# Opinion

> District Court, C.D. California · July 7, 2026

URL: https://www.frixlaw.com/law-library/cases/11386514

## Case

- **Full name:** VYACHESLAV FINOGEYEV, et. al. v. MERCEDES-BENZ FINANCIAL SERVICES USA, LLC et al.
- **Court:** District Court, C.D. California
- **Decided:** July 7, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1
UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3

4
VYACHESLAV FINOGEYEV, Case No. 2:26-cv-02999-WLH-
5
et. al., DMK
6 Plaintiff(s),
7 v.
STIPULATED PROTECTIVE
8 MERCEDES-BENZ FINANCIAL ORDER1

9 SERVICES USA, LLC et al.,

10 Defendant(s).

11
12
1. INTRODUCTION
13
1.1 Purposes and Limitations. Discovery in this action is likely to
14
involve production of confidential, proprietary, or private information for
15
which special protection from public disclosure and from use for any
16
purpose other than prosecuting this litigation may be warranted.
17
Accordingly, the parties hereby stipulate to and petition the court to
18
19 enter the following Stipulated Protective Order. The parties
20 acknowledge that this Order does not confer blanket protections on all
21 disclosures or responses to discovery and that the protection it affords
22 from public disclosure and use extends only to the limited information or
23 items that are entitled to confidential treatment under the applicable
24 legal principles.
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Diana M. Kwok’s
1 1.2 Good Cause Statement. This action is likely to involve
2 documents related to an ongoing criminal investigation by Non-Party
3 State of California, acting by and through California Highway Patrol
4 (CHP), which contain information that is generally unavailable to the
5 public and/or privileged or otherwise protected from disclosure under
6 state or federal statues, court rules, case decisions, or common law. CHP
7 may also be producing documents that contain information concerning
8
its confidential internal policies which are generally unavailable to the
9
public. The disclosure of this information may jeopardize the security of
10
CHP’s operations and jeopardize the safety of peace officers. CHP may
11
also be producing documents that contain personal and confidential
12
information regarding individuals which information is generally
13
unavailable to the public, including peace officer personnel records and
14
records related to third parties. The disclosure of this information to the
15
public may violate those individuals’ privacy rights. CHP may also be
16
producing video, audio and still photo images related to the incident at
17
issue in this case, which are generally unavailable to the public. In
18
addition, CHP may be producing investigation reports which are
19
generally unavailable to the public, the disclosure of which could violate
20
individuals’ privacy rights, jeopardize the safety of officers, and
21
22 jeopardize the integrity of the ongoing criminal investigation.
23 Accordingly, to expedite the flow of information, to facilitate the prompt
24 resolution of disputes over confidentiality of discovery materials, to
25 adequately protect information the parties are entitled to keep
26 confidential, to ensure that the parties are permitted reasonable
27 necessary uses of such material in preparation for and in the conduct of
1 ends of justice, a protective order for such information is justified in this
2 matter. It is the intent of the parties that information will not be
3 designated as confidential for tactical reasons and that nothing be so
4 designated without a good faith belief that it has been maintained in a
5 confidential, non-public manner, and there is good cause why it should
6 not be part of the public record of this case. In addition, this Action may
7 involve the production of confidential, proprietary, or commercially
8
sensitive information by other Parties or Non-Parties, including any
9
Non-Party that may be subpoenaed in connection with this Action. Such
10
information may include, without limitation, proprietary commercial or
11
financial information and nonpublic customer or account data, the
12
disclosure of which could cause competitive or other injury. Accordingly,
13
and for the same reasons set forth above, good cause exists for this Order
14
to extend equally to such material upon proper designation in accordance
15
with the terms below.
16
1.3 Acknowledgment of Procedure for Filing Under Seal. The
17
parties further acknowledge, as set forth in Section 12.3, below, that this
18
Stipulated Protective Order does not entitle them to file confidential
19
information under seal; Local Rule 79-5 sets forth the procedures that
20
must be followed and the standards that will be applied when a party
21
22 seeks permission from the court to file material under seal.
23 There is a strong presumption that the public has a right of access
24 to judicial proceedings and records in civil cases. In connection with
25 non-dispositive motions, good cause must be shown to support a filing
26 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
27 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
1 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
2 protective orders require good cause showing), and a specific showing of
3 good cause or compelling reasons with proper evidentiary support and
