Case 2:22-cv-04204-MWF-GJS Document 44 Filed 01/17/23 Page 1 of 16 Page ID #:282

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5 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

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7 NADER AHMED and SADIA Case No.: 2:22-cv-04204-MWF-GJS 8

HASAN,

9 STIPULATED PROTECTIVE 10 Plaintiffs, ORDER1

11 v. 12

TOYOTA MOTOR CREDIT

13 CORPORATION; TRANS UNION 14 LLC; EQUIFAX INFORMATION SERVICES, LLC; and EXPERIAN 15 INFORMATION SOLUTIONS, INC., 16 Defendants. 17 18 1. 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 disclosure 21 and from use for any purpose other than pursuing this litigation may be warranted. 22 Accordingly, the parties hereby stipulate to and petition the Court to enter the 23 following Stipulated Protective Order. The parties acknowledge that this Order does 24 not confer blanket protections on all disclosures or responses to discovery and that 25 the protection it affords from public disclosure and use extends only to the limited 26 27 1 This Stipulated Protective Order is substantially based on the model protective 28 order provided under Magistrate Judge Gail J. Standish’s Procedures.

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1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. 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 from 7 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, court 14 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 such 18 material in preparation for and in the conduct of trial, to address their handling at the 19 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

C. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE

26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information 28

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1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 2 the standards that will be applied when a party seeks permission from the court to 3 file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 proceedings and records in civil cases. In connection with non-dispositive motions, 6 good cause must be shown to support a filing under seal. See Kamakana v. City and 7 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 8 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 9 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 10 good cause showing), and a specific showing of good cause or compelling reasons 11 with proper evidentiary support and legal justification, must be made with respect to 12 Protected Material that a party seeks to file under seal. The parties’ mere designation 13 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 14 submission of competent evidence by declaration, establishing that the material 15 sought to be filed under seal qualifies as confidential, privileged, or otherwise 16 protectable—constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, then 18 compelling reasons, not only good cause, for the sealing must be shown, and the 19 relief sought shall be narrowly tailored to serve the specific interest to be protected. 20 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 21 item or type of information, document, or thing sought to be filed or introduced under 22 seal, the party seeking protection must articulate compelling reasons, supported by 23 specific facts and legal justification, for the requested sealing order. Again, 24 competent evidence supporting the application to file documents under seal must be 25 provided by declaration. 26 Any document that is not confidential, privileged, or otherwise protectable in 27 its entirety will not be filed under seal if the confidential portions can be redacted. If 28

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1 documents can be redacted, then a redacted version for public viewing, omitting only 2 the confidential, privileged, or otherwise protectable portions of the document, shall 3 be filed. Any application that seeks to file documents under seal in their entirety 4 should include an explanation of why redaction is not feasible. 5 2. DEFINITIONS 6 2.1 Action: Ahmed, Nader and Sadia Hasan v. Credit Corporation, et al., 7 2:22-cv-04204-MWF-GJS. 8 2.2 Challenging Party: a Party or Non-Party that challenges the 9 designation of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 13 Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced or 22 generated in disclosures or responses to discovery. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.8 House Counsel: attorneys who are employees of a party to this Action. 27 28

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

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1 Any use of Protected Material at trial shall be governed by the orders of the 2 trial judge and other applicable authorities. This Order does not govern the use of 3 Protected Material at trial. 4 4. DURATION 5 FINAL DISPOSITION of the action is defined as the conclusion of any 6 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 7 has run. Except as set forth below, the terms of this protective order apply through 8 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 9 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 10 but will have to file a separate action for enforcement of the agreement once all 11 proceedings in this case are complete. 12 Once a case proceeds to trial, information that was designated as 13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 14 as an exhibit at trial becomes public and will be presumptively available to all 15 members of the public, including the press, unless compelling reasons supported by 16 specific factual findings to proceed otherwise are made to the trial judge in advance 17 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record). Accordingly, the 20 terms of this protective order do not extend beyond the commencement of the trial. 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for 23 Protection. Each Party or Non-Party that designates information or items 24 for protection under this Order must take care to limit any such designation to specific 25 material that qualifies under the appropriate standards. The Designating Party must 26 designate for protection only those parts of material, documents, items or oral or 27 written communications that qualify so that other portions of the material, 28

