1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION 11 ALEX LOPEZ and TRAVELL CASE NO.: 2:25-cv-07808-FWS (JDEx) 12 WOODS, on behalf of themselves and all others similarly situated, STIPULATED PROTECTIVE ORDER 13

14 Plaintiffs,

15 vs. Filed (state court): March 19, 2025 16 Removed: August 14, 2025

SUZUKI MOTOR OF AMERICA,

17 INC., and DOES 1-50, inclusive, 18 Defendants. 19 20 Based on the Parties’ Stipulation (Dkt. 19) and for good cause shown, the Court 21 finds and orders as follows. 22 1. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, proprietary 24 or private information for which special protection from public disclosure and from use 25 for any purpose other than pursuing this litigation may be warranted. This Order does not 26 confer blanket protections on all disclosures or responses to discovery. The protection it 27 affords from public disclosure and use extends only to the limited information or items 1 2. GOOD CAUSE STATEMENT 2 This action is likely to involve trade secrets, customer and pricing lists and other 3 valuable research, development, commercial, financial, technical and/or proprietary 4 information for which special protection from public disclosure and from use for any 5 purpose other than prosecution of this action is warranted. Such confidential and 6 proprietary materials and information consist of, among other things, confidential business 7 or financial information, information regarding confidential business practices, or other 8 confidential research, development, or commercial information (including information 9 implicating privacy rights of third parties), personal identifying information of third 10 parties, information otherwise generally unavailable to the public, or which may be 11 privileged or otherwise protected from disclosure under state or federal statutes, court 12 rules, case decisions, or common law. Accordingly, to expedite the flow of information, to 13 facilitate the prompt resolution of disputes over confidentiality of discovery materials, to 14 adequately protect information the parties are entitled to keep confidential, to ensure that 15 the parties are permitted reasonable necessary uses of such material in preparation for and 16 in the conduct of trial, to address their handling at the end of the litigation, and serve the 17 ends of justice, a protective order for such information is justified in this matter. It is the 18 intent of the parties that information will not be designated as confidential for tactical 19 reasons and that nothing be so designated without a good faith belief that it has been 20 maintained in a confidential, non-public manner, and there is good cause why it should 21 not be part of the public record of this case. 22 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 23 The parties further acknowledge, as set forth in Section 14.3, below, that this 24 Stipulated Protective Order does not entitle them to file confidential information under 25 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 26 standards that will be applied when a party seeks permission from the court to file material 27 under seal. There is a strong presumption that the public has a right of access to judicial proceedings and records in civil cases. In connection with non-dispositive motions, good 1 cause must be shown to support a filing under seal. See Kamakana v. City and County of 2 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 3 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 4 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and 5 a specific showing of good cause or compelling reasons with proper evidentiary support 6 and legal justification, must be made with respect to Protected Material that a party seeks 7 to file under seal. The parties’ mere designation of Disclosure or Discovery Material as 8 CONFIDENTIAL or HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY does 9 not— without the submission of competent evidence by declaration, establishing that the 10 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 11 protectable—constitute good cause. 12 Further, if a party requests sealing related to a dispositive motion or trial, then 13 compelling reasons, not only good cause, for the sealing must be shown, and the relief 14 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 15 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of 16 information, document, or thing sought to be filed or introduced under seal, the party 17 seeking protection must articulate compelling reasons, supported by specific facts and 18 legal justification, for the requested sealing order. Again, competent evidence supporting 19 the application to file documents under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable in its entirety 21 will not be filed under seal if the confidential portions can be redacted. If documents can 22 be redacted, then a redacted version for public viewing, omitting only the confidential, 23 privileged, or otherwise protectable portions of the document, shall be filed. Any 24 application that seeks to file documents under seal in their entirety should include an 25 explanation of why redaction is not feasible. 26 4. DEFINITIONS 27 4.1 Action: Lopez et al. v. Suzuki Motor of Am., Inc. et al., Case No.: 2:25-cv- 07808-FWS (JDEx). 1 4.2 Challenging Party: a Party or Non-Party that challenges the designation of 2 information or items under this Order. 3 4.3 “CONFIDENTIAL” Information or Items: information (documents, tangible 4 things, including written discovery responses, deposition testimony, all other information 5 that may be disclosed, as well as compilations or excerpts of such materials, regardless of 6 how such information or materials are generated, stored or maintained), that qualify for 7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 8 Good Cause Statement. 9 4.4 “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY” Information or 10 Items: Information (regardless of how it is generated, stored or maintained) or tangible 11 things that are Confidential but require further limited access for the use in this Action 12 because the Designating Party has reasonable grounds to believe the information or items 13 would, if known to any officer, director, employee, or agent of a Party, a Non-Party, or the 14 public, lead to significant or irreparable harm or injury to the reputation and/or business of 15 the Designating Party or materially impair the legitimate competitive interests of the 16 Designating Party, which cannot be avoided by less restrictive means and include, but are 17 not limited to, research, development, design, testing, financial, or commercial 18 information. 