Mauricio Gonzalez v. Western Refining Retail LLC et al

Filing 18

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym re 17 (SEE ORDER FOR DETAILS). (kca)

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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Eric A. Welter, Bar No. 270591
[e-mail]
WELTER LAW FIRM, P.C.
20130 Lakeview Center Plaza, Suite 400
Ashburn, VA 20147
Telephone: [phone]
Facsimile: [phone]
Julie R. Trotter, Bar No. 209675
Mireya A. R. Llaurado, Bar No. 194882
CALL & JENSEN APC
610 Newport Center Drive, Suite 700
Newport Beach, CA 92660
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
Western Refining Retail, LLC
and Speedway LLC
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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MAURICIO GONZALEZ, an
individual,

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Plaintiff;

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Assigned to: Judge Sheri Pym

v.

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WESTERN REFINING RETAIL, LLC;
SPEEDWAY LLC; and DOES 1 to 20,

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CASE NO. 5:23-cv-01995-SP

STIPULATED PROTECTIVE
ORDER

Defendants.

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1.

A. PURPOSES AND LIMITATIONS

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Disclosure and discovery activity in this Action are likely to involve production

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of 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 discovery
STIPULATED PROTECTIVE ORDER

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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and that the protection it affords from public disclosure and use extends only to the

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

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applicable legal principles. The parties further acknowledge, as set forth in Section

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

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

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

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from the court to file material under seal.

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B. GOOD CAUSE STATEMENT

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This Action is likely to involve trade secrets and other valuable research,

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development, commercial, financial, technical, proprietary, confidential, and/or private

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information for which special protection from public disclosure, and from use for any

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purpose other than prosecution of this Action, is warranted. Such confidential and

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proprietary materials and information consist of, among other things, confidential

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business or financial information, information regarding confidential business practices,

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or other confidential research, development, or commercial information (including

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information implicating privacy rights of third parties), information prohibited from

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disclosure pursuant to a written agreement to maintain such information in confidence,

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and information otherwise generally unavailable to the public or which may be

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privileged or otherwise protected from disclosure under state or federal statutes, court

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rules, case decisions, or common law. Accordingly, to expedite the flow of information,

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to facilitate the prompt resolution of disputes over confidentiality of discovery

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materials, to adequately protect information the Parties are entitled to keep confidential,

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to 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 the

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

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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 without

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STIPULATED PROTECTIVE ORDER

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a good faith belief that it has been maintained in a confidential, non-public manner, and

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there is good cause why it should not be part of the public record of this case.

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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2.

DEFINITIONS
2.1

Action: This above-entitled case styled Mauricio Gonzalez v. Western

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Refining Retail et al., United States District Court for the Central District of California,

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Case No. 5:23-cv-01995-SP.

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2.2

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 how

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

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Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

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Statement.

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2.4

Counsel:

Outside Counsel of Record and House Counsel (and their

support staff).
2.5

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

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items that it produces in disclosures or in responses to discovery as

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“CONFIDENTIAL.”

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2.6

Disclosure or Discovery Material: all items or information, regardless of

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

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

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in disclosures or responses to discovery in this matter.

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2.7

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 an

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expert witness or as a consultant in this Action.

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2.8

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.
STIPULATED PROTECTIVE ORDER

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2.9

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

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2.10 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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ASHBURN, VA 20147
[phone]

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WELTER LAW FIRM, P.C.

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

2.11 Producing Party:

a Party or Non-Party that produces Disclosure or

Discovery Material in this action.

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2.12 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) and

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their employees and subcontractors.

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2.13 Protected Material:
designated as “CONFIDENTIAL.”

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any Disclosure or Discovery Material that is

2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulated Protective Order cover not only

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

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

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Protected Material; and (3) any testimony, conversations, or presentations by Parties or

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their Counsel that might reveal Protected Material. However, the protections conferred

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by this Stipulation and Order do not cover the following information: (a) any

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information that is in the public domain at the time of disclosure to a Receiving Party

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

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of publication not involving a violation of this Order, including becoming part of the

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public record through trial or otherwise; and (b) any information known to the

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Receiving Party prior to the disclosure or obtained by the Receiving Party after the
STIPULATED PROTECTIVE ORDER

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disclosure from a source who obtained the information lawfully and under no obligation

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of confidentiality to the Designating Party. Any use of Protected Material at trial shall

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be governed by the orders of the trial judge. This Order does not govern the use of

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Protected Material at trial.

