The opinion
1 Patricia T. Stambelos (SBN 166998)
Stambelos Law Office
2 543 Country Club Dr., Ste B209
Simi Valley, CA 93065
3 Telephone: (805) 578-3474
Fax: (805) 994-1099
4 patricia@patriciastambelos.com
5 Gregory M. Saylin (SBN 185328)
Adam Bouka (SBN 322388)
6 HOLLAND & HART LLP
222 South Main Street, Suite 2200
7 Salt Lake City, UT 84101
Telephone: (801) 799-5800
8 gmsaylin@hollandhart.com
abouka@hollandhart.com
9
Attorneys for Defendant SkyWest Airlines, Inc.
10
RISE LAW FIRM, PC
11 ELIOT J. RUSHOVICH (SBN 252343)
LISA M. WATANABE-PEAGLER (SBN 258182)
12 ELISSA A. WAIZMAN (SBN 329959)
8383 Wilshire Blvd., Suite 800
13 Beverly Hills, California 90211
Telephone: 310-728-6588
14 Facsimile: 310-728-6560
eliot@riselawfirm.com
15 lisa@riselawfirm.com
elissa@riselawfirm.com
16
Attorneys for Plaintiff Raymond Wright
17
IN THE UNITED STATES DISTRICT COURT
18
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
19
20 RAYMOND WRIGHT, an individual; Case No. 2:25-cv-11466-SSC
21 Plaintiff, [Assigned for all Purposes to the Hon.
Stephanie S. Christensen, Courtroom
22
vs. 790]
23
SKYWEST AIRLINES, INC.; a Utah STIPULATED (PROPOSED)
24 Corporation and DOES 1 through 50, PROTECTIVE ORDER1
inclusive,
25
26
27 1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of
Defendants. Complaint Filed: October 23, 2025
1
Removal Date: December 1, 2025
2 Trial Date: October 19, 2027
3 1. INTRODUCTION
4 1.1 Purposes and Limitations. Discovery in this action is likely to involve
5 production of confidential, proprietary, or private information for which special
6 protection from public disclosure and from use for any purpose other than
7 prosecuting this litigation may be warranted. Accordingly, the parties hereby
8 stipulate to and petition the court to enter the following Stipulated Protective Order.
9 The parties acknowledge that this Order does not confer blanket protections on all
10 disclosures or responses to discovery and that the protection it affords from public
11 disclosure and use extends only to the limited information or items that are entitled
12 to confidential treatment under the applicable legal principles.
13 1.2 Good Cause Statement: This action is likely to involve confidential
14 medical information, protected health information (“PHI”), personnel records,
15 payroll and compensation information, attendance and reliability records,
16 accommodation and interactive-process communications, internal operational
17 procedures, proprietary business information, and other private or commercially
18 sensitive information for which special protection from public disclosure and from
19 use for any purpose other than prosecution or defense of this action is warranted.
20 Such confidential materials and information include, among other things: medical
21 records and information relating to Plaintiff’s alleged disabilities and emotional
22 distress, treatment, accommodations, and/or health conditions related thereto;
23 personnel and employment records; attendance, scheduling, and operational
24 reliability records; internal communications regarding employment decisions;
25 confidential business practices and procedures; non-public financial or operational
26 information; and information implicating the privacy rights of current or former
27 employees and third parties. Such information may be protected from disclosure by
1 federal or state privacy laws, including HIPAA, the California Confidentiality of
2 Medical Information Act (“CMIA”), California constitutional privacy protections,
3 federal and state employment laws, court rules, case decisions, or common law.
4 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
5 of disputes over confidentiality of discovery materials, to adequately protect
6 information the parties are entitled to keep confidential, to ensure that the parties are
7 permitted reasonable necessary uses of such material in preparation for and in the
8 conduct of trial, to address their handling at the end of the litigation, and serve the
9 ends of justice, a protective order for such information is justified in this matter. It
10 is the intent of the parties that information will not be designated as confidential for
11 tactical reasons and that nothing be so designated without a good faith belief that it
12 has been maintained in a confidential, non-public manner, and there is good cause
13 why it should not be part of the public record of this case.
