Opinion

Court: District Court, C.D. California
Filed: Feb 25, 2026
Cited by: 0 cases
Authority: More cited than 41.3%

The opinion

1 F. Jay Rahimi, Esq. (SBN: 305286)

E-mail: Jay@LALSLaw.com

2 Los Angeles Legal Solutions

17207 Ventura Blvd., Suite 4

3 Encino, CA 91316

Telephone: (818) 510.0555

4 Facsimile: (818) 510.0590

5 Attorneys for Plaintiff,

Akmaral Babas Takhirov

7 Genevieve Walser-Jolly (SBN 262784)

Genevieve.Walser-Jolly@wbd-us.com

8 Monique Matar (SBN 317145)

Monique.Matar@wbd-us.com

9 WOMBLE BOND DICKINSON (US) LLP

400 Spectrum Center Drive, Suite 1700

Irvine, California 92618

11 Telephone: (714) 557-3800

Facsimile: (714) 557-3347

13 Attorneys for Defendant

NISSAN MOTOR ACCEPTANCE

COMPANY, LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

AKMARAL BABAS TAKHIROV, Case No. 2:25-CV-08408-SSC

Plaintiff,

20 STIPULATED PROTECTIVE

21 vs. ORDER1

22 NISSAN MOTOR ACCEPTANCE

COMPANY, LLC. et al.,

24 Defendants.

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 1. INTRODUCTION

2 1.1 Purposes and Limitations. Discovery in this action is likely to

3 involve production of confidential, proprietary, or private information for

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

5 purpose other than prosecuting this litigation may be warranted.

6 Accordingly, the parties hereby stipulate to and petition the court to

7 enter the following Stipulated Protective Order. The parties

acknowledge that this Order does not confer blanket protections on all

disclosures or responses to discovery and that the protection it affords

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

items that are entitled to confidential treatment under the applicable

legal principles.

1.2 Good Cause Statement. This action is likely to involve trade

secrets, customer and pricing lists and other valuable research,

development, commercial, financial, technical and/or proprietary

information for which special protection from public disclosure and from

use for any purpose other than prosecution of this action is warranted.

Such confidential and proprietary materials and information consist of,

among other things, confidential business or financial information,

information regarding confidential business practices, or other

22 confidential research, development, or commercial information (including

23 information implicating privacy rights of third parties), information

24 otherwise generally unavailable to the public, or which may be privileged

25 or otherwise protected from disclosure under state or federal statutes,

26 court rules, case decisions, or common law. Accordingly, to expedite the

27 flow of information, to facilitate the prompt resolution of disputes over

1 the parties are entitled to keep confidential, to ensure that the parties

2 are permitted reasonable necessary uses of such material in preparation

3 for and in the conduct of trial, to address their handling at the end of the

4 litigation, and serve the ends of justice, a protective order for such

5 information is justified in this matter. It is the intent of the parties that

6 information will not be designated as confidential for tactical reasons

7 and that nothing be so designated without a good faith belief that it has

been maintained in a confidential, non-public manner, and there is good

cause why it should not be part of the public record of this case.

1.3 Acknowledgment of Procedure for Filing Under Seal. The

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

Stipulated Protective Order does not entitle them to file confidential

information under seal; Local Rule 79-5 sets forth the procedures that

must be followed and the standards that will be applied when a party

seeks permission from the court to file material 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 cause must be shown to support a filing

under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

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

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

24 protective orders require good cause showing), and a specific showing of

25 good cause or compelling reasons with proper evidentiary support and

26 legal justification, must be made with respect to Protected Material that

27 a party seeks to file under seal. The parties’ mere designation of

1 without the submission of competent evidence by declaration,

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

3 confidential, privileged, or otherwise protectable—constitute good cause.

4 Further, if a party requests sealing related to a dispositive motion

5 or trial, then compelling reasons, not only good cause, for the sealing

6 must be shown, and the relief sought shall be narrowly tailored to serve

7 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

information, document, or thing sought to be filed or introduced under

seal in connection with a dispositive motion or trial, the party seeking

protection must articulate compelling reasons, supported by specific

facts and legal justification, for the requested sealing order. Again,

competent evidence supporting the application to file documents under

seal must be provided by declaration.

