Case 2:21-cv-07526-VAP-KES Document 32 Filed 05/27/22 Pagelof15 Page ID#:573

1 || SARAH E. ROSS, Bar No. 252206 sross@littler com 2 || ALEXANDRA BERNSTEIN, Bar No. 327492 abernstein@littler-com 3 || LITTLER MENDELSON, P.C. 2049 Century Park East 4 || 5th Floor □ Los Angeles, California 90067.3107 5 Telephone: 310.553.0308 ‘ Fax No.: 310.553.5583 Attorneys for Defendant 7 || THE GOODYEAR TIRE & RUBBER

COMPANY

LARRY W. LEE, bar no. 228175 9 Wwiee(@diversitylaw.com MAX W. GAVRON, bar no. 291697 10 meravron @diversity‘aw.com

DIVERSITY LAW GROUP, P.C.

11 | S5I15S. Figueroa Street, Suite 1250 Los Angeles, CA 90071 12 | Telephone: 213.488.6555 3 Fax No. 213.488.6554 Attorneys for Plaintiff 14 DANIEL RODAS 15 16

UNITED STATES DISTRICT COURT

17

CENTRAL DISTRICT OF CALIFORNIA

18 19 DANIEL RODAS, Case No. 2:21-cv-07526-VAP-(KESx) 20 Plaintiff, STIPULATED PROTECTIVE 21 ORDER Vv. 22 Judge: Hon. Virginia A. Phillips

THE GOODYEAR TIRE & RUBBER

23 | COMPANY, Complaint Filed: August 4, 2021 Los ngcles County Superior Court 24 Defendant. 21STCV28702 25 26 27 28

Case 2:21-cv-07526-VAP-KES Document 32 Filed 05/27/22 Page 2 of 15 Page ID #:574

1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 6 Stipulated Protective Order. The parties acknowledge that this Order does not confer 7 blanket protections on all disclosures or responses to discovery and that the protection 8 it affords from public disclosure and use extends only to the limited information or items 9 that are entitled to confidential treatment under the applicable legal principles. The 10 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 11 Protective Order does not entitle them to file confidential information under seal; Civil 12 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 13 will be applied when a party seeks permission from the court to file material under seal. 14 B. GOOD CAUSE STATEMENT 15 This action is likely to involve confidential, non-public, sensitive, and/or 16 proprietary trade secrets, business, employment, financial, and personally identifiable 17 information, documents and other materials for which special protection from public 18 disclosure and from use for any purpose other than prosecution of this action is 19 warranted. Such confidential and proprietary materials and information consist of, 20 among other things, confidential business or financial information, information 21 regarding confidential business practices, or other confidential research, development, 22 or commercial information (including information implicating privacy rights of third 23 parties), information otherwise generally unavailable to the public, or which may be 24 privileged or otherwise protected from disclosure under state or federal statutes, court 25 rules, case decisions, or common law. Accordingly, to expedite the flow of information, 26 to facilitate the prompt resolution of disputes over confidentiality of discovery 27 materials, to adequately protect information the parties are entitled to keep confidential, 28 to ensure that the parties are permitted reasonable necessary uses of such material in

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1 preparation for and in the conduct of trial, to address their handling at the end of the 2 litigation, and serve the ends of justice, a protective order for such information is 3 justified in this matter. It is the intent of the parties that information will not be 4 designated as confidential for tactical reasons and that nothing be so designated without 5 a good faith belief that it has been maintained in a confidential, non-public manner, and 6 there is good cause why it should not be part of the public record of this case. 7 2. DEFINITIONS 8 2.1 Action: Daniel Rodas v. The Goodyear Tire & Rubber Company, Case No. 9 2:21-cv-07526-VAP-(KESx) 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 11 information or items under this Order. 12 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how 13 it is generated, stored or maintained) or tangible things that qualify for protection under 14 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 15 Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 17 support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless of 22 the medium or manner in which it is generated, stored, or maintained (including, among 23 other things, testimony, transcripts, and tangible things), that are produced or generated 24 in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 27 expert witness or as a consultant in this Action. 28

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1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 7 this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm which 9 has appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only Protected 25 Material (as defined above), but also (1) any information copied or extracted from 26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 Material; and (3) any testimony, conversations, or presentations by Parties or their 28 Counsel that might reveal Protected Material.