14 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
15 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
16 Protective Order does not entitle them to file confidential information under seal;
17 Local Rule 79-5 sets forth the procedures that must be followed and the standards
18 that will be applied when a party seeks permission from the court to file material
19 under seal.
20 There is a strong presumption that the public has a right of access to judicial
21 proceedings and records in civil cases. In connection with non-dispositive motions,
22 good cause must be shown to support a filing under seal. See Kamakana v. City
23 and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
24 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-
25 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
26 protective orders require good cause showing), and a specific showing of good
27 cause or compelling reasons with proper evidentiary support and legal justification,
1 must be made with respect to Protected Material that a party seeks to file under
2 seal. The parties’ mere designation of Disclosure or Discovery Material as
3 CONFIDENTIAL does not—without the submission of competent evidence by
4 declaration, establishing that the material sought to be filed under seal qualifies as
5 confidential, privileged, or otherwise protectable—constitute good cause.
6 Further, if a party requests sealing related to a dispositive motion or trial,
7 then compelling reasons, not only good cause, for the sealing must be shown, and
8 the relief sought shall be narrowly tailored to serve the specific interest to be
9 protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.
10 2010). For each item or type of information, document, or thing sought to be filed
11 or introduced under seal in connection with a dispositive motion or trial, the party
12 seeking protection must articulate compelling reasons, supported by specific facts
13 and legal justification, for the requested sealing order. Again, competent evidence
14 supporting the application to file documents under seal must be provided by
15 declaration.
16 Any document that is not confidential, privileged, or otherwise protectable in
17 its entirety will not be filed under seal if the confidential portions can be redacted.
18 If documents can be redacted, then a redacted version for public viewing, omitting
19 only the confidential, privileged, or otherwise protectable portions of the document,
20 shall be filed. Any application that seeks to file documents under seal in their
21 entirety should include an explanation of why redaction is not feasible.
22 2. DEFINITIONS
23 2.1 Action: this action captioned Raymond Wright v. SkyWest Airlines,
24 Inc., Case No. 2:25-cv-11466-SSC, pending in the United States District Court for
25 the Central District of California, Western Division, including any subsequent
26 related proceedings.
27
2.2 “Court” means the Hon. Stephanie S. Christensen, or any other judge or
1 magistrate to which this Action may be assigned, including Court staff participating
2 in such proceedings.
3 2.3 Challenging Party: a Party or Non-Party that challenges the designation
4 of information or items under this Order.
5 2.4 “CONFIDENTIAL” Information or Items: information (regardless of
6 how it is generated, stored or maintained) or tangible things that qualify for
7 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified
8 above in the Good Cause Statement.
9 2.5 Counsel: Outside Counsel of Record and In-House Counsel (as well as
10 their support staff).
11 2.6 Designating Party: a Party or Non-Party that designates information or
12 items that it produces in disclosures or in responses to discovery as
13 “CONFIDENTIAL.”
14 2.7 Disclosure or Discovery Material: all items or information, regardless
15 of the medium or manner in which it is generated, stored, or maintained (including,
16 among other things, documents, testimony, transcripts, and tangible things), that are
17 produced or generated in disclosures or responses to discovery in this matter.
18 2.8 Expert: a person with specialized knowledge or experience in a matter
19 pertinent to the litigation who has been retained by a Party or its counsel to serve as
20 an expert witness or as a consultant in this Action.
21 2.9 Final Disposition: the later of (1) dismissal of all claims and defenses
22 in this Action, with or without prejudice; and (2) final judgment herein after the
23 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
24 this Action, including the time limits for filing any motions or applications for
25 extension of time pursuant to applicable law.