4 legal justification, must be made with respect to Protected Material that
5 a party seeks to file under seal. The parties’ mere designation of
6 Disclosure or Discovery Material as CONFIDENTIAL does not—
7 without the submission of competent evidence by declaration,
8
establishing that the material sought to be filed under seal qualifies as
9
confidential, privileged, or otherwise protectable—constitute good cause.
10
Further, if a party requests sealing related to a dispositive motion
11
or trial, then compelling reasons, not only good cause, for the sealing
12
must be shown, and the relief sought shall be narrowly tailored to serve
13
the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
14
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
15
information, document, or thing sought to be filed or introduced under
16
seal in connection with a dispositive motion or trial, the party seeking
17
protection must articulate compelling reasons, supported by specific
18
facts and legal justification, for the requested sealing order. Again,
19
competent evidence supporting the application to file documents under
20
seal must be provided by declaration.
21
22 Any document that is not confidential, privileged, or otherwise
23 protectable in its entirety will not be filed under seal if the confidential
24 portions can be redacted. If documents can be redacted, then a redacted
25 version for public viewing, omitting only the confidential, privileged, or
26 otherwise protectable portions of the document, shall be filed. Any
27 application that seeks to file documents under seal in their entirety
1
2 2. DEFINITIONS
3 2.1 Action: this pending federal lawsuit.
4
2.2 Challenging Party: a Party or Non-Party that challenges the
5
designation of information or items under this Order.
6
2.3 “CONFIDENTIAL” Information or Items: information
7
(regardless of how it is generated, stored or maintained) or tangible
8
things that qualify for protection under Rule 26(c) of the Federal Rules of
9
Civil Procedure, and as specified above in the Good Cause Statement.
10
2.4 Counsel: Outside Counsel of Record and In-House Counsel (as
11
well as their support staff).
12
2.5 Designating Party: a Party or Non-Party that designates
13
information or items that it produces in disclosures or in responses to
14
discovery as “CONFIDENTIAL.”
15
2.6 Disclosure or Discovery Material: all items or information,
16
regardless of the medium or manner in which it is generated, stored, or
17
18 maintained (including, among other things, testimony, transcripts, and
19 tangible things), that are produced or generated in disclosures or
20 responses to discovery in this matter.
21 2.7 Expert: a person with specialized knowledge or experience in
22 a matter pertinent to the litigation who has been retained by a Party or
23 its counsel to serve as an expert witness or as a consultant in this Action.
24 2.8 Final Disposition: the later of (1) dismissal of all claims and
25 defenses in this Action, with or without prejudice; and (2) final judgment
26 herein after the completion and exhaustion of all appeals, rehearings,
27
remands, trials, or reviews of this Action, including the time limits for
1 filing any motions or applications for extension of time pursuant to
2 applicable law.
3 2.9 In-House Counsel: attorneys who are employees of a party to
4 this Action. In-House Counsel does not include Outside Counsel of
5 Record or any other outside counsel.
6 2.10 Non-Party: any natural person, partnership, corporation,
7 association, or other legal entity not named as a Party to this action.
8
2.11 Outside Counsel of Record: attorneys who are not employees
9
of a party to this Action but are retained to represent or advise a party to
10
this Action and have appeared in this Action on behalf of that party or
11
are affiliated with a law firm which has appeared on behalf of that party,
12
and includes support staff.
13
2.12 Party: any party to this Action, including all of its officers,
14
directors, employees, consultants, retained experts, and Outside Counsel
15
of Record (and their support staffs).
16
2.13 Producing Party: a Party or Non-Party that produces
17
Disclosure or Discovery Material in this Action.
18
2.14 Professional Vendors: persons or entities that provide
19
litigation-support services (e.g., photocopying, videotaping, translating,
20
preparing exhibits or demonstrations, and organizing, storing, or
21
22 retrieving data in any form or medium) and their employees and
23 subcontractors.
24 2.15 Protected Material: any Disclosure or Discovery Material that
25 is designated as “CONFIDENTIAL.”
26 2.16 Receiving Party: a Party that receives Disclosure or Discovery
27 Material from a Producing Party.
1 3. SCOPE
2 The protections conferred by this Stipulation and Order cover not
3 only Protected Material (as defined above), but also (1) any information
4
copied or extracted from Protected Material; (2) all copies, excerpts,
5
summaries, or compilations of Protected Material; and (3) any
6
testimony, conversations, or presentations by Parties or their Counsel
7
that might reveal Protected Material.
8
//
9
Any use of Protected Material at trial shall be governed by the
10
orders of the trial judge. This Stipulated Protective Order does not
11
govern the use of Protected Material at trial.
12