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1 Any use of Protected Material at trial shall be governed by the orders of the trial 2 judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 Once a case proceeds to trial, all of the court-filed information to be introduced 5 that was previously designated as confidential or maintained pursuant to this protective 6 order becomes public and will be presumptively available to all members of the public, 7 including the press, unless compelling reasons supported by specific factual findings to 8 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 9 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 10 “good cause” showing for sealing documents produced in discovery from “compelling 11 reasons” standard when merits-related documents are part of court record). 12 Accordingly, the terms of this protective order do not extend beyond the 13 commencement of the trial. 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection under this 17 Order must take care to limit any such designation to specific material that qualifies 18 under the appropriate standards. The Designating Party must designate for protection 19 only those parts of material, documents, items, or oral or written communications that 20 qualify so that other portions of the material, documents, items, or communications for 21 which protection is not warranted are not swept unjustifiably within the ambit of this 22 Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations that 24 are shown to be clearly unjustified or that have been made for an improper purpose 25 (e.g., to unnecessarily encumber the case development process or to impose 26 unnecessary expenses and burdens on other parties) may expose the Designating Party 27 to sanctions. 28 If it comes to a Designating Party’s attention that information or items that it

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1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 5.2 Manner and Timing of Designations. Except as otherwise provided in this 4 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 5 or ordered, Disclosure or Discovery Material that qualifies for protection under this 6 Order must be clearly so designated before the material is disclosed or produced. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or electronic 9 documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion or portions of the material on a page 13 qualifies for protection, the Producing Party also must clearly identify the protected 14 portion(s) (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and before 18 the designation, all of the material made available for inspection shall be deemed 19 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 20 copied and produced, the Producing Party must determine which documents, or portions 21 thereof, qualify for protection under this Order. Then, before producing the specified 22 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 23 that contains Protected Material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify the protected 25 portion(s) (e.g., by making appropriate markings in the margins). 26 (b) for testimony given in depositions that the Designating Party 27 identify the Disclosure or Discovery Material on the record, before the close of the 28 deposition all protected testimony.

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1 (c) for information produced in some form other than documentary and 2 for 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 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive the 9 Designating Party’s right to secure protection under this Order for such material. Upon 10 timely correction of a designation, the Receiving Party must make reasonable efforts to 11 assure that the material is treated in accordance with the provisions of this Order. 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s Scheduling 15 Order. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 Burden. The burden of persuasion in any such challenge proceeding shall 19 be on the Designating Party. Frivolous challenges, and those made for an improper 20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 21 may expose the Challenging Party to sanctions. Unless the Designating Party has 22 waived or withdrawn the confidentiality designation, all parties shall continue to afford 23 the material in question the level of protection to which it is entitled under the Producing 24 Party’s designation until the Court rules on the 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 Action 28 only for prosecuting, defending, or attempting to settle this Action. Such Protected

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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 13 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 8 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 9 may disclose any information or item designated “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 11 employees of said Outside Counsel of Record to whom it is reasonably necessary to 12 disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 28 not be permitted to keep any confidential information unless they sign the

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1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 2 by the Designating Party or ordered by the court. Pages of transcribed deposition 3 testimony or exhibits to depositions that reveal Protected Material may be separately 4 bound by the court reporter and may not be disclosed to anyone except as permitted 5 under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 9 OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” 12 that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification shall 14 include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the subpoena or 17 order is subject to this Protective Order. Such notification shall include a copy of this 18 Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with the 22 subpoena or court order shall not produce any information designated in this action as 23 “CONFIDENTIAL” before a determination by the court from which the subpoena or 24 order issued, unless the Party has obtained the Designating Party’s permission. The 25 Designating Party shall bear the burden and expense of seeking protection in that court 26 of its confidential material and nothing in these provisions should be construed as 27 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 28 from another court.