26 2.10 In-House Counsel: attorneys who are employees of a party to this
27 Action. In-House Counsel does not include Outside Counsel of Record or any other
1 outside counsel.
2 2.11 Non-Party: any natural person, partnership, corporation, association, or
3 other legal entity not named as a Party to this action.
4 2.12 Outside Counsel of Record: attorneys who are not employees of a party
5 to this Action but are retained to represent or advise a party to this Action and have
6 appeared in this Action on behalf of that party or are affiliated with a law firm which
7 has appeared on behalf of that party, and includes support staff.
8 2.13 Party: any party to this Action, including all of its officers, directors,
9 employees, consultants, retained experts, and Outside Counsel of Record (and their
10 support staffs).
11 2.14 Producing Party: a Party or Non-Party that produces Disclosure or
12 Discovery Material in this Action.
13 2.15 Professional Vendors: persons or entities that provide litigation-
14 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
15 demonstrations, and organizing, storing, or retrieving data in any form or medium)
16 and their employees and subcontractors.
17 2.16 Protected Material: any Disclosure or Discovery Material that is
18 designated as “CONFIDENTIAL.”
19 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material
20 from a Producing Party.
21 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only
23 Protected Material (as defined above), but also (1) any information copied or
24 extracted from Protected Material; (2) all copies, excerpts, summaries, or
25 compilations of Protected Material; and (3) any testimony, conversations, or
26 presentations by Parties or their Counsel that might reveal Protected Material.
27
1 Any use of Protected Material at trial shall be governed by the orders of the
2 trial judge. This Stipulated Protective Order does not govern the use of Protected
3 Material at trial.
4 4. TRIAL AND DURATION
5 The terms of this Stipulated Protective Order apply through Final Disposition
6 of the Action.
7
Once a case proceeds to trial, information that was designated as
8
CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
9
used or introduced as an exhibit at trial becomes public and will be presumptively
10
available to all members of the public, including the press, unless compelling
11
reasons supported by specific factual findings to proceed otherwise are made to the
12
trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
13
(distinguishing “good cause” showing for sealing documents produced in discovery
14
from “compelling reasons” standard when merits-related documents are part of
15
court record). Accordingly, for such materials, the terms of this Stipulated
16
Protective Order do not extend beyond the commencement of the trial.
17
Even after Final Disposition of this litigation, the confidentiality obligations
18
imposed by this Stipulated Protective Order shall remain in effect until a
19
Designating Party agrees otherwise in writing or a court order otherwise directs.
20
5. DESIGNATING PROTECTED MATERIAL
21
5.1 Exercise of Restraint and Care in Designating Material for Protection.
22
Each Party or Non-Party that designates information or items for protection under
23
this Order must take care to limit any such designation to specific material that
24
qualifies under the appropriate standards. The Designating Party must designate for
25
protection only those parts of material, documents, items, or oral or written
26
communications that qualify so that other portions of the material, documents,
27
1 unjustifiably within the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited. Designations
3 that are shown to be clearly unjustified or that have been made for an improper
4 purpose (e.g., to unnecessarily encumber the case development process or to
5 impose unnecessary expenses and burdens on other parties) may expose the
6 Designating Party to sanctions.
7 If it comes to a Designating Party’s attention that information or items that it
8 designated for protection do not qualify for protection, that Designating Party must
9 promptly notify all other Parties that it is withdrawing the inapplicable designation.
10 5.2 Manner and Timing of Designations. Except as otherwise provided in
11 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
12 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
13 qualifies for protection under this Stipulated Protective Order must be clearly so
14 designated before the material is disclosed or produced.
15 Designation in conformity with this Stipulated Protective Order requires:
16 (a) for information in documentary form (e.g., paper or electronic
17 documents, but excluding transcripts of depositions or other pretrial or trial
18 proceedings), that the Producing Party affix at a minimum, the legend
19 “CONFIDENTIAL” to each page that contains protected material. If only a portion
20 or portions of the material on a page qualifies for protection, the Producing Party
21 also must clearly identify the protected portion(s) (e.g., by making appropriate
22 markings in the margins).
