David MacTavish et al v. American Honda Motor Co., Inc. et al

Filing 60

STIPULATED PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 59 . [See Order for details.] (es)

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ROBERT AHDOOT (SBN 172098)
[e-mail]
TINA WOLFSON (SBN 174806)
[e-mail]
AHDOOT & WOLFSON, PC
2600 W. Olive Avenue, Suite 500
Burbank, CA 91505-4521
Telephone: [phone]
Facsimile: 310.474.8585
ANDREW W. FERICH*
[e-mail]
AHDOOT & WOLFSON, PC
201 King of Prussia Road, Suite 650
Radnor, PA 19087
Telephone: [phone]

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Attorneys for Plaintiffs and the Putative
Class (*admitted pro hac vice)

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[Additional counsel on signature page]

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IN THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
DAVID MACTAVISH, et al.,
individually and on behalf of all others
similarly situated,

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STIPULATED PROTECTIVE
ORDER

Plaintiffs,
CLASS ACTION

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No. 2:21-cv-04289-GW-JEM

v.
AMERICAN HONDA MOTOR CO.,
INC.,

Second Am. Class Action Compl.
Filed: November 12, 2021

Defendant.

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STIPULATED PROTECTIVE ORDER

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1.

INTRODUCTION

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1.1

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Disclosure and discovery in this action are likely to involve production of

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confidential, proprietary, or private information for which special protection from

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public disclosure and from use for any purpose other than prosecuting this litigation

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may be warranted. Accordingly, the parties hereby stipulate to and petition the Court

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to enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles. The parties further acknowledge, as set forth

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in Section 12.3, below, that this Stipulated Protective Order does not entitle them to

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file confidential information under seal; Civil Local Rule 79-5 sets forth the

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

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seeks permission from the Court to file material under seal.

PURPOSES AND LIMITATIONS

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1.2

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This action is likely to involve confidential information, including trade

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secrets and other valuable research, development, commercial, financial,

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technical, and/or proprietary information for which special protection from public

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disclosure and from use for any purpose other than prosecution of this Action may

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be warranted. Such confidential and proprietary materials and information may

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consist of, among other things, confidential business or financial information,

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information regarding confidential business practices, or other confidential

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research, development, or commercial information (including information

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implicating privacy rights of third parties), information otherwise generally

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unavailable to the public, or which may be privileged or otherwise protected from

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disclosure under state or federal statutes, court rules, case decisions, or common

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law. Accordingly, to expedite the flow of information, to facilitate the prompt

GOOD CAUSE STATEMENT

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STIPULATED PROTECTIVE ORDER

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resolution of disputes over confidentiality of discovery materials, and to

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adequately protect information the parties are entitled to keep confidential, to

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ensure that the Parties are permitted reasonable necessary uses of such material in

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

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

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is justified in this matter. It is the intent of the parties that information will not be

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designated as confidential for tactical reasons and that nothing be so designated

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without a good faith belief that it has been maintained in a confidential, non-public

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manner, and there is good cause why it should not be part of the public record of

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this case.

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2.

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DEFINITIONS
2.1

Action: MacTavish, et al. v. American Honda Motor Co., Inc., Case No.

2:21-cv-04289-GW-JEM (C.D. Cal.).
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Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

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how it is generated, stored or maintained) or tangible things that qualify for

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protection under Federal Rule of Civil Procedure 26(c), and as specified above in

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the Good Cause Statement.

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2.4

Conflicted Expert: any consultant, investigator, or Expert (a) who is an

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employee of an Automobile Manufacturer Competitor (as defined herein) of a

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Honda Entity (as defined herein); (b) who was in the employ of an Automobile

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Manufacturer Competitor of a Honda Entity 1 year prior to the time disclosure is

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made; or (c) who is serving as a consultant to an Automobile Manufacturer

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Competitor of a Honda Entity on matters relating to the tailgate wiring harness,

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backup camera, and other connected vehicle component(s) at issue in this Action.

