The opinion
1 LEWIS BRISBOIS BISGAARD & SMITH LLP
BRIAN C. VANDERHOOF, SB# 248511
2 E-Mail: Brian.Vanderhoof@lewisbrisbois.com
JONATHAN WON, SB# 293910
3 E-Mail: Jonathan.Won@lewisbrisbois.com
45 Fremont Street, Suite 3000
4 San Francisco, California 94105
Telephone: 213.680.5064
5 Facsimile: 213.250.7900
6 Attorneys for Defendant FORD MOTOR
COMPANY
7
8 UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
11 JAMES OLIVER, Case No. 1:25-cv-00088-KES-BAM
12 Plaintiff, Magistrate Judge Barbara A. McAuliffe
13 vs.
STIPULATED PROTECTIVE
14 FORD MOTOR COMPANY, A ORDER
Delaware Corporation; and DOES 1
15 through 10, inclusive,
16 Defendants. Trial Date: February 16, 2026
17
STIPULATED PROTECTIVE ORDER:
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1. PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action is likely to involve production
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of confidential, proprietary, commercially sensitive, personal identifiable
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information (“PII”) or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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only to the limited information or items that are entitled to confidential treatment
1 under the applicable legal principles. The parties further acknowledge, as set forth
2 in Section XIII(C), below, that this Stipulated Protective Order does not entitle them
3 to file confidential information under seal; Civil Local Rule 141 sets forth
4 procedures that must be followed and the standards that will be applied when a party
5 seeks permission from the court to file material under seal.
6 2. DEFINITIONS
7 2.1. Challenging Party: a Party or Non-Party that challenges the
8 designation of information or items under this Order.
9 2.2. “CONFIDENTIAL” Information or Items: information (regardless of
10 how it is generated, stored or maintained) or tangible things that qualify for
11 protection under Federal Rule of Civil Procedure 26(c).
12 2.3. Counsel (without qualifier): Outside Counsel of Record and House
13 Counsel (as well as their support staff).
14 2.4. Designating Party: a Party or Non-Party that designates information or
15 items that it produces in disclosures or in responses to discovery as
16 “CONFIDENTIAL.”
17 2.5. Disclosure or Discovery Material: all items or information, regardless
18 of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 generated in disclosures or responses to discovery in this matter.
21 2.6. Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a non-attorney consultant in this action, provided that no
24 disclosure shall be made to any expert or consultant who is employed by a
25 competitor of Ford Motor Company (“Ford.”)
26 2.7. House Counsel: attorneys who are employees of a party to this action.
27 House Counsel does not include Outside Counsel of Record or any other outside
1 2.8. Non-Party: any natural person, partnership, corporation, association, or
2 other legal entity not named as a Party to this action.
3 2.9. Outside Counsel of Record: attorneys who are not employees of a
4 party to this action but are retained to represent or advise a party to this action and
5 have appeared in this action on behalf of that party or are affiliated with a law firm
6 which has appeared on behalf of that party.
7 2.10. Party: any party to this action, including all of its officers, directors,
8 employees, consultants, retained experts, and Outside Counsel of Record (and their
9 support staffs).
10 2.11. Producing Party: a Party or Non-Party that produces Disclosure or
11 Discovery Material in this action.
12 2.12. Professional Vendors: persons or entities that provide litigation
13 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
14 demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 and their employees and subcontractors.
16 2.13. Protected Material: any Disclosure or Discovery Material that is
17 designated as “CONFIDENTIAL.”
18 2.14. Receiving Party: a Party that receives Disclosure or Discovery
19 Material from a Producing Party.
20 3. SCOPE
21 The protections conferred by this Stipulation and Order cover not only
22 Protected Material (as defined above), but also (1) any information copied or
23 extracted from Protected Material; (2) all copies, excerpts, summaries, or
24 compilations of Protected Material; and (3) any testimony, conversations, or
25 presentations by Parties or their Counsel that might reveal Protected Material.