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1 documents, items or communications for which protection is not warranted are not 2 swept unjustifiably within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 13 that qualifies for protection under this Order must be clearly so designated before the 14 material is disclosed or produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Producing Party affix at a minimum, the legend 19 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 20 contains protected material. If only a portion of the material on a page qualifies for 21 protection, the Producing Party also must clearly identify the protected portion(s) 22 (e.g., by making appropriate markings in the margins). 23 A Party or Non-Party that makes original documents available for inspection 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 28

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1 it wants copied and produced, the Producing Party must determine which documents, 2 or portions thereof, qualify for protection under this Order. Then, before producing 3 the specified documents, the Producing Party must affix the “CONFIDENTIAL 4 legend” to each page that contains Protected Material. If only a portion of the material 5 on a page qualifies for protection, the Producing Party also must clearly identify the 6 protected portion(s) (e.g., by making appropriate markings in the margins). 7 (b) for testimony given in depositions that the Designating Party 8 identifies the Disclosure or Discovery Material on the record, before the close of the 9 deposition all protected testimony. 10 (c) for information produced in some form other than documentary and 11 for any other tangible items, that the Producing Party affix in a prominent place on 12 the exterior of the container or containers in which the information is stored the 13 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive 18 the Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Order. 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37-1 et seq. 28

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1 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 2 stipulation pursuant to Local Rule 37-2. 3 6.4 The burden of persuasion in any such challenge proceeding shall be on the 4 Designating Party. Frivolous challenges, and those made for an improper purpose 5 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 6 expose the Challenging Party to sanctions. Unless the Designating Party has waived 7 or withdrawn the confidentiality designation, all parties shall continue to afford the 8 material in question the level of protection to which it is entitled under the Producing 9 Party’s designation until the Court rules on the challenge. 10 7. ACCESS TO AND USE OF PROTECTED MATERIAL 11 7.1 Basic Principles. A Receiving Party may use Protected Material that is 12 disclosed or produced by another Party or by a Non-Party in connection with this 13 Action only for prosecuting, defending or attempting to settle this Action. Such 14 Protected Material may be disclosed only to the categories of persons and under the 15 conditions described in this Order. When the Action has been terminated, a Receiving 16 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 17 Protected Material must be stored and maintained by a Receiving Party at a 18 location and in a secure manner that ensures that access is limited to the persons 19 authorized under this Order. 20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 21 otherwise ordered by the court or permitted in writing by the Designating Party, a 22 Receiving Party may disclose any information or item designated 23 “CONFIDENTIAL” only to: 24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 25 well as employees of said Outside Counsel of Record to whom it is reasonably 26 necessary to disclose the information for this Action; 27 28

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1 (b) the officers, directors, and employees (including House Counsel) of 2 the Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Comply” (Exhibit A); 6 (d) the court and its personnel and any juror or alternate juror; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Comply” (Exhibit A); 11 (g) the author or recipient of a document containing the information or 12 a custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in 14 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 15 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 16 they will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Comply” (Exhibit A), unless otherwise agreed 18 by the Designating Party or ordered by the court. Pages of transcribed deposition 19 testimony or exhibits to depositions that reveal Protected Material may be separately 20 bound by the court reporter and may not be disclosed to anyone except as permitted 21 under this Stipulated Protective Order; and 22 (i) any mediators or settlement officers and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25

PRODUCED IN OTHER LITIGATION

26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 28

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1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification 3 shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or 5 order to issue in the other litigation that some or all of the material covered by the 6 subpoena or order is subject to this Protective Order. Such notification shall include 7 a copy of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be 9 pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with 11 the subpoena or court order shall not produce any information designated in this 12 action as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this Action 17 to disobey a lawful directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 20 BE PRODUCED IN THIS LITIGATION 21 (a) The terms of this Order are applicable to information produced by a Non- 22 Party in this Action and designated as “CONFIDENTIAL.” Such information 23 produced by Non-Parties in connection with this litigation is protected by the 24 remedies and relief provided by this Order. Nothing in these provisions should be 25 construed as prohibiting a Non-Party from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to produce 27 a Non-Party’s confidential information in its possession, and the Party is subject to 28

