Raul Martinez et al v. Knight Transportation, Inc. et al

Filing 11

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym (SEE ORDER FOR DETAILS). (kca)

Case 5:21-cv-00572-JWH-SP Document 11 Filed 07/19/21 Page 1 of 18 Page ID #:207

1 Jonathan M. Lebe (State Bar No. 284605)
[e-mail]
2
Annaliz Loera (State Bar No. 334129)
3 [e-mail]
Lebe Law, APLC
4
777 S. Alameda Street, Second Floor
5 Los Angeles, CA 90021
Telephone: [phone]
6
Facsimile: [phone]
7
Attorneys for Plaintiffs RAUL MARTINEZ,
8
PHILIPPE VIEUX, Individually
9 and on behalf of all others similarly situated
10
11

Counsel of Record for Defendants on the Following Page

12

UNITED STATES DISTRICT COURT

13

CENTRAL DISTRICT OF CALIFORNIA, EASTERN DIVISION

14
15 RAUL MARTINEZ, PHILIPPE
VIEUX, Individually and on behalf of
16 all others similarly situated,
17

Case No. 5:21−cv−00572 JWH (SPx)
Hon. John W. Holcomb, Crtrm. 2

Plaintiff,

STIPULATED PROTECTIVE
ORDER

19 KNIGHT TRANSPORTATION, INC.
Which Will Do Business In California
20 As Arizona Knight Transportation, Inc.;
And Does 1 Through 20, Inclusive,
21
Defendants.
22

[Removed from San Bernardino
Superior Court, Case No.
CIVDS2015264]

18

v.

Complaint Filed: July 8, 2020
None
Trial Date:

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SMRH:4852-5092-4014.2

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Case No. 5:21−cv−00572 JWH (SPx)
STIPULATED PROTECTIVE ORDER

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1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
2
PAUL S. COWIE, Cal. Bar No. 250131
3 JOHN ELLIS, Cal. Bar No. 269221
FATEMEH S. MASHOUF, Cal. Bar No. 288667
4 Four Embarcadero Center, 17th Floor
San Francisco, California 94111-4109
5 Telephone: [phone]
Facsimile: 415.434.3947
[e-mail]
6 Email
[e-mail]
[e-mail]
7
8 Attorneys for Defendant KNIGHT
TRANSPORTATION, INC.
9
10
11
12
13
14
15
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17
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Case No. 5:21−cv−00572 JWH (SPx)
STIPULATED PROTECTIVE ORDER

Case 5:21-cv-00572-JWH-SP Document 11 Filed 07/19/21 Page 3 of 18 Page ID #:209

1 1.

A. PURPOSES AND LIMITATIONS

2

Discovery in this action is likely to involve production of confidential,

3 proprietary, or private information for which special protection from public disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
11 that this Stipulated Protective Order does not entitle them to file confidential
12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
13 followed and the standards that will be applied when a party seeks permission from
14 the court to file material under seal.
15
16 B. GOOD CAUSE STATEMENT
17

This action is likely to involve production of internal policy documents that

18 Defendant considers confidential. This action is also likely to involve customer,
19 employee, compensation, pricing and other valuable research, development,
20 commercial, financial, and/or proprietary information for which special protection
21 from public disclosure is warranted. Such confidential materials and information
22 consist of, among other things, proprietary business or financial information,
23 information regarding confidential business practices, or other confidential research,
24 development, or commercial information. Furthermore, private employment and
25 compensation data is likely to be implicated in discovery.
26
27
28
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1

Accordingly, a protective order is necessary to adequately protect information

2 the parties are entitled to keep confidential, and to protect the parties and third parties
3 from annoyance, embarrassment, oppression, or undue burden or expense. It is the
4 intent of the parties that information will not be designated as confidential for tactical
5 reasons and that nothing be so designated without a good faith belief that it has been
6 maintained in a confidential, non-public manner, and there is good cause why it
7 should not be part of the public record of this case.
8
9 2.
10

