Opinion

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION

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ALEX LOPEZ and TRAVELL CASE NO.: 2:25-cv-07808-FWS (JDEx)

12 WOODS, on behalf of themselves and

all others similarly situated, STIPULATED PROTECTIVE ORDER

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14 Plaintiffs,

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vs. Filed (state court): March 19, 2025

16 Removed: August 14, 2025

SUZUKI MOTOR OF AMERICA,

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INC., and DOES 1-50, inclusive,

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Defendants.

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20 Based on the Parties’ Stipulation (Dkt. 19) and for good cause shown, the Court

21 finds and orders as follows.

22 1. PURPOSES AND LIMITATIONS

23 Discovery in this action is likely to involve production of confidential, proprietary

24 or private information for which special protection from public disclosure and from use

25 for any purpose other than pursuing this litigation may be warranted. This Order does not

26 confer blanket protections on all disclosures or responses to discovery. The protection it

27 affords from public disclosure and use extends only to the limited information or items

1 2. GOOD CAUSE STATEMENT

2 This action is likely to involve trade secrets, customer and pricing lists and other

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

4 information for which special protection from public disclosure and from use for any

5 purpose other than prosecution of this action is warranted. Such confidential and

6 proprietary materials and information consist of, among other things, confidential business

7 or financial information, information regarding confidential business practices, or other

8 confidential research, development, or commercial information (including information

9 implicating privacy rights of third parties), personal identifying information of third

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

11 privileged or otherwise protected from disclosure under state or federal statutes, court

12 rules, case decisions, or common law. Accordingly, to expedite the flow of information, to

13 facilitate the prompt resolution of disputes over confidentiality of discovery materials, to

14 adequately protect information the parties are entitled to keep confidential, to ensure that

15 the parties are permitted reasonable necessary uses of such material in preparation for and

16 in the conduct of trial, to address their handling at the end of the litigation, and serve the

17 ends of justice, a protective order for such information is justified in this matter. It is the

18 intent of the parties that information will not be designated as confidential for tactical

19 reasons and that nothing be so designated without a good faith belief that it has been

20 maintained in a confidential, non-public manner, and there is good cause why it should

21 not be part of the public record of this case.

22 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE

23 The parties further acknowledge, as set forth in Section 14.3, below, that this

24 Stipulated Protective Order does not entitle them to file confidential information under

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

26 standards that will be applied when a party seeks permission from the court to file material

27 under seal. There is a strong presumption that the public has a right of access to judicial

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

1 cause must be shown to support a filing under seal. See Kamakana v. City and County of

2 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d

3 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,

4 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and

5 a specific showing of good cause or compelling reasons with proper evidentiary support

6 and legal justification, must be made with respect to Protected Material that a party seeks

7 to file under seal. The parties’ mere designation of Disclosure or Discovery Material as

8 CONFIDENTIAL or HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY does

9 not— without the submission of competent evidence by declaration, establishing that the

10 material sought to be filed under seal qualifies as confidential, privileged, or otherwise

11 protectable—constitute good cause.

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

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

14 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

15 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of

16 information, document, or thing sought to be filed or introduced under seal, the party

17 seeking protection must articulate compelling reasons, supported by specific facts and

18 legal justification, for the requested sealing order. Again, competent evidence supporting

19 the application to file documents under seal must be provided by declaration.

20 Any document that is not confidential, privileged, or otherwise protectable in its entirety

21 will not be filed under seal if the confidential portions can be redacted. If documents can

22 be redacted, then a redacted version for public viewing, omitting only the confidential,

23 privileged, or otherwise protectable portions of the document, shall be filed. Any

24 application that seeks to file documents under seal in their entirety should include an

25 explanation of why redaction is not feasible.

26 4. DEFINITIONS

27 4.1 Action: Lopez et al. v. Suzuki Motor of Am., Inc. et al., Case No.: 2:25-cv-

07808-FWS (JDEx).

1 4.2 Challenging Party: a Party or Non-Party that challenges the designation of

2 information or items under this Order.