19 4.5 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff). 21 4.6 Designating Party: a Party or Non-Party that designates information or items 22 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or 23 “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY.” 24 4.7 Disclosure or Discovery Material: all items or information, regardless of the 25 medium or manner in which it is generated, stored, or maintained (including, among other 26 things, testimony, transcripts, and tangible things), that are produced or generated in 27 disclosures or responses to discovery. 1 4.8 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 an 3 expert witness or as a consultant in this Action. 4 4.9 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 counsel. 6 4.10 Non-Party: any natural person, partnership, corporation, association or other 7 legal entity not named as a Party to this action. 8 4.11 Outside Counsel of Record: attorneys who are not employees of a party to 9 this Action but are retained to represent a party to this Action and have appeared in this 10 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf 11 of that party, and includes support staff. 12 4.12 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 4.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 16 Material in this Action. 17 4.14 Professional Vendors: persons or entities that provide litigation support 18 services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 20 their employees and subcontractors. 21 4.15 Protected Material: any Disclosure or Discovery Material that is designated 22 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY.” 23 4.16 Receiving Party: a Party that receives Disclosure or Discovery 24 Material from a Producing Party. 25 5. SCOPE 26 The protections conferred by this Stipulation and Order cover not only Protected 27 Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 1 Material; and (3) any testimony, conversations, or presentations by Parties or their 2 Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial 4 judge and other applicable authorities. This Order does not govern the use of Protected 5 Material at trial. 6 6. DURATION 7 Once a case proceeds to trial, information used or introduced as an exhibit at trial 8 that was designated as CONFIDENTIAL or HIGHLY CONFIDENTIAL- 9 ATTORNEY’S EYES ONLY or maintained pursuant to this protective order becomes 10 public and will be presumptively available to all members of the public, including the 11 press, unless compelling reasons supported by specific factual findings to proceed 12 otherwise are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 13 1180-81 (distinguishing “good cause” showing for sealing documents produced in 14 discovery from “compelling reasons” standard when merits-related documents are part of 15 court record); Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1097 (9th Cir. 16 2016) (holding that “compelling reason[s]” include “when a court record might be used to 17 ‘gratify private spite or promote public scandal,’ to circulate ‘libelous’ statements, or ‘as 18 sources of business information that might harm a litigant’s competitive standing’”). 19 The confidentiality obligations imposed by this Order upon all other information 20 not used or introduced as an exhibit at trial that was designated as CONFIDENTIAL or 21 HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY or maintained pursuant to this 22 protective order, shall remain in effect until a Designating Party agrees otherwise in 23 writing or a court order otherwise directs, even after final disposition of this litigation. 24 Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses 25 in this Action, with or without prejudice; and (2) final judgment herein after the 26 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 27 Action, including the time limits for filing any motions or applications for extension of time pursuant to applicable law. 1 7. DESIGNATING PROTECTED MATERIAL 2 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 3 Party or Non-Party that designates information or items for protection under this Order 4 must take care to limit any such designation to specific material that qualifies under the 5 appropriate standards. The Designating Party must designate for protection only those 6 parts of material, documents, items or oral or written communications that qualify so that 7 other portions of the material, documents, items or communications for which protection 8 is not warranted are not swept unjustifiably within the ambit of this Order. 9 Mass, indiscriminate or routinized designations are prohibited. Designations that 10 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 11 to unnecessarily encumber the case development process or to impose unnecessary 12 expenses and burdens on other parties) may expose the Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 7.2 Manner and Timing of Designations. Except as otherwise provided in this 17 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 18 qualifies for protection under this Order must be clearly so designated before the material 19 is disclosed or produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 24 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES 25 ONLY” (hereinafter “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY 26 legend”)), to each page that contains protected material. If only a portion of the material 27 on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 1 A Party or Non-Party that makes original documents available for inspection need 2 not designate them for protection until after the inspecting Party has indicated which 3 documents it would like copied and produced. During the inspection and before the 4 designation, all of the material made available for inspection shall be deemed “HIGHLY 5 CONFIDENTIAL-ATTORNEY’S EYES ONLY.” After the inspecting Party has 6 identified the documents it wants copied and produced, the Producing Party must 7 determine which documents, or portions thereof, qualify for protection under this Order. 8 Then, before producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES 10 ONLY legend” to each page that contains Protected Material. If only a portion of the 11 material on a page qualifies for protection, the Producing Party also must clearly identify 12 the protected portion(s) (e.g., by making appropriate markings in the margins). 