Case 2:20-cv-02466-SSS-AGR Document 69 Filed 08/08/22 Page 1 of 14 Page ID #:976

1 LEWIS BRISBOIS BISGAARD & SMITH LLP

JUDD A. GILEFSKY, SB# 198694

2 E-Mail: Judd.Gilefsky@lewisbrisbois.com

RYAN K. MARDEN, SB# 217709

3 E-Mail: Ryan Marden@lewisbrisbois.com

KARYN L. IHARA, SB# 298950

4 E-Mail: Karyn.Ihara@lewisbrisbois.com 633 West 5th Street, Suite 4000 5 Los Angeles, California 90071 Telephone: 213.250.1800 6 Facsimile: 213.250.7900

7 Attorneys for Defendant,

BMW OF NORTH AMERICA, LLC

8

9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 JACQUELINE PHILLIPS-HARRIS, Case No. 2:20-CV-02466-SSS-AGR

13 Plaintiff, JOINT STIPULATED

PROTECTIVE ORDER

14 vs.

15 BMW OF NORTH AMERICA, LLC, et al. 16 Trial Date: None Set Defendant. 17

18 I. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary, or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 23 enter the following Stipulated Protective Order. The parties acknowledge that this 24 Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 only to the limited information or items that are entitled to confidential treatment 27 under the applicable legal principles. The parties further acknowledge, as set forth in LEWIS 28 Section 12.3, below, that this Stipulated Protective Order does not entitle them to

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1 file confidential information under seal; Civil Local Rule 79-5 sets forth the 2 procedures that must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve valuable research, development, 6 commercial, financial, technical and/or proprietary information for which 7 special protection from public disclosure and from use for any purpose other 8 than prosecution of this action is warranted. Such confidential and proprietary 9 materials and information consist of, among other things, confidential 10 information regarding confidential business practices, or other confidential 11 research, development, or commercial information (including information 12 implicating privacy rights of third parties), information otherwise generally 13 unavailable to the public, or which may be privileged or otherwise protected 14 from disclosure under state or federal statutes, court rules, case decisions, or 15 common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to 18 ensure that the parties are permitted reasonable necessary uses of such material 19 in preparation for and in the conduct of trial, to address their handling at the end of 20 the litigation, and serve the ends of justice, a protective order for such information 21 is justified in this matter. It is the intent of the parties that information will not 22 be designated as confidential for tactical reasons and that nothing be so 23 designated without a good faith belief that it has been maintained in a confidential, 24 non-public manner, and there is good cause why it should not be part of the public 25 record of this case. 26 Designating Party must provide Receiving Party with a Good Cause 27 Statement for each Information or Items it designates as “CONFIDENTIAL.”

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1 II. DEFINITIONS 2 2.1 Action: This pending action entitled Phillips-Harris v. BMW NA et. al. 3 2.2 Challenging Party: a Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 6 how it is generated, stored or maintained) or tangible things that qualify for 7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 8 the Good Cause Statement. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 10 their support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless 15 of the medium or manner in which it is generated, stored, or maintained (including, 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8 House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9 Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 2.10 Outside Counsel of Record: attorneys who are not employees of a 27 party to this Action but are retained to represent or advise a party to this Action and LEWIS 28 have appeared in this Action on behalf of that party or are affiliated with a law firm

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1 which 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 8 support 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 14 Material 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. 21 Any use of Protected Material at trial shall be governed by the orders of the 22 trial judge. This Order does not govern the use of Protected Material at trial. 23 4. DURATION 24 Once a case proceeds to trial, all of the information that was designated as 25 confidential or maintained pursuant to this protective order becomes public and will 26 be presumptively available to all members of the public, including the press, unless 27 compelling reasons supported by specific factual findings to proceed otherwise are LEWIS 28 made to the trial judge in advance of the trial. See Kamakana v. City and County of

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1 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 2 showing for sealing documents produced in discovery from “compelling reasons” 3 standard when merits-related documents are part of court record). Accordingly, the 4 terms of this protective order do not extend beyond the commencement of the trial. 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 8 under this Order must take care to limit any such designation to specific material 9 that qualifies under the appropriate standards. The Designating Party must designate 10 for 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 Nothing in this Protective Order shall be interpreted to restrict or curtail 23 Plaintiff’s rights under California Civil Code Section 1793.26, which prohibits 24 confidentiality clause, gag clause, or similar clause in any agreement between 25 Plaintiff and Defendant regarding the disclosure of problems with the vehicle 26 experienced by Plaintiff or the nonfinancial terms of the reacquisition. 27 5.2 Manner and Timing of Designations: Except as otherwise provided in LEWIS 28 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

