Opinion

Court: District Court, C.D. California
Filed: Jun 25, 2026
Cited by: 0 cases
Authority: More cited than 41.6%

The opinion

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

4 AMBER MEDINA,

Case No.: 2:26-cv-01338-FLA-SSC

5 Plaintiff,

6 v.

STIPULATED PROTECTIVE

7 DIRECTV, LLC; CREDENCE ORDER1

RESOURCE MANAGEMENT,

8 LLC; AND I.C. SYSTEM, INC.,

9 Defendants.

11 1. INTRODUCTION

12 1.1 Purposes and Limitations. Discovery in this action is likely to

involve production of confidential, proprietary, or private information for

which special protection from public disclosure and from use for any

purpose other than prosecuting this litigation may be warranted.

Accordingly, the parties hereby stipulate to and petition the court to 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 private, confidential, proprietary,

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 and/or commercially-sensitive information for which special protection

2 from public disclosure and from use for any purpose other than prosecution

3 of this action is warranted. Such confidential and proprietary materials

4 and information consist of, among other things, private financial, credit,

5 and personal identifying information, as well as confidential business,

6 financial, and/or contractual information, information regarding

7 confidential business practices, or other confidential research,

development, or commercial information (including information

implicating privacy rights of third parties), information otherwise

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

otherwise protected from disclosure under state or federal statutes, court

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

information, to facilitate the prompt resolution of disputes over

confidentiality of discovery materials, to adequately protect information

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

permitted reasonable necessary uses of such material in preparation for

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

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

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

information will not be designated as confidential for tactical reasons and

22 that nothing be so designated without a good faith belief that it has been

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

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

25 1.3 Acknowledgment of Procedure for Filing Under Seal. The

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

27 Stipulated Protective Order does not entitle them to file confidential

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

2 seeks permission from the court to file material under seal.

3 There is a strong presumption that the public has a right of access to

4 judicial proceedings and records in civil cases. In connection with non-

5 dispositive motions, good cause must be shown to support a filing under

6 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176

7 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d

1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 187

F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require

good cause showing), and a specific showing of good cause or compelling

reasons with proper evidentiary support and legal justification, must be

made with respect to Protected Material that a party seeks to file under

seal. The parties’ mere designation of Disclosure or Discovery Material as

CONFIDENTIAL does not—without the submission of competent

evidence by declaration, establishing that the material sought to be filed

under seal qualifies as confidential, privileged, or otherwise protectable—

constitute good cause.

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

trial, then compelling reasons, not only good cause, for the sealing must be

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

22 specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605

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

24 document, or thing sought to be filed or introduced under seal in

25 connection with a dispositive motion or trial, the party seeking protection

26 must articulate compelling reasons, supported by specific facts and legal

27 justification, for the requested sealing order. Again, competent evidence

1 by declaration.

2 Any document that is not confidential, privileged, or otherwise

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

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

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

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

7 application that seeks to file documents under seal in their entirety

should include an explanation of why redaction is not feasible.

2. DEFINITIONS

2.1 Action: This pending federal lawsuit.

2.2 Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.

2.3 “CONFIDENTIAL” Information or Items: information

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

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

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

19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well

20 as their support staff).

21 2.5 Designating Party: a Party or Non-Party that designates

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

23 discovery as “CONFIDENTIAL.”

24 2.6 Disclosure or Discovery Material: all items or information,

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

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

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

1 to discovery in this matter.

2 2.7 Expert: a person with specialized knowledge or experience in a

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

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

5 2.8 Final Disposition: the later of (1) dismissal of all claims and

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

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

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

filing any motions or applications for extension of time pursuant to

applicable law.

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

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

or any other outside counsel.

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

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

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

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

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

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

includes support staff.

22 2.12 Party: any party to this Action, including all of its officers,

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

24 Record (and their support staffs).

25 2.13 Producing Party: a Party or Non-Party that produces Disclosure

26 or Discovery Material in this Action.

27 2.14 Professional Vendors: persons or entities that provide litigation-

1 exhibits or demonstrations, and organizing, storing, or retrieving data in

2 any form or medium) and their employees and subcontractors.

3 2.15 Protected Material: any Disclosure or Discovery Material that is

4 designated as “CONFIDENTIAL.”

5 2.16 Receiving Party: a Party that receives Disclosure or Discovery

6 Material from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not

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

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

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

conversations, or presentations by Parties or their Counsel that might

reveal Protected Material.

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

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

18 the use of Protected Material at trial.