DEFINITIONS
2.1

Action: Raul Martinez and Philippe Vieux v. Knight Transportation,

11 Inc., Case No. 5:21−cv−00572 JWH (SPx)
12

2.2

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

13 of information or items under this Order.
14

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
17 Cause Statement.
18

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as their

19 support staff).
20

2.5

Designating Party: a Party or Non-Party that designates information or

21 items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23

2.6

Disclosure or Discovery Material: all items or information, regardless

24 of the medium or manner in which it is generated, stored, or maintained (including,
25 among other things, testimony, transcripts, and tangible things) that are produced or
26 generated in disclosures or responses to discovery in this matter.
27
28
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STIPULATED PROTECTIVE ORDER

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1

2.7

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

2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4

2.8

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

5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7

2.9

Non-Party: any natural person, partnership, corporation, association or

8 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 party

10 to this Action but are retained to represent or advise a party to this Action and have
11 appeared in this Action on behalf of that party or are affiliated with a law firm that
12 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 support

19 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 Material

25 from a Producing Party.
26 ///
27 ///
28 ///
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STIPULATED PROTECTIVE ORDER

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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 extracted
4 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
5 Protected Material; and (3) any testimony, conversations, or presentations by Parties
6 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

Even after final disposition of this litigation, the confidentiality obligations

12 imposed by this Order shall remain in effect until a Designating Party agrees
13 otherwise in writing or a court order otherwise directs. Final disposition shall be
14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
15 or without prejudice; and (2) final judgment herein after the completion and
16 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
17 including the time limits for filing any motions or applications for extension of time
18 pursuant to applicable law.
19
20 5.

DESIGNATING PROTECTED MATERIAL

21

5.1

Exercise of Restraint and Care in Designating Material for Protection.

22 Each Party or Non-Party that designates information or items for protection under this
23 Order must take care to limit any such designation to specific material that qualifies
24 under the appropriate standards. The Designating Party must designate for protection
25 only those parts of material, documents, items or oral or written communications that
26 qualify so that other portions of the material, documents, items or communications
27 for which protection is not warranted are not swept unjustifiably within the ambit of
28 this Order.
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1

Mass, indiscriminate or routinized designations are prohibited. Designations

2 that are shown to be clearly unjustified or that have been made for an improper
3 purpose (e.g., to unnecessarily encumber the case development process or to impose
4 unnecessary expenses and burdens on other parties) may expose the Designating Party
5 to sanctions.
6

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

7 designated for protection do not qualify for protection, that Designating Party must
8 promptly notify all other Parties that it is withdrawing the inapplicable designation.
9

5.2

Manner and Timing of Designations. Except as otherwise provided in

10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
12 under this Order must be clearly so designated before the material is disclosed or
13 produced.
14
15

Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic

16 documents, but excluding transcripts of depositions or other pretrial or trial
17 proceedings), that the Producing Party affix at a minimum, the legend
18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 contains protected material. If only a portion of the material on a page qualifies for
20 protection, the Producing Party also must clearly identify the protected portion(s)
21 (e.g., by making appropriate markings in the margins).
22
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25
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1

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

2 need not designate them for protection until after the inspecting Party has indicated
3 which documents it would like copied and produced. During the inspection and
4 before the designation, all of the material made available for inspection shall be
5 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
6 it wants copied and produced, the Producing Party must determine which documents,
7 or portions thereof, qualify for protection under this Order. Then, before producing
8 the specified documents, the Producing Party must affix the “CONFIDENTIAL
9 legend” to each page that contains Protected Material. If only a portion or portions
10 of the material on a page qualifies for protection, the Producing Party also must clearly
11 identify the protected portion(s) (e.g., by making appropriate markings in the
12 margins).
13

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

14 the Disclosure or Discovery Material on the record, before the close of the deposition
15 all protected testimony.
16

(c) for information produced in some form other than documentary and

17 for any other tangible items, that the Producing Party affix in a prominent place on
18 the exterior of the container or containers in which the information is stored the legend
19 “CONFIDENTIAL.” If only a portion or portions of the information warrants
20 protection, the Producing Party, to the extent practicable, shall identify the protected
21 portion(s).
22

