Robin Shenas v. Jaguar Land Rover North America LLC ( 2023 )

1 BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505) 2 Theodore Dorenkamp III (SBN: 277004) Bryan A. Reynolds (SBN: 296434) 3 970 West 190th Street, Suite 700 Torrance, California 90502 4 Tel No: 310/ 768-3068 Fax No: 310/ 719-1019 5 6 Attorneys for Defendant JAGUAR LAND ROVER NORTH AMERICA, LLC 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 ROBIN SHENAS, ) CASE NO.: 2:22-cv-09360-RGK-RAO ) 12 Plaintiff, ) Assigned to: Hon. R. Gary Klausner ) 13 vs. ) ) STIPULATED PROTECTIVE ORDER1 14 JAGUAR LAND ROVER NORTH ) AMERICA, LLC; and DOES 1 ) 15 through 10, inclusive, ) ) 16 Defendants. ) ) 17 ) 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 enter the following Stipulated Protective Order. The parties acknowledge that this 25 Order does not confer blanket protections on all disclosures or responses to 26 discovery and that the protection it affords from public disclosure and use extends 27 28 1 This Stipulated Protective Order is substantially based on the model protective 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets and other valuable research, 6 development, commercial, financial, technical and/or proprietary information for 7 which special protection from public disclosure and from use for any purpose other 8 than prosecution of this action is warranted. Such confidential and proprietary 9 materials and information consist of, among other things, confidential business or 10 financial information, information regarding confidential business practices, or 11 other confidential research, development, or commercial information (including 12 information implicating privacy rights of third parties), information otherwise 13 generally unavailable to the public, or which may be privileged or otherwise 14 protected from disclosure under state or federal statutes, court rules, case decisions, 15 or common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to 18 ensure that the parties are permitted reasonable necessary uses of such material in 19 preparation for and in the conduct of trial, to address their handling at the end of 20 the litigation, and serve the ends of justice, a protective order for such information 21 is justified in this matter. It is the intent of the parties that information will not be 22 designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of 25 this case. 26 27 28 order provided under Magistrate Judge Rozella A. Oliver’s Procedures. 1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 2 SEAL 3 The parties further acknowledge, as set forth in Section 12.3, below, that 4 this Stipulated Protective Order does not entitle them to file confidential 5 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 6 be followed and the standards that will be applied when a party seeks permission 7 from the court to file material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive 10 motions, good cause must be shown to support a filing under seal. See Kamakana 11 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. 12 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. 13 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of good 15 cause or compelling reasons with proper evidentiary support and legal justification, 16 must be made with respect to Protected Material that a party seeks to file under 17 seal. The parties’ mere designation of Disclosure or Discovery Material as 18 CONFIDENTIAL does not—without the submission of competent evidence by 19 declaration, establishing that the material sought to be filed under seal qualifies as 20 confidential, privileged, or otherwise protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, 22 then compelling reasons, not only good cause, for the sealing must be shown, and 23 the relief sought shall be narrowly tailored to serve the specific interest to be 24 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 25 2010). For each item or type of information, document, or thing sought to be filed 26 or introduced under seal in connection with a dispositive motion or trial, the party 27 seeking protection must articulate compelling reasons, supported by specific facts 28 and legal justification, for the requested sealing order. Again, competent evidence 1 supporting the application to file documents under seal must be provided by 2 declaration. 3 Any document that is not confidential, privileged, or otherwise protectable 4 in its entirety will not be filed under seal if the confidential portions can be 5 redacted. If documents can be redacted, then a redacted version for public 6 viewing, omitting only the confidential, privileged, or otherwise protectable 7 portions of the document shall be filed. Any application that seeks to file 8 documents under seal in their entirety should include an explanation of why 9 redaction is not feasible. 10 11 2. DEFINITIONS 12 2.1 Action: [this pending federal lawsuit]. [*Option: consolidated or 13 related actions.] 14 2.2 Challenging Party: a Party or Non-Party that challenges the 15 designation of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 19 the Good Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 21 their support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information 23 or items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless 26 of the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things) that are produced 28 or generated in disclosures or responses to discovery in this matter. 1 2.7 Expert: a person with specialized knowledge or experience in a 2 matter pertinent to the litigation who has been retained by a Party or its counsel to 3 serve as an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this 5 Action. House Counsel does not include Outside Counsel of Record or any other 6 outside counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association 8 or other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a 10 party to this Action but are retained to represent or advise a party to this Action 11 and have appeared in this Action on behalf of that party or are affiliated with a law 12 firm that has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 27 / / / 28 / / / 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Order does not govern the use of Protected Material at trial. 