26 However, the protections conferred by this Stipulation and Order do not cover the
27 following information: (a) any information that is in the public domain at the time of
1 disclosure to a Receiving Party as a result of publication not involving a violation of
2 this or any other court order, including becoming part of the public record through
3 trial or otherwise; and (b) any information known to the Receiving Party prior to the
4 disclosure or obtained by the Receiving Party after the disclosure from a source who
5 obtained the information lawfully and under no obligation of confidentiality to the
6 Designating Party. Any use of Protected Material at trial shall be governed by the
7 orders of the trial judge.
8 4. DURATION
9 Even after final disposition of this litigation, the confidentiality obligations
10 imposed by this Order shall remain in effect until a Designating Party agrees
11 otherwise in writing or a court order otherwise directs. Final disposition shall be
12 deemed to be the later of (1) dismissal of all claims and defenses in this action, with
13 or without prejudice; and (2) final judgment herein after the completion and
14 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
15 including the time limits for filing any motions or applications for extension of time
16 pursuant to applicable law.
17 5. DESIGNATING PROTECTED MATERIAL
18 5.1. Exercise of Restraint and Care in Designating Material for Protection.
19 Each Party or Non-Party that designates information or items for protection under
20 this Order must take care to limit any such designation to specific material that
21 qualifies under the appropriate standards. The Designating Party must designate for
22 protection only those parts of material, documents, items, or oral or written
23 communications that qualify so that other portions of the material, documents,
24 items, or communications for which protection is not warranted are not swept
25 unjustifiably within the ambit of this Order.
26 Mass, indiscriminate, or routinized designations are prohibited. Designations
27 that are shown to be clearly unjustified or that have been made for an improper
1 to impose unnecessary expenses and burdens on other parties) may expose the
2 Designating Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the mistaken designation.
6 5.2. Manner and Timing of Designations. Except as otherwise provided in
7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic
13 documents, but excluding transcripts of depositions or other pretrial or trial
14 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each
15 page that contains protected material. If only a portion or portions of the material on
16 a page qualifies for protection, the Producing Party also must clearly identify the
17 protected portion(s) (e.g., by making appropriate markings in the margins). A Party
18 or Non-Party that makes original documents or materials available for inspection
19 need not designate them for protection until after the inspecting Party has indicated
20 which materials it would like copied and produced. During the inspection and
21 before the designation, all of the material made available for inspection shall be
22 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
23 documents it wants copied and produced, the Producing Party must determine which
24 documents, or portions thereof, qualify for protection under this Order. Then,
25 before producing the specified documents, the Producing Party must affix the
26 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a
27 portion or portions of the material on a page qualifies for protection, the Producing
1 markings in the margins).
2 (b) for testimony given in deposition or in other pretrial or trial
3 proceedings, the Designating Party may either (1) identify on the record, before the
4 close of the deposition, hearing, or other proceeding, all protected testimony; or (2)
5 identify more specific portions of the testimony as to which protection is sought
6 within 30 days following receipt of the final deposition transcript. In circumstances
7 where portions of the deposition testimony are designated for protection, the
8 transcript pages containing Protected Material may be separately bound by the court
9 reporter, who must affix to the top of each page the legend “Confidential” as
10 instructed by the Designating Party.
11 (c) for information produced in form other than document and for any
12 other tangible items, that the Producing Party affix in a prominent place on the
13 exterior of the container or containers in which the information or item is stored the
14 legend “CONFIDENTIAL.” If only a portion or portions of the information or item
15 warrant protection, the Producing Party, to the extent practicable, shall identify the
16 protected portion(s).
17 5.3. Failure to Designate. If timely corrected, a failure to designate qualified
18 information or items does not, standing alone, waive the Designating Party’s right to
19 secure protection under this Order for such material. Upon timely correction of a
20 designation, the Receiving Party must make reasonable efforts to assure that the
21 material is treated in accordance with the provisions of this Order.
22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1. Timing of Challenges. Any party or Non-Party may challenge a
24 designation of confidentiality at any time. Unless a prompt challenge to a
25 Designating Party’s confidentiality designation is necessary to avoid foreseeable,
26 substantial unfairness, unnecessary economic burdens, or a significant disruption or
27 delay of the litigation, a Party does not waive its right to challenge a confidentiality
1 designation is disclosed.