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

23 failure to designate qualified information or items does not, standing alone, waive the
24 Designating Party’s right to secure protection under this Order for such material.
25 Upon timely correction of a designation, the Receiving Party must make reasonable
26 efforts to assure that the material is treated in accordance with the provisions of this
27 Order.
28
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1

5.4

Withdrawal of Designation. At any time in the Action, a Producing Party

2

may waive or withdraw the confidentiality designation by informing the non-

3

Producing Party in writing of the specific materials for which the designation is being

4

removed/altered. The non-Producing Party shall have up to five business days to

5

request that the confidentiality designation remain; in such a case, the non-Producing

6

Party becomes the Producing Party for purposes of any procedures for dealing with

7

the designation as dictated in the Protective Order. Parties need not seek Court

8

intervention in order to alter a confidentiality designation where neither Party has

9

objected to the change pursuant to this paragraph or where it is the Producing Party

10

that has given notice to remove the confidentiality designation.

11
12
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20
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1 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

2

6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
5

6.2

Meet and Confer.

The challenging Party shall initiate the dispute

6 resolution process under Local Rule 37.1 et seq.
7

6.3

The burden of persuasion in any such challenge proceeding shall be on

8 the Designating Party. Frivolous challenges, and those made for an improper purpose
9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
10 expose the Challenging Party to sanctions. Unless the Designating Party has waived
11 or withdrawn the confidentiality designation, all parties shall continue to afford the
12 material in question the level of protection to which it is entitled under the Producing
13 Party’s designation until the Court rules on the challenge.
14
15 7.

ACCESS TO AND USE OF PROTECTED MATERIAL

16

7.1

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

17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a Receiving
21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
22

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

23 location and in a secure manner that ensures that access is limited to the persons
24 authorized under this Order.
25

7.2

Disclosure of “CONFIDENTIAL” Information or Items.

Unless

26 otherwise ordered by the court or permitted in writing by the Designating Party, a
27 Receiving

Party

may

disclose

any

information

or

item

designated

28 “CONFIDENTIAL” only to:
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1

(a) the Receiving Party’s Outside Counsel of Record in this Action, as

2 well as employees of said Outside Counsel of Record to whom it is reasonably
3 necessary to disclose the information for this Action;
4

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

5 the Receiving Party to whom disclosure is reasonably necessary for this Action;
6

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

7 disclosure is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
9

(d) the court and its personnel;

10

(e) court reporters and their staff;

11

(f) professional jury or trial consultants, mock jurors, and Professional

12 Vendors to whom disclosure is reasonably necessary for this Action and who have
13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14

(g) the author or recipient of a document containing the information or

15 a custodian or other person who otherwise possessed or knew the information;
16

(h) during their depositions, witnesses, and attorneys for witnesses, in

17 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
18 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they
19 will not be permitted to keep any confidential information unless they sign the
20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
21 agreed by the Designating Party or ordered by the court. Pages of transcribed
22 deposition testimony or exhibits to depositions that reveal Protected Material may be
23 separately bound by the court reporter and may not be disclosed to anyone except as
24 permitted under this Stipulated Protective Order; and
25

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

26 mutually agreed upon by any of the parties engaged in settlement discussions.
27
28
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1 8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

2 OTHER LITIGATION
3

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

4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6

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

7 include a copy of the subpoena or court order;
8

(b) promptly notify in writing the party who caused the subpoena or order to

9 issue in the other litigation that some or all of the material covered by the subpoena
10 or order is subject to this Protective Order. Such notification shall include a copy of
11 this Stipulated Protective Order; and
12

(c) cooperate with respect to all reasonable procedures sought to be pursued

13 by the Designating Party whose Protected Material may be affected.
14

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

15 the subpoena or court order shall not produce any information designated in this action
16 as “CONFIDENTIAL” before a determination by the court from which the subpoena
17 or order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party shall bear the burden and expense of seeking protection in that court
19 of its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
21 directive from another court.
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
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1 9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

2 PRODUCED IN THIS LITIGATION
3

(a) The terms of this Order are applicable to information produced by a Non-

4 Party in this Action and designated as “CONFIDENTIAL.”

Such information

5 produced by Non-Parties in connection with this litigation is protected by the
6 remedies and relief provided by this Order. Nothing in these provisions should be
7 construed as prohibiting a Non-Party from seeking additional protections.
8