9 10 4. DURATION 11 Once a case proceeds to trial, information that was designated as 12 CONFIDENTIAL or maintained pursuant to this protective order used or 13 introduced as an exhibit at trial becomes public and will be presumptively 14 available to all members of the public, including the press, unless compelling 15 reasons supported by specific factual findings to proceed otherwise are made to the 16 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 17 (distinguishing “good cause” showing for sealing documents produced in 18 discovery from “compelling reasons” standard when merits-related documents are 19 part of court record). Accordingly, the terms of this protective order do not extend 20 beyond the commencement of the trial. 21 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 Each Party or Non-Party that designates information or items for protection under 25 this Order must take care to limit any such designation to specific material that 26 qualifies under the appropriate standards. The Designating Party must designate 27 for protection only those parts of material, documents, items or oral or written 28 communications that qualify so that other portions of the material, documents, 1 items or communications for which protection is not warranted are not swept 2 unjustifiably within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to 6 impose unnecessary expenses and burdens on other parties) may expose the 7 Designating Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 under this Order must be clearly so designated before the material is disclosed or 15 produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or trial 19 proceedings), that the Producing Party affix at a minimum, the legend 20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 21 contains protected material. If only a portion of the material on a page qualifies for 22 protection, the Producing Party also must clearly identify the protected portion(s) 23 (e.g., by making appropriate markings in the margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 1 documents it wants copied and produced, the Producing Party must determine 2 which documents, or portions thereof, qualify for protection under this Order. 3 Then, before producing the specified documents, the Producing Party must affix 4 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 5 only a portion of the material on a page qualifies for protection, the Producing 6 Party also must clearly identify the protected portion(s) (e.g., by making 7 appropriate markings in the margins). 8 (b) for testimony given in depositions that the Designating Party 9 identifies the Disclosure or Discovery Material on the record, before the close of 10 the deposition all protected testimony. 11 (c) for information produced in some form other than documentary 12 and for any other tangible items, that the Producing Party affix in a prominent 13 place on the exterior of the container or containers in which the information is 14 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 15 information warrants protection, the Producing Party, to the extent practicable, 16 shall identify the protected portion(s). 17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 failure to designate qualified information or items does not, standing alone, waive 19 the Designating Party’s right to secure protection under this Order for such 20 material. Upon timely correction of a designation, the Receiving Party must make 21 reasonable efforts to assure that the material is treated in accordance with the 22 provisions of this Order. 23 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 1 resolution process under Local Rule 37.1 et seq. 2 6.3 The burden of persuasion in any such challenge proceeding shall be 3 on the Designating Party. Frivolous challenges, and those made for an improper 4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 5 parties) may expose the Challenging Party to sanctions. Unless the Designating 6 Party has waived or withdrawn the confidentiality designation, all parties shall 7 continue to afford the material in question the level of protection to which it is 8 entitled under the Producing Party’s designation until the Court rules on the 9 challenge. 10 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles. A Receiving Party may use Protected Material that 13 is disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under 16 the conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 13 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 27 well as employees of said Outside Counsel of Record to whom it is reasonably 28 necessary to disclose the information for this Action; 1 (b) the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing 15 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 16 they will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 deposition testimony or exhibits to depositions that reveal Protected Material may 20 be separately bound by the court reporter and may not be disclosed to anyone 21 except as permitted under this Stipulated Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 28 that compels disclosure of any information or items designated in this Action as 1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification shall 3 include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or order to 5 issue in the other litigation that some or all of the material covered by the subpoena 6 or order is subject to this Protective Order. Such notification shall include a copy 7 of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be pursued 9 by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with the 11 subpoena or court order shall not produce any information designated in this action 12 as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this Action 17 to