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An “Automobile Manufacturer Competitor” refers to any company that

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manufactures or distributes automobiles equipped with tailgate wiring harnesses or
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STIPULATED PROTECTIVE ORDER

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backup cameras, and any suppliers of such tailgate wiring harnesses or backup

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cameras. Protected Material may not be disclosed under any circumstances to a

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Conflicted Expert. “Honda Entity” currently refers to any of the following:

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American Honda Motor Co., Inc. (“AHM”), Honda Motor Co., Ltd. (“HMC”),

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Honda R&D Co., Ltd. (“HRD”), Honda R&D Americas, Inc. (“HRA”), Honda of

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America Mfg., Inc. (“HAM”), Honda of Canada Mfg. (“HCM”), Honda de Mexico,

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S.A. de C.V. (“HDM”), Honda of the UK Manufacturing Ltd. (“HUM”), Honda

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Manufacturing of Indiana, LLC (“HMIN”), Honda Manufacturing of Alabama, LLC

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(“HMA”), or Honda Development & Manufacturing of America, LLC (HDMA)

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(each a “Honda Entity” or collectively, the “Honda Entities”). To the extent that a

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new or different Honda entity emerges during this litigation, the Parties shall meet

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and confer about revising the definition of “Honda Entity” as appropriate.

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2.5

Counsel (without qualifier): Outside Counsel of Record and House

Counsel (as well as their support staff).
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Designating Party: a Party or Non-Party that designates Disclosure or

Discovery Material as “CONFIDENTIAL.”
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Disclosure or Discovery Material: all items or information, regardless

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of the medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things), that are produced or

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generated in disclosures or responses to discovery in this matter.

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2.8

Expert: a person with specialized knowledge or experience in a matter

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pertinent to the litigation who has been retained by a Party or its counsel to serve as

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an expert witness or as a consultant in this Action. For purposes of this Stipulated

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Protective Order, the term “Expert” excludes any “Conflicted Expert.”

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2.9

House Counsel: attorneys who are employees of a party to this Action.

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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.

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2.10 Non-Party: any natural person, partnership, corporation, association, or
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STIPULATED PROTECTIVE ORDER

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

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

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

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appeared in this Action on behalf of that party or are affiliated with a law firm which

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has appeared on behalf of that party, and includes support staff.

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

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).

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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

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2.14 Professional Vendors: persons or entities that provide litigation support

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium)

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and their employees and subcontractors.

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2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”

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

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from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

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

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presentations by Parties or their Counsel that might reveal Protected Material.

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The protections conferred by this Stipulation and Order do not cover the

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following information: (a) any information that is in the public domain at the time

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of disclosure to a Receiving Party or becomes part of the public domain after its

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disclosure to a Receiving Party as a result of publication not involving a violation of
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STIPULATED PROTECTIVE ORDER

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this Order, including becoming part of the public record through trial or otherwise;

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and (b) any information known to the Receiving Party prior to the disclosure or

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obtained by the Receiving Party after the disclosure from a source who obtained the

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information lawfully and under no obligation of confidentiality to the Designating

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Party.

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Neither this paragraph, nor anything else in this Stipulated Protective Order,

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will require a Receiving Party to evaluate whether any document it has lawfully

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obtained from the public domain or from a third-party is also a document a

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Designating Party has designated as CONFIDENTIAL.

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Any use of Protected Material at trial will be governed by the orders of the

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trial judge. This Order does not govern the use of Protected Material at trial.

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4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees

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otherwise in writing or a court order otherwise directs. Final disposition shall be

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deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

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or without prejudice; and (2) final judgment herein after the completion and

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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including the time limits for filing any motions or applications for extension of time

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pursuant to applicable law.

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The Court shall retain jurisdiction, both before and after the entry of a final

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judgment in this case, whether by settlement or adjudication, to construe, enforce,

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and amend the provisions of this Order.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for
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STIPULATED PROTECTIVE ORDER

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protection only those parts of material, documents, items, or oral or written

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communications that qualify – so that other portions of the material, documents,

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items, or communications for which protection is not warranted are not swept

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unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose

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unnecessary expenses and burdens on other parties) may expose the Designating

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

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

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Party must promptly notify all other Parties that it is withdrawing the inapplicable

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designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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this Order (see, e.g., second paragraph of section 5.2(a) and section 5.3(b) below),

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or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies

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for protection under this Order must be clearly so designated before the material is

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disclosed or produced.

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Designation in conformity with this Order requires:

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(a)

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

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documents, but excluding transcripts of depositions or other pretrial or

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trial proceedings), that the Producing Party affix the legend

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“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) to each

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page that contains protected material.

