The opinion
1 Craig G. Staub, Bar No. 172857
cstaub@littler.com
2 Erin N. Collins, Bar No. 291726
ecollins@littler.com
3 LITTLER MENDELSON, P.C.
633 West 5th Street
4 63rd Floor
Los Angeles, California 90071
5 Telephone: 213.443.4300
Facsimile: 800.715.1330
6
Attorneys for Defendant
7
MARATHON PETROLEUM LOGISTICS
8 SERVICES, INC.
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
12 JACQUELINE GARCIA, Case No. 2:25-cv-03806-ODW-PDx
13 Plaintiff, STIPULATED PROTECTIVE ORDER
14 v.
Trial Date: August 25, 2026
15
MARATHON PETROLEUM LOGISTICS Removal Filed: April 30, 2025
16 SERVICES, LLC, and DOES 1 to 100, Complaint Filed: March 24, 2025
17 Defendants.
18
19
20
21
22
23
24
25
26
27
28
1 1. INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential, proprietary,
4 or private information for which special protection from public disclosure and from use for
5 any purpose other than prosecuting this litigation may be warranted. Accordingly, the
6 parties hereby stipulate to and petition the Court to enter the following Stipulated
7 Protective Order.
8 The parties acknowledge that this Order does not confer blanket protections on all
9 disclosures or responses to discovery and that the protection it affords from public
10 disclosure and use extends only to the limited information or items that are entitled to
11 confidential treatment under the applicable legal principles.
12 Personnel files, human resources records, and investigative materials shall not be
13 designated ‘CONFIDENTIAL’ solely by virtue of their label or source. However, due to
14 the likelihood that such materials contain sensitive, private, or legally protected
15 information of employees or third parties, a producing party may designate such documents
16 as ‘CONFIDENTIAL’ in the first instance, subject to the right of any party to challenge
17 specific designations under Section 6.
18 The parties further acknowledge, as set forth in Section 12.3, below, that this
19 Stipulated Protective Order does not entitle them to file confidential information under
20 seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the
21 standards that will be applied when a party seeks permission from the court to file material
22 under seal.
23 1.2 GOOD CAUSE STATEMENT
24 This action is likely to involve the production of personnel records of third-party
25 employees and/or former employees who are not parties to this litigation. Such records—
26 which may include performance evaluations, disciplinary history, compensation data, and
27 residential contact information—are maintained by the employer in a confidential and non-
28 public manner.
1 Special protection from public disclosure is warranted because these records
2 implicate the constitutional privacy rights of non-party employees under California and
3 federal law. Public disclosure of this information would cause unwarranted annoyance,
4 embarrassment, and oppression to these third parties and could expose them to the risk of
5 identity theft or unwanted solicitation.
6 Accordingly, to facilitate the prompt resolution of discovery disputes and to
7 adequately protect the privacy of non-parties while ensuring the parties have access to
8 relevant evidence for the prosecution or defense of this action, a protective order is
9 justified.
10 2. DEFINITIONS
11 2.1 Action: Jacqueline Garcia v. Marathon Petroleum Logistics Services, LLC,
12 U.S. District Court for the Central District of California Case No. 2:25-cv-03806-ODW-
13 PD.
14 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
15 information or items under this Order.
16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it
17 is generated, stored or maintained) or tangible things that qualify for protection under
18 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement.
19 Information shall not be designated ‘CONFIDENTIAL’ merely because it may be
20 embarrassing or adverse to a party’s litigation position, provided that nothing in this
21 paragraph limits a party’s ability to designate information that independently qualifies for
22 protection under Rule 26(c), including information implicating privacy rights, proprietary
23 business information, or sensitive personnel data.
24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 2.5 Designating Party: a Party or Non-Party that designates information or items
27 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
28 2.6 Disclosure or Discovery Material: all items or information, regardless of the
1 medium or manner in which it is generated, stored, or maintained (including, among other
2 things, testimony, transcripts, and tangible things), that are produced or generated in
3 disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
6 expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to
8 this Action. House Counsel does not include Outside Counsel of Record or any other
9 outside counsel.
10 2.9 Non-Party: any natural person, partnership, corporation, association, or other
11 legal entity not named as a Party to this action.
12 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
13 this Action but are retained to represent or advise a party to this Action and have appeared
14 in this Action on behalf of that party or are affiliated with a law firm which has appeared
15 on behalf of that party, and includes support staff.