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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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 otherwise

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

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the later of (1) dismissal of all claims and defenses in this action, with or without

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prejudice; and (2) final judgment herein after the completion and exhaustion of all

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appeals, rehearings, remands, trials, or reviews of this action, including the time limits

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for filing any motions or applications for extension of time pursuant to applicable law.

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5.

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 this

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

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under the appropriate standards. The Designating Party must designate for protection

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only those parts of material, documents, items, or oral or written communications that

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qualify so that other portions of the material, documents, items, or communications for

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which protection is not warranted are not swept unjustifiably within the ambit of this

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Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations that

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

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

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unnecessary expenses and burdens on other parties) expose the Designating Party to

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sanctions.
STIPULATED PROTECTIVE ORDER

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

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the mistaken designation.

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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5.2

Manner and Timing of Designations. Except as otherwise provided in this

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

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

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material is 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 documents,

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but excluding transcripts of depositions or other pretrial or trial proceedings), that the

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Producing Party affix the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL

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legend”), to each 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 must clearly

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identify the protected portion(s) (e.g., by making appropriate markings in the margins).

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

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inspection need not designate them for protection until after the inspecting Party has

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indicated which material it would like copied and produced. During the inspection and

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before the designation, all of the material made available for inspection shall be deemed

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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

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copied and produced, the Producing Party must determine which documents, or portions

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thereof, qualify for protection under this Order. Then, before producing the specified

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documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

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

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qualifies for protection, the Producing Party also must clearly identify the protected

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portion(s) (e.g., by making appropriate markings in the margins).

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(b) for testimony given in deposition or in other pretrial or trial proceedings, that
the Designating Party:

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STIPULATED PROTECTIVE ORDER

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(i)

other proceeding, all protected testimony, or

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

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WELTER LAW FIRM, P.C.

identify on the record, before the close of the deposition, hearing, or

(ii)

designate the entirety of the testimony at the deposition, hearing, or

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other proceeding as “Confidential” (before the deposition, hearing, or proceeding is

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concluded) with the right to identify more specific portions of the testimony as to which

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protection is sought within 30 days following receipt of the deposition, hearing, or

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proceeding transcript. In this regard, counsel shall send written notice to the court

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reporter, to counsel for the Parties, and to any other person known to have a copy of

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said transcript of the specific portions of the testimony to be designated. The notice

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shall reference this Stipulated Protective Order and identify the pages and/or exhibits

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designated as “CONFIDENTIAL.”

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In circumstances where portions of the deposition, hearing, or proceeding

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testimony are designated for protection, the transcript pages containing “Confidential”

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information must be separately bound by the court reporter, who must affix to the top

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of each page the legend “CONFIDENTIAL,” as instructed by the Designating Party.

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

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other tangible items, that the Producing Party affix in a prominent place on the exterior

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of the container or containers in which the information or item is stored the legend

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“CONFIDENTIAL.” If only a portion or portions of the information or item warrant

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protection, the 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. An inadvertent failure to designate

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qualified information or items does not, standing alone, waive the Designating Party’s

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right to secure protection under this Order for such material so long as written notice of

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the inadvertent failure to designate is provided within 60 days of discovery by

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Designating Party of inadvertent failure to designate. Upon timely correction of a

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designation, the Receiving Party must make reasonable efforts to assure that the

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material is treated in accordance with the provisions of this Order. This provision is not
STIPULATED PROTECTIVE ORDER

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intended to apply to any inadvertent production of any information or items protected

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by attorney-client or work product privileges. No provision in this Order shall affect a

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Party’s right to object to the designation of any document or other material as

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“CONFIDENTIAL” on any ground that is available under applicable law.

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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6.

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 Scheduling

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Order. Unless a prompt challenge to a Designating Party’s confidentiality designation

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is necessary to avoid foreseeable, substantial unfairness, unnecessary economic

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burdens, or a significant disruption or delay of the litigation, a Party does not waive its

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right to challenge a confidentiality designation by electing not to mount a challenge

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promptly after the original designation is disclosed.

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6.2

Meet and Confer.

The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3

Judicial Intervention.