Any document that is not confidential, privileged, or otherwise

protectable in its entirety will not be filed under seal if the confidential

portions can be redacted. If documents can be redacted, then a redacted

version for public viewing, omitting only the confidential, privileged, or

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

application that seeks to file documents under seal in their entirety

22 should include an explanation of why redaction is not feasible.

24 2. DEFINITIONS

25 2.1 Action: This pending litigation captioned as AKMARAL

26 BABAS TAKHIROV, Plaintiff, vs. NISSAN MOTOR ACCEPTANCE

27 COMPANY, LLC. et al., Defendants, Case No. 2:25-CV-08408-SSC.

1 designation of information or items under this Order.

2 2.3 “CONFIDENTIAL” Information or Items: information

3 (regardless of how it is generated, stored or maintained) or tangible

4 things that qualify for protection under Rule 26(c) of the Federal Rules of

5 Civil Procedure, and as specified above in the Good Cause Statement.

6 2.4 Counsel: Outside Counsel of Record and House Counsel (as

7 well as their support staff).

2.5 Designating Party: a Party or Non-Party that designates

information or items that it produces in disclosures or in responses to

discovery as “CONFIDENTIAL.”

2.6 Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or

maintained (including, among other things, testimony, transcripts, and

tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in

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

its counsel to serve as an expert witness or as a consultant in this Action.

2.8 Final Disposition: the later of (1) dismissal of all claims and

defenses in this Action, with or without prejudice; and (2) final judgment

22 herein after the completion and exhaustion of all appeals, rehearings,

23 remands, trials, or reviews of this Action, including the time limits for

24 filing any motions or applications for extension of time pursuant to

25 applicable law.

26 2.9 In-House Counsel: attorneys who are employees of a party to

27 this Action. In-House Counsel does not include Outside Counsel of

1 2.10 Non-Party: any natural person, partnership, corporation,

2 association, or other legal entity not named as a Party to this action.

3 2.11 Outside Counsel of Record: attorneys who are not employees

4 of a party to this Action but are retained to represent or advise a party to

5 this Action and have appeared in this Action on behalf of that party or

6 are affiliated with a law firm which has appeared on behalf of that party,

7 and includes support staff.

2.12 Party: any party to this Action, including all of its officers,

directors, employees, consultants, retained experts, and Outside Counsel

of Record (and their support staffs).

2.13 Producing Party: a Party or Non-Party that produces

Disclosure or Discovery Material in this Action.

2.14 Professional Vendors: persons or entities that provide

litigation- support services (e.g., photocopying, videotaping, translating,

preparing exhibits or demonstrations, and organizing, storing, or

retrieving data in any form or medium) and their employees and

subcontractors.

2.15 Protected Material: any Disclosure or Discovery Material that

is designated as “CONFIDENTIAL.”

2.16 Receiving Party: a Party that receives Disclosure or Discovery

22 Material from a Producing Party.

24 3. SCOPE

25 The protections conferred by this Stipulation and Order cover not

26 only Protected Material (as defined above), but also (1) any information

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

1 summaries, or compilations of Protected Material; and (3) any

2 testimony, conversations, or presentations by Parties or their Counsel

3 that might reveal Protected Material.

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

5 orders of the trial judge. This Stipulated Protective Order does not

6 govern the use of Protected Material at trial.

4. TRIAL AND DURATION

The terms of this Stipulated Protective Order apply through Final

Disposition of the Action.

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

CONFIDENTIAL or maintained pursuant to this Stipulated Protective

14 Order and used or introduced as an exhibit at trial becomes public and

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

16 the press, unless compelling reasons supported by specific factual

17 findings to proceed otherwise are made to the trial judge in advance of

18 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

19 cause” showing for sealing documents produced in discovery from

20 “compelling reasons” standard when merits-related documents are part

21 of court record). Accordingly, for such materials, the terms of this

22 Stipulated Protective Order do not extend beyond the commencement of

the trial.