23 A Party or Non-Party that makes original documents available for inspection
24 need not designate them for protection until after the inspecting Party has indicated
25 which documents it would like copied and produced. During the inspection and
26 before the designation, all of the material made available for inspection shall be
27 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
1 it wants copied and produced, the Producing Party must determine which
2 documents, or portions thereof, qualify for protection under this Stipulated
3 Protective Order. Then, before producing the specified documents, the Producing
4 Party must affix the “CONFIDENTIAL” legend to each page that contains
5 Protected Material. If only a portion or portions of the material on a page qualifies
6 for protection, the Producing Party also must clearly identify the protected
7 portion(s) (e.g., by making appropriate markings in the margins).
8 a. (b) for testimony given in depositions that the Designating
9 Party identify the Disclosure or Discovery Material on the record, before the close
10 of the deposition all protected testimony or designate the entirety of the testimony at
11 the deposition as “CONFIDENTIAL” (before the deposition is concluded) with the
12
right to identify more specific portions of the testimony as to which protection is
13
sought within 30 days following receipt of the deposition transcript. In
14
circumstances where portions of the deposition Testimony are designated for
15
protection, the transcript pages containing “CONFIDENTIAL” Information may be
16
17 separately bound by the court reporter, who must affix to the top of each page the
18 legend “CONFIDENTIAL,” as instructed by the Designating Party.
19
(c) for information produced in some form other than documentary and
20
for any other tangible items, that the Producing Party affix in a prominent place on
21
the exterior of the container or containers in which the information is stored the
22
“CONFIDENTIAL” legend. If only a portion or portions of the information
23
warrants protection, the Producing Party, to the extent practicable, shall identify the
24
protected portion(s).
25 2. Inadvertent Failures to Designate. The inadvertent production by any
26
of the undersigned Parties or non-Parties of any Discovery Material during discovery
27
in this Action without a “CONFIDENTIAL” designation, shall be without prejudice
to any claim that such item is “CONFIDENTIAL” and such Party shall not be held
1
2 to have waived any rights by such inadvertent production. In the event that any
3 Document, Testimony, or Information that is subject to a “CONFIDENTIAL”
4 designation is inadvertently produced without such designation, the Party that
5
inadvertently produced the document shall give written notice of such inadvertent
6
production within twenty (20) days of discovery of the inadvertent production,
7
together with a further copy of the subject information designated as
8
“CONFIDENTIAL” (the “Inadvertent Production Notice”). Upon receipt of such
9
10 Inadvertent Production Notice, the Party that received the inadvertently produced
11 Document, Testimony, or Information shall promptly destroy the inadvertently
12 produced Document, Testimony, or Information and all copies thereof, or, at the
13
expense of the producing Party, return such together with all copies of such
14
Document, Testimony or Information to counsel for the producing Party and shall
15
retain only the “Confidential” materials. Should the receiving Party choose to destroy
16
such inadvertently produced Document, Testimony, or Information, the receiving
17
18 Party shall notify the producing Party in writing of such destruction within ten (10)
19 days of receipt of written notice of the inadvertent production. This provision is not
20 intended to apply to any inadvertent production of any Document, Testimony, or
21
Information protected by attorney-client or work product privileges. In the event that
22
this provision conflicts with any applicable law regarding waiver of confidentiality
23
through the inadvertent production of Documents, Testimony or Information, such
24
law shall govern.
25
26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
27
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
1 designation of confidentiality at any time that is consistent with the court’s
2 Scheduling Order.
3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
4 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
5 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2
6 6.3 The burden of persuasion in any such challenge proceeding shall be on
7 the Designating Party. Frivolous challenges, and those made for an improper
8 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
9 parties) may expose the Challenging Party to sanctions. Unless the Designating
10 Party has waived or withdrawn the confidentiality designation, all parties shall
11 continue to afford the material in question the level of protection to which it is
12 entitled under the Producing Party’s designation until the court rules on the
13 challenge.