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A Party or Non-Party that makes original documents or materials

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available for inspection need not designate them for protection until

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after the inspecting Party has indicated which material it would like

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copied and produced. During the inspection and before the designation,

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all of the material made available for inspection shall be deemed
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STIPULATED PROTECTIVE ORDER

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“CONFIDENTIAL.” After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for protection

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under this Order. Then, before producing the specified documents, the

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Producing Party must affix the “CONFIDENTIAL legend” to each

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page that contains Protected Material. If only a portion or portions of

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the material on a page qualifies for protection, the Producing Party also

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must clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins).

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(b)

for testimony given in depositions, that the Designating Party make

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designations of Protected Material within 30 days after the transcript is

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delivered. All deposition testimony taken in this case shall be treated as

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Protected Material until the expiration of the thirtieth day after the

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transcript is delivered to any party or the witness. Within this time

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period, a Designating Party may serve a Notice of Designation to all

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parties of record as to specific portions of the testimony that are

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designated Protected Material, and thereafter only those portions

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identified in the Notice of Designation shall be protected by the terms

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of this Order.

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(c)

for testimony given in other pretrial proceedings, that the Designating

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Party identify on the record, before the close of the hearing or other

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proceeding, all protected testimony. When it is impractical to identify

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separately each portion of testimony that is entitled to protection, the

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Designating Party may invoke on the record (before the hearing or other

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proceeding is concluded) a right to have up to 30 days to identify the

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specific portions of the testimony as to which protection is sought.

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(d)

for information produced in some form other than documentary and for
any other tangible items, that the Producing Party affix in a prominent
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STIPULATED PROTECTIVE ORDER

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

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

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portion or portions of the information or item warrant protection, the

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Producing Party, to the extent practicable, shall identify the protected

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portion(s).

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5.3

Inadvertent Failures to Designate. If promptly corrected by a

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Designating Party upon its discovery of an inadvertent failure to designate qualified

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information, an inadvertent failure to designate qualified information or items does

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not, standing alone, waive the Designating Party’s right to secure protection under

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this Order for such material. Upon timely correction of a designation, the Receiving

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Party must make reasonable efforts to assure that the material is treated in

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accordance with the provisions of this Order.

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

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designation of confidentiality at any time that is consistent with the Court’s

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Scheduling Order. Unless a prompt challenge to a Designating Party’s

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confidentiality designation is necessary to avoid foreseeable, substantial unfairness,

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unnecessary economic burdens, or a significant disruption or delay of the litigation,

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a Party does not waive its right to challenge a confidentiality designation by electing

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not to mount a challenge promptly after the original designation is disclosed.

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6.2

Meet and Confer; Judicial Intervention. The Challenging Party will

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initiate the dispute resolution process (and, if necessary, file a discovery motion)

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under Local Rule 37-1, et seq. With respect to the preparation of the Joint Stipulation

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required under L.R. 37-2.2, if the Parties cannot resolve a challenge after good faith

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efforts to meet and confer under Local Rule 37-1, unless the parties agree otherwise,

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counsel for the opposing party shall have fourteen (14) days following the receipt of

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the moving party’s material to e-mail to counsel for the moving party the opposing

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party’s portion of the stipulation, together with all declarations and exhibits to be
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STIPULATED PROTECTIVE ORDER

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offered in support of the opposing party’s position.

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6.3

The burden of persuasion in any such challenge proceeding will be

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on the Designating Party. Challenges made for an improper purpose (e.g., to

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harass or impose unnecessary expenses and burdens on other parties) may expose

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the Challenging Party to sanctions. Unless the Designating Party has waived or

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withdrawn the confidentiality designation, all parties will continue to afford the

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

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

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

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disclosed or produced by another Party or by a Non-Party in connection with this

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Action only for prosecuting, defending, or attempting to settle this Action. Such

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Protected Material may be disclosed only to the categories of persons and under the

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conditions described in this Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of section 13 below (FINAL

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DISPOSITION).

