Taylor v. Ford Motor Co ( 2024 )

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 | LAUREN TAYLOR, Case No. 2:23-cv-03031-KJM-CSK 11 Plaintiff, ORDER GRANTING MODIFIED 10 y STIPULATED PROTECTIVE ORDER (ECF No 14) 13 | FORD MOTOR COMPANY, et al., 14 Defendants. 15 16 The Court has reviewed the parties’ stipulated protective order below (ECF No. 17 || 14.), and finds it comports with the relevant authorities and the Court’s Local Rule. See 18 | L.R. 141.1. The Court APPROVES the protective order, subject to the following 19 | clarification. The Court’s Local Rules indicate that once an action is closed, it “will not 20 | retain jurisdiction over enforcement of the terms of any protective order filed in that 21 | action.” L.R. 141.1(f); see MD Helicopters, Inc. v. Aerometals, Inc., 2017 WL 495778 22 | (E.D. Cal., Feb. 03, 2017) (noting that courts in the district generally do not retain 23 | jurisdiction for disputes concerning protective orders after closure of the case). Thus, the 24 | Court will not retain jurisdiction over this protective order once the case is closed. 25 26 || Dated: May 20, 2024 C i s 27 CHI SOO KIM 28 | 5 tay.s031 UNITED STATES MAGISTRATE JUDGE 1 Tionna Carvalho (SBN: 299010) tcarvalho@slpattorney.com 2 Elizabeth A. LaRocque (SBN: 219977) elarocque@slpattoreny.com 3 STRATEGIC LEGAL PRACTICES, APC 1888 Century Park East, 19th Floor 4 Los Angeles, CA 90067 Tel: (310)929-4900 5 Fax: (310)943-3838 Attorneys For Plaintiff, 6 LAUREN TAYLOR 7 Spencer P. Hugret (SBN: 240424) shugret@grsm.com 8 Katherine P. Vilchez (SBN: 212179) kvilchez@grsm.com 9 Trina M. Clayton (SBN: 204215) tclayton@grsm.com 10 GORDON REES SCULLY MANSUKHANI, LLP 275 Battery Street, Suite 2000 11 San Francisco, CA 94111 Telephone: (415) 986-5900 12 Facsimile: (415) 986-8054 Attorneys for Defendants 13 FORD MOTOR COMPANY 14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16 17 LAUREN TAYLOR, ) Case No.: 2:23-cv-03031-KJM-CSK ) 18 Plaintiff, ) Judge: Hon. Kimberly J. Mueller ) Magistrate Judge: Chi Soo Kim 19 vs. ) ) 20 FORD MOTOR COMPANY; and STIPULATED [PROPOSED] DOES 1 through 10, inclusive, ) PROTECTIVE ORDER – 21 ) DISCOVERY ONLY Defendants. ) 22 ) ) 23 24 25 26 27 28 1 IT IS HEREBY STIPULATED by and between the Parties to Lauren 2 Taylor v. Ford Motor Company, et al., by and through their respective counsel of 3 record, that in order to facilitate the exchange of information and documents which 4 may contain trade secret or other confidential research, technical, cost, price, 5 marketing or other commercial information, as is contemplated by Federal Rule of 6 Civil Procedure 26(c)(1)(G), the Parties stipulate as follows: 7 1. PURPOSES AND LIMITATIONS 8 Disclosure and discovery activity in this action are likely to involve production 9 of confidential, proprietary, commercially sensitive, personally identifiable 10 information (“PII”), or private information for which special protection from public 11 disclosure and from use for any purpose other than prosecuting this litigation may be 12 warranted. Accordingly, the parties hereby stipulate to and petition the court to enter 13 the following Stipulated Protective Order. The parties acknowledge that this Order 14 does not confer blanket protections on all disclosures or responses to discovery and 15 that the protection it affords from public disclosure and use extends only to the 16 limited information or items that are entitled to confidential treatment under the 17 applicable legal principles. The parties further acknowledge, as set forth in Section 18 12.3, below, that this Stipulated Protective Order does not entitle them to file 19 confidential information under seal; Civil Local Rule 141 sets forth the procedures 20 that must be followed and the standards that will be applied when a party seeks 21 permission from the court to file material under seal. 22 2. DEFINITIONS 23 2.1 Challenging Party: a Party or Non-Party that challenges the 24 designation of information or items under this Order. 25 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 26 how it is generated, stored or maintained) or tangible things that qualify for 27 protection under Federal Rule of Civil Procedure 26(c), including materials that 28 contain trade secret or other confidential research, technical, cost, price, marketing, 1 or other commercial information, which are, for competitive reasons, normally, 2 kept confidential by the parties, as contemplated by Federal Rules of Civil 3 Procedure 26(c)(1)(G). 4 2.3 Counsel (without qualifier): Outside Counsel of Record and House 5 Counsel (as well as their support staff). 6 2.4 Designating Party: a Party or Non-Party that designates information or 7 items that it produces in disclosures or in responses to discovery as 8 “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER.” 9 2.5 Disclosure or Discovery Material: all items or information, regardless 10 of the medium or manner in which it is generated, stored, or maintained (including, 11 among other things, testimony, transcripts, and tangible things), that are produced 12 or generated in disclosures or responses to discovery in this matter. 