2 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
3 resolution process under Local Rule 251, et seq., by providing written notice of each
4 designation it is challenging, identifying where applicable the challenged
5 designation by Bates number, and describing the basis for each challenge. To avoid
6 ambiguity as to whether a challenge has been made, the written notice must recite
7 that the challenge to confidentiality is being made in accordance with this specific
8 paragraph of the Protective Order. The parties shall attempt to resolve each
9 challenge in good faith and must begin the process by conferring directly (in voice
10 to voice dialogue; other forms of communication are not sufficient) within 14 days
11 of the date of service of notice. In conferring, the Challenging Party must explain
12 the basis for its belief that the confidentiality designation was not proper and must
13 give the Designating Party an opportunity to review the designated material, to
14 reconsider the circumstances, and, if no change in designation is offered, to explain
15 the basis for the chosen designation. A Challenging Party may proceed to the next
16 stage of the challenge process only if it has engaged in this meet and confer process
17 first or establishes that the Designating Party is unwilling to participate in the meet
18 and confer process in a timely manner.
19 6.3. Judicial Intervention. If the Parties cannot resolve a challenge without
20 court intervention, the Designating Party shall file and serve a motion to retain
21 confidentiality under Civil Local Rule 251 (and in compliance with Civil Local Rule
22 230, if applicable) within 21 days of the initial notice of challenge or within 14 days
23 of the parties agreeing that the meet and confer process will not resolve their
24 dispute, whichever is earlier. Each such motion must be accompanied by a
25 competent declaration affirming that the movant has complied with the meet and
26 confer requirements imposed in the preceding paragraph. Failure by the Designating
27 Party to make such a motion including the required declaration within 21 days (or
1 each challenged designation. In addition, the Challenging Party may file a motion
2 challenging a confidentiality designation at any time if there is good cause for doing
3 so, including a challenge to the designation of a deposition transcript or any portions
4 thereof. Any motion brought pursuant to this provision must be accompanied by a
5 competent declaration affirming that the movant has complied with the meet and
6 confer requirements imposed by the preceding paragraph.
7 The burden of persuasion in any such challenge proceeding shall be on
8 the Designating Party. Frivolous challenges, and those made for an improper
9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
10 parties) may expose the Challenging Party to sanctions. Unless the Designating
11 Party has waived the confidentiality designation by failing to file a motion to retain
12 confidentiality as described above, all parties shall continue to afford the material in
13 question the level of protection to which it is entitled under the Producing Party’s
14 designation until the court rules on the challenge.
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1. Basic Principles. A Receiving Party may use Protected Material that is
17 disclosed or produced by another Party or by a Non-Party in connection with this
18 case only for prosecuting, defending, or attempting to settle this litigation. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the litigation has been terminated, a
21 Receiving Party must comply with the provisions of section 13 below (FINAL
22 DISPOSITION). Protected Material must be stored and maintained by a Receiving
23 Party at a location and in a secure manner that ensures that access is limited to the
24 persons authorized under this Order.
25 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
26 otherwise ordered by the court or permitted in writing by the Designating Party, a
27 Receiving Party may disclose any information or item designated
1 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
2 employees of said Outside Counsel of Record to whom it is reasonably necessary to
3 disclose the information for this litigation and who have signed the
4 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A;
5 (b) the officers, directors, and employees (including House Counsel) of the
6 Receiving Party to whom disclosure is reasonably necessary for this litigation and
7 who have signed the “Acknowledgment and Agreement to Be Bound” that is
8 attached hereto as Exhibit A;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this litigation and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the court and its personnel;
13 (e) court reporters, videographers and their staff, professional jury or trial
14 consultants, mock jurors, and Professional Vendors to whom disclosure is
15 reasonably necessary for this litigation and who have signed the “Acknowledgment
16 and Agreement to be Bound” (Exhibit A);
17 (f) during their depositions, witnesses in the action to whom disclosure is
18 reasonably necessary and who have signed the “Acknowledgment and Agreement to
19 Be Bound” (Exhibit A),” unless otherwise agreed by the Designating Party or
20 ordered by the court. Pages of transcribed deposition testimony or exhibits to
21 depositions that reveal Protected Material must be separately bound by the court
22 reporter and may not be disclosed to anyone except as permitted under this
23 Stipulated Protective Order; however, nothing in this paragraph shall limit the use of
24 Ford documents in deposition of Ford representatives or employees who have a
25 legitimate need to see the information based on the intended subject matter of the
26 deposition.
