing Party.
16 3. SCOPE
17 The protections conferred by this Stipulation and Order cover not only Protected
18 Material (as defined above), but also (1) any information copied or extracted from
19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
20 Material; and (3) any testimony, conversations, or presentations by Parties or their
21 Counsel that might reveal Protected Material; so long as such information, copies,
22 excerpts, summaries, compilations, testimony, conversations, or presentations are
23 independently designated as confidential pursuant to this order within 30 days .
24 Any use of Protected Material at trial shall be governed by the orders of the trial
25 judge. This Order does not govern the use of Protected Material at trial.
26 4. DURATION
27 Even after final disposition of this litigation, the confidentiality obligations
1 in writing or a court order otherwise directs. Final disposition shall be deemed to be the
2 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice;
3 and (2) final judgment herein after the completion and exhaustion of all appeals,
4 rehearings, remands, trials, or reviews of this Action, including the time limits for filing
5 any motions or applications for extension of time pursuant to applicable law.
6 5. DESIGNATING PROTECTED MATERIAL
7 5.1 Exercise of Restraint and Care in Designating Material for Protection.
8 Each Party or Non-Party that designates information or items for protection under this
9 Order must take care to limit any such designation to specific material that qualifies
10 under the appropriate standards. The Designating Party must designate for protection
11 only those parts of material, documents, items, or oral or written communications that
12 qualify so that other portions of the material, documents, items, or communications for
13 which protection is not warranted are not swept unjustifiably within the ambit of this
14 Order.
15 Mass, indiscriminate, or routinized designations are prohibited. Designations that
16 are shown to be clearly unjustified or that have been made for an improper purpose
17 (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating Party
19 to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2 Manner and Timing of Designations. Except as otherwise provided in this
24 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
25 or ordered, Disclosure or Discovery Material that qualifies for protection under this
26 Order must be clearly so designated before the material is disclosed or produced.
27 Designation in conformity with this Order requires:
1 (a) for information in documentary form (e.g., paper or electronic documents, but
2 excluding transcripts of depositions or other pretrial or trial proceedings), that the
3 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
5 portion or portions of the material on a page qualifies for protection, the Producing Party
6 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
7 in the margins).
8 A Party or Non-Party that makes original documents available for inspection
9 need not designate them for protection until after the inspecting Party has indicated
10 which documents it would like copied and produced. During the inspection and before
11 the designation, all of the material made available for inspection shall be deemed
12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it
13 wants copied and produced, the Producing Party must determine which documents, or
14 portions thereof, qualify for protection under this Order. Then, before producing the
15 specified documents, the Producing Party must affix the “CONFIDENTIAL
16 legend” to each page that contains Protected Material. If only a portion or portions of
17 the material on a page qualifies for protection, the Producing Party also must clearly
18 identify the protected portion(s) (e.g., by making appropriate markings in the margins).
19 (b) for testimony given in depositions that the Designating Party identify the
20 Disclosure or Discovery Material on the record, before the close of the deposition, or
21 within 30 days following receipt of the deposition transcript, all protected testimony.
22 (c) for information produced in some form other than documentary and for any
23 other tangible items, that the Producing Party affix in a prominent place on the exterior
24 of the container or containers in which the information is stored the legend
25 “CONFIDENTIAL.” If only a portion or portions of the information warrants
26 protection, the Producing Party, to the extent practicable, shall identify the protected
27 portion(s).
1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
2 failure to designate qualified information or items does not, standing alone, waive the
3 Designating Party’s right to secure protection under this Order for such material. Upon
4 timely correction of a designation, the Receiving Party must make reasonable efforts to
5 assure that the material is treated in accordance with the provisions of this Order.
6 In the event that any Document, Testimony or Information that is subject to a
7 “Confidential” designation is inadvertently produced without such designation, the
8 Party that inadvertently produced the document shall give written notice of such
9 inadvertent production within twenty (20) days of discovery of the inadvertent
10 production, together with a further copy of the subject Document, Testimony or
11 Information designated as “Confidential” (the “Inadvertent Production Notice”). Upon
12 receipt of such Inadvertent Production Notice, the Party that received the inadvertently
13 produced Document, Testimony or Information shall promptly destroy the inadvertently
14 produced Document, Testimony or Information and all copies thereof, or, at the expense
15 of the producing Party, return such together with all copies of such Document,
16 Testimony or Information to counsel for the producing Party and shall retain only the
17 “Confidential” designated Materials. Should the receiving Party choose to destroy such
18 inadvertently produced Document, Testimony or Information, the receiving Party shall
19 notify the producing Party in writing of such destruction within ten (10) days of receipt
20 of written notice of the inadvertent production. This provision is not intended to apply
21 to any inadvertent production of any Information protected by attorney-client or work
22 product privileges. In the event that this provision conflicts with any applicable law
23 regarding waiver of confidentiality through the inadvertent production of Documents,
24 Testimony or Information, such law shall govern.
25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
26 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
27 designation of confidentiality at any time that is consistent with the Court’s Scheduling
1 6.2 Meet and Confer. The Challenging Party shall initiate the informal
2 discovery resolution process set forth in the Court’s Civil Standing Orders. See
3 https://www.caed.uscourts.gov/caednew/index.cfm/judges/all-judges/united-states-
4 magistrate-judge-chi-soo-kim-csk/.