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1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 5 by Non-Parties in connection with this litigation is protected by the remedies and relief 6 provided by this Order. Nothing in these provisions should be construed as prohibiting 7 a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery request. 23 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 24 any information in its possession or control that is subject to the confidentiality 25 agreement with the Non-Party before a determination by the court. Absent a court order 26 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 27 in this court of its Protected Material. 28

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1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 9 that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 Stipulated Protective Order. Similarly, no Party waives any right to object on any

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1 ground to use in evidence of any of the material covered by this Protective Order. 2 12.3 Filing Protected Material. A Party that seeks to file under seal any 3 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 4 only be filed under seal pursuant to a court order authorizing the sealing of the specific 5 Protected Material at issue. If a Party’s request to file Protected Material under seal is 6 denied by the court, then the Receiving Party may file the information in the public 7 record unless otherwise instructed by the Court. 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, within 60 days of a written request by 10 the Designating Party, each Receiving Party must return all Protected Material to the 11 Producing Party or destroy such material. As used in this subdivision, “all Protected 12 Material” includes all copies, abstracts, compilations, summaries, and any other format 13 reproducing or capturing any of the Protected Material. Whether the Protected Material 14 is returned or destroyed, the Receiving Party must submit a written certification to the 15 Producing Party (and, if not the same person or entity, to the Designating Party) by the 16 60 day deadline that affirms that the Receiving Party has not retained any copies, 17 abstracts, compilations, summaries or any other format reproducing or capturing any of 18 the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 19 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 20 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 21 work product, and consultant and expert work product, even if such materials contain 22 Protected Material. Any such archival copies that contain or constitute Protected 23 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 24 // 25 // 26 // 27 // 28 //

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1 |) 14. VIOLATION 2 Any violation of this Order may be punished by any and all appropriate measures 3 || including, without limihttps://www.johnnywas.com/customer/account/login/tation, 4 || contempt proceedings and/or monetary sanctions. 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 || Dated: May 26, 2022 DIVERSITY LAW GROUP, P.C. 10 /s/ Max W. Gavron 11 LARRY W. LEE

MAX W. GAVRON

12 Attorneys for Plaintiff

DANIEL RODAS

13 14 15 16 || Dated: May 26, 2022 LITTLER MENDELSON P.C. 17 18 /s/ Alexandra Bernstein 19 SARAH E. ROSS

ALEXANDRA BERNSTEIN

20 Attorneys for Defendant

THE GOODYEAR TIRE & RUBBER

21 COMPANY 22 23

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

24 Dated: May 27, 2022 25 *! Toms 6 Seatts 27 || Hon. Karen E. Scott 28 || United States Magistrate Judge sneer 13.

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1 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Alexandra Bernstein, hereby attest that 2 all signatories on whose behalf this filing is submitted, concur in the filing’s content, 3 have authorized the filing of this document, and I have obtained authorization to affix 4 Plaintiff’s counsel’s electronic signature to this document. 5

6 Dated: May 26, 2022 7 8 /s/ Alexandra Bernstein 9 ALEXANDRA BERNSTEIN

10

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that I 5 have read in its entirety and understand the Protective Order that was issued by the 6 United States District Court for the Central District of California on 7 _________________________ in the case of Daniel Rodas v. The Goodyear Tire & 8 Rubber Company, Case No. 2:21-cv-07526-VAP-(KESx). I agree to comply with and 9 to be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Protective Order to any person or entity except 13 in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with this 20 action or any proceedings related to enforcement of this Stipulated Protective Order. 21 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________

26 4 883-2901-3794.1 / 056530-1316

27 28

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