1 BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505) 2 E-mail: [email protected] Theodore Dorenkamp III (SBN: 277004) 3 E-mail: [email protected] Brian A. Reynolds (SBN: 296434) 4 E-mail: [email protected] 970 West 190th Street, Suite 700 5 Torrance, California 90502 Tel No.: 310/ 768-3068 6 Fax No.: 310/ 719-1019 7 Attorneys for Defendant JAGUAR LAND ROVER NORTH AMERICA, LLC 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION 11 12 ROBERT LOBL, ) CASE NO: 2:19-cv-04828 ODW (SKx) ) 13 Plaintiff, ) District Judge: Otis D. Wright, II ) Magistrate Judge: Steve Kim 14 vs. ) ) 15 JAGUAR LAND ROVER NORTH ) STIPULATED PROTECTIVE ORDER AMERICA, LLC, a Limited ) 16 Liability Company; and DOES 1 ) through 100, inclusive, ) Trial: June 2, 2020 17 ) Defendants. ) 18 ) 19 20 A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 25 to enter the following Stipulated Protective Order. The parties acknowledge that 26 this Order does not confer blanket protections on all disclosures or responses to 27 discovery and that the protection it affords from public disclosure and use extends 28 only to the limited information or items that are entitled to confidential treatment 1 under the applicable legal principles. 2 B. GOOD CAUSE STATEMENT 3 This action is likely to involve trade secrets, customer information, and 4 other valuable research, development, commercial, financial, technical and/or 5 proprietary information for which special protection from public disclosure and 6 from use for any purpose other than prosecution of this action is warranted. Such 7 confidential and proprietary materials and information consist of, among other 8 things, confidential business or financial information, information regarding 9 confidential business practices, or other confidential research, development, or 10 commercial information (including information implicating privacy rights of third 11 parties), information otherwise generally unavailable to the public, or which may 12 be privileged or otherwise protected from disclosure under state or federal statutes, 13 court rules, case decisions, or common law. Accordingly, to expedite the flow of 14 information, to facilitate the prompt resolution of disputes over confidentiality of 15 discovery materials, to adequately protect information the parties are entitled to 16 keep confidential, to ensure that the parties are permitted reasonable necessary 17 uses of such material in preparation for and in the conduct of trial, to address their 18 handling at the end of the litigation, and serve the ends of justice, a protective 19 order for such information is justified in this matter. It is the intent of the parties 20 that information will not be designated as confidential for tactical reasons and that 21 nothing be so designated without a good faith belief that it has been maintained in 22 a confidential, non-public manner, and there is good cause why it should not be 23 part of the public record of this case. 24 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 25 SEAL 26 The parties further acknowledge, as set forth in Section 12.3, below, that 27 this Stipulated Protective Order does not entitle them to file confidential 28 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 1 be followed and the standards that will be applied when a party seeks permission 2 from the court to file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 proceedings and records in civil cases. In connection with non-dispositive 5 motions, good cause must be shown to support a filing under seal. See Kamakana 6 v. City and County of Honolulu,

(9th Cir. 2006), Phillips v. 7 Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. 8 Sony Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated 9 protective orders require good cause showing), and a specific showing of good 10 cause or compelling reasons with proper evidentiary support and legal 11 justification, must be made with respect to Protected Material that a party seeks to 12 file under seal. The parties' mere designation of Disclosure or Discovery Material 13 as CONFIDENTIAL does not—without the submission of competent evidence by 14 declaration, establishing that the material sought to be filed under seal qualifies as 15 confidential, privileged, or otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, 17 then compelling reasons, not only good cause, for the sealing must be shown, and 18 the relief sought shall be narrowly tailored to serve the specific interest to be 19 protected. See Pintos v. Pacific Creditors Ass'n.,

(9th Cir. 20 2010). For each item or type of information, document, or thing sought to be filed 21 or introduced under seal in connection with a dispositive motion or trial, the party 22 seeking protection must articulate compelling reasons, supported by specific facts 23 and legal justification, for the requested sealing order. Again, competent evidence 24 supporting the application to file documents under seal must be provided by 25 declaration. 26 Any document that is not confidential, privileged, or otherwise protectable 27 in its entirety will not be filed under seal if the confidential portions can be 28 redacted. If documents can be redacted, then a redacted version for public 1 viewing, omitting only the confidential, privileged, or otherwise protectable 2 portions of the document, shall be filed. Any application that seeks to file 3 documents under seal in their entirety should include an explanation of why 4 redaction is not feasible. 5 2. DEFINITIONS 6 2.1 Action: Robert Lobl v. Jaguar Land Rover North America, LLC, et. 7 al., United States District Court — Central District, Case No. 2:19-cv-04828 ODW 8 (SKx). 9 2.2 Challenging Party: a Party or Non-Party that challenges the 10 designation of information or items under this Order. 11 2.3 "CONFIDENTIAL" Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 16 their support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information 18 or items that it produces in disclosures or in responses to discovery as 19 "CONFIDENTIAL." 20 2.6 Disclosure or Discovery Material: all items or information, 21 regardless of the medium or manner in which it is generated, stored, or maintained 22 (including, among other things, testimony, transcripts, and tangible things), that 23 are produced or generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a 25 matter pertinent to the litigation who has been retained by a Party or its counsel to 26 serve as an expert witness or as a consultant in this Action. 27 2.8 House Counsel: attorneys who are employees of a party to this 28 Action. House Counsel does not include Outside Counsel of Record or any other 1 outside counsel. 2 2.9 Non-Party: any natural person, partnership, corporation, association 3 or other legal entity not named as a Party to this action. 4 2.10 Outside Counsel of Record: attorneys who are not employees of a 5 party to this Action but are retained to represent or advise a party to this Action 6 and have appeared in this Action on behalf of that party or are affiliated with a law 7 firm that has appeared on behalf of that party, and includes support staff. 8 2.11 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Outside Counsel of Record (and 10 their support staffs). 11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.13 Professional Vendors: persons or entities that provide litigation 14 support services (e.g., photocopying, videotaping, translating, preparing exhibits 15 or demonstrations, and organizing, storing, or retrieving data in any form or 16 medium) and their employees and subcontractors. 17 2.14 Protected Material: any Disclosure or Discovery Material that is 18 designated as "CONFIDENTIAL." 19 2.15 Receiving Party: a Party that receives Disclosure or Discovery 20 Material from a Producing Party. 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 trial judge. This Order does not govern the use of Protected Material at trial. 1 4. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or 4 introduced as an exhibit at trial becomes public and will be presumptively 5 available to all members of the public, including the press, unless compelling 6 reasons supported by specific factual findings to proceed otherwise are made to 7 the trial judge in advance of the trial. See Kamakana,