5 6.3 The burden of persuasion in any such challenge proceeding shall be on the
6 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
7 to harass or impose unnecessary expenses and burdens on other parties) may expose the
8 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
9 the confidentiality designation, all parties shall continue to afford the material in
10 question the level of protection to which it is entitled under the Producing Party’s
11 designation until the Court rules on the challenge.
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this Action
15 only for prosecuting, defending, or attempting to settle this Action. Such Protected
16 Material may be disclosed only to the categories of persons and under the conditions
17 described in this Order. When the Action has been terminated, a Receiving Party must
18 comply with the provisions of section below (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
23 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
24 may disclose any information or item designated “CONFIDENTIAL” only to:
25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
26 employees of said Outside Counsel of Record to whom it is reasonably necessary to
27 disclose the information for this Action;
1 (b) the officers, directors, and employees of the Receiving Party to whom
2 disclosure is reasonably necessary for this Action;
3 (c) Experts (as defined in this Order), whether or not retained, of the Receiving
4 Party to whom disclosure is reasonably necessary for this Action and who have signed
5 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (d) the court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
9 to whom disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (g) the author or recipient of a document containing the information or a
12 custodian or other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, trial or
14 hearing witnesses, in the Action to whom disclosure is reasonably necessary provided:
15 (1) the deposing party requests that the witness sign the form attached as Exhibit A
16 hereto; and (2) they will not be permitted to keep any confidential information unless
17 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
18 otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
19 deposition testimony or exhibits to depositions that reveal Protected Material may be
20 separately bound by the court reporter and may not be disclosed to anyone except as
21 permitted under this Stipulated Protective Order;
22 (i) any mediator or settlement officer, and their supporting personnel, mutually
23 agreed upon by any of the parties engaged in settlement discussions; and
24 (j) any other person that the Designating Party agrees to in writing.
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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2 PRODUCED IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to issue
9 in the other litigation that some or all of the material covered by the subpoena or order
10 is subject to this Protective Order. Such notification shall include a copy of this
11 Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by
13 the Designating Party whose Protected Material may be affected. If the Designating
14 Party timely seeks a protective order, the Party served with the subpoena or court order
15 shall not produce any information designated in this action as “CONFIDENTIAL”
16 before a determination by the court from which the subpoena or order issued, unless the
17 Party has obtained the Designating Party’s permission. Upon receipt of this notice, the
18 Designating Party may, in its sole discretion and at its own cost, move to quash or limit
19 the Subpoena, otherwise oppose production of the Confidential Materials, and/or seek
20 to obtain confidential treatment of such Confidential Materials from the subpoenaing
21 person or entity to the fullest extent available under law. The Designating Party shall
22 bear the burden and expense of seeking protection in that court of its confidential
23 material and nothing in these provisions should be construed as authorizing or
24 encouraging a Receiving Party in this Action to disobey a lawful directive from another
25 court.
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1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a Non-
4 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
5 by Non-Parties in connection with this litigation is protected by the remedies and relief
6 provided by this Order. Nothing in these provisions should be construed as prohibiting
7 a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to produce
9 a Non-Party’s confidential information in its possession, and the Party is subject to an
10 agreement with the Non-Party not to produce the Non-Party’s confidential information,
11 then the Party shall:
12 (1) promptly notify in writing the Requesting Party and the Non-Party that some
13 or all of the information requested is subject to a confidentiality agreement with a Non-
14 Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
16 Order in this Action, the relevant discovery request(s), and a reasonably specific
17 description of the information requested; and
18 (3) make the information requested available for inspection by the Non-Party, if
19 requested.
20 (c) If the Non-Party fails to seek a protective order from this court within 14 days
21 of receiving the notice and accompanying information, the Receiving Party may
22 produce the Non-Party’s confidential information responsive to the discovery request.
23 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
24 any information in its possession or control that is subject to the confidentiality
25 agreement with the Non-Party before a determination by the court. Absent a court order
26 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
27 in this court of its Protected Material.
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
6 all unauthorized copies of the Protected Material, (c) inform the person or persons to
7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
9 that is attached hereto as Exhibit A.
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other protection,
14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
16 may be established in an e-discovery order that provides for production without prior
17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
18 parties reach an agreement on the effect of disclosure of a communication or
19 information covered by the attorney-client privilege or work product protection, the
20 parties may incorporate their agreement in the stipulated protective order submitted to
21 the court.