Should the dispute resolution process be

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unsuccessful, although Challenging Party will move to have the “CONFIDENTIAL”

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designation removed from the Protected Material, the burden of persuasion in any such

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motion proceeding shall be on the Designating Party. Frivolous challenges, and those

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made for an improper purpose (e.g., to harass or impose unnecessary expenses and

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burdens on other parties) may expose the Challenging Party to sanctions. Unless the

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Designating Party has waived or withdrawn the confidentiality designation, or unless

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the Designating Party agrees to de-designate the challenged Protected Materials, all

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Parties shall continue to afford the material in question the level of protection to which

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it is entitled under the Producing Party’s designation until the Court rules on the

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challenge.

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STIPULATED PROTECTIVE ORDER

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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7.

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 Action

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only for prosecuting, defending, or attempting to settle this litigation, and not for any

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business or other purpose whatsoever. Such Protected Material may be disclosed only

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to the categories of persons and under the conditions described in this Order. When the

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Action has been terminated, a Receiving Party must comply with the provisions of

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section 13 below (FINAL 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 reasonably ensures that access is limited to the

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persons authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

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may disclose any information or item designated “CONFIDENTIAL” only to:

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

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employees of said Outside Counsel of Record to whom it is reasonably necessary to

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disclose the information for this Action;

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

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the Receiving Party to whom disclosure is reasonably necessary for this Action and who

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have been advised of the “Confidential” designation. ;

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

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is reasonably necessary for this litigation and who have signed the “Acknowledgment

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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, mock jurors, and Professional Vendors

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to whom disclosure is reasonably necessary for this litigation and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
STIPULATED PROTECTIVE ORDER

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;

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(h) any deposition, proceeding, or hearing witness who previously has had access

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to the “CONFIDENTIAL” Information or who is currently or was previously an officer,

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director, employee or agent of an entity that has had access to the “CONFIDENTIAL”

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Information;

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(i) during their depositions, witnesses, and attorneys for witnesses, in the Action

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who previously did not have access to the “CONFIDENTIAL” Information, provided

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that: (1) disclosure is reasonably necessary, (2) the deposing party requests that the

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witness and the attorney for the witness sign the “Acknowledgment and Agreement to

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Be Bound” (Exhibit A); and (3) the witness and the attorney for the witness will not be

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permitted to keep any confidential information unless they sign the “Acknowledgment

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and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating

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Party or ordered by the Court;

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(j) any mediator, third-party neutral, or settlement officer, and their supporting

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personnel, mutually agreed upon by any of the Parties engaged in settlement

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discussions; and

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(k) any other person or entity that Designating Party agrees to in writing.

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Pages of transcribed deposition testimony or exhibits to depositions that reveal

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Protected Material may be separately bound by the court reporter and may not be

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disclosed to anyone except as permitted under this Stipulated Protective Order.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:

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STIPULATED PROTECTIVE ORDER

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

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

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

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order is subject to this Protective Order. Such notification shall include a copy of this

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Stipulated Protective Order; and

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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(c) cooperate with respect to all reasonable procedures sought to be pursued by
the Designating Party whose Protected Material may be affected.

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

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

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“CONFIDENTIAL” before a determination by the court from which the subpoena or

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

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contrary to law. 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 to

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disobey a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

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IN THIS LITIGATION

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

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in this Action and designated by a Non-Party or Party as “CONFIDENTIAL.” Such

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information produced by Non-Parties in connection with this litigation is protected by

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the remedies and relief provided by this Order. Any such designation shall also function

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as consent by such producing Non-Party to the authority of the Court in the Action to

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resolve and conclusively determine any motion or other application made by any person

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or Party with respect to such designation, or any other matter otherwise arising under

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this Order. Nothing in these provisions should be construed as prohibiting a Non-Party

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from seeking additional protections.
STIPULATED PROTECTIVE ORDER

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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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 writing

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

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

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whom unauthorized disclosures were made of all the terms of this Order, and (d) request

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such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

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that is attached hereto as Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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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 as

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trial-preparation material, the obligations of the Receiving Parties are those set forth in

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Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

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whatever procedure may be established in an e-discovery order that provides for

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production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d)

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and (e), insofar as the Parties reach an agreement on the effect of disclosure of a

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communication or information covered by the attorney-client privilege or work product

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protection, the Parties may incorporate their agreement in the stipulated protective order

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submitted to the Court.