20 4. TRIAL AND DURATION

21 The terms of this Stipulated Protective Order apply through Final

22 Disposition of the Action.

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

CONFIDENTIAL or maintained pursuant to this Stipulated Protective

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

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

1 proceed otherwise are made to the trial judge in advance of the trial. See

2 Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for

3 sealing documents produced in discovery from “compelling reasons”

4 standard when merits-related documents are part of court record).

5 Accordingly, for such materials, the terms of this Stipulated Protective

6 Order do not extend beyond the commencement of the trial.

7 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.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for

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

18 standards. The Designating Party must designate for protection only those

19 parts of material, documents, items, or oral or written communications

20 that qualify so that other portions of the material, documents, items, or

21 communications for which protection is not warranted are not swept

22 unjustifiably within the ambit of this Order.

23 Mass, indiscriminate, or routinized designations are prohibited.

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

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

26 development process or to impose unnecessary expenses and burdens on

other parties) may expose the Designating Party to sanctions.

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

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

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

4 withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise

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

requires:

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

documents, but excluding transcripts of depositions or other pretrial or

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

17 legend “CONFIDENTIAL” to each page that contains protected material.

18 If only a portion or portions of the material on a page qualifies for

19 protection, the Producing Party also must clearly identify the protected

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

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

22 inspection need not designate them for protection until after the

23 inspecting Party has indicated which documents it would like copied and

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

25 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

1 portions thereof, qualify for protection under this Stipulated Protective

2 Order. Then, before producing the specified documents, the Producing

3 Party must affix the “CONFIDENTIAL” legend to each page that contains

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

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

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

7 margins).

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

identify the Disclosure or Discovery Material either on the record, or

within 30 days of the Designating Party’s receipt of the certified transcript

of the deposition from the court reporter preparing the transcript.

and for any other tangible items, that the Producing Party affix in a

prominent place on the exterior of the container or containers in which the

information is stored the “CONFIDENTIAL” legend. If only a portion or

portions of the information warrants protection, the Producing Party, to

the extent practicable, shall identify the protected portion(s).

19 5.3 Inadvertent Failures to Designate. If timely corrected, an

20 inadvertent failure to designate qualified information or items does not,

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

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

23 designation, the Receiving Party must make reasonable efforts to assure

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

25 Stipulated Protective Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

1 6.1 Timing of Challenges. Any Party or Non-Party may challenge

2 a designation of confidentiality at any time that is consistent with the

3 court’s Scheduling Order.

4 6.2 Meet and Confer. The Challenging Party shall initiate the

5 dispute resolution process under Local Rule 37.1 et seq. and with Section 2

6 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion

7 Conference.”2

6.3 The burden of persuasion in any such challenge proceeding

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

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

and burdens on other parties) may expose the Challenging Party to

sanctions. Unless the Designating Party has waived or withdrawn the

confidentiality designation, all parties shall continue to afford the

material in question the level of protection to which it is entitled under the

Producing Party’s designation until the court rules on the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

19 7.1 Basic Principles. A Receiving Party may use Protected

20 Material that is disclosed or produced by another Party or by a Non-Party

21 in connection with this Action only for prosecuting, defending, or

22 attempting to settle this Action. Such Protected Material may be

23 disclosed only to the categories of persons and under the conditions

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

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

2 Judge Christensen’s Procedures are available at

1 Protected Material must be stored and maintained by a Receiving

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

3 limited to the persons authorized under this Stipulated Protective Order.

4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

5 otherwise ordered by the court or permitted in writing by the Designating

6 Party, a Receiving Party may disclose any information or item designated

7 “CONFIDENTIAL” only:

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

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

is reasonably necessary to disclose the information for this Action;

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

Counsel) of the Receiving Party to whom disclosure is reasonably

necessary for this Action;

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

22 Action and who have signed the “Acknowledgment and Agreement to Be

23 Bound” (Exhibit A);

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

25 information or a custodian or other person who otherwise possessed or

26 knew the information;

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

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

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

3 witness will not be permitted to keep any confidential information unless

4 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),

5 unless otherwise agreed by the Designating Party or ordered by the court.

6 Pages of transcribed deposition testimony or exhibits to depositions that

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

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

Stipulated Protective Order; and

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

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

settlement discussions.

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

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:

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

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

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

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

24 covered by the subpoena or order is subject to this Protective Order. Such

25 notification shall include a copy of this Stipulated Protective Order; and

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

be pursued by the Designating Party whose Protected Material may be

1 affected.