13 2.6 Expert: a non-attorney person with specialized knowledge or 14 experience in a matter pertinent to the litigation who has been retained by a Party or 15 its counsel to serve as an expert witness or as a consultant in this action, provided 16 that no disclosure shall be made to any expert or consultant who is currently 17 employed by a competitor of the Designating Party. 18 2.7 House Counsel: attorneys who are employees of a party to this action. 19 House Counsel does not include Outside Counsel of Record or any other outside 20 counsel. 21 2.8 Non-Party: any natural person, partnership, corporation, association, or 22 other legal entity not named as a Party to this action. 23 2.9 Outside Counsel of Record: attorneys who are not employees of a 24 party to this action but are retained to represent or advise a party to this action and 25 have appeared in this action on behalf of that party or are affiliated with a law firm 26 which has appeared on behalf of that party. 27 28 1 2.10 Party: any party to this action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 4 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 5 Discovery Material in this action. 6 2.12 Professional Vendors: persons or entities that provide litigation 7 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) 9 and their employees and subcontractors. 10 2.13 Protected Material: any Disclosure or Discovery Material that is 11 designated as “CONFIDENTIAL” or ‘SUBJECT TO PROTECTIVE ORDER.” 12 2.14 Receiving Party: a Party that receives Disclosure or Discovery 13 Material from a Producing Party. 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 presentations by Parties or their Counsel that might reveal Protected Material. 20 However, the protections conferred by this Stipulation and Order do not cover the 21 following information: (a) any information that is in the public domain at the time 22 of disclosure to a Receiving Party or becomes part of the public domain after its 23 disclosure to a Receiving Party as a result of publication not involving a violation 24 of this Order, including becoming part of the public record through trial or 25 otherwise; and (b) any information known to the Receiving Party prior to the 26 disclosure or obtained by the Receiving Party after the disclosure from a source 27 who obtained the information lawfully and under no obligation of confidentiality to 28 1 the Designating Party. Any use of Protected Material at trial shall be governed by a 2 separate agreement or order. 3 4. DURATION 4 Even after final disposition of this litigation, the confidentiality obligations 5 imposed by this Order shall remain in effect until a Designating Party agrees 6 otherwise in writing or a court order otherwise directs. Final disposition shall be 7 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 8 or without prejudice; and (2) final judgment herein after the completion and 9 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 10 including the time limits for filing any motions or applications for extension of time 11 pursuant to applicable law. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under 15 this Order must take care to limit any such designation to specific material that 16 qualifies under the appropriate standards. The Designating Party must designate for 17 protection only those parts of material, documents, items, or oral or written 18 communications that qualify – so that other portions of the material, documents, 19 items, or communications for which protection is not warranted are not swept 20 unjustifiably within the ambit of this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber or retard the case development process or 24 to impose unnecessary expenses and burdens on other parties) expose the 25 Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the mistaken designation. 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) For information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” or 10 “SUBJECT TO PROTECTIVE ORDER” to each page that contains protected 11 material. 12 A Party or Non-Party that makes original documents or materials available 13 for inspection need not designate them for protection until after the inspecting Party 14 has indicated which material it would like copied and produced. During the 15 inspection and before the designation, all of the material made available for 16 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 17 identified the documents it wants copied and produced, the Producing Party must 18 determine which documents, or portions thereof, qualify for protection under this 19 Order. Then, before producing the specified documents, the Producing Party must 20 affix the “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER” legend 21 to each page that contains Protected Material. 22 (b) for testimony given in deposition or in other pretrial or trial 23 proceedings, that the Designating Party identify on the record, before the close of 24 the deposition, hearing, or other proceeding, all protected testimony. 