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12.

MISCELLANEOUS

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

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person to seek its modification or additional relief by the Court in the future. This Order

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shall not be construed to preclude either Party from asserting in good faith that certain
STIPULATED PROTECTIVE ORDER

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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“CONFIDENTIAL” Information or Items require additional protection. The Parties

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shall meet and confer to agree upon the terms of such additional protection.

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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 Material.

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

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imposed by the Local Rules. Protected Material may only be filed under seal pursuant

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

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Receiving Party's request to file Protected Material under seal is denied by the Court,

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then the Receiving Party may file the information in the public record pursuant to Civil

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Local Rule 79-5 unless otherwise instructed by the Court.

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12.4 Waiver of Designating Party. This Order is entered into without prejudice

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to the right of any Party to knowingly waive the applicability of this Order to any

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“CONFIDENTIAL” Information or Items designated by that Party.

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12.5 Previously Produced Documents. The Parties agree to be bound by the

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terms set forth herein with regard to any “CONFIDENTIAL” information or items that

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have been produced before the Court signs this Order. In the event that the Court

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modifies this Order, or in the event that the Court enters a different Protective Order,

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the Parties agree to be bound by this Order until such time as the Court may enter such

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a different Order.

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STIPULATED PROTECTIVE ORDER

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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13.

FINAL DISPOSITION

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Within 60 days after the final disposition of this Action, as defined in paragraph

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4, and only upon written request by the Designating Party, each Receiving Party must

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return all Protected Material to the Producing Party or destroy such material no later

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than 60 days after Designating Party’s written request. As used in this subdivision, “all

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

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other 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 written

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

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Designating Party) by the 60-day deadline if requested at that time by Producing Party

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that (1) identifies (by category, where appropriate) all the Protected Material that was

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returned or destroyed and (2) affirms that the Receiving Party has not retained any

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copies, abstracts, compilations, summaries or any other format reproducing or capturing

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any of the Protected Material. Notwithstanding this provision, Counsel are entitled to

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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

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reports, attorney work product, and consultant and expert work product, even if such

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materials contain Protected Material.

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constitute Protected Material remain subject to this Protective Order as set forth in

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Section 4 (DURATION). To the extent permitted by law, the Court shall retain

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jurisdiction to enforce, modify, or reconsider this Order, even after final disposition of

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the Action.

Any such archival copies that contain or

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14.

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including, without limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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

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STIPULATED PROTECTIVE ORDER

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DATED: March 25, 2024

LAW OFFICES OF SANDRA H. CASTRO, INC.

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By:

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/s/ Sandra H. Castro
Sandra H. Castro
Kathleen A. Juarez
Attorneys for Plaintiff

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20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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DATED: March 25, 2024

LAW OFFICES OF KRISTEN BROWN

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By:

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DATED: March 25, 2024

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WELTER LAW FIRM, P.C.
By:

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/s/ Kristen Brown
Kristen Brown
Attorney for Plaintiff

/s/ Eric A. Welter
Eric A. Welter
Attorney for Defendants Western Refining
Retail, LLC and Speedway LLC

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: March 27, 2024
By:
Sheri Pym
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND

20130 LAKEVIEW CTR. PLAZA, STE 400
ASHBURN, VA 20147
[phone]

WELTER LAW FIRM, P.C.

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I, ______________, of ____________________________ [print or type full

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address], declare under penalty of perjury that I have read in its entirety and

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understand the Stipulated Protective Order that was issued by the United States

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District Court for the Central District of California on [date] in the case of Mauricio

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Gonzalez v. Western Refining Retail et al., United States District Court for the Central

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District of California, Case No. 5:23-cv-01995-SP. I agree to comply with and to be

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bound 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 punishment

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

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any information or item that is subject to this Stipulated Protective Order to any

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person or entity except in strict compliance with the provisions of this Order.

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

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for the Central District of California for the purposes of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination

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____________________________ [print or type full address] as my California agent

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for service of process in connection with this action or any proceedings related to

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enforcement of this Stipulated Protective Order.

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Date:

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City and State where sworn and signed:

of

this

action.

I

hereby

appoint

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Printed name:

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Signature:

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STIPULATED PROTECTIVE ORDER

______________,

of