27 (g) the author or recipient of a document containing the information or a
1 (h) Any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
4 IN OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any information or items designated in this action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification
9 shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the
12 subpoena or order is subject to this Protective Order. Such notification shall
13 include a copy of this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 pursued by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served with
17 the subpoena or court order shall not produce any information designated in this
18 action as “CONFIDENTIAL” before a determination by the court from which the
19 subpoena or order issued, unless the Party has obtained the Designating Party’s
20 permission. The Designating Party shall bear the burden and expense of seeking
21 protection in that court of its confidential material - and nothing in these provisions
22 should be construed as authorizing or encouraging a Receiving Party in this action
23 to disobey a lawful directive from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a Non-
27 Party in this action and designated as “CONFIDENTIAL.” Such information
1 remedies and relief provided by this Order. Nothing in these provisions should be
2 construed as prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is
5 subject to an agreement with the Non-Party not to produce the Non-Party’s
6 confidential information, then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-Party
8 that some or all of the information requested is subject to a confidentiality
9 agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this litigation, the relevant discovery request(s), and a
12 reasonably specific description of the information requested; and
13 (3) make the information requested available for inspection by the Non-
14 Party, if requested.
15 (c) If the Non-Party fails to object or seek a protective order from this court
16 within 14 days of receiving the notice and accompanying information, the Receiving
17 Party may produce the Non-Party’s confidential information responsive to the
18 discovery request. If the Non-Party timely seeks a protective order, the Receiving
19 Party shall not produce any information in its possession or control that is subject to
20 the confidentiality agreement with the Non-Party before a determination by the
21 court. Absent a court order to the contrary, the Non-Party shall bear the burden and
22 expense of seeking protection in this court of its Protected Material.
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (within 7 days of
27 discovery) (a) notify in writing the Designating Party of the unauthorized
1 Protected Material, (c) inform the person or persons to whom unauthorized
2 disclosures were made of all the terms of this Order, (d) request such person or
3 persons to execute the “Acknowledgment and Agreement to be Bound” that is
4 attached hereto as Exhibit A; and (e) cooperate with efforts of the Producing Party
5 to claw back any such documents from third party recipients.
6 11. PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
7 MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain
9 produced material is subject to a claim of privilege or other protection, the
10 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
12 procedure may be established in an e-discovery order that provides for production
13 without prior privilege review. Further, the parties invoke the provisions of Federal
14 Rule of Evidence 502(d) and (e), including that the disclosure of Protected Materials
15 in this action is not a waiver of the attorney-client privilege, work product doctrine
16 or any other asserted privilege in any other federal or state proceeding.
17 12. MISCELLANEOUS
18 12.1. Right to Further Relief. Nothing in this Order abridges the right of any
19 person to seek its modification by the court in the future.
20 12.2. Right to Assert Other Objections. By stipulating to the entry of this
21 Protective Order, no Party waives any right it otherwise would have to object to
22 disclosing or producing any information or item on any ground not addressed in this
23 Stipulated Protective Order. Similarly, no Party waives any right to object on any
24 ground to use in evidence of any of the material covered by this Protective Order.
25 12.3 Filing Protected Material. Without written permission from the
26 Designating Party or a court order secured after appropriate notice, or upon another
27 timeframe agreeable under the circumstances, to all interested persons, a Party may
1 to file under seal any Protected Material must comply with Civil Local Rules.
2 Protected Material may only be filed under seal pursuant to a court order authorizing
3 the sealing of the specific Protected Material at issue. Pursuant to Civil Local Rules,
4 a sealing order will issue only upon a request establishing that the Protected
5 Material at issue is privileged, protectable as a trade secret, or otherwise entitled to
6 protection under the law. If a Receiving Party's request to file Protected Material
7 under seal pursuant to Civil Local Rules is denied by the court, then the Receiving
8 Party may file the information in the public record pursuant to Civil Local Rules
9 unless otherwise instructed by the court.
