Dean Rollolazo et al v. BMW of North America, LLC et al

Filing 77

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re Stipulation for Protective Order 76 . (See document for details). (mr)

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1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 3 4 BARRY BRAVERMAN, HAKOP DEMIRCHYAN, JOEL GREEN, CHEVAY 5 JONES, DR. GLYNDA ROBERSON, EDO TSOAR, PETER WEINSTEIN, THOMAS 6 MUNK, PETER BERNARD, LAWRENCE CURCIO, NAVEEN PARMESHWAR, ADEEL 7 SIDDIQUI, CHARLES OLSEN, ROBERT DESATNIK, ERIC WONDERLY, JOHN 8 LINGSWEILER, STEVE RIDGES, AND BRANDON REDMOND, 9 Plaintiffs, 10 vs. 11 BMW OF NORTH AMERICA, LLC, a 12 Delaware Limited Liability Company, and BMW AG, a corporation organized 13 under the laws of Germany, 14 Case No. 8:16-CV-00966-BRO (SSx) Hon. Beverly Reid O’Connell STIPULATED PROTECTIVE ORDER Defendants. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3 below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 4825-0227-6175.1 1 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 that must be followed and the standards that will be applied when a party seeks 2 permission from the court to file material under seal. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, customer and pricing lists and 5 other valuable research, development, commercial, financial, technical and/or 6 proprietary information for which special protection from public disclosure and 7 from use for any purpose other than prosecution of this action is warranted. Such 8 confidential and proprietary materials and information consist of, among other 9 things, confidential business or financial information, information regarding 10 confidential business practices, or other confidential research, development, or 11 commercial information (including information implicating privacy rights of third 12 parties), information otherwise generally unavailable to the public, or which may be 13 privileged or otherwise protected from disclosure under state or federal statutes, 14 court rules, case decisions, or common law. Accordingly, to expedite the flow of 15 information, to facilitate the prompt resolution of disputes over confidentiality of 16 discovery materials, to adequately protect information the parties are entitled to keep 17 confidential, to ensure that the parties are permitted reasonable necessary uses of 18 such material in preparation for and in the conduct of trial, to address their handling 19 at the end of the litigation, and serve the ends of justice, a protective order for such 20 information is justified in this matter. It is the intent of the parties that information 21 will not be designated as confidential for tactical reasons and that nothing be so 22 designated without a good faith belief that it has been maintained in a confidential, 23 non-public manner, and there is good cause why it should not be part of the public 24 record of this case. 25 2. DEFINITIONS 26 2.1 Action: this pending federal law suit, captioned Rollolazo et al. v. BMW 27 of North America, et al. (Case No. 2:16-CV-00966-BRO-SSX). 28 4825-0227-6175.1 2 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 // 2 2.2 Challenging Party: a Party or Non-Party that challenges the designation 3 of information or items under this Order. 4 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 5 how it is generated, stored or maintained) or tangible things that qualify for 6 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 7 the Good Cause Statement. 8 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 9 their respective support staff). 10 2.5 Designating Party: a Party or Non-Party that designates information or 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL.” 13 2.6 Disclosure or Discovery Material: all items or information, regardless 14 of the medium or manner in which it is generated, stored, or maintained (including, 15 among other things, testimony, transcripts, and tangible things), that are produced or 16 generated in disclosures or responses to discovery in this matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as 19 an expert witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other outside 22 counsel. 23 2.9 Non-Party: any natural person, partnership, corporation, association, or 24 other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees of a party 26 to this Action but are retained to represent or advise a party to this Action and have 27 appeared in this Action on behalf of that party or are affiliated with a law firm which 28 4825-0227-6175.1 3 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 has appeared on behalf of that party, and includes support staff. 2 2.11 Party: any party to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 support staffs). 5 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 6 Discovery Material in this Action. 7 2.13 Professional Vendors: persons or entities that provide litigation support 8 services (e.g., photocopying, videotaping, translating, preparing exhibits or 9 demonstrations, and organizing, storing, or retrieving data in any form or medium) 10 and their employees and subcontractors. 11 2.14 Protected Material: any Disclosure or Discovery Material that is 12 designated as “CONFIDENTIAL.” 13 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 14 from a Producing Party. 