16 2.11 Party: any party to this Action, including all of its officers, directors,
17 employees, consultants, retained experts, and Outside Counsel of Record (and their support
18 staffs).
19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
20 Material in this Action.
21 2.13 Professional Vendors: persons or entities that provide litigation support
22 services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
24 their employees and subcontractors.
25 2.14 Protected Material: any Disclosure or Discovery Material that
26 is designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
28 a Producing Party.
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
5 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel
6 that might reveal Protected Material.
7 Any use of Protected Material at trial will be governed by the orders of the trial
8 judge. This Order does not govern the use of Protected Material at trial.
9
10 4. DURATION
11 Once a case proceeds to trial, all of the information that was designated as
12 confidential or maintained pursuant to this protective order becomes public and will be
13 presumptively available to all members of the public, including the press, unless
14 compelling reasons supported by specific factual findings to proceed otherwise are made
15 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,
16 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
17 documents produced in discovery from “compelling reasons” standard when merits-
18 related documents are part of court record). Accordingly, the terms of this protective order
19 do not extend beyond the commencement of the trial.
20
21 5. DESIGNATING PROTECTED MATERIAL
22 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
23 Party or Non-Party that designates information or items for protection under this Order
24 must take care to limit any such designation to specific material that qualifies under the
25 appropriate standards. The Designating Party must designate for protection only those
26 parts of material, documents, items, or oral or written communications that qualify so that
27 other portions of the material, documents, items, or communications for which protection
28 is not warranted are not swept unjustifiably within the ambit of this Order.
1 Mass, indiscriminate, or routinized designations are prohibited. Designations that
2 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
3 to unnecessarily encumber the case development process or to impose unnecessary
4 expenses and burdens on other parties) may expose the Designating Party to sanctions.
5 Parties shall make reasonable efforts to limit designations to specific material that
6 qualifies for protection.If it comes to a Designating Party’s attention that information or
7 items that it designated for protection do not qualify for protection, that Designating Party
8 must promptly notify all other Parties that it is withdrawing the inapplicable designation.
9 5.2 Manner and Timing of Designations. Except as otherwise provided in this
10 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
11 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
12 must be clearly so designated before the material is disclosed or produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic documents, but
15 excluding transcripts of depositions or other pretrial or trial proceedings), that the
16 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
17 “CONFIDENTIAL legend”), to each page that contains protected material. If only
18 a portion or portions of the material on a page qualifies for protection, the Producing Party
19 also must clearly identify the protected portion(s) (e.g., by making appropriate markings in
20 the margins).
21 A Party or Non-Party that makes original documents available for inspection need
22 not designate them for protection until after the inspecting Party
23 has indicated which documents it would like copied and produced. During the inspection
24 and before the designation, all of the material made available for
25 inspection will be deemed “CONFIDENTIAL.” After the inspecting Party
26 has identified the documents it wants copied and produced, the Producing Party
27 must determine which documents, or portions thereof, qualify for protection under this
28 Order. Then, before producing the specified documents, the Producing Party must affix the
1 “CONFIDENTIAL legend” to each page that contains Protected Material. If only
2 a portion or portions of the material on a page qualifies for protection, the Producing Party
3 also must clearly identify the protected portion(s) (e.g., by making appropriate markings in
4 the margins).
5 (b) for testimony given in depositions that the Designating Party identify the
6 Disclosure or Discovery Material on the record, before the close of the deposition all
7 protected testimony.
8 (c) for information produced in some form other than documentary and for any other
9 tangible items, that the Producing Party affix in a prominent place on the exterior of the
10 container or containers in which the information is stored the
11 legend “CONFIDENTIAL.” If only a portion or portions of the information
12 warrants protection, the Producing Party, to the extent practicable, will identify the
13 protected portion(s).
14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
15 to designate qualified information or items does not, standing alone, waive the Designating
16 Party’s right to secure protection under this Order for such
17 material. Upon timely correction of a designation, the Receiving Party must make
18 reasonable efforts to assure that the material is treated in accordance with the provisions of
19 this Order.
20
21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
23 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
24 6.2 Meet and Confer. The Challenging Party will initiate the dispute resolution
25 process (and, if necessary, file a discovery motion) under Local Rule 37.1 et seq.
26 6.3 The burden of persuasion in any such challenge proceeding will be on the
27 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to
28 harass or impose unnecessary expenses and burdens on other parties) may expose the
1 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the
2 confidentiality designation, all parties will continue to afford the material in question the
3 level of protection to which it is entitled under the Producing Party’s designation until
4 the Court rules on the challenge.