14 7. ACCESS TO AND USE OF PROTECTED MATERIAL
15 7.1 Basic Principles. A Receiving Party may use Protected Material that
16 is disclosed or produced by another Party or by a Non-Party in connection with this
17 Action only for prosecuting, defending, or attempting to settle this Action. Such
18 Protected Material may be disclosed only to the categories of persons and under the
19 conditions described in this Order. When the Action reaches a Final Disposition, a
20 Receiving Party must comply with the provisions of section 13 below.
21 Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons
23 authorized under this Stipulated Protective Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
25 otherwise ordered by the court or permitted in writing by the Designating Party, a
26
27
2 Judge Christensen’s Procedures are available at
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only:
3 (a) Counsel of record in the Action and their affiliated attorneys,
4 paralegals, clerical and secretarial staff employed by such attorneys who are
5 actively involved in the Action and are not employees of any Party;
6 (b) to the Receiving Party’s Outside Counsel of Record in this Action, as
7 well as employees of said Outside Counsel of Record to whom it is reasonably
8 necessary to disclose the information for this Action. Provided, however, that each
9 non-lawyer given access to Confidential Materials shall be advised that such
10 materials are being Disclosed pursuant to, and are subject to, the terms of this
11 Stipulated Protective Order and that they may not be Disclosed other than pursuant
12 to its terms;;
13 (c) to the officers, directors, and employees (including In-House Counsel)
14 of the Receiving Party to whom disclosure is reasonably necessary for this Action
15 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
16 A);
17 (d) to 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);
20 (e) to the court and its personnel;
21 (f) to court reporters and their staff;
22 (g) to professional jury or trial consultants, mock jurors, and Professional
23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (h) to the author or recipient of a document containing the information or
26 a custodian or other person who otherwise possessed or knew the information;
27 (i) during their depositions, to witnesses, and attorneys for witnesses, in
1 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
2 party requests that the witness sign the “Acknowledgment and Agreement to Be
3 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
4 confidential information unless they sign the “Acknowledgment and Agreement to
5 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
6 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
8 reporter and may not be disclosed to anyone except as permitted under this
9 Stipulated Protective Order; and
10 (j) to any mediator or settlement officer, and their supporting personnel,
11 mutually agreed upon by any of the parties engaged in settlement discussions.
12 (k) mock jury participants and who have signed the “Acknowledgment
13 and Agreement to Be Bound” (Exhibit A);
14 (l) any other person or entity that the Designating Party agrees to in
15 writing.
16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
17 PRODUCED IN OTHER LITIGATION
18 If a Party is served with a subpoena or a court order issued in other litigation
19 that compels disclosure of any information or items designated in this Action as
20 “CONFIDENTIAL,” that Party must:
21
(a) promptly notify in writing the Designating Party. Such notification
22
shall include a copy of the subpoena or court order;
23
(b) promptly notify in writing the party who caused the subpoena or order
24
to issue in the other litigation that some or all of the material covered by the
25
subpoena or order is subject to this Protective Order. Such notification shall include
26
a copy of this Stipulated Protective Order; and
27
(c) cooperate with respect to all reasonable procedures sought to be
1 pursued by the Designating Party whose Protected Material may be affected.
2 If the Designating Party timely seeks a protective order, the Party served
3 with the subpoena or court order shall not produce any information designated in
4 this action as “CONFIDENTIAL” before a determination by the court from which
5 the subpoena or order issued, unless the Party has obtained the Designating Party’s
6 permission. The Designating Party shall bear the burden and expense of seeking
7 protection in that court of its confidential material and nothing in these provisions
8 should be construed as authorizing or encouraging a Receiving Party in this Action
9 to disobey a lawful directive from another court.