3 4.3 “CONFIDENTIAL” Information or Items: information (documents, tangible

4 things, including written discovery responses, deposition testimony, all other information

5 that may be disclosed, as well as compilations or excerpts of such materials, regardless of

6 how such information or materials are generated, stored or maintained), that qualify for

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

8 Good Cause Statement.

9 4.4 “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY” Information or

10 Items: Information (regardless of how it is generated, stored or maintained) or tangible

11 things that are Confidential but require further limited access for the use in this Action

12 because the Designating Party has reasonable grounds to believe the information or items

13 would, if known to any officer, director, employee, or agent of a Party, a Non-Party, or the

14 public, lead to significant or irreparable harm or injury to the reputation and/or business of

15 the Designating Party or materially impair the legitimate competitive interests of the

16 Designating Party, which cannot be avoided by less restrictive means and include, but are

17 not limited to, research, development, design, testing, financial, or commercial

18 information.

19 4.5 Counsel: Outside Counsel of Record and House Counsel (as well as their

20 support staff).

21 4.6 Designating Party: a Party or Non-Party that designates information or items

22 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or

23 “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY.”

24 4.7 Disclosure or Discovery Material: all items or information, regardless of the

25 medium or manner in which it is generated, stored, or maintained (including, among other

26 things, testimony, transcripts, and tangible things), that are produced or generated in

27 disclosures or responses to discovery.

1 4.8 Expert: a person with specialized knowledge or experience in a matter

2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

3 expert witness or as a consultant in this Action.

4 4.9 House Counsel: attorneys who are employees of a party to this Action.

5 House Counsel does not include Outside Counsel of Record or any other outside counsel.

6 4.10 Non-Party: any natural person, partnership, corporation, association or other

7 legal entity not named as a Party to this action.

8 4.11 Outside Counsel of Record: attorneys who are not employees of a party to

9 this Action but are retained to represent a party to this Action and have appeared in this

10 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf

11 of that party, and includes support staff.

12 4.12 Party: any party to this Action, including all of its officers, directors,

13 employees, consultants, retained experts, and Outside Counsel of Record (and their

14 support staffs).

15 4.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

16 Material in this Action.

17 4.14 Professional Vendors: persons or entities that provide litigation support

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

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

20 their employees and subcontractors.

21 4.15 Protected Material: any Disclosure or Discovery Material that is designated

22 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY.”

23 4.16 Receiving Party: a Party that receives Disclosure or Discovery

24 Material from a Producing Party.

25 5. SCOPE

26 The protections conferred by this Stipulation and Order cover not only Protected

27 Material (as defined above), but also (1) any information copied or extracted from

Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

1 Material; and (3) any testimony, conversations, or presentations by Parties or their

2 Counsel that might reveal Protected Material.

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

4 judge and other applicable authorities. This Order does not govern the use of Protected

5 Material at trial.

6 6. DURATION

7 Once a case proceeds to trial, information used or introduced as an exhibit at trial

8 that was designated as CONFIDENTIAL or HIGHLY CONFIDENTIAL-

9 ATTORNEY’S EYES ONLY or maintained pursuant to this protective order becomes

10 public and will be presumptively available to all members of the public, including the

11 press, unless compelling reasons supported by specific factual findings to proceed

12 otherwise are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at

13 1180-81 (distinguishing “good cause” showing for sealing documents produced in

14 discovery from “compelling reasons” standard when merits-related documents are part of

15 court record); Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1097 (9th Cir.

16 2016) (holding that “compelling reason[s]” include “when a court record might be used to

17 ‘gratify private spite or promote public scandal,’ to circulate ‘libelous’ statements, or ‘as

18 sources of business information that might harm a litigant’s competitive standing’”).

19 The confidentiality obligations imposed by this Order upon all other information

20 not used or introduced as an exhibit at trial that was designated as CONFIDENTIAL or

21 HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY or maintained pursuant to this

22 protective order, shall remain in effect until a Designating Party agrees otherwise in

23 writing or a court order otherwise directs, even after final disposition of this litigation.

24 Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses

25 in this Action, with or without prejudice; and (2) final judgment herein after the

26 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this

27 Action, including the time limits for filing any motions or applications for extension of

time pursuant to applicable law.

1 7. DESIGNATING PROTECTED MATERIAL

2 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each

3 Party or Non-Party that designates information or items for protection under this Order

4 must take care to limit any such designation to specific material that qualifies under the

5 appropriate standards. The Designating Party must designate for protection only those

6 parts of material, documents, items or oral or written communications that qualify so that

7 other portions of the material, documents, items or communications for which protection

8 is not warranted are not swept unjustifiably within the ambit of this Order.