Even after Final Disposition of this litigation, the confidentiality

obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

order otherwise directs.

1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for

3 Protection. Each Party or Non-Party that designates information or

items for protection under this Order must take care to limit any such

designation to specific material that qualifies under the appropriate

standards. The Designating Party must designate for protection only

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

communications that qualify so that other portions of the material,

documents, items, or communications for which protection is not

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

Mass, indiscriminate, or routinized designations are prohibited.

Designations that are shown to be clearly unjustified or that have been

made for an improper purpose (e.g., to unnecessarily encumber the case

development process or to impose unnecessary expenses and burdens on

other parties) may expose the Designating Party to sanctions.

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

18 items that it designated for protection do not qualify for protection, that

19 Designating Party must promptly notify all other Parties that it is

20 withdrawing the inapplicable designation.

21 5.2 Manner and Timing of Designations. Except as otherwise

22 provided in this Stipulated Protective Order (see, e.g., second paragraph

of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

or Discovery Material that qualifies for protection under this Stipulated

Protective Order must be clearly so designated before the material is

disclosed or produced.

Designation in conformity with this Stipulated Protective Order

1 requires:

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

3 documents, but excluding transcripts of depositions or other pretrial or

4 trial proceedings), that the Producing Party affix at a minimum, the

5 legend “CONFIDENTIAL” to each page that contains protected

6 material. If only a portion or portions of the material on a page

7 qualifies for protection, the Producing Party also must clearly identify

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

margins).

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

inspection need not designate them for protection until after the

inspecting Party has indicated which documents it would like copied

and produced. During the inspection and before the designation, all of

the material made available for inspection shall be deemed

CONFIDENTIAL. After the inspecting Party has identified the

documents it wants copied and produced, the Producing Party must

determine which documents, or portions thereof, qualify for protection

under this Stipulated Protective Order. Then, before producing the

specified documents, the Producing Party must affix the

21 “CONFIDENTIAL” legend to each page that contains Protected

22 Material. If only a portion or portions of the material on a page

23 qualifies for protection, the Producing Party also must clearly identify

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

25 margins).

26 (b) for testimony given in depositions that the Designating Party

27 identify the Disclosure or Discovery Material on the record, before the

1 (c) for information produced in some form other than

2 documentary and for any other tangible items, that the Producing Party

3 affix in a prominent place on the exterior of the container or containers

4 in which the information is stored the “CONFIDENTIAL” legend. If only

5 a portion or portions of the information warrants protection, the

6 Producing Party, to the extent practicable, shall identify the protected

7 portion(s).

5.3 Inadvertent Failures to Designate. If timely corrected, an

inadvertent failure to designate qualified information or items does not,

standing alone, waive the Designating Party’s right to secure protection

under this Order for such material. Upon timely correction of a

designation, the Receiving Party must make reasonable efforts to assure

that the material is treated in accordance with the provisions of this

Stipulated Protective Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

18 6.1 Timing of Challenges. Any Party or Non-Party may

19 challenge a designation of confidentiality at any time that is consistent

20 with the court’s Scheduling Order.

21 6.2 Meet and Confer. The Challenging Party shall initiate the

22 dispute resolution process under Local Rule 37.1 et seq. and with

Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

Discovery Motion Conference.”2

6.3 The burden of persuasion in any such challenge proceeding

2 Judge Christensen’s Procedures are available at

1 shall be on the Designating Party. Frivolous challenges, and those

2 made for an improper purpose (e.g., to harass or impose unnecessary

3 expenses and burdens on other parties) may expose the Challenging

4 Party to sanctions. Unless the Designating Party has waived or

5 withdrawn the confidentiality designation, all parties shall continue to

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

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

the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected

Material that is 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 Material may be

disclosed only to the categories of persons and under the conditions

17 described in this Order. When the Action reaches a Final Disposition, a

18 Receiving Party must comply with the provisions of section 13 below.

19 Protected Material must be stored and maintained by a Receiving

20 Party at a location and in a secure manner that ensures that access is

21 limited to the persons authorized under this Stipulated Protective

22 Order.

23 7.2 Disclosure of “CONFIDENTIAL” Information or Items.