(b) In the event that a Party is required, by a valid discovery request, to produce

9 a Non-Party’s confidential information in its possession, and the Party is subject to an
10 agreement with the Non-Party not to produce the Non-Party’s confidential
11 information, then the Party shall:
12

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

13 that some of all of the information requested is subject to a confidentiality agreement
14 with a Non-Party;
15

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

16 Protective Order in this Action, the relevant discovery request(s), and a reasonably
17 specific description of the information requested; and
18

(3) make the information requested available for inspection by the Non-

19 Party, if requested.
20

(c) If the Non-Party fails to seek a protective order from this court within 14

21 days of receiving the notice and accompanying information, the Receiving Party may
22 produce the Non-Party’s confidential information responsive to the discovery request.
23 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
24 any information in its possession or control that is subject to the confidentiality
25 agreement with the Non-Party before a determination by the court. Absent a court
26 order to the contrary, the Non-Party shall bear the burden and expense of seeking
27 protection in this court of its Protected Material.
28
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1 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

2

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

3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of this Order,
8 and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” that is attached hereto as Exhibit A.
10
11 11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

12 PROTECTED MATERIAL
13

When a Producing Party gives notice to Receiving Parties that certain

14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted
22 to the court.
23
24 12.

MISCELLANEOUS

25

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

26 person to seek its modification by the Court in the future.
27
28
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1

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

2 Protective Order no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6

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

7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
8 only be filed under seal pursuant to a court order authorizing the sealing of the specific
9 Protected material at issue. If a Party’s request to file Protected Material under seal
10 is denied by the court, then the Receiving Party may file the information in the public
11 record unless otherwise instructed by the court.
12 ///
13 ///
14 ///
15 ///
16 ///
17 ///
18 ///
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
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1 13.

FINAL DISPOSITION

2

After the final disposition of this Action, as defined in paragraph 4, within 60

3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected material to the Producing Party or destroy such material. As used in this
5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
11 destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 abstracts, compilations, summaries or any other format reproducing or capturing any
13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 retain an 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 such
17 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).
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
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STIPULATED PROTECTIVE ORDER

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1 14.

Any violation of this Order may be punished by any and all appropriate

2 measures including, without limitation, contempt proceedings and/or monetary
3 sanctions.
4
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD
6

July 15, 2021
7 DATED: _____________________________
8
/s/ Jonathan M. Lebe
9 _______________________________________
Jonathan M. Lebe
10
Annaliz Loera
11 Attorneys for Plaintiff
12
13

July 15, 2021
DATED: _____________________________

14
15

/s/ Fatemeh S. Mashouf
_______________________________________
16 Paul S. Cowie
John Ellis
17
Fatemeh S. Mashouf
18 Attorneys for Defendant
19
20
21
22
23

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: July 19, 2021

24

_______________________________________
25 Honorable Sheri Pym
26 United States Magistrate Judge
27
28
SMRH:4852-5092-4014.2

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Case No. 5:21−cv−00572 JWH (SPx)
STIPULATED PROTECTIVE ORDER

Case 5:21-cv-00572-JWH-SP Document 11 Filed 07/19/21 Page 18 of 18 Page ID #:224

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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4 I, _____________________________ [print or type full name], of _________________
5 [print or type full address], declare under penalty of perjury that I have read in its entirety
6 and understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on [date] in the case of ___________
8 [insert formal name of the case and the number and initials assigned to it by the
9 court]. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could expose
11 me to sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the provisions of
14 this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the
16 Central District of California for enforcing the terms of this Stipulated Protective Order,
17 even if such enforcement proceedings occur after termination of this action. I hereby
18 appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and telephone
20 number] as my California agent for service of process in connection with this action or any
21 proceedings related to enforcement of this Stipulated Protective Order.
22 Date: __________________________________
23 City and State where sworn and signed: __________________________________
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25 Printed name: __________________________________
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27 Signature: __________________________________
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SMRH:4852-5092-4014.2

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Case No. 5:21−cv−00572 JWH (SPx)
STIPULATED PROTECTIVE ORDER