25 (c) for information produced in some form other than documentary and 26 for any other tangible items, that the Producing Party affix in a prominent place on 27 the exterior of the container or containers in which the information or item is stored 28 the legend “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER.” 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such 4 material. Upon timely correction of a designation, the Receiving Party must make 5 reasonable efforts to assure that the material is treated in accordance with the 6 provisions of this Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time. Unless a prompt challenge to a 10 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 11 substantial unfairness, unnecessary economic burdens, or a significant disruption or 12 delay of the litigation, a Party does not waive its right to challenge a confidentiality 13 designation by electing not to mount a challenge promptly after the original 14 designation is disclosed. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process by providing written notice of each designation it is challenging, 17 identifying where applicable the challenged designation by Bates number, and 18 describing the basis for each challenge. To avoid ambiguity as to whether a 19 challenge has been made, the written notice must recite that the challenge to 20 confidentiality is being made in accordance with this specific paragraph of the 21 Protective Order. The parties shall attempt to resolve each challenge in good faith 22 and must begin the process by conferring directly (in voice to voice dialogue; other 23 forms of communication are not sufficient) within 14 days of the date of service of 24 notice. In conferring, the Challenging Party must explain the basis for its belief that 25 the confidentiality designation was not proper and must give the Designating Party 26 an opportunity to review the designated material, to reconsider the circumstances, 27 and, if no change in designation is offered, to explain the basis for the chosen 28 designation. A Challenging Party may proceed to the next stage of the challenge 1 process only if it has engaged in this meet and confer process first or establishes 2 that the Designating Party is unwilling to participate in the meet and confer process 3 in a timely manner. 4 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 5 court intervention, the Designating Party shall file and serve a motion to retain 6 confidentiality within 45 days of the initial notice of challenge or within 30 days of 7 the parties agreeing that the meet and confer process will not resolve their dispute, 8 whichever is earlier. Each such motion must be accompanied by a competent 9 declaration affirming that the movant has complied with the meet and confer 10 requirements imposed in the preceding paragraph. Failure by the Designating Party 11 to make such a motion including the required declaration within 45 days (or 30 12 days, if applicable) shall automatically waive the confidentiality designation for 13 each challenged designation. In addition, the Challenging Party may file a motion 14 challenging a confidentiality designation at any time if there is good cause for doing 15 so, including a challenge to the designation of a deposition transcript or any 16 portions thereof. Any motion brought pursuant to this provision must be 17 accompanied by a competent declaration affirming that the movant has complied 18 with the meet and confer requirements imposed by the preceding paragraph. 19 The burden of persuasion in any such challenge proceeding shall be on the 20 Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 the confidentiality designation by failing to file a motion to retain confidentiality as 24 described above, all parties shall continue to afford the material in question the 25 level of protection to which it is entitled under the Producing Party’s designation 26 until the court rules on the challenge. 27 7. ACCESS TO AND USE OF PROTECTED MATERIAL 28 1 7.1 Basic Principles. A Receiving Party may use Protected Material that is 2 disclosed or produced by another Party or by a Non-Party in connection with this 3 case only for prosecuting, defending, or attempting to settle this litigation. Such 4 Protected Material may be disclosed only to the categories of persons and under the 5 conditions described in this Order. When the litigation has been terminated, a 6 Receiving Party must comply with the provisions of section 13 below (FINAL 7 DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons 10 authorized under this Order. 