13 (b) for testimony given in depositions, or in other pretrial proceedings, that 14 the Designating Party identifies the Disclosure or Discovery Material on the record 15 whenever practical, before the close of the deposition, hearing, or other proceeding, all 16 protected testimony. A Party may also designate the testimony that is entitled to protection 17 or a portion of the testimony as containing Confidential Information after transcription of 18 the proceedings. A Party will have until thirty (30) days after receipt of the deposition 19 transcript to inform the other party or parties to the Action of the portions of the transcript 20 to be designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S 21 EYES ONLY” and until such designation is made either on the record or after 22 transcription of the proceedings, the entire transcript shall be treated as “HIGHLY 23 CONFIDENTIAL – FOR ATTORNEY’S EYES ONLY.” 24 (c) The use of a document as an exhibit at a deposition shall not in any way 25 affect its designation as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- 26 ATTORNEY’S EYES ONLY.” Transcripts containing Protected Material shall have an 27 obvious legend on the title pages that the transcript contains Protected Material. The Designating Party shall inform the court reporter of this requirement. 1 (d) for information produced in some form other than documentary and for 2 any other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 5 the Producing Party, to the extent practicable, shall identify the protected portion(s). 6 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 7 to designate qualified information or items does not, standing alone, waive the 8 Designating Party’s right to secure protection under this Order for such material. Upon 9 timely correction of a designation, the Receiving Party must make reasonable efforts to 10 assure that the material is treated in accordance with the provisions of this Order. 11 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 13 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 14 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 15 process under Local Rule 37-1 et seq. 16 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 17 stipulation pursuant to Local Rule 37-2. 18 8.4 The burden of persuasion in any such challenge proceeding shall be on the 19 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 20 harass or impose unnecessary expenses and burdens on other parties) may expose the 21 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the 22 confidentiality designation, all parties shall continue to afford the material in question the 23 level of protection to which it is entitled under the Producing Party’s designation until the 24 Court rules on the challenge. 25 9. ACCESS TO AND USE OF PROTECTED MATERIAL 26 9.1 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 Action only for prosecuting, defending or attempting to settle this Action. Such Protected 1 Material may be disclosed only to the categories of persons and under the conditions 2 described in this Order. When the Action has been terminated, a Receiving Party must 3 comply with the provisions of section 15 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a location 5 and in a secure manner that ensures that access is limited to the persons authorized under 6 this Order. 7 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 10 only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 12 employees of said Outside Counsel of Record to whom it is reasonably necessary to 13 disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of the 15 Receiving Party to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 23 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided they will not be permitted to keep any confidential information unless they sign the “Acknowledgment and Agreement 1 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by 2 the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 3 Protected Material may be separately bound by the court reporter and may not be 4 disclosed to anyone except as permitted under this Stipulated Protective Order; and 5 (i) any mediators or settlement officers and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 9.3 Disclosure of “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY” 8 Information or Items. Unless otherwise ordered by the court or permitted in writing by the 9 Designating Party, a Receiving Party may disclose any information or item designated 10 “HIGHLY CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 12 employees of said Outside Counsel of Record to whom it is reasonably necessary to 13 disclose the information for this Action; 14 (b) House Counsel of the Receiving Party to whom disclosure is reasonably 15 necessary for this Action and who has signed the “Acknowledgment and Agreement to be 16 Bound” (Exhibit A); 17 (c) Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), provided that the Expert is 20 not a current officer, director, or employee of a competitor of a Party or anticipated to 21 become one; 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 26 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 1 (h) during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit A hereto (“Acknowledgment 4 and Agreement to Be Bound”); and (2) they will not be permitted to keep any confidential 5 information unless they sign Exhibit A, unless otherwise agreed by the Designating Party 6 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 7 depositions that reveal Protected Material may be separately bound by the court reporter 8 and may not be disclosed to anyone except as permitted under this Stipulated Protective 9 Order; and 10 (i) any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 13 IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation that 15 compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY,” that 17 Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to 21 issue in the other litigation that some or all of the material covered by the subpoena or 22 order is subject to this Protective Order. Such notification shall include a copy of this 23 Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued 25 by the Designating Party whose Protected Material may be affected. If the Designating 26 Party timely seeks a protective order, the Party served with the subpoena or court order 27 shall not produce any information designated in this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEY’S EYES ONLY” before a determination by 1 the court from which the subpoena or order issued, unless the Party has obtained the 2 Designating Party’s permission. The Designating Party shall bear the burden and expense 3 of seeking protection in that court of its confidential material and nothing in these 4 provisions should be construed as authorizing or encouraging a Receiving Party in this 5 Action to disobey a lawful directive from another court. 