disobey a lawful directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 PRODUCED IN THIS LITIGATION 21 (a) The terms of this Order are applicable to information produced by a 22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 23 produced by Non-Parties in connection with this litigation is protected by the 24 remedies and relief provided by this Order. Nothing in these provisions should be 25 construed as prohibiting a Non-Party from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 produce a Non-Party’s confidential information in its possession, and the Party is 28 subject to an agreement with the Non-Party not to produce the Non-Party’s 1 confidential information, then the Party shall: 2 (1) promptly notify in writing the Requesting Party and the Non-Party that 3 some or all of the information requested is subject to a confidentiality agreement with 4 a Non-Party; 5 (2) promptly provide the Non-Party with a copy of the Stipulated 6 Protective Order in this Action, the relevant discovery request(s), and a reasonably 7 specific description of the information requested; and 8 (3) make the information requested available for inspection by the Non- 9 Party, if requested. 10 (c) If the Non-Party fails to seek a protective order from this court within 14 11 days of receiving the notice and accompanying information, the Receiving Party 12 may produce the Non-Party’s confidential information responsive to the discovery 13 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 14 not produce any information in its possession or control that is subject to the 15 confidentiality agreement with the Non-Party before a determination by the court. 16 Absent a court order to the contrary, the Non-Party shall bear the burden and 17 expense of seeking protection in this court of its Protected Material. 18 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has 21 disclosed Protected Material to any person or in any circumstance not authorized 22 under this Stipulated Protective Order, the Receiving Party must immediately (a) 23 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 24 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 25 the person or persons to whom unauthorized disclosures were made of all the terms 26 of this Order, and (d) request such person or persons to execute the 27 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 28 A. 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other 5 protection, the obligations of the Receiving Parties are those set forth in Federal 6 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 7 whatever procedure may be established in an e-discovery order that provides for 8 production without prior privilege review. Pursuant to Federal Rule of Evidence 9 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 10 of a communication or information covered by the attorney-client privilege or 11 work product protection, the parties may incorporate their agreement in the 12 stipulated protective order submitted to the court. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of 16 any person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in 20 this Stipulated Protective Order. Similarly, no Party waives any right to object on 21 any ground to use in evidence of any of the material covered by this Protective 22 Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material 25 may only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material at issue. If a Party’s request to file Protected Material 27 under seal is denied by the court, then the Receiving Party may file the information 28 in the public record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 3 60 days of a written request by the Designating Party, each Receiving Party must 4 return all Protected Material to the Producing Party or destroy such material. As 5 used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 Receiving Party must submit a written certification to the Producing Party (and, if 9 not the same person or entity, to the Designating Party) by the 60 day deadline that 10 (1) identifies (by category, where appropriate) all the Protected Material that was 11 returned or destroyed and (2) affirms that the Receiving Party has not retained any 12 copies, abstracts, compilations, summaries or any other format reproducing or 13 capturing any of the Protected Material. Notwithstanding this provision, Counsel 14 are entitled to retain an archival copy of all pleadings, motion papers, trial, 15 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 16 and trial exhibits, expert reports, attorney work product, and consultant and expert 17 work product, even if such materials contain Protected Material. Any such 18 archival copies that contain or constitute Protected Material remain subject to this 19 Protective Order as set forth in Section 4 (DURATION). 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || DATED: December 18, 2023 STRATEGIC LEGAL PRACTICES, APC 8 9 BY: _/s/ Elizabeth Larocque Tionna Dolin 10 Elizabeth Larocque Rabiya Tirmizi 11 Attorneys for Plaintiff D ROBIN-SHENAS 13 14 DATED: December 18, 2023 BOWMAN AND BROOKE LLP 15 BY: _/s/ Bryan A. Reynolds 16 Brian Takahashi Theodore Dorenkamp III 17 Bryan A. Reynolds Attorneys for Defendant 18 J AGUAR LAND ROVER NORTH 19 AMERICA, LLC 20 21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 || DATED: December 18, 2023 24 || £_.. eo . 95 rare a. Gy, ‘ Qe —, HON. ROZELLA A. OLIVER 26 || United States Magistrate Judge 27 28 28600556v2 15 CASE NO.: 2:22-cv-09360-RGK-RAO 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of ___________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or 20 type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 1 CERTIFICATE OF SERVICE 2 I hereby certify that on December 18, 2023, I filed the foregoing document 3 entitled STIPULATED PROTECTIVE ORDER with the clerk of court using the 4 CM/ECF system, which will send a notice of electronic filing to all counsel of 5 record in this action. 6 7 /s/ Bryan Reynolds 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28