11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 12 otherwise ordered by the court or permitted in writing by the Designating Party, a 13 Receiving Party may disclose any information or item designated 14 “CONFIDENTIAL” only to: 15 (a) the Receiving Party’s Outside Counsel of Record in this action, as 16 well as employees of said Outside Counsel of Record to whom it is reasonably 17 necessary to disclose the information for this litigation and who have signed the 18 Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 19 A; 20 (b) the officers, directors, and employees (including House Counsel) of 21 the Receiving Party to whom disclosure is reasonably necessary for this litigation 22 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 23 A); 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this litigation and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 1 (e) court reporters, videographers, and their staff, who are not 2 personnel of the court, professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably necessary for this litigation 4 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 5 A); 6 (f) during their depositions, witnesses in the action to whom disclosure 7 is reasonably necessary and who have signed the “Acknowledgment and 8 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 9 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits 10 to depositions that reveal Protected Material must be separately bound by the court 11 reporter and may not be disclosed to anyone except as permitted under this 12 Stipulated Protective Order. Nothing in this paragraph shall limit the use of Ford 13 documents in deposition of Ford representatives or employees who have a 14 legitimate need to see the information based on the intended subject matter of the 15 deposition. 16 (g) the author or recipient of a document containing the information or 17 a custodian who otherwise possessed or knew the information provided that these 18 individuals may only be shown the protected information and may not retain a copy 19 of the protected information that was produced in this case. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 21 IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this action as 24 “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification 26 shall include a copy of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or 28 order to issue in the other litigation that some or all of the material covered by the 1 subpoena or order is subject to this Protective Order. Such notification shall include 2 a copy of this Stipulated Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” or “SUBJECT TO PROTECTIVE ORDER,” before 8 a determination by the court from which the subpoena or order issued, unless the 9 Party has obtained the Designating Party’s permission. The Designating Party shall 10 bear the burden and expense of seeking protection in that court of its confidential 11 material – and nothing in these provisions should be construed as authorizing or 12 encouraging a Receiving Party in this action to disobey a lawful directive from 13 another court. 14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a 17 Non-Party in this action and designated as “CONFIDENTIAL” or “SUBJECT TO 18 PROTECTIVE ORDER.” Such information produced by Non-Parties in connection 19 with this litigation is protected by the remedies and relief provided by this Order. 20 Nothing in these provisions should be construed as prohibiting a Non-Party from 21 seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non- 27 Party that some or all of the information requested is subject to a confidentiality 28 agreement with a Non-Party; 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this litigation, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and 4 (3) make the information requested available for inspection by the 5 Non-Party. 6 (c) If the Non-Party fails to object or seek a protective order from this 7 court within 30 days of receiving the notice and accompanying information, the 8 Receiving Party may produce the Non-Party’s confidential information responsive 9 to the discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party shall not produce any information in its possession or control that 11 is subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the Non-Party shall 13 bear the burden and expense of seeking protection in this court of its Protected 14 Material. 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best 20 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 21 person or persons to whom unauthorized disclosures were made of all the terms of 22 this Order, and (d) request such person or persons to execute the “Acknowledgment 23 and Agreement to Be Bound” that is attached hereto as Exhibit A. 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other 28 protection, the obligations of the Receiving Parties are those set forth in Federal 1 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 2 whatever procedure may be established in an e-discovery order that provides for 3 production without prior privilege review. Pursuant to Federal Rule of Evidence 4 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 5 of a communication or information covered by the attorney-client privilege or work 6 product protection, the parties may incorporate their agreement in the stipulated 7 protective order submitted to the court. 