15 3. SCOPE 16 The protections conferred by this Stipulation and Order cover not only 17 Protected Material (as defined above), but also (1) any information copied or 18 extracted from Protected Material; (2) all copies, excerpts, summaries, or 19 compilations of Protected Material; and (3) any testimony, conversations, or 20 presentations by Parties or their Counsel that might reveal Protected Material. Any 21 use of Protected Material at trial shall be governed by the orders of the trial judge. 22 This Order does not govern the use of Protected Material at trial. 23 4. DURATION 24 Even after final disposition of this litigation, the confidentiality obligations 25 imposed by this Order shall remain in effect until a Designating Party agrees 26 otherwise in writing or a court order otherwise directs. Final disposition shall be 27 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 28 4825-0227-6175.1 4 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 or without prejudice; and (2) final judgment herein after the completion and 2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 3 including the time limits for filing any motions or applications for extension of time 4 pursuant to applicable law. 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 protection only those parts of material, documents, items, or oral or written 11 communications that qualify so that other portions of the material, documents, 12 items, or communications for which protection is not warranted are not swept 13 unjustifiably within the ambit of this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating 18 Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 25 under this Order must be clearly so designated before the material is disclosed or 26 produced. 27 Designation in conformity with this Order requires: 28 4825-0227-6175.1 5 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, before 15 producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 portion or portions of the material on a page qualifies for protection, the Producing 18 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 19 markings in the margins). (b) 20 for testimony given in depositions that the Designating Party 21 identify the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony, where practicable, but in no event any later than 23 30 days after the transcript containing Protected Material is provided to the 24 Producing Party. During this 30 day period, the transcript in its entirety will be 25 treated as being designated as “CONFIDENTIAL.” (c) 26 for information produced in some form other than documentary 27 and for any other tangible items, that the Producing Party affix in a prominent place 28 4825-0227-6175.1 6 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 on the exterior of the container or containers in which the information is stored the 2 legend “CONFIDENTIAL.” If only a portion or portions of the information 3 warrants protection, the Producing Party, to the extent practicable, shall identify the 4 protected portion(s). 5 5.3 Inadvertent Failures to Designate. If corrected not more than six (6) 6 months after production, an inadvertent failure to designate qualified information or 7 items does not, standing alone, waive the Designating Party’s right to secure 8 protection under this Order for such material. Upon timely correction of a 9 designation, the Receiving Party must make reasonable efforts to assure that the 10 material is treated in accordance with the provisions of this Order. 11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s 14 Scheduling Order. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process under Local Rule 37.1 et seq. 17 6.3 The burden of persuasion in any such challenge proceeding shall be on 18 the Designating Party. Frivolous challenges, and those made for an improper 19 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 20 parties) may expose the Challenging Party to sanctions. Unless the Designating 21 Party has waived or withdrawn the confidentiality designation, all parties shall 22 continue to afford the material in question the level of protection to which it is 23 entitled under the Producing Party’s designation until the Court rules on the 24 challenge. 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this 28 4825-0227-6175.1 7 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 Action only for prosecuting, defending, or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, 14 as well as employees of said Outside Counsel of Record to whom it is reasonably 15 necessary to disclose the information for this Action; (b) 16 the officers, directors, and employees (including House Counsel) 17 of the Receiving Party to whom disclosure is reasonably necessary for this Action; (c) 18 Experts (as defined in this Order) of the Receiving Party to 19 whom disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the court and its personnel, as needed for the conduct of the (e) court reporters and their staff, as needed for the conduct of the (f) 21 professional jury or trial consultants, mock jurors, and 22 Action; 23 24 Action; 25 26 Professional Vendors to whom disclosure is reasonably necessary for this Action 27 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 28 4825-0227-6175.1 8 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 A); (g) 2 the author or recipient of a document containing the information 3 or a custodian or other person who otherwise possessed or knew the information; (h) 4 during their depositions, witnesses, and attorneys for witnesses, 5 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 6 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 7 they will not be permitted to keep any confidential information unless they sign the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 9 agreed by the Designating Party or ordered by the court. Pages of transcribed 10 deposition testimony or exhibits to depositions that reveal Protected Material may 11 be separately bound by the court reporter and may not be disclosed to anyone except 12 as permitted under this Stipulated Protective Order; and (i) 13 any mediator or settlement officer, and their supporting 14 personnel, mutually agreed upon by any of the parties engaged in settlement 15 discussions. 