10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
11 PRODUCED IN THIS LITIGATION
12 9.1 Application. The terms of this Stipulated Protective Order are
13 applicable to information produced by a Non-Party in this Action and designated as
14 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
15 this litigation is protected by the remedies and relief provided by this Order.
16 Nothing in these provisions should be construed as prohibiting a Non-Party from
17 seeking additional protections.
18 9.2 Notification. In the event that a Party is required, by a valid discovery
19 request, to produce a Non-Party’s confidential information in its possession, and the
20 Party is subject to an agreement with the Non-Party not to produce the Non-
21 Party’s confidential information, then the Party shall:
22 (a) promptly notify in writing the Requesting Party and the Non-Party
23 that some or all of the information requested is subject to a confidentiality
24 agreement with a Non-Party;
25 (b) make the information requested available for inspection by the Non-
26 Party, if requested.
27 9.3 Conditions of Production. If the Non-Party fails to seek a protective
1 order from this court within 14 days of receiving the notice and accompanying
2 information, the Receiving Party may produce the Non-Party’s confidential
3 information responsive to the discovery request. If the Non-Party timely seeks a
4 protective order, the Receiving Party shall not produce any information in its
5 possession or control that is subject to the confidentiality agreement with the Non-
6 Party before a determination by the court. Absent a court order to the contrary, the
7 Non-Party shall bear the burden and expense of seeking protection in this court of its
8 Protected Material.
9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
10 If a Receiving Party learns that, by inadvertence or otherwise, it has
11 disclosed Protected Material to any person or in any circumstance not authorized
12 under this Stipulated Protective Order, the Receiving Party must immediately (a)
13 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
14 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
15 the person or persons to whom unauthorized disclosures were made of all the terms
16 of this Order, and (d) request such person or persons to execute the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
18
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
19
PROTECTED MATERIAL
20
When a Producing Party gives notice to Receiving Parties that certain
21
inadvertently produced material is subject to a claim of privilege or other
22
protection, the obligations of the Receiving Parties are those set forth in Rule
23
26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
24
to modify whatever procedure may be established in an e-discovery order that
25
provides for production without prior privilege review. Pursuant to Rules 502(d)
26
and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
27
1 attorney-client privilege or work product protection, the parties may incorporate
2 their agreement in the stipulated protective order submitted to the court.
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
5 abridges the right of any person to seek its modification by the court in the future.
6
12.2 Right to Assert Other Objections. The entry of this Stipulated
7
Protective Order does not alter, waive, modify, or abridge any right, privilege, or
8
protection otherwise available to any Party with respect to the discovery of matters,
9
including but not limited to any Party’s right to assert the attorney-client privilege,
10
the attorney work product doctrine, or other privileges, or any Party’s right to
11
contest any such assertion. Similarly, no Party waives any right to object on any
12
ground to use in evidence of any of the material covered by this Stipulated
13
Protective Order.
14
12.3 Filing Protected Material. A Party that seeks to file under seal any
15
Protected Material must comply with Local Rule 79-5. Protected Material may
16
only be filed under seal pursuant to a court order authorizing the sealing of the
17
specific Protected Material at issue. If a Party's request to file Protected Material
18
under seal is denied by the court, then the Receiving Party may file the information
19
in the public record unless otherwise instructed by the court.
20
12.4 After this Stipulated Protective Order has been signed by counsel for
21
all Parties, it shall be presented to the Court for entry. Counsel agree to be bound
22
by the terms set forth herein with regard to any Protected Materials that have been
23
produced before the Court signs this Stipulated Protective Order. The Parties and
24
all signatories to the Certification attached hereto as Exhibit A agree to be bound
25
by this Stipulated Protective Order pending its approval and entry by the Court. In
26
the event that the Court modifies this Stipulated Protective Order, or in the event
27
that the Court enters a different Protective Order, the Parties agree to be bound by
1 this Stipulated Protective Order until such time as the Court may enter such a
2 different Order. It is the Parties’ intent to be bound by the terms of this Stipulated
3 Protective Order pending its entry so as to allow for immediate production of
4 Protected Materials under the terms herein.
5 12.5 This Stipulation and Protective Order may be executed in
6 counterparts.