8 12. MISCELLANEOUS 9 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 10 person to seek its modification by the court in the future. 11 12.2 Right to Assert Other Objections. By stipulating to the entry of this 12 Protective Order no Party waives any right it otherwise would have to object to 13 disclosing or producing any information or item on any ground not addressed in 14 this Stipulated Protective Order. Similarly, no Party waives any right to object on 15 any ground to use in evidence of any of the material covered by this Protective 16 Order. 17 12.3 Filing Protected Material. Without written permission from the 18 Designating Party or a court order secured after appropriate notice, or upon another 19 timeframe agreeable under the circumstances, to all interested persons, a Party may 20 not file in the public record in this action any Protected Material. A Party that seeks 21 to file under seal any Protected Material must comply with Local Rule 141. 22 Protected Material may only be filed under seal pursuant to a court order 23 authorizing the sealing of the specific Protected Material at issue. A sealing order 24 will issue only upon a request establishing that the Protected Material at issue is 25 privileged, protectable as a trade secret, or otherwise entitled to protection under the 26 law. If a Receiving Party's request to file Protected Material under seal is denied by 27 the court, then the Receiving Party may file the information in the public record 28 unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 Within 60 days after the final disposition of this action, as defined in 3 paragraph 4, each Receiving Party must return all Protected Material to the 4 Producing Party or destroy such material. As used in this subdivision, “all Protected 5 Material” includes all copies, abstracts, compilations, summaries, and any other 6 format reproducing or capturing any of the Protected Material. Whether the 7 Protected Material is returned or destroyed, the Receiving Party must submit a 8 written certification to the Producing Party (and, if not the same person or entity, to 9 the Designating Party) by the 60 day deadline that (1) identifies (by category, where 10 appropriate) all the Protected Material that was returned or destroyed and (2) 11 affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if 17 such materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). With respect to those materials that this provision allows 20 the Receiving Party to retain after final disposition of this action, exhibits to the 21 retained materials must be returned to the Producing Party or destroyed on or before 22 5 years after final disposition (as defined in Section 4: DURATION) of this 23 action. The parties agree to meet and confer prior to moving to enforce compliance 24 with this provision. 25 26 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 27 Dated: May 10, 2024 STRATEGIC LEGAL PRACTICES, A 28 1 By /s/ Elizabeth A. LaRocque Elizabeth A. LaRocque 2 Attorneys for Plaintiff LAUREN TAYLOR 3 4 5 Dated: May 10, 2024 GORDON REES SCULLY MANSUKHANI, LLP 6 7 8 By: /s/ Trina M. Clayton 9 Spencer P. Hugret 10 Katherine P. Vilchez Trina M. Clayton 11 Kenneth Hollenbeck Attorneys for Defendant 12 FORD MOTOR COMPANY 13 14 ORDER 15 GOOD CAUSE APPEARING, the Court hereby approves this Stipulated Protective Order. 16 IT IS SO ORDERED. 17 18 DATED: _________________ _________________________________ 19 Hon. Kimberly J. Mueller United States Magistrate Judge 20 21 22 23 24 25 26 27 28 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 Eastern District of California 7 on [ ] in the case Lauren Taylor v. Ford Motor Company, et 8 al. Case No. 2:23-cv-03031-KJM-CSK. I agree to comply with and to be bound by 9 all the terms of this Stipulated Protective Order and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the nature 11 of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Eastern District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: 25 _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 1 CERTIFICATE OF SERVICE 2 3 I, the undersigned, declare that I am over the age of 18 and am not a party to 4 this action. I am employed in the City of Los Angeles, California; my business 5 address is Strategic Legal Practices, A Professional Corporation at 1888 Century 6 Park East, Floor 19, Los Angeles, California 90067. 7 On the date below, I served a copy of the foregoing document entitled: 8 STIPULATED [PROPOSED] PROTECTIVE ORDER – DISCOVERY ONLY 9 on the interested parties in said case as follows: 10 11 Served Electronically Via the Court’s CM/ECF System 12 13 I declare under penalty of perjury under the laws of the United States of 14 America that the foregoing is true and correct. I declare that I am employed in the 15 office of a member of the Bar of this Court, at whose direction the service was 16 made. This declaration is executed in Los Angeles, California on May 20, 2024. 17 18 19 /s/ Elizabeth A. LaRocque 20 Elizabeth A. LaRocque 21 22 23 24 25 26 27 28