10 13. FINAL DISPOSITION
11 After the final disposition of this action, as defined in paragraph 4, within 60
12 days of a written request by the Designating Party, each Receiving Party must return
13 all Protected Material to the Producing Party or destroy such material. As used in
14 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
15 summaries, and any other format reproducing or capturing any of the Protected
16 Material. Whether the Protected Material is returned or destroyed, the Receiving
17 Party must submit a written certification to the Producing Party (and, if not the same
18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
19 (by category, where appropriate) all the Protected Material that was returned or
20 destroyed and (2) affirms that the Receiving Party has not retained any copies,
21 abstracts, compilations, summaries or any other format reproducing or capturing any
22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
25 reports, attorney work product, and consultant and expert work product, even if such
26 materials contain Protected Material. Any such archival copies that contain or
27 constitute Protected Material remain subject to this Protective Order as set forth in
1 the Receiving Party to retain after final disposition of this action, Confidential
2 Material must be returned to the Producing Party or destroyed on or before 5 years
3 after final disposition (as defined in Section 4: DURATION) of this action. The
4 parties agree to meet and confer prior to moving to enforce compliance with this
5 provision.
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7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: September 3, 2025 /s/ Russell Higgins
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Attorney(s) for Plaintiff(s)
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Dated: September 3, 2025 /s/ Jonathan Won
13 Attorney(s) for Defendant(s)
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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 penalty of perjury that I have
5 read in its entirety and understand the Stipulated Protective Order that was issue by the
6 United States District court for the Eastern District of California on [DATE] in the case of
7 James Oliver v. Ford Motor Company, et al, Case No. 1:25-AT-00088-KES-BAM. I
8 agree to comply with and to be bound by all the terms of this Stipulated Protective Order
9 and I understand and acknowledge that failure to so comply could expose me to sanctions
10 and punishment in the nature of contempt. I solemnly promise that I will not disclose in
11 any manner any information or item that is subject to this Stipulated Protective Order to
12 any person or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District court for
14 the Eastern District of California for the purpose of enforcing the terms of this Stipulated
15 Protective Order, even if such enforcement proceedings occur after termination of this
16 action.
17 I hereby appoint [print or type full name] of
18 [print or type full address and telephone number] as my
19 California agent for service of process in connection with this action or any proceedings
20 related to enforcement of this Stipulated Protective Order.
21 Date:
22 City and State where sworn and signed:
23 Printed Name:
24 Signature:
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1 ORDER
2 Having considered the parties’ stipulated protective order, and finding good
3 cause, the Court adopts the Stipulated Protective Order, (Doc. 16), subject to the
4 following modifications:
5 Exhibit A. line 7: “James Oliver v. Ford Motor Company, et al, Case No.
6 1:25-AT-00088-KES-BAM” is corrected to “James Oliver v. Ford Motor Company,
7 et al, Case No. 1:25-cv-00088-KES-BAM.”
8 Exhibit A, lines 13-16: “I further agree to submit to the jurisdiction of the
9 United States District court for the Eastern District of California for the purpose of
10 enforcing the terms of this Stipulated Protective Order, even if such enforcement
11 proceedings occur after termination of this action” shall be replaced with “I further
12 agree to submit to the jurisdiction of the United States District court for the Eastern
13 District of California for the purpose of enforcing the terms of this Stipulated
14 Protective Order up to and until the termination of this action.”
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16 The parties are advised that pursuant to the Local Rules of the United States
17 District Court, Eastern District of California, any documents subject to the
18 protective order to be filed under seal must be accompanied by a written request
19 which complies with Local Rule 141 prior to sealing. The party making a request to
20 file documents under seal shall be required to show good cause for documents
21 attached to a non-dispositive motion or compelling reasons for documents attached
22 to a dispositive motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78
23 (9th Cir. 2009). Within five (5) days of any approved document filed under seal, the
24 party shall file a redacted copy of the sealed document. The redactions shall be
25 narrowly tailored to protect only the information that is confidential or was deemed
26 confidential.
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1 The parties also shall consider resolving any dispute arising under the
2 stipulated protective order according to the Court’s informal discovery dispute
3 procedure.
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5 IT IS SO ORDERED.
6 Dated: September 5, 2025 /s/ Barbara A. McAuliffe _
7 UNITED STATES MAGISTRATE JUDGE
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