13
14 4. TRIAL AND DURATION
15 The terms of this Stipulated Protective Order apply through Final
16 Disposition of the Action.
17
Once a case proceeds to trial, information that was designated as
18
CONFIDENTIAL or maintained pursuant to this Stipulated Protective
19
Order and used or introduced as an exhibit at trial becomes public and
20
will be presumptively available to all members of the public, including
21
the press, unless compelling reasons supported by specific factual
22
findings to proceed otherwise are made to the trial judge in advance of
23
the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
24
cause” showing for sealing documents produced in discovery from
25
“compelling reasons” standard when merits-related documents are part
26
of court record). Accordingly, for such materials, the terms of this
27
1 the trial.
2 Even after Final Disposition of this litigation, the confidentiality
3 obligations imposed by this Stipulated Protective Order shall remain in
4 effect until a Designating Party agrees otherwise in writing or a court
5 order otherwise directs.
6 //
7 //
8
5. DESIGNATING PROTECTED MATERIAL
9
5.1 Exercise of Restraint and Care in Designating Material for
10
Protection. Each Party or Non-Party that designates information or
11
items for protection under this Order must take care to limit any such
12
designation to specific material that qualifies under the appropriate
13
standards. The Designating Party must designate for protection only
14
those parts of material, documents, items, or oral or written
15
communications that qualify so that other portions of the material,
16
documents, items, or communications for which protection is not
17
18 warranted are not swept unjustifiably within the ambit of this Order.
19 Mass, indiscriminate, or routinized designations are prohibited.
20 Designations that are shown to be clearly unjustified or that have been
21 made for an improper purpose (e.g., to unnecessarily encumber the case
22 development process or to impose unnecessary expenses and burdens on
23 other parties) may expose the Designating Party to sanctions.
24 If it comes to a Designating Party’s attention that information or
25 items that it designated for protection do not qualify for protection, that
26 Designating Party must promptly notify all other Parties that it is
27
withdrawing the inapplicable designation.
1 5.2 Manner and Timing of Designations. Except as otherwise
2 provided in this Stipulated Protective Order (see, e.g., second paragraph
3 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
4 or Discovery Material that qualifies for protection under this Stipulated
5 Protective Order must be clearly so designated before the material is
6 disclosed or produced.
7
//
8
Designation in conformity with this Stipulated Protective Order
9
requires:
10
(a) for information in documentary form (e.g., paper or electronic
11
documents, but excluding transcripts of depositions or other pretrial or
12
trial proceedings), that the Producing Party affix at a minimum, the
13
legend “CONFIDENTIAL” to each page that contains protected
14
material. If only a portion or portions of the material on a page
15
qualifies for protection, the Producing Party also must clearly identify
16
17 the protected portion(s) (e.g., by making appropriate markings in the
18 margins).
19 A Party or Non-Party that makes original documents available for
20 inspection need not designate them for protection until after the
21 inspecting Party has indicated which documents it would like copied
22 and produced. During the inspection and before the designation, all of
23 the material made available for inspection shall be deemed
24 CONFIDENTIAL. After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must
26
determine which documents, or portions thereof, qualify for protection
27
under this Stipulated Protective Order. Then, before producing the
1 specified documents, the Producing Party must affix the
2 “CONFIDENTIAL” legend to each page that contains Protected
3 Material. If only a portion or portions of the material on a page
4 qualifies for protection, the Producing Party also must clearly identify
5 the protected portion(s) (e.g., by making appropriate markings in the
6 margins).
7 (b) for testimony given in depositions that the Designating Party
8
identify the Disclosure or Discovery Material on the record, before the
9
close of the deposition all protected testimony.
10
(c) for information produced in some form other than
11
documentary and for any other tangible items, that the Producing Party
12
affix in a prominent place on the exterior of the container or containers
13
in which the information is stored the “CONFIDENTIAL” legend. If only
14
a portion or portions of the information warrants protection, the
15
Producing Party, to the extent practicable, shall identify the protected
16
portion(s).
17
18 5.3 Inadvertent Failures to Designate. If timely corrected, an
19 inadvertent failure to designate qualified information or items does not,
20 standing alone, waive the Designating Party’s right to secure protection
21 under this Order for such material. Upon timely correction of a
22 designation, the Receiving Party must make reasonable efforts to assure
23 that the material is treated in accordance with the provisions of this
24 Stipulated Protective Order.
25
26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
27
6.1 Timing of Challenges. Any Party or Non-Party may
1 challenge a designation of confidentiality at any time that is consistent
2 with the court’s Scheduling Order.
3 6.2 Meet and Confer. The Challenging Party shall initiate the
4 dispute resolution process under Local Rule 37.1 et seq.
5 6.3 The burden of persuasion in any such challenge proceeding
6 shall be on the Designating Party. Frivolous challenges, and those
7 made for an improper purpose (e.g., to harass or impose unnecessary
8
expenses and burdens on other parties) may expose the Challenging
9
Party to sanctions. Unless the Designating Party has waived or
10
withdrawn the confidentiality designation, all parties shall continue to
11
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
13
the challenge.
14