16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 17 IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in other litigation 19 that compels disclosure of any information or items designated in this Action as 20 “CONFIDENTIAL,” that Party must: (a) 21 22 promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) 23 promptly notify in writing the party who caused the subpoena or 24 order to issue in the other litigation that some or all of the material covered by the 25 subpoena or order is subject to this Protective Order. Such notification shall include 26 a copy of this Stipulated Protective Order; and 27 28 4825-0227-6175.1 9 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 2 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 3 4 the subpoena or court order shall not produce any information designated in this 5 action as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action 10 to disobey a lawful directive from another court. 11 9. A 12 PRODUCED IN THIS LITIGATION 13 NON-PARTY’S (a) PROTECTED MATERIAL SOUGHT TO BE The terms of this Order are applicable to information produced 14 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 15 information produced by Non-Parties in connection with this litigation is protected 16 by the remedies and relief provided by this Order. Nothing in these provisions 17 should be construed as prohibiting a Non-Party from seeking additional protections. (b) 18 In the event that a Party is required, by a valid discovery request, 19 to produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: (1) 22 promptly notify in writing the Requesting Party and the 23 Non-Party that some or all of the information requested is subject to a 24 confidentiality agreement with a Non-Party; (2) 25 promptly provide the Non-Party with a copy of the 26 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 27 reasonably specific description of the information requested; and 28 4825-0227-6175.1 10 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 (3) make the information requested available for inspection by 2 the Non-Party, if requested. (c) 3 If the Non-Party fails to seek a protective order from this court 4 within 14 days of receiving the notice and accompanying information, the 5 Receiving Party may produce the Non-Party’s confidential information responsive 6 to the discovery request. If the Non-Party timely seeks a protective order, the 7 Receiving Party shall not produce any information in its possession or control that 8 is subject to the confidentiality agreement with the Non-Party before a 9 determination by the court. Absent a court order to the contrary, the Non-Party shall 10 bear the burden and expense of seeking protection in this court of its Protected 11 Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best 17 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 18 person or persons to whom unauthorized disclosures were made of all the terms of 19 this Order, and (d) request such person or persons to execute the “Acknowledgment 20 and Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other 25 protection, the obligations of the Receiving Parties are those set forth in Federal 26 Rule of Civil Procedure 26(b)(5)(B), except as modified by this Order. 27 Recognizing that despite reasonable efforts, inadvertent disclosures of 28 4825-0227-6175.1 11 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 privileged or confidential material may occur, particularly when large volumes of 2 electronically stored information are involved, the parties and Court agree to apply 3 the provisions of Federal Rule of Evidence 502(d), as expanded by this Order, if 4 information subject to a claim of attorney-client privilege, work product protection, 5 or any other privilege or immunity is inadvertently produced, such production shall 6 in no way prejudice or otherwise constitute a waiver of, or estoppel as to, any claim 7 of privilege, work product protection or other ground for withholding production to 8 which any Producing Party would otherwise be entitled in this or any other action. 9 Specifically, no waiver of the attorney-client privilege, attorney work product 10 protection or immunity or any other doctrine protecting the confidentiality of 11 information shall have occurred where the production of the privileged, protected or 12 immune information was inadvertent, and after such disclosure, the Producing Party 13 took reasonable steps to rectify the error, as required by Federal Rule of Evidence 14 502 (information meeting these requirements shall be referred to herein as 15 “Inadvertently Disclosed Material”). The parties stipulate and the Court orders that 16 any Inadvertently Disclosed Material disclosed in connection with the instant 17 proceeding and pursuant to this Order shall not constitute a waiver of any privilege, 18 protection, or immunity, which would otherwise exist but for the inadvertent 19 disclosure, for purposes of the instant litigation or any other state, federal, or 20 administrative proceeding. Subject to the provisions of Federal Rule of Evidence 21 502(d), any Inadvertently Disclosed Material shall be returned promptly to the 22 Producing Party upon request and all copies destroyed. 