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise ordered by the Court or permitted in writing by the Designating Party, a

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Receiving

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“CONFIDENTIAL” only to:

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(a)

Party

may

disclose

any

information

or

item

designated

the Receiving Party’s Outside Counsel of Record in this action, as well

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as employees of said Outside Counsel of Record to whom it is

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reasonably necessary to disclose the information for this litigation and

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who have signed the “Acknowledgment and Agreement to Be Bound”

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that is attached hereto as Exhibit A;
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STIPULATED PROTECTIVE ORDER

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(b)

the officers, directors, and employees (including House Counsel) of the

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Receiving Party to whom disclosure is reasonably necessary for this

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litigation;

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(c)

Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary for this Action and who have signed

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

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(d)

the Court and its personnel;

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(e)

court reporters and their staff;

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(f)

professional jury or trial consultants (but not including mock jurors),

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and Professional Vendors to whom disclosure is reasonably necessary

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for this Action and who have signed the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A);

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(g)

the author or recipient of a document containing the information or a

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custodian or other person who otherwise possessed or knew the

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information;

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(h)

during their depositions, witnesses, and attorneys for witnesses, in the

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Action to whom disclosure is reasonably necessary provided: (1) the

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witness and witness’s attorney (with the exception of the Parties and

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counsel of record for the Parties) have signed the “Acknowledgment

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and Agreement to Be Bound” (Exhibit A) and (2) they will not be

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permitted to keep any confidential information unless they sign the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

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otherwise agreed by the Designating Party or ordered by the Court.

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Pages of transcribed deposition testimony or exhibits to depositions that

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reveal Protected Material must be separately bound by the court

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

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this Stipulated Protective Order; and

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(i)

any mediator or settlement officer, and their supporting personnel,
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mutually agreed upon by any of the parties engaged in settlement

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discussions.

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8.

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PROTECTED MATERIAL SUBPOENAED
PRODUCED IN OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation

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that compels disclosure of any information or items designated in this Action as

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“CONFIDENTIAL,” that Party must:
(a)

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OR

ORDERED

promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;

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(b)

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promptly notify in writing the party who caused the subpoena or order

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

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

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notification shall include a copy of this Stipulated Protective Order; and
(c)

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cooperate with respect to all reasonable procedures sought to be

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pursued by the Designating Party whose Protected Material may be

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affected.

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this

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action as “CONFIDENTIAL” before a determination by the court from which the

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subpoena or order issued, unless the Party has obtained the Designating Party’s

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permission. The Designating Party shall bear the burden and expense of seeking

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protection in that court of its confidential material – and nothing in these provisions

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should be construed as authorizing or encouraging a Receiving Party in this Action

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to disobey a lawful directive from another court.

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9.

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A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a)

The terms of this Order are applicable to information produced by a
Non-Party in this Action and designated as “CONFIDENTIAL.” Such
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information produced by Non-Parties in connection with this litigation

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is protected by the remedies and relief provided by this Order. Nothing

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in these provisions should be construed as prohibiting a Non-Party from

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seeking additional protections.

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(b)

In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party’s confidential information in its possession, and

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the Party is subject to an agreement with the Non-Party not to produce

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the Non-Party’s confidential information, then the Party will:

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1. promptly notify in writing the Requesting Party and the Non-

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

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a confidentiality agreement with a Non-Party;

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2. promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this Action, the relevant discovery

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request(s), and a reasonably specific description of the

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information requested; and

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3. make the information requested available for inspection by the

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Non-Party, if requested.
(c)

If the Non-Party fails to object or seek a protective order from this Court

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within twenty-one (21) days of receiving the notice and accompanying

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information, the Receiving Party may produce the Non-Party’s

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confidential information responsive to the discovery request. If the

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

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

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the confidentiality agreement with the Non-Party before a

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determination by the Court. Absent a Court order to the contrary, the

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Non-Party shall bear the burden and expense of seeking protection in

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this Court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

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to retrieve all unauthorized copies of the Protected Material, (c) inform the person

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or persons to whom unauthorized disclosures were made of all the terms of this

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Order, and (d) request such person or persons to execute the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A).

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other protection,

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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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may be established in an e-discovery order that provides for production without prior

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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parties may incorporate their agreement in the stipulated protective order submitted

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to the court.

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12.

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11.

MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any

person to seek its modification by the Court in the future.

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12.2 Right to Assert Other Objections. By stipulating to the entry of this

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Protective Order no Party waives any right it otherwise would have to object to

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disclosing or producing any information or item on any ground not addressed in this

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Stipulated Protective Order. Similarly, no Party waives any right to object on any
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ground to use in evidence of any of the material covered by this Protective Order.