15
7. ACCESS TO AND USE OF PROTECTED MATERIAL
16
17 7.1 Basic Principles. A Receiving Party may use Protected
18 Material that is disclosed or produced by another Party or by a Non-
19 Party in connection with this Action only for prosecuting, defending, or
20 attempting to settle this Action. Such Protected Material may be
21 disclosed only to the categories of persons and under the conditions
22 described in this Order. When the Action reaches a Final Disposition, a
23 Receiving Party must comply with the provisions of section 13 below.
24 Protected Material must be stored and maintained by a Receiving
25 Party at a location and in a secure manner that ensures that access is
26
limited to the persons authorized under this Stipulated Protective
27
Order.
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
2 Unless otherwise ordered by the court or permitted in writing by the
3 Designating Party, a Receiving Party may disclose any information or
4 item designated “CONFIDENTIAL” only:
5 (a) to the Receiving Party’s Outside Counsel of Record in this
6 Action, as well as employees of said Outside Counsel of Record to whom
7 it is reasonably necessary to disclose the information for this Action;
8
//
9
(b) to the officers, directors, and employees (including In-House
10
Counsel) of the Receiving Party to whom disclosure is reasonably
11
necessary for this Action;
12
(c) to Experts (as defined in this Order) of the Receiving Party to
13
whom disclosure is reasonably necessary for this Action and who have
14
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15
(d) to the court and its personnel;
16
(e) to court reporters and their staff;
17
(f) to professional jury or trial consultants, mock jurors, and
18
Professional Vendors to whom disclosure is reasonably necessary for
19
this Action and who have signed the “Acknowledgment and Agreement
20
to Be Bound” (Exhibit A);
21
22 (g) to the author or recipient of a document containing the
23 information or a custodian or other person who otherwise possessed or
24 knew the information;
25 (h) during their depositions, to witnesses, and attorneys for
26 witnesses, in the Action to whom disclosure is reasonably necessary,
27 provided: (1) the deposing party requests that the witness sign the
1 witness will not be permitted to keep any confidential information
2 unless they sign the “Acknowledgment and Agreement to Be Bound”
3 (Exhibit A), unless otherwise agreed by the Designating Party or
4 ordered by the court. Pages of transcribed deposition testimony or
5 exhibits to depositions that reveal Protected Material may be separately
6 bound by the court reporter and may not be disclosed to anyone except
7 as permitted under this Stipulated Protective Order; and
8
//
9
(i) to any mediator or settlement officer, and their supporting
10
personnel, mutually agreed upon by any of the parties engaged in
11
settlement discussions.
12
7.3 The parties acknowledge that the Court authorized early
13
discovery, in part, to permit Plaintiffs to identify and substitute Doe
14
defendants. Accordingly, notwithstanding any other provision of this
15
Order, Plaintiffs may use officer-identifying information produced by the
16
California Highway Patrol—including officer names, badge numbers,
17
titles/ranks, agency affiliation, and the officers’ alleged roles in the
18
events at issue—to amend the complaint, substitute Doe defendants,
19
effect service, and prosecute this Action. The filing of such officer-
20
identifying information for those limited purposes shall not constitute a
21
22 violation of this Order and shall not waive confidentiality as to the
23 underlying documents or any other Protected Material. This provision
24 does not permit public disclosure of peace officer personnel records,
25 personal contact information, home addresses, dates of birth, family
26 information, medical or disciplinary information, confidential law-
27 enforcement techniques, criminal-investigation strategy, third-party
1 written agreement of the Designating Party or court order.
2
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
4 PRODUCED IN OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in
6 other litigation that compels disclosure of any information or items
7 designated in this Action as “CONFIDENTIAL,” that Party must:
8
(a) promptly notify in writing the Designating Party. Such
9
notification shall include a copy of the subpoena or court order;
10
(b) promptly notify in writing the party who caused the
11
subpoena or order to issue in the other litigation that some or all of the
12
material covered by the subpoena or order is subject to this Protective
13
Order. Such notification shall include a copy of this Stipulated
14
Protective Order; and
15
(c) cooperate with respect to all reasonable procedures sought to
16
be pursued by the Designating Party whose Protected Material may be
17
18 affected.
19 If the Designating Party timely seeks a protective order, the
20 Party served with the subpoena or court order shall not produce any
21 information designated in this action as “CONFIDENTIAL” before a
22 determination by the court from which the subpoena or order issued,
23 unless the Party has obtained the Designating Party’s permission. The
24 Designating Party shall bear the burden and expense of seeking
25 protection in that court of its confidential material and nothing in these
26 provisions should be construed as authorizing or encouraging a
27
Receiving Party in this Action to disobey a lawful directive from another
1 court.
2
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 9.1 Application. The terms of this Stipulated Protective Order
6 are applicable to information produced by a Non-Party in this Action and
7 designated as “CONFIDENTIAL.” Such information produced by Non-
8
Parties in connection with this litigation is protected by the remedies
9
and relief provided by this Order. Nothing in these provisions should be
10
construed as prohibiting a Non-Party from seeking additional
11
protections.
12
9.2 Notification. In the event that a Party is required, by a valid
13
discovery request, to produce a Non-Party’s confidential information in
14
its possession, and the Party is subject to an agreement with the Non-
15
Party not to produce the Non-Party’s confidential information, then the
16
Party shall:
17
(a) promptly notify in writing the Requesting Party and the
18
Non-Party that some or all of the information requested is subject to a
19
confidentiality agreement with a Non-Party;
20
21
(b) make the information requested available for inspection by
22 the Non-Party, if requested.
23 9.3 Conditions of Production. If the Non-Party fails to seek a
24 protective order from this court within 14 days of receiving the notice
25 and accompanying information, the Receiving Party may produce the
26 Non-Party’s confidential information responsive to the discovery request.
27 If the Non-Party timely seeks a protective order, the Receiving Party
1 subject to the confidentiality agreement with the Non-Party before a
2 determination by the court. Absent a court order to the contrary, the
3 Non-Party shall bear the burden and expense of seeking protection in
4 this court of its Protected Material.
5
6
7