23 This provision is not intended to modify whatever procedure may be 24 established in an e-discovery order that provides for production without prior 25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 26 the parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the 28 4825-0227-6175.1 12 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 parties may incorporate their agreement in the stipulated protective Order submitted 2 to the court. 3 12. 4 MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 7 Protective Order no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 12.3 Filing Protected Material. A Party that seeks to file under seal any 11 12 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 13 only be filed under seal pursuant to a court order authorizing the sealing of the 14 specific Protected Material at issue. If a Party’s request to file Protected Material 15 under seal is denied by the court, then the Receiving Party may file the information 16 in the public record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days of a written request by the Designating Party, each Receiving Party must 20 return all Protected Material to the Producing Party or destroy such material. As 21 used in this subdivision, “all Protected Material” includes all copies, abstracts, 22 compilations, summaries, and any other format reproducing or capturing any of the 23 Protected Material. Regardless whether the Protected Material is returned or 24 destroyed, the Receiving Party must submit a written certification to the Producing 25 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 26 deadline that (1) identifies (by category, where appropriate) all the Protected 27 Material that was returned or destroyed and (2) affirms that the Receiving Party has 28 4825-0227-6175.1 13 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 not retained any copies, abstracts, compilations, summaries or any other format 2 reproducing or capturing any of the Protected Material. Notwithstanding this 3 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 4 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 5 deposition and trial exhibits, expert reports, attorney work product, and consultant 6 and expert work product, even if such materials contain Protected Material. Any 7 such archival copies that contain or constitute Protected Material remain subject to 8 this Protective Order as set forth in Section 4 (DURATION). 9 // 10 // 11 // 12 // 13 14. 14 measures including, without limitation, contempt proceedings and/or monetary 15 sanctions. Any violation of this Order may be punished by any and all appropriate 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 DATED: October 17, 2017 LEWIS BRISBOIS BISGAARD & SMITH LLP 20 By: 21 22 23 24 DATED: October 17, 2017 /s/ Eric Kizirian Eric Y. Kizirian Attorneys for Defendant, BMW of North America, LLC HAGENS BERMAN SOBOL SHAPIRO LLP By: 25 /s/ Jessica Thompson 26 27 28 4825-0227-6175.1 14 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx Steve W. Berman (pro hac vice) Thomas E. Loeser Jessica Thompson (pro hac vice) HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 Seattle, WA 98101 Interim Lead Counsel for Plaintiffs and the Proposed Class 1 2 3 4 5 6 Benjamin F. Johns (pro hac vice) Andrew W. Ferich (pro hac vice) CHIMICLES & TIKELLIS LLP 361 West Lancaster Avenue Haverford, PA 19041 Plaintiffs’ Executive Committee 7 8 9 10 11 Jonathan A. Michaels MLG AUTOMOTIVE LAW APLC 2801 West Cost Highway, Suite 370 Newport, CA 92663 Plaintiffs’ Executive Committee 12 13 14 15 Hovanes Margarian THE MARGARIAN LAW FIRM 801 N. Brand Blvd., Suite 210 Glendale, CA 91203 Additonal Class Counsel 16 17 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 DATED: October 18, 2017 21 22 /S/ 23 Honorable Suzanne H. Segal United States Magistrate Judge Central District of California 24 25 26 27 28 4825-0227-6175.1 15 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 I, ___________________________[print or type full name], of [print or type 4 full address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] in the case of Rollolazo 7 v. BMW of North America, LLC, Case No. 2:16-cv-00966-BRO-SSx. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order and 9 I understand and acknowledge that failure to so comply could expose me to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I will 11 not disclose in any manner any information or item that is subject to this Stipulated 12 Protective Order to any person or entity except in strict compliance with the 13 provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 15 Court for the Central District of California for the purpose of enforcing the terms 16 of this Stipulated Protective Order, even if such enforcement proceedings occur 17 after termination of this action. I hereby appoint _______________________ [print 18 or type full name] of ________________________________________ [print or type 19 full address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 23 Date: ________________ 24 City and State where sworn and signed: ______________________________ 25 Printed name: ______________________________ 26 Signature: ______________________________ 27 28 4825-0227-6175.1 16 STIPULATED PROTECTIVE ORDER 2:16-cv-00966-BRO-SSx

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