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12.3 Filing Protected Material. Without written permission from the

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Designating Party or a Court order secured after appropriate notice to all interested

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persons, a Party may not file in the public record in this action any Protected

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Material. This provision shall not prohibit a Party from using information it/they

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lawfully obtained from the public domain or from a third-party independent of

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information derived from Protected Material.

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A Party that seeks to file under seal any Protected Material must comply with

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Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to

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

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Party's request to file Protected Material under seal is denied by the court, then the

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Receiving Party may file the information in the public record in compliance with

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Civil Local Rule 79-5.2.2 unless otherwise instructed by the Court.

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13.

FINAL DISPOSITION

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Within 90 days after the final disposition of this Action, as defined in

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paragraph 4, each Receiving Party must return all Protected Material to the

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Producing Party or destroy such material. As used in this subdivision, “all Protected

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Material” includes all copies, abstracts, compilations, summaries, and any other

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format reproducing or capturing any of the Protected Material. Whether the

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Protected Material is returned or destroyed, the Receiving Party must submit a

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written certification to the Producing Party (and, if not the same person or entity, to

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the Designating Party) by the 90-day deadline that (1) identifies (by category, where

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appropriate) all the Protected Material that was returned or destroyed; and (2) affirms

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that the Receiving Party has not retained any copies, abstracts, compilations,

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summaries or any other format reproducing or capturing any of the Protected

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Material. Notwithstanding this provision, Counsel are entitled to retain an archival

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copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

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memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
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STIPULATED PROTECTIVE ORDER

1

work product, and consultant and expert work product, even if such materials contain

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in Section 4 above

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(DURATION).

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14.

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evidentiary sanctions, or other appropriate action at the discretion of the Court.

Any willful violation of this Order may be punished by financial or

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: February 24, 2022

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Respectfully submitted,
/s/ Robert R. Ahdoot
ROBERT R. AHDOOT (SBN 172098)
[e-mail]
TINA WOLFSON (SBN 174806)
[e-mail]
AHDOOT & WOLFSON, PC
2600 W. Olive Avenue, Suite 500
Burbank, California 91505
Telephone: [phone]
ANDREW W. FERICH (pro hac vice)
[e-mail]
AHDOOT & WOLFSON, PC
201 King of Prussia Road, Suite 650
Radnor, PA 19087
Telephone: [phone]
BEN BARNOW (pro hac vice)
[e-mail]
ANTHONY PARKHILL (pro hac vice)
[e-mail]
BARNOW AND ASSOCIATES, P.C.
205 W. Randolph Street, Suite 1630
Chicago, IL 60606
Telephone: [phone]
Counsel for Plaintiffs and the
Putative Class

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STIPULATED PROTECTIVE ORDER

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2

DATED: February 24, 2022

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Attorneys for Defendant
American Honda Motor Co., Inc.

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/s/ William A. Delgado
William A. Delgado
[e-mail]
Megan O’Neill
[e-mail]
Justin T. Goodwin
[e-mail]
DTO LAW
601 South Figueroa Street, Suite 2130
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: 2/24/2022

________________________________
HON. JOHN E. MCDERMOTT
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

_____________________________

[full

name],

of

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_________________ [full address], declare under penalty of perjury that I have

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read in its entirety and understand the Stipulated Protective Order that was issued

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by the United States District Court for the Central District of California on [date]

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in the case of MacTavish, et al. v. American Honda Motor Co., Inc., USDC C.D

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Cal. Case No. 2:21-cv-04289-GHW-JEM. I agree to comply with and to be bound

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by all the terms of this Stipulated Protective Order and I understand and

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acknowledge that failure to so comply could expose me to sanctions and

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punishment in the nature of contempt. I solemnly promise that I will not disclose

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in any manner any information or item that is subject to this Stipulated Protective

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Order to any person or entity except in strict compliance with the provisions of

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this Order.

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I further agree to submit to the jurisdiction of the United States District

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Court for the Central District of California for the purpose of enforcing the terms

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of this Stipulated Protective Order, even if such enforcement proceedings occur

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after termination of this action. I hereby appoint __________________________

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[full name] of _______________________________________ [full address

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and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this

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Stipulated Protective Order.

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Date: ______________________________________

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City and State where signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________

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STIPULATED PROTECTIVE ORDER
215325.1