5
6 7. ACCESS TO AND USE OF PROTECTED MATERIAL
7 7.1 Basic Principles. A Receiving Party may use Protected Material that
8 is disclosed or produced by another Party or by a Non-Party in connection with
9 this Action only for prosecuting, defending, or attempting to settle this Action. Such
10 Protected Material may be disclosed only to the categories of persons and under the
11 conditions described in this Order. When the Action has been terminated, a Receiving
12 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
13 Protected Material must be stored and maintained by a Receiving Party at a location
14 and in a secure manner that ensures that access is limited to the persons authorized under
15 this Order.
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
17 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
18 may disclose any information or item designated “CONFIDENTIAL” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
20 employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (b) the officers, directors, and employees (including House Counsel) of the
23 Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure
25 is reasonably necessary for this Action and who have signed the “Acknowledgment and
26 Agreement to Be Bound” (Exhibit A);
27 (d) the Court and its personnel;
28 (e) court reporters and their staff;
1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to
2 whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a custodian
5 or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to
7 whom disclosure is reasonably necessary provided: (1) the deposing party requests that the
8 witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to
9 keep any confidential information unless they sign the “Acknowledgment and Agreement
10 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by
11 the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
12 Protected Material may be separately bound by the court reporter and may not
13 be disclosed to anyone except as permitted under this Stipulated Protective Order; and
14 (i) For the avoidance of doubt, this includes disclosure to Plaintiff for purposes of
15 case evaluation, deposition preparation, and testimony.
16 (j) any mediator or settlement officer, and their supporting personnel, mutually
17 agreed upon by any of the parties engaged in settlement discussions.
18 (h) Nothing in this Order limits the use of Protected Material in examining or cross-
19 examining witnesses.
20
21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
22 IN OTHER LITIGATION
23 If a Party is served with a subpoena or a court order issued in other litigation that
24 compels disclosure of any information or items designated in this Action as
25 “CONFIDENTIAL,” that Party must:
26 (a) promptly notify in writing the Designating Party. Such notification will include
27 a copy of the subpoena or court order;
28 (b) promptly notify in writing the party who caused the subpoena or order to issue
1 in the other litigation that some or all of the material covered by the subpoena or order is
2 subject to this Protective Order. Such notification will include a copy of this Stipulated
3 Protective Order; and
4 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
5 Designating Party whose Protected Material may be affected.
6 If the Designating Party timely seeks a protective order, the Party served with the
7 subpoena or court order will not produce any information designated in this action as
8 “CONFIDENTIAL” before a determination by the court from which the subpoena or order
9 issued, unless the Party has obtained the Designating Party’s permission. The Designating
10 Party will bear the burden and expense of seeking protection in that court of its confidential
11 material and nothing in these provisions should be construed as authorizing or encouraging
12 a Receiving Party in this Action to disobey a lawful directive from another court.
13
14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
15 PRODUCED IN THIS LITIGATION
16 (a) The terms of this Order are applicable to information produced by a Non-Party
17 in this Action and designated as “CONFIDENTIAL.” Such information produced by
18 Non-Parties in connection with this litigation is protected by the remedies and relief
19 provided by this Order. Nothing in these provisions should be construed as prohibiting a
20 Non-Party from seeking additional protections.
21 (b) In the event that a Party is required, by a valid discovery request, to produce a
22 Non-Party’s confidential information in its possession, and the Party is subject to an
23 agreement with the Non-Party not to produce the Non-Party’s confidential information,
24 then the Party will:
25 (1) promptly notify in writing the Requesting Party and the Non-Party that some
26 or all of the information requested is subject to a confidentiality agreement with a Non-
27 Party;
28 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order
1 in this Action, the relevant discovery request(s), and a reasonably specific description of
2 the information requested; and
3 (3) make the information requested available for inspection by the Non-Party,
4 if requested.
5 (c) If the Non-Party fails to seek a protective order from this court within 14 days of
6 receiving the notice and accompanying information, the Receiving Party may produce the
7 Non-Party’s confidential information responsive to the discovery request. If the Non-Party
8 timely seeks a protective order, the Receiving Party will not produce any information in its
9 possession or control that is subject to the confidentiality agreement with the Non-Party
10 before a determination by the court. Absent a court order to the contrary, the Non-
11 Party will bear the burden and expense of seeking protection in this court of its Protected
12 Material.
13
14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the
18 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
19 unauthorized copies of the Protected Material, (c) inform the person or persons to whom
20 unauthorized disclosures were made of all the terms of this Order, and (d) request such
21 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is
22 attached hereto as Exhibit A.