9 Mass, indiscriminate or routinized designations are prohibited. Designations that

10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

11 to unnecessarily encumber the case development process or to impose unnecessary

12 expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

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

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

16 7.2 Manner and Timing of Designations. Except as otherwise provided in this

17 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that

18 qualifies for protection under this Order must be clearly so designated before the material

19 is disclosed or produced.

20 Designation in conformity with this Order requires:

21 (a) for information in documentary form (e.g., paper or electronic documents,

22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the

23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

24 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES

25 ONLY” (hereinafter “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY

26 legend”)), to each page that contains protected material. If only a portion of the material

27 on a page qualifies for protection, the Producing Party also must clearly identify the

protected portion(s) (e.g., by making appropriate markings in the margins).

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

2 not designate them for protection until after the inspecting Party has indicated which

3 documents it would like copied and produced. During the inspection and before the

4 designation, all of the material made available for inspection shall be deemed “HIGHLY

5 CONFIDENTIAL-ATTORNEY’S EYES ONLY.” After the inspecting Party has

6 identified the documents it wants copied and produced, the Producing Party must

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

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

9 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES

10 ONLY legend” to each page that contains Protected Material. If only a portion of the

11 material on a page qualifies for protection, the Producing Party also must clearly identify

12 the protected portion(s) (e.g., by making appropriate markings in the margins).

13 (b) for testimony given in depositions, or in other pretrial proceedings, that

14 the Designating Party identifies the Disclosure or Discovery Material on the record

15 whenever practical, before the close of the deposition, hearing, or other proceeding, all

16 protected testimony. A Party may also designate the testimony that is entitled to protection

17 or a portion of the testimony as containing Confidential Information after transcription of

18 the proceedings. A Party will have until thirty (30) days after receipt of the deposition

19 transcript to inform the other party or parties to the Action of the portions of the transcript

20 to be designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S

21 EYES ONLY” and until such designation is made either on the record or after

22 transcription of the proceedings, the entire transcript shall be treated as “HIGHLY

23 CONFIDENTIAL – FOR ATTORNEY’S EYES ONLY.”

24 (c) The use of a document as an exhibit at a deposition shall not in any way

25 affect its designation as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-

26 ATTORNEY’S EYES ONLY.” Transcripts containing Protected Material shall have an

27 obvious legend on the title pages that the transcript contains Protected Material. The

Designating Party shall inform the court reporter of this requirement.

1 (d) for information produced in some form other than documentary and for

2 any other tangible items, that the Producing Party affix in a prominent place on the

3 exterior of the container or containers in which the information is stored the legend

4 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,

5 the Producing Party, to the extent practicable, shall identify the protected portion(s).

6 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

7 to designate qualified information or items does not, standing alone, waive the

8 Designating Party’s right to secure protection under this Order for such material. Upon

9 timely correction of a designation, the Receiving Party must make reasonable efforts to

10 assure that the material is treated in accordance with the provisions of this Order.

11 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

12 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation

13 of confidentiality at any time that is consistent with the Court’s Scheduling Order.

14 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

15 process under Local Rule 37-1 et seq.

16 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint

17 stipulation pursuant to Local Rule 37-2.

18 8.4 The burden of persuasion in any such challenge proceeding shall be on the

19 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to

20 harass or impose unnecessary expenses and burdens on other parties) may expose the

21 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the

22 confidentiality designation, all parties shall continue to afford the material in question the

23 level of protection to which it is entitled under the Producing Party’s designation until the

24 Court rules on the challenge.

25 9. ACCESS TO AND USE OF PROTECTED MATERIAL

26 9.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

1 Material may be disclosed only to the categories of persons and under the conditions

2 described in this Order. When the Action has been terminated, a Receiving Party must

3 comply with the provisions of section 15 below (FINAL DISPOSITION).

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

5 and in a secure manner that ensures that access is limited to the persons authorized under

6 this Order.