8
10. UNAUTHORIZED DISCLOSURE OF PROTECTED
9
MATERIAL
10
If a Receiving Party learns that, by inadvertence or otherwise, it
11
has disclosed Protected Material to any person or in any circumstance
12
not authorized under this Stipulated Protective Order, the Receiving
13
Party must immediately (a) notify in writing the Designating Party of
14
the unauthorized disclosures, (b) use its best efforts to retrieve all
15
16 unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of
18 this Order, and (d) request such person or persons to execute the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
20
21
11. INADVERTENT PRODUCTION OF PRIVILEGED OR
22
OTHERWISE PROTECTED MATERIAL
23
When a Producing Party gives notice to Receiving Parties that
24
certain inadvertently produced material is subject to a claim of privilege
25
or other protection, the obligations of the Receiving Parties are those set
26
forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
27
1 established in an e-discovery order that provides for production without
2 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
3 Rules of Evidence, insofar as the parties reach an agreement on the
4 effect of disclosure of a communication or information covered by the
5 attorney-client privilege or work product protection, the parties may
6 incorporate their agreement in the stipulated protective order
7 submitted to the court.
8
12. MISCELLANEOUS
9
12.1 Right to Further Relief. Nothing in this Stipulated
10
Protective Order abridges the right of any person to seek its
11
modification by the court in the future.
12
12.2 Right to Assert Other Objections. By stipulating to the entry
13
of this Stipulated Protective Order no Party waives any right it
14
otherwise would have to object to disclosing or producing any
15
information or item on any ground not addressed in this Stipulated
16
Protective Order. Similarly, no Party waives any right to object on any
17
18 ground to use in evidence of any of the material covered by this
19 Stipulated Protective Order.
20 12.3 Filing Protected Material. A Party that seeks to file under
21 seal any Protected Material must comply with Local Rule 79-5.
22 Protected Material may only be filed under seal pursuant to a court
23 order authorizing the sealing of the specific Protected Material at issue.
24 If a Party's request to file Protected Material under seal is denied by the
25 court, then the Receiving Party may file the information in the public
26 record unless otherwise instructed by the court.
27
1 13. FINAL DISPOSITION
2 After the Final Disposition of this Action, as defined in paragraph
3 4, within 60 days of a written request by the Designating Party, each
4
Receiving Party must return all Protected Material to the Producing
5
Party or destroy such material. As used in this subdivision, “all
6
Protected Material” includes all copies, abstracts, compilations,
7
summaries, and any other format reproducing or capturing any of the
8
Protected Material. Whether the Protected Material is returned or
9
destroyed, the Receiving Party must submit a written certification to
10
the Producing Party (and, if not the same person or entity, to the
11
Designating Party) by the 60 day deadline that (1) identifies (by
12
category, where appropriate) all the Protected Material that was
13
returned or destroyed and (2) affirms that the Receiving Party has not
14
retained any copies, abstracts, compilations, summaries or any other
15
format reproducing or capturing any of the Protected Material.
16
Notwithstanding this provision, Counsel is entitled to retain an archival
17
18 copy of all pleadings, motion papers, trial, deposition, and hearing
19 transcripts, legal memoranda, correspondence, deposition and trial
20 exhibits, expert reports, attorney work product, and consultant and
21 expert work product, even if such materials contain Protected Material.
22 Any such archival copies that contain or constitute Protected Material
23 remain subject to this Protective Order as set forth in Section 4.
24