24 Unless otherwise ordered by the court or permitted in writing by the

25 Designating Party, a Receiving Party may disclose any information or

item designated “CONFIDENTIAL” only:

(a) to the Receiving Party’s Outside Counsel of Record in this

1 Action, as well as employees of said Outside Counsel of Record to whom

2 it is reasonably necessary to disclose the information for this Action;

3 (b) to the officers, directors, and employees (including House

4 Counsel) of the Receiving Party to whom disclosure is reasonably

5 necessary for this Action;

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

7 whom disclosure is reasonably necessary for this Action and who have

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

(d) to the court and its personnel;

(e) to court reporters and their staff;

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

Professional Vendors to whom disclosure is reasonably necessary for

this Action and who have signed the “Acknowledgment and Agreement

to Be Bound” (Exhibit A);

(g) to the author or recipient of a document containing the

information or a custodian or other person who otherwise possessed or

knew the information;

(h) during their depositions, to witnesses, and attorneys for

witnesses, in the Action to whom disclosure is reasonably necessary,

provided: (1) the deposing party requests that the witness sign the

22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

23 witness will not be permitted to keep any confidential information

24 unless they sign the “Acknowledgment and Agreement to Be Bound”

25 (Exhibit A), unless otherwise agreed by the Designating Party or

26 ordered by the court. Pages of transcribed deposition testimony or

27 exhibits to depositions that reveal Protected Material may be separately

1 as permitted under this Stipulated Protective Order; and

2 (i) to any mediator or settlement officer, and their supporting

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

4 settlement discussions.

6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

7 PRODUCED IN OTHER LITIGATION

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

other litigation that compels disclosure of any information or items

designated in this Action as “CONFIDENTIAL,” that Party must:

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

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

(b) promptly notify in writing the party who caused the

subpoena or order to issue in the other litigation that some or all of the

material covered by the subpoena or order is subject to this Protective

Order. Such notification shall include a copy of this Stipulated

18 Protective Order; and

19 (c) cooperate with respect to all reasonable procedures sought to

20 be pursued by the Designating Party whose Protected Material may be

21 affected.

22 If the Designating Party timely seeks a protective order, the

23 Party served with the subpoena or court order shall not produce any

24 information designated in this action as “CONFIDENTIAL” before a

25 determination by the court from which the subpoena or order issued,

26 unless the Party has obtained the Designating Party’s permission. The

Designating Party shall bear the burden and expense of seeking

1 protection in that court of its confidential material and nothing in these

2 provisions should be construed as authorizing or encouraging a

3 Receiving Party in this Action to disobey a lawful directive from another

4 court.

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

7 PRODUCED IN THIS LITIGATION

9.1 Application. The terms of this Stipulated Protective Order

are applicable to information produced by a Non-Party in this Action and

designated as “CONFIDENTIAL.” Such information produced by Non-

Parties in connection with this litigation is protected by the remedies

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

construed as prohibiting a Non-Party from seeking additional

protections.

9.2 Notification. In the event that a Party is required, by a valid

discovery request, to produce a Non-Party’s confidential information in

its possession, and the Party is subject to an agreement with the Non-

Party not to produce the Non-Party’s confidential information, then the

Party shall:

21 (a) promptly notify in writing the Requesting Party and the

22 Non-Party that some or all of the information requested is subject to a

23 confidentiality agreement with a Non-Party;

24 (b) make the information requested available for inspection by

25 the Non-Party, if requested.