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1 an agreement with the Non-Party not to produce the Non-Party’s confidential 2 information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and the Non-Party 4 that some or all of the information requested is subject to a confidentiality agreement 5 with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the Non- 10 Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court within 14 12 days of receiving the notice and accompanying information, the Receiving Party may 13 produce the Non-Party’s confidential information responsive to the discovery 14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 15 not produce any information in its possession or control that is subject to the 16 confidentiality agreement with the Non-Party before a determination by the court. 17 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 18 of seeking protection in this court of its Protected Material. 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 21 Protected Material to any person or in any circumstance not authorized under this 22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 23 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 24 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 25 persons to whom unauthorized disclosures were made of all the terms of this Order, 26 and (d) request such person or persons to execute the “Acknowledgment an 27 Agreement to Comply” attached hereto as Exhibit A. 28

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1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 2 OTHERWISE PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material. If a Party’s request to file Protected Material under seal 25 is denied by the court, then the Receiving Party may file the information in the public 26 record unless otherwise instructed by the court. 27 13. FINAL DISPOSITION 28

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1 After the final disposition of this Action, as defined in paragraph 6, within 60 2 days of a written request by the Designating Party, each Receiving Party must return 3 all Protected Material to the Producing Party or destroy such material. As used in this 4 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 5 summaries, and any other format reproducing or capturing any of the Protected 6 Material. Whether the Protected Material is returned or destroyed, the Receiving 7 Party must submit a written certification to the Producing Party (and, if not the same 8 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 9 (by category, where appropriate) all the Protected Material that was returned or 10 destroyed and (2) affirms that the Receiving Party has not retained any copies, 11 abstracts, compilations, summaries or any other format reproducing or capturing any 12 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 13 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 14 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 15 reports, attorney work product, and consultant and expert work product, even if such 16 materials contain Protected Material. Any such archival copies that contain or 17 constitute Protected Material remain subject to this Protective Order as set forth in 18 Section 4 (DURATION). 19

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I 14. VIOLATION

2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. > | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. DATED: January 16, 2023 /s/ Youssef H. Hammoud 7 Attorneys for Plaintiffs 8 Nader Ahmed and Sadia Hasan 10 DATED: January 16, 2023 /s/Jennifer Brooks Attorneys for Defendant 11 Equifax Information Services LLC 12 13 || DATED: January 16, 2023 /s/ Zachary Frampton 14 Attorneys for Defendant Toyota Motor Credit Corporation 15 16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 || DATED: January 17, 2023 19 20 HON. GAIL J. STANDISH □□ United States Magistrate Judge 22 23 24 25 26 27 28 -15-

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1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO COMPLY 3 I, [ print or type full name], declare under penalty of perjury 4 as follows: 5 1. My address is . 6 2. My present employer is . 7 3. My present occupation or job description is . 8 4. I have read in its entirety and understand the Stipulated Protective Order 9 that was issued by the United States District Court for the Central District of 10 California on [date] in this case of Nader Ahmed and Sadia Hasan v. Toyota Motor 11 Credit Corporation, et al., 2:22-cv-04204-MWF-GJS. 12 5. I agree to comply with all the terms of this Stipulated Protective Order 13 and I understand and acknowledge that failure to comply could expose me to 14 sanctions and punishment in the nature of contempt. 15 6. I solemnly promise that I will not disclose in any manner any 16 information or item that is subject to this Stipulated Protective Order to any person 17 or entity except in strict compliance with the provisions of this Order. 18 7. I further agree to submit to the jurisdiction of the Unites Sates District 19 Court for the Central District of California for enforcing the terms of this Stipulated 20 Protective Order, even if such enforcement proceedings occur after termination of 21 this action. 22 Date: 23 24 City and State where sworn and signed: 25 Printed name: 26 27 Signature: 28

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