22 12. MISCELLANEOUS
23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
24 person to seek its modification by the Court in the future.
25 12.2 Right to Assert Other Objections. By stipulating to the entry of this
26 Protective Order no Party waives any right it otherwise would have to object to
27 disclosing or producing any information or item on any ground not addressed in this
1 Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 ground to use in evidence of any of the material covered by this Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Civil Local Rule 141. Protected Material may
5 only be filed under seal pursuant to a court order authorizing the sealing of the specific
6 Protected Material at issue. If a Party's request to file Protected Material under seal is
7 denied by the court, then the Receiving Party may file the information in the public
8 record unless otherwise instructed by the court.
9 13. FINAL DISPOSITION
10 After the final disposition of this Action, as defined in Section 4 (DURATION),
11 within 60 days of a written request by the Designating Party, each Receiving Party must
12 return all Protected Material to the Producing Party or destroy such material. As used
13 in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
14 summaries, and any other format reproducing or capturing any of the Protected
15 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
16 must submit a written certification to the Producing Party (and, if not the same person
17 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
18 category, where appropriate) all the Protected Material that was returned or destroyed
19 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
20 compilations, summaries or any other format reproducing or capturing any of the
21 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
22 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
23 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
24 work product, and consultant and expert work product, even if such materials contain
25 Protected Material. Any such archival copies that contain or constitute Protected
26 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
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1 14. Any violation of this Order may be punished by any and all appropriate
2 measures including, without limitation, contempt proceedings and/or monetary
3 sanctions.
4 ///
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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
(As Authorized on
2
DATED: June 20, 2024 By: /s/ Nicole Gilanians 6/19/2024)
3 Carney R. Shegerian (SBN: 150461)
cshegerian@shegerianlaw.com
4 Nicole Gilanians (SBN: 346710)
ngilanians@shegerianlaw.com
5 SHEGERIAN & ASSOCIATES, INC.
11520 San Vicente Blvd.
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Los Angeles, CA 90049
Tel: +1 310.860.0770
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Attorney for Plaintiff, RAMON QUESADA
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(As Authorized on
9 DATED: June 20, 2024 By: /s/ Jennifer R. Lucas 6/17/2024)
Michelle F. Ferber (SBN: 149929)
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mferber@ferberlaw.com
Jennifer R. Lucas (SBN: 227505)
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jlucas@ferberlaw.com
12 FERBER LAW, A.P.C.
2603 Camino Ramon
13 San Ramon, CA 94583
Tel: +1 925.355.9800
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Attorney for Individual Defendants,
15 ANN BAUER, TABETHA CRANDALL AND
JEFFREY GREILING
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17 DATED: June 20, 2024 By: /s/ Michael E. Brewer
Michael E. Brewer (SBN: 177912)
18
michael.brewer@bakermckenzie.com
Kimberly R. Rich (SBN: 185507)
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kimberly.rich@bakermckenzie.com
20 BAKER & MCKENZIE LLP
Two Embarcadero Center, 11th Floor
21 Telephone: +1 415.576.3000
22 Attorney for Defendants, MARTEN
TRANSPORT, LTD. and MARTEN
23 TRANSPORT SERVICES, LTD
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25 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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DATED:
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Honorable Chi Soo Kim
1 ATTESTATION
2 I, Michael E. Brewer, hereby certify that the contents of this document are
3 acceptable to all counsel, and that I have obtained all necessary authorizations to affix
4 counsels’ electronic signatures to the document.
5
6 Dated: June 20, 2024 /s/ Michael E. Brewer
7 Michael E. Brewer
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1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3 I, _____________________ [print or type full name], of _____________________
4 [print or type full address], declare under penalty of perjury that I have read in its
5 entirety and understand the Stipulated Protective Order that was issued by the United
6 States District Court for the Eastern District of California on __________ [date] in the
7 case of Ramon Quesada v. Marten Transport, Ltd., Marten Transport Services, Ltd.,
8 Ann Bauer, Tabetha Crandall, and Jeffrey Greiling, Case No. 2:23-cv-00311-DAD-
9 CSK. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
12 that I will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15
16 I further agree to submit to the jurisdiction of the United States District Court for the
17 Eastern District of California for the purpose of enforcing the terms of this Stipulated
18 Protective Order, even if such enforcement proceedings occur after termination of this
19 action. I hereby appoint _____________________ [print or type full name] of
20 _____________________ [print or type full address and telephone number] as my
21 California agent for service of process in connection with this action or any proceedings
22 related to enforcement of this Stipulated Protective Order.
23 Date: _____________________
24 City and State where sworn and signed: _____________________
25 Printed name: _____________________
26 Signature: _____________________
27