7 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

8 otherwise ordered by the court or permitted in writing by the Designating Party, a

9 Receiving Party may disclose any information or item designated “CONFIDENTIAL”

10 only to:

11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

12 employees of said Outside Counsel of Record to whom it is reasonably necessary to

13 disclose the information for this Action;

14 (b) the officers, directors, and employees (including House Counsel) of the

15 Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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

19 (d) the court and its personnel;

20 (e) court reporters and their staff;

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

22 Vendors to whom disclosure is reasonably necessary for this Action and who have signed

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

24 (g) the author or recipient of a document containing the information or a

25 custodian or other person who otherwise possessed or knew the information;

26 (h) during their depositions, witnesses, and attorneys for witnesses, in the

27 Action to whom disclosure is reasonably necessary provided they will not be permitted to

keep any confidential information unless they sign the “Acknowledgment and Agreement

1 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by

2 the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal

3 Protected Material may be separately bound by the court reporter and may not be

4 disclosed to anyone except as permitted under this Stipulated Protective Order; and

5 (i) any mediators or settlement officers and their supporting personnel,

6 mutually agreed upon by any of the parties engaged in settlement discussions.

7 9.3 Disclosure of “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY”

8 Information or Items. Unless otherwise ordered by the court or permitted in writing by the

9 Designating Party, a Receiving Party may disclose any information or item designated

10 “HIGHLY CONFIDENTIAL” only to:

11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

12 employees of said Outside Counsel of Record to whom it is reasonably necessary to

13 disclose the information for this Action;

14 (b) House Counsel of the Receiving Party to whom disclosure is reasonably

15 necessary for this Action and who has signed the “Acknowledgment and Agreement to be

16 Bound” (Exhibit A);

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

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

19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), provided that the Expert is

20 not a current officer, director, or employee of a competitor of a Party or anticipated to

21 become one;

22 (d) the court and its personnel;

23 (e) court reporters and their staff;

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

25 Vendors to whom disclosure is reasonably necessary for this Action and who have signed

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

27 (g) the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;

1 (h) during their depositions, witnesses, and attorneys for witnesses, in the

2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

3 requests that the witness sign the form attached as Exhibit A hereto (“Acknowledgment

4 and Agreement to Be Bound”); and (2) they will not be permitted to keep any confidential

5 information unless they sign Exhibit A, unless otherwise agreed by the Designating Party

6 or ordered by the court. Pages of transcribed deposition testimony or exhibits to

7 depositions that reveal Protected Material may be separately bound by the court reporter

8 and may not be disclosed to anyone except as permitted under this Stipulated Protective

9 Order; and

10 (i) any mediator or settlement officer, and their supporting personnel,

11 mutually agreed upon by any of the parties engaged in settlement discussions.

12 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

13 IN OTHER LITIGATION

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

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

16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY,” that

17 Party must:

18 (a) promptly notify in writing the Designating Party. Such notification shall

19 include a copy of the subpoena or court order;

20 (b) promptly notify in writing the party who caused the subpoena or order to

21 issue in the other litigation that some or all of the material covered by the subpoena or

22 order is subject to this Protective Order. Such notification shall include a copy of this

23 Stipulated Protective Order; and

24 (c) cooperate with respect to all reasonable procedures sought to be pursued

25 by the Designating Party whose Protected Material may be affected. If the Designating

26 Party timely seeks a protective order, the Party served with the subpoena or court order

27 shall not produce any information designated in this action as “CONFIDENTIAL” or

“HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY” before a determination by

1 the court from which the subpoena or order issued, unless the Party has obtained the

2 Designating Party’s permission. The Designating Party shall bear the burden and expense

3 of seeking protection in that court of its confidential material and nothing in these

4 provisions should be construed as authorizing or encouraging a Receiving Party in this

5 Action to disobey a lawful directive from another court.

6 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

7 PRODUCED IN THIS LITIGATION

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

9 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY

10 CONFIDENTIAL-ATTORNEY’S EYES ONLY.” Such information produced by Non-

11 Parties in connection with this litigation is protected by the remedies and relief provided

12 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party

13 from seeking additional protections.

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

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

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

17 information, then the Party shall:

18 (1) promptly notify in writing the Requesting Party and the Non-Party that

19 some or all of the information requested is subject to a confidentiality agreement with a

20 Non-Party;

21 (2) promptly provide the Non-Party with a copy of the Stipulated Protective

22 Order in this Action, the relevant discovery request(s), and a reasonably specific

23 description of the information requested; and

24 (3) make the information requested available for inspection by the Non-Party,

25 if requested.