25
26
27
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.
5
6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7 DATED: July 7, 2026 LAW OFFICE OF LOUIS P. DELL
8
/s/ Louis P. Dell
9
John-Louis H. Dell
10 Louis P. Dell
Attorneys for Plaintiffs
11
VYACHESLAV FINOGEYEV and
12 NATALYA FINOGEYEVA
13

14
DATED: July 7, 2026 WOMBLE BOND DICKINSON (US)
15 LLP
16
/s/ Alisa A. Givental
17
Alisa A. Givental
18 Attorneys for Defendant
MERCEDES-BENZ FINANCIAL
19
SERVICES USA LLC
20
21
22 DATED: July 7, 2026 SIDRAN LAW CORP.

23
/s/ David R. Sidran
24 David R. Sidran
Thomas M. Crowell
25
Attorneys for Defendant
26 URT KEYSTONE, INC.

27
1
2 || DATED: July 7, 2026 ROB BONTA
3 Attorney General of California
4 /s/ Donna M. Dean
5 DONNA M. DEAN
Supervising Deputy Attorney
6 General
7 Attorneys for Non-Party
STATE OF CALIFORNIA, by and
8 through CALIFORNIA HIGHWAY
9 PATROL
10
1] □ □
Attestation of Signatures
12
I, Louis P. Dell, attest that all other signatories listed, and on
13
14 whose behalf the filing is submitted, concur in the filing’s content and

15 have authorized the filing.
16
/s/ Louis P. Dell
Louis P. Dell
18
19
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22
33 DATED: July 7, 2026

54 DIANA M. Kwok
United States Magistrate Judge
25
26
27
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1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, ________________________ [print or type full name], of
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_________________ [print or type full address], declare under
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penalty of perjury that I have read in its entirety and understand the
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Stipulated Protective Order that was issued by the United States
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District Court for the Central District of California on [date] in the
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case of __________ [insert formal name of the case and the
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number and initials assigned to it by the court]. I agree to
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comply with and to be bound by all the terms of this Stipulated
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Protective Order and I understand and acknowledge that failure to so
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comply could expose me to sanctions and punishment in the nature of
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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]
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of _________ [print or type full address and telephone number] as
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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.
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5 Date: ___________________________
6 City and State where sworn and
7 signed: ___________________________
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Printed name: ___________________________
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Signature: ___________________________
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11386514. Public record. Not legal advice.