7 13. FINAL DISPOSITION
8 After the Final Disposition of this Action, as defined in paragraph 4, within
9 60 days of a written request by the Designating Party, each Receiving Party must
10 return all Protected Material to the Producing Party or destroy such material. As
11 used in this subdivision, “all Protected Material” includes all copies, abstracts,
12 compilations, summaries, and any other format reproducing or capturing any of the
13 Protected Material. Whether the Protected Material is returned or destroyed, the
14 Receiving Party must submit a written certification to the Producing Party (and, if
15 not the same person or entity, to the Designating Party) by the 60 day deadline that
16 (1) identifies (by category, where appropriate) all the Protected Material that was
17 returned or destroyed and (2) affirms that the Receiving Party has not retained any
18 copies, abstracts, compilations, summaries or any other format reproducing or
19 capturing any of the Protected Material. Notwithstanding this provision, Counsel is
20 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
21 and hearing transcripts, legal memoranda, correspondence, deposition and trial
22 exhibits, expert reports, attorney work product, and consultant and expert work
23 product, even if such materials contain Protected Material. Any such archival
24 copies that contain or constitute Protected Material remain subject to this Protective
25 Order as set forth in Section 4.
26 14. VIOLATION
27 Any violation of this Stipulated Protective Order may be punished by any
1 || and all appropriate measures including, without limitation, contempt proceedings
2 || and/or monetary sanctions.
3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4 || Dated: June 4, 2026 HOLLAND & HART LLP
5
6 By: /s/ Adam Bouka
Gregory M. Saylin
7 Adam Bouka
8 STAMBELOS LAW FIRM
9 Patricia T. Stambelos
10 Attorneys for Defendant SkyWest Airlines,
1 Inc.
12 Dated: June 4, 2026 RISE LAW FIRM, PC
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14 By: /s/ Elissa A. Waizman (with permission)
Eliot J. Rushovich
15 Lisa M. Watanabe-Peagler
16 Elissa A. Waizman
17 Attorneys for Plaintiff Raymond Wright
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19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
20 LZ
DATED: June 4, 2026
STEPHANIE S. CHRISTENSEN
United States Magistrate Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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3 I, _________________________ ______ [print or type full name], of
4 [print or type full address], declare under penalty of perjury that I have read in
5 its entirety and understand the Stipulated Protective Order that was issued by the
6 United States District Court for the Central District of California in the case of
7 Raymond Wright v. SkyWest Airlines, Inc., Case No. 2:25-cv-11466-SSC. I
8 agree to comply with and to be bound by all the terms of this Stipulated
9 Protective Order and I understand and acknowledge that failure to so comply
10 could expose me to sanctions and punishment in the nature of contempt. I
11 solemnly promise that I will not disclose in any manner any information or item
12 that is subject to this Stipulated Protective Order to any person or entity except in
13 strict compliance with the provisions of this Order. I further agree that any
14 Protected Material, including any Protected Health Information (“PHI”), medical
15 records, personnel records, operational information, or proprietary business
16 information disclosed to me shall be used solely for purposes of this litigation and
17 for no other purpose.
18 I further agree to submit to the jurisdiction of the United States District
19 Court for the Central District of California for the purpose of enforcing the terms
20 of this Stipulated Protective Order, even if such enforcement proceedings occur
21 after termination of this action. I hereby appoint
22 _______________________________________ [print or type full name] of
23 ___________________________________ [print or type full address and
24 telephone number] as
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my California agent for service of process in connection with this action or any
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proceedings related to enforcement of this Stipulated Protective Order.
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6 Date: ___________________________
7 City and State where sworn and signed:
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9 Printed Name: __________________________________
10 Signature: _____________________________________
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