6 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a Non- 9 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 10 CONFIDENTIAL-ATTORNEY’S EYES ONLY.” Such information produced by Non- 11 Parties in connection with this litigation is protected by the remedies and relief provided 12 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party 13 from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is subject 16 to an agreement with the Non-Party not to produce the Non-Party’s confidential 17 information, then the Party shall: 18 (1) promptly notify in writing the Requesting Party and the Non-Party that 19 some or all of the information requested is subject to a confidentiality agreement with a 20 Non-Party; 21 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 22 Order in this Action, the relevant discovery request(s), and a reasonably specific 23 description of the information requested; and 24 (3) make the information requested available for inspection by the Non-Party, 25 if requested. 26 (c) If the Non-Party fails to seek a protective order from this court within 14 27 days of receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential information responsive to the discovery request. If 1 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 2 information in its possession or control that is subject to the confidentiality agreement 3 with the Non-Party before a determination by the court. Absent a court order to the 4 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 5 court of its Protected Material. 6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 10 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 11 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 12 unauthorized disclosures were made of all the terms of this Order, and (d) request such 13 person or persons to execute the “Acknowledgment an Agreement to Be Bound” attached 14 hereto as Exhibit A. 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain inadvertently 18 produced material is subject to a claim of privilege or other protection, the obligations of 19 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 20 This provision is not intended to modify whatever procedure may be established in an e- 21 discovery order that provides for production without prior privilege review. Pursuant to 22 Federal Rule of Evidence 502(b), an inadvertent disclosure of information covered by the 23 attorney-client privilege or work-product protection does not operate as a waiver of that 24 protection if: (1) the disclosure is inadvertent; (2) the holder of the privilege or protection 25 took reasonable steps to prevent disclosure; and (3) the holder promptly took reasonable 26 steps to rectify the error, including (if applicable) following Federal Rule of Civil 27 Procedure 26(b)(5)(B). Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or information 1 covered by the attorney-client privilege or work product protection, the parties may 2 incorporate their agreement in the stipulated protective order submitted to the court. 3 14. MISCELLANEOUS 4 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person 5 to seek its modification by the Court in the future. 6 14.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it otherwise would have to object to disclosing 8 or producing any information or item on any ground not addressed in this Stipulated 9 Protective Order. Similarly, no Party waives any right to object on any ground to use in 10 evidence of any of the material covered by this Protective Order. 11 14.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Civil Rule 79-5. Protected Material may only 13 be filed under seal pursuant to a court order authorizing the sealing of the specific 14 Protected Material. If a Party’s request to file Protected Material under seal is denied by 15 the court, then the Receiving Party may file the information in the public record unless 16 otherwise instructed by the court. 17 15. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 6, within 60 days 19 of a written request by the Designating Party, each Receiving Party must return all 20 Protected Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected Material. 23 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 24 a written certification to the Producing Party (and, if not the same person or entity, to the 25 Designating Party) by the 60-day deadline that (1) identifies (by category, where 26 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 27 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this 1 |} provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work 4|| product, even if such materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order as set □□□□□ 6 || in Section 6 (DURATION). 7 16. VIOLATION 8 Any violation of this Order may be punished by appropriate measure 9 || including, without limitation, contempt proceedings and/or monetary sanctions. 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 1] je de Dated: November 5, 2025

B IQEPED. EARLY

nited States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 Attachment A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I declare under penalty of perjury that I have read in its entirety and understand the 5 Stipulated Protective Order that was issued by the United States District Court for the 6 Central District of California in the case of : Lopez et al. v. Suzuki Motor of Am., Inc. et al., 7 Case No.: 2:25-cv-07808-FWS (JDEx). I agree to comply with and to be bound by all the 8 terms of this Stipulated Protective Order and I understand and acknowledge that failure to 9 so comply could expose me to sanctions and punishment in the nature of contempt. I 10 solemnly promise that I will not disclose in any manner any information or item that is 11 subject to this Stipulated Protective Order to any person or entity except in strict 12 compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Central District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. 17 18 Date: _______________________ 19 20 City and State where sworn and signed: 21 22 23 Printed Name: _______________________ 24 25 Signature: _______________________ 26 27