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

3 served with the subpoena or court order shall not produce any information

4 designated in this action as “CONFIDENTIAL” before a determination by

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

6 obtained the Designating Party’s permission. The Designating Party shall

7 bear the burden and expense of seeking protection in that court of its

confidential material and nothing in these provisions should be construed

as authorizing or encouraging a Receiving Party in this Action to disobey a

lawful directive from another court.

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

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.

21 9.2 Notification. In the event that a Party is required, by a valid

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

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

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

25 shall:

26 (a) promptly notify in writing the Requesting Party and the Non-

27 Party that some or all of the information requested is subject to a

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

2 Non-Party, if requested.

3 9.3 Conditions of Production. If the Non-Party fails to seek a

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

5 accompanying information, the Receiving Party may produce the Non-

6 Party’s confidential information responsive to the discovery request. If the

7 Non-Party timely seeks a protective order, the Receiving Party shall not

produce any information in its possession or control that is subject to the

confidentiality agreement with the Non-Party before a determination by

the court. Absent a court order to the contrary, the Non-Party shall bear

the burden and expense of seeking protection in this court of its Protected

Material.

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

17 disclosed Protected Material to any person or in any circumstance not

18 authorized under this Stipulated Protective Order, the Receiving Party

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

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

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

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

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

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

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

1 When a Producing Party gives notice to Receiving Parties that

2 certain inadvertently produced material is subject to a claim of privilege

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

4 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

5 provision is not intended to modify whatever procedure may be

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

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

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

of disclosure of a communication or information covered by the attorney-

client privilege or work product protection, the parties may 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

17 court in the future.

18 12.2 Right to Assert Other Objections. By stipulating to the entry

19 of this Stipulated Protective Order no Party waives any right it otherwise

20 would have to object to disclosing or producing any information or item on

21 any ground not addressed in this Stipulated Protective Order. Similarly,

22 no Party waives any right to object on any ground to use in evidence of

23 any of the material covered by this Stipulated Protective Order.

24 12.3 Filing Protected Material. A Party that seeks to file under seal

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

Material may only be filed under seal pursuant to a court order

authorizing the sealing of the specific Protected Material at issue. If a

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

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

3 record unless otherwise instructed by the court.

5 13. FINAL DISPOSITION

6 Within 60 days of the Final Disposition of this Action, as defined in

7 paragraph 4, 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 format reproducing or

capturing any of the Protected Material. Notwithstanding this provision,

Counsel is entitled to retain an archival copy of all pleadings, motion

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

22 correspondence, deposition and trial exhibits, expert reports, attorney

23 work product, and consultant and expert work product, even if such

24 materials contain Protected Material. Any such archival copies that

25 contain or constitute Protected Material remain subject to this Protective

26 Order as set forth in Section 4.

27 14. VIOLATION

1 by any and all appropriate measures including, without limitation,

2 contempt proceedings and/or monetary sanctions.

3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Date: June 25, 2026 LOKER LAW, APC

BY: ___/S/ SHELBY J. RADECKI _

SHELBY J. RADECKI, ESQ.

7 ATTORNEY FOR PLAINTIFF

FAEGRE DRINKER BIDDLE & REATH LLP

10 By: _____/s/Kaylee A. Racs _

KAYLEE A. RACS, ESQ.

COUNSEL FOR DIRECTV, LLC

SESSIONS, ISRAEL AND SHARTLE, LLP

14 By: _____/s/ Kenneth Akira Ohashi _

15 KENNETH AKIRA OHASHI, ESQ.

COUNSEL FOR DEFENDANT

CREDENCE RESOURCE MANAGEMENT, LLC

YU MOHANDESI LLP

19 By: _____/s/ Brett B. Goodman _

BRETT B. GOODMAN, ESQ.

COUNSEL FOR DEFENDANT I.C. SYSTEM, INC.

SIGNATURE CERTIFICATION

Pursuant to Section 2(f)(44) of the Electronic Case Filing

24 Administrative Policies and Procedures Manual, I hereby certify that the

content of this document is acceptable to all defense counsel, and that I

have obtained their authorization to affix electronic signatures to this

26 document.

/s/ Kenneth Ohashi

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

2 LZ

3 DATED: June 25, 2026

4 STEPHANIE 8. CHRISTENSEN

5 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 __________

Amber Medina v. DirecTV, LLC, et al., United States District

Court for the Central District of California, Case No. 2:26-cv-

01338. 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

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

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

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

17 the 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 hereby

22 appoint ________________________ [print or type full name] of

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

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

or any proceedings related to enforcement of this Stipulated Protective

Order.

1 Date: ___________________________

2 City and State where sworn and

___________________________

3 signed:

4 Printed name: ___________________________

5 Signature: ___________________________

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