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1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 2 under this Order must be clearly so designated before the material is disclosed or 3 produced. 4 Designation in conformity with this Order requires: 5 (a) for information in documentary form (e.g., paper or electronic 6 documents, but excluding transcripts of depositions or other pretrial or trial 7 proceedings), that the Producing Party affix at a minimum, the legend 8 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 9 contains protected material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly identify the protected 11 portion(s) (e.g., by making appropriate markings in the margins). 12 13 Before producing the documents it deems to be qualified for protection under 14 this Order, the Producing Party must affix the “CONFIDENTIAL legend” to each 15 page that contains Protected Material. If only a portion or portions of the material on 16 a page qualifies for protection, the Producing Party also must clearly identify the 17 protected portion(s) (e.g., by making appropriate markings in the margins). 18 For documents that have already been produced prior to the signing of this 19 Stipulated Protective Order, the Producing Party must designate the Information or 20 Items it deems “CONFIDENTIAL” and re-produce them according to the manner 21 described under section 5.2(a) of this Stipulated Protective Order, subject to the 22 Good Cause Requirement and the Receiving Party’s objection. 23 (b) for testimony given in depositions that the Designating Party identify 24 the Disclosure or Discovery Material on the record, before the close of the 25 deposition all protected testimony. 26 (c) for information produced in some form other than documentary and for 27 any other tangible items, that the Producing Party affix in a prominent place on the LEWIS 28 exterior of the container or containers in which the information is stored the legend

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1 “CONFIDENTIAL.” If only a portion or portions of the information warrants 2 protection, the Producing Party, to the extent practicable, shall identify the protected 3 portion(s). 4 5.3 Inadvertent Failures to Designate: If timely corrected, an inadvertent 5 failure to designate qualified information or items does not, standing alone, waive 6 the Designating Party’s right to secure protection under this Order for such material. 7 Upon timely correction of a designation, the Receiving Party must make reasonable 8 efforts to assure that the material is treated in accordance with the provisions of this 9 Order. 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges: Any Party or Non-Party may challenge a 12 designation of confidentiality at any time that is consistent with the Court’s 13 Scheduling Order. 14 6.2 Meet and Confer: The Challenging Party shall initiate the dispute 15 resolution process under Local Rule 37.1 et seq. 16 6.3 The burden of persuasion in any such challenge proceeding shall be on 17 the Designating Party: Frivolous challenges, and those made for an improper 18 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 19 parties) may expose the Challenging Party to sanctions. Unless the Designating 20 Party has waived or withdrawn the confidentiality designation, all parties shall 21 continue to afford the material in question the level of protection to which it is 22 entitled under the Producing Party’s designation until the Court rules on the 23 challenge. 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles: A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending, or attempting to settle this Action. Such LEWIS 28 Protected Material may be disclosed only to the categories of persons and under the

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1 conditions described in this Order. When the Action has been terminated, a 2 Receiving Party must comply with the provisions of section 13 below (FINAL 3 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 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 10 “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 12 as employees of said Outside Counsel of Record to whom it is reasonably necessary 13 to 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 23 signed 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: (1) the deposing party LEWIS 28 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

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

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

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

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1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material: A Party that seeks to file under seal any 4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the 6 specific Protected Material at issue. If a Party's request to file Protected Material 7 under seal is denied by the court, then the Receiving Party may file the information 8 in the public record unless otherwise instructed by the court. 9 13. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 4, within 60 11 days of a written request by the Designating Party, each Receiving Party must return 12 all Protected Material to the Producing Party or destroy such material. As used in 13 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 14 summaries, and any other format reproducing or capturing any of the Protected 15 Material. Whether the Protected Material is returned or destroyed, the Receiving 16 Party must submit a written certification to the Producing Party (and, if not the same 17 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 18 (by category, where appropriate) all the Protected Material that was returned or 19 destroyed and (2)affirms that the Receiving Party has not retained any copies, 20 abstracts, compilations, summaries or any other format reproducing or capturing any 21 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 22 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 24 reports, attorney work product, and consultant and expert work product, even if such 25 materials contain Protected Material. Any such archival copies that contain or 26 constitute Protected Material remain subject to this Protective Order as set forth in 27 Section 4 (DURATION). LEWIS 28 14. Any violation of this Order may be punished by any and all appropriate

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1 || measures including, without limitation, contempt proceedings and/or monetary 2 || sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 6|}DATED: August 3 __, 2022 GOLDSMITH WEST 8 By: 9 DA . LDSMITH

PHUC M. LE

10 Attorneys for Plaintiff JACQUELINE 11 PHILLIPS-HARRIS 12 13 DATED: August 5, 2022 JUDD A. GILEFSKY 14 RYAN MARDEN 15 KARYN L. IHARA 6 LEWIS BRISBOIS BISGAARD & SMITH LLP BA 17 By: ie i" L- 18 RYAN MARDEN 19 Attorneys for Defendant BMW NORTH

AMERICA, LLC

20 71 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED: 22 23 DATED: August 8, 2022 24 Mini A Kearny 26 7 ALICIA G. ROSENBERG United States Magistrate Judge Lewis 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 Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of ________________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and I understand 10 and acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 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 of 16 this Stipulated Protective Order. I hereby appoint _________________________ 17 [print or type full name] of ___________________________ [print or type full 18 address and telephone number] as my California agent for service of process in 19 connection with this action or any proceedings related to enforcement of this 20 Stipulated Protective Order. 21 22 DATED: ____________________ 23 City and State where sworn and signed: ______________________________ 24 Printed Name: ________________________ 25 Signature: ___________________________ 26 27

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