26 (c) If the Non-Party fails to seek a protective order from this court within 14

27 days of receiving the notice and accompanying information, the Receiving Party may

produce the Non-Party’s confidential information responsive to the discovery request. If

1 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

2 information in its possession or control that is subject to the confidentiality agreement

3 with the Non-Party before a determination by the court. Absent a court order to the

4 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

5 court of its Protected Material.

6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

10 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

11 unauthorized copies of the Protected Material, (c) inform the person or persons to whom

12 unauthorized disclosures were made of all the terms of this Order, and (d) request such

13 person or persons to execute the “Acknowledgment an Agreement to Be Bound” attached

14 hereto as Exhibit A.

15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

16 PROTECTED MATERIAL

17 When a Producing Party gives notice to Receiving Parties that certain inadvertently

18 produced material is subject to a claim of privilege or other protection, the obligations of

19 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).

20 This provision is not intended to modify whatever procedure may be established in an e-

21 discovery order that provides for production without prior privilege review. Pursuant to

22 Federal Rule of Evidence 502(b), an inadvertent disclosure of information covered by the

23 attorney-client privilege or work-product protection does not operate as a waiver of that

24 protection if: (1) the disclosure is inadvertent; (2) the holder of the privilege or protection

25 took reasonable steps to prevent disclosure; and (3) the holder promptly took reasonable

26 steps to rectify the error, including (if applicable) following Federal Rule of Civil

27 Procedure 26(b)(5)(B). 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

1 covered by the attorney-client privilege or work product protection, the parties may

2 incorporate their agreement in the stipulated protective order submitted to the court.

3 14. MISCELLANEOUS

4 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person

5 to seek its modification by the Court in the future.

6 14.2 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 disclosing

8 or producing any information or item on any ground not addressed in this Stipulated

9 Protective Order. Similarly, no Party waives any right to object on any ground to use in

10 evidence of any of the material covered by this Protective Order.

11 14.3 Filing Protected Material. A Party that seeks to file under seal any

12 Protected Material must comply with Local Civil Rule 79-5. Protected Material may only

13 be filed under seal pursuant to a court order authorizing the sealing of the specific

14 Protected Material. If a Party’s request to file Protected Material under seal is denied by

15 the court, then the Receiving Party may file the information in the public record unless

16 otherwise instructed by the court.

17 15. FINAL DISPOSITION

18 After the final disposition of this Action, as defined in paragraph 6, within 60 days

19 of a written request by the Designating Party, each Receiving Party must return all

20 Protected Material to the Producing Party or destroy such material. As used in this

21 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

22 summaries, and any other format reproducing or capturing any of the Protected Material.

23 Whether the Protected Material is returned or destroyed, the Receiving Party must submit

24 a written certification to the Producing Party (and, if not the same person or entity, to the

25 Designating Party) by the 60-day deadline that (1) identifies (by category, where

26 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that

27 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any

other format reproducing or capturing any of the Protected Material. Notwithstanding this

1 |} provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers,

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

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

4|| product, even if such materials contain Protected Material. Any such archival copies that

contain or constitute Protected Material remain subject to this Protective Order as set □□□□□

6 || in Section 6 (DURATION).

7 16. VIOLATION

8 Any violation of this Order may be punished by appropriate measure

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

10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

1] je de

Dated: November 5, 2025

B IQEPED. EARLY

nited States Magistrate Judge

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1 Attachment A

2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND

3

4 I declare under penalty of perjury that I have read in its entirety and understand the

5 Stipulated Protective Order that was issued by the United States District Court for the

6 Central District of California in the case of : Lopez et al. v. Suzuki Motor of Am., Inc. et al.,

7 Case No.: 2:25-cv-07808-FWS (JDEx). I agree to comply with and to be bound by all the

8 terms of this Stipulated Protective Order and I understand and acknowledge that failure to

9 so comply could expose me to sanctions and punishment in the nature of contempt. I

10 solemnly promise that I will not disclose in any manner any information or item that is

11 subject to this Stipulated Protective Order to any person or entity except in strict

12 compliance with the provisions of this Order.

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

14 Central 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.

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18 Date: _______________________

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20 City and State where sworn and signed:

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23 Printed Name: _______________________

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25 Signature: _______________________

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