23
24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
25 PROTECTED MATERIAL
26 When a Producing Party gives notice to Receiving Parties that certain inadvertently
27 produced material is subject to a claim of privilege or other protection, the obligations of
28 the Receiving Parties are those set forth in Federal Rule of Civil Procedure
1 26(b)(5)(B). This provision is not intended to modify whatever procedure may
2 be established in an e-discovery order that provides for production without
3 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
4 parties reach an agreement on the effect of disclosure of a communication or information
5 covered by the attorney-client privilege or work product protection, the parties may
6 incorporate their agreement in the stipulated protective order submitted to the court.
7
8 12. MISCELLANEOUS
9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
10 to seek its modification by the Court in the future.
11 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
12 Order no Party waives any right it otherwise would have to object to disclosing or
13 producing any information or item on any ground not addressed in this Stipulated
14 Protective Order. Similarly, no Party waives any right to object on any ground to use in
15 evidence of any of the material covered by this Protective Order.
16 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
17 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
18 under seal pursuant to a court order authorizing the sealing of the specific Protected
19 Material at issue. The burden associated with any sealing motion will be governed by
20 applicable law, including the standards set forth in Kamakana v. City and County of
21 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006) and progeny. If a Party's request to file
22 Protected Material under seal is denied by the court, then the Receiving Party may file the
23 information in the public record unless otherwise instructed by the court.
24
25 13. FINAL DISPOSITION
26 After the final disposition of this Action, as defined in paragraph 4, within 60
27 days of a written request by the Designating Party, each Receiving Party must return all
28 Protected Material to the Producing Party or destroy such material. As used in this
1 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
2 summaries, and any other format reproducing or capturing any of the Protected
3 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
4 must submit a written certification to the Producing Party (and, if not the same person or
5 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category,
6 where appropriate) all the Protected Material that was returned or destroyed and (2) affirms
7 that the Receiving Party has not retained any copies, abstracts, compilations, summaries or
8 any other format reproducing or capturing any of the Protected Material. Notwithstanding
9 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion
10 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
11 deposition and trial exhibits, expert reports, attorney work product, and consultant and
12 expert work product, even if such materials contain Protected Material. Any such archival
13 copies that contain or constitute Protected Material remain subject to this Protective Order
14 as set forth in Section 4 (DURATION).
15
16 14. Any willful violation of this Order may be punished by civil or
17 criminal contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
18 authorities, or other appropriate action at the discretion of the Court.
19
20 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
21
22 Dated: February 18, 2026 LITTLER MENDELSON, P.C.
23
/s/ Erin N. Collins
24 Craig G. Staub
Erin N. Collins
25
Attorneys for Plaintiff
26 JACQUELINE GARCIA
27
28
1
5 Dated: February 18, 2026 FRONTIER LAW CENTER
3 /s/ Samara Cidrim
Samara Cidrim
4 Manny Starr
5 Nicole Clancy
6 Attorneys for Plaintiff
4 JACQUELINE GARCIA
8
9 Filer’s Attestation (LR 5-4.3.4)
10 I, Erin N. Collins, attest that all other signatories listed, and on whose behalf this
filing is submitted, have authorized the filing of this document, and I have obtained their
D concurrence to use their electronic signatures.
3 Dated: 2/18/26
14 By: /s/ Erin N. Collins, SBN 291726, Littler Mendelson P.C.
215
17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
20 DATED: 02/20/2026 — Aaliuaes Monokoe_
HON. PATRICIA DONAHUE
21 United States Magistrate Judge
22
23
24
25
26
27 || 4913-9997-6848
28
STIPULATED PROTECTIVE
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _______________________ [full name], of __________________________
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States District
7 Court for the Central District of California on _________ [date] in the case of Jacqueline
8 Garcia v. Marathon Petroleum Logistics Services, LLC, Case No. 2:25-cv-03806-ODW-
9 PD. 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 expose
11 me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the provisions of
14 this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for
16 the Central District of California for the purpose of enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action. I hereby appoint __________________________ [full name] of
19 _________________________________________ [full address and telephone number]
20 as my California agent for service of process in connection with this action or any
21 proceedings related to enforcement of this Stipulated Protective Order.
22
Date: ___________________________________________________
23
City and State where signed: ________________________________
24
Printed name: ____________________________________________
25
Signature: _______________________________________________
26
27
28