26 9.3 Conditions of Production. If the Non-Party fails to seek a

27 protective order from this court within 14 days of receiving the notice

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

2 If the Non-Party timely seeks a protective order, the Receiving Party

3 shall not produce any information in its possession or control that is

4 subject to the confidentiality agreement with the Non-Party before a

5 determination by the court. Absent a court order to the contrary, the

6 Non-Party shall bear the burden and expense of seeking protection in

7 this court of its Protected Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED

MATERIAL

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

has disclosed Protected Material to any person or in any circumstance

not authorized under this Stipulated Protective Order, the Receiving

Party must immediately (a) notify in writing the Designating Party of

the unauthorized disclosures, (b) use its best efforts to retrieve all

17 unauthorized copies of the Protected Material, (c) inform the person or

18 persons to whom unauthorized disclosures were made of all the terms of

19 this Order, and (d) request such person or persons to execute the

20 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that

certain inadvertently produced material is subject to a claim of privilege

or other protection, the obligations of the Receiving Parties are those set

1 provision is not intended to modify whatever procedure may be

2 established in an e-discovery order that provides for production without

3 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

4 Rules of Evidence, insofar as the parties reach an agreement on the

5 effect of disclosure of a communication or information covered by the

6 attorney-client privilege or work product protection, the parties may

7 incorporate their agreement in the stipulated protective order

submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Stipulated

Protective Order abridges the right of any person to seek its

modification by the court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry

of this Stipulated Protective Order no Party waives any right it

17 otherwise would have to object to disclosing or producing any

18 information or item on any ground not addressed in this Stipulated

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

20 ground to use in evidence of any of the material covered by this

21 Stipulated Protective Order.

22 12.3 Filing Protected Material. A Party that seeks to file under

23 seal any Protected Material must comply with Local Rule 79-5.

24 Protected Material may only be filed under seal pursuant to a court

25 order authorizing the sealing of the specific Protected Material at issue.

If a Party's request to file Protected Material under seal is denied by the

court, then the Receiving Party may file the information in the public

1 record unless otherwise instructed by the court.

3 13. FINAL DISPOSITION

After the Final Disposition of this Action, as defined in paragraph

4, within 60 days of a written request by the Designating Party, each

Receiving Party must return all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations,

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

Protected Material. Whether the Protected Material is returned or

destroyed, the Receiving Party must submit a written certification to

the Producing Party (and, if not the same person or entity, to the

Designating Party) by the 60 day deadline that (1) identifies (by

category, where appropriate) all the Protected Material that was

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

retained any copies, abstracts, compilations, summaries or any other

18 format reproducing or capturing any of the Protected Material.

19 Notwithstanding this provision, Counsel is entitled to retain an archival

20 copy of all pleadings, motion papers, trial, deposition, and hearing

21 transcripts, legal memoranda, correspondence, deposition and trial

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

23 expert work product, even if such materials contain Protected Material.

24 Any such archival copies that contain or constitute Protected Material

25 remain subject to this Protective Order as set forth in Section 4.

1 || 14. VIOLATION

2 Any violation of this Stipulated Protective Order may be punished

3 || by any and all appropriate measures including, without limitation,

4 || contempt proceedings and/or monetary sanctions.

6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 DATED: February 24, 2026 /s/ Jay Rahimi

° Attorney(s) for Plaintiff(s)

DATED: February 24, 2026 /s/ Monique Matar

3 Attorney(s) for Defendant(s)

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

ig || DATED: February 25, 2026

19 STEPHANIE S. CHRISTENSEN

50 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

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

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

case of __________ [insert formal name of the case and the

number and initials assigned to it by the court]. I agree to

comply with and to be bound by all the terms of this Stipulated

Protective Order and I understand and acknowledge that failure to so

comply could expose me to sanctions and punishment in the nature of

14 contempt. I solemnly promise that I will not disclose in any manner

15 any information or item that is subject to this Stipulated Protective

16 Order to any person or entity except in strict compliance with the

17 provisions of this Order.

18 I further agree to submit to the jurisdiction of the United States

19 District Court for the Central District of California for the purpose of

20 enforcing the terms of this Stipulated Protective Order, even if such

21 enforcement proceedings occur after termination of this action. I

22 hereby appoint ________________________ [print or type full name]

of _________ [print or type full address and telephone number] as

1 my California agent for service of process in connection with this action

2 or any proceedings related to enforcement of this Stipulated Protective

3 Order.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

Printed name: ___________________________

Signature: ___________________________

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