-81 8 (distinguishing "good cause" showing for sealing documents produced in 9 discovery from "compelling reasons" standard when merits-related documents are 10 part of court record). Accordingly, the terms of this protective order do not extend 11 beyond the commencement of the trial. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under 15 this Order must take care to limit any such designation to specific material that 16 qualifies under the appropriate standards. The Designating Party must designate 17 for protection only those parts of material, documents, items or oral or written 18 communications that qualify so that other portions of the material, documents, 19 items or communications for which protection is not warranted are not swept 20 unjustifiably within the ambit of this Order. 21 Mass, indiscriminate or routinized designations are prohibited. 22 Designations that are shown to be clearly unjustified or that have been made for an 23 improper purpose (e.g., to unnecessarily encumber the case development process 24 or to impose unnecessary expenses and burdens on other parties) may expose the 25 Designating Party to sanctions. 26 If it comes to a Designating Party's attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party 28 must promptly notify all other Parties that it is withdrawing the inapplicable 1 designation. 2 5.2 Manner and Timing of Designations. Except as otherwise provided in 3 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 4 stipulated or ordered, Disclosure or Discovery Material that qualifies for 5 protection under this Order must be clearly so designated before the material is 6 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 of the material on a page qualifies 13 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 16 inspection need not designate them for protection until after the inspecting Party 17 has indicated which documents it would like copied and produced. During the 18 inspection and before the designation, all of the material made available for 19 inspection shall be deemed "CONFIDENTIAL." After the inspecting Party has 20 identified the documents it wants copied and produced, the Producing Party must 21 determine which documents, or portions thereof, qualify for protection under this 22 Order. Then, before producing the specified documents, the Producing Party must 23 affix the "CONFIDENTIAL legend" to each page that contains Protected Material. 24 If only a portion of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making 26 appropriate markings in the margins). 27 (b) for testimony given in depositions that the Designating Party identifies 28 the Disclosure or Discovery Material on the record, before the close of the 1 deposition all protected testimony. 2 (c) for information produced in some form other than documentary and for 3 any other tangible items, that the Producing Party affix in a prominent place on the 4 exterior of the container or containers in which the information is stored the 5 legend "CONFIDENTIAL." If only a portion or portions of the information 6 warrants protection, the Producing Party, to the extent practicable, shall identify 7 the protected portion(s). 8 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 9 failure to designate qualified information or items does not, standing alone, waive 10 the Designating Party's right to secure protection under this Order for such 11 material. Upon timely correction of a designation, the Receiving Party must make 12 reasonable efforts to assure that the material is treated in accordance with the 13 provisions of this Order. 14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 16 designation of confidentiality at any time that is consistent with the Court's 17 Scheduling Order. 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 19 resolution process under Local Rule 37-1 et seq. 20 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 21 joint stipulation pursuant to Local Rule 37-2. 22 6.4 The burden of persuasion in any such challenge proceeding shall be 23 on the Designating Party. Frivolous challenges, and those made for an improper 24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 25 parties) may expose the Challenging Party to sanctions. Unless the Designating 26 Party has waived or withdrawn the confidentiality designation, all parties shall 27 continue to afford the material in question the level of protection to which it is 28 entitled under the Producing Party's designation until the Court rules on the 1 challenge. 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 7.1 Basic Principles. A Receiving Party may use Protected Material that 4 is disclosed or produced by another Party or by a Non-Party in connection with 5 this Action only for prosecuting, defending or attempting to settle this Action. 6 Such Protected Material may be disclosed only to the categories of persons and 7 under the conditions described in this Order. When the Action has been 8 terminated, a Receiving Party must comply with the provisions of section 13 9 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 14 otherwise ordered by the court or permitted in writing by the Designating Party, a 15 Receiving Party may disclose any information or item designated 16 "CONFIDENTIAL" only to: 17 (a) the Receiving Party's Outside Counsel of Record in this Action, as well 18 as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) of the 21 Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 disclosure is reasonably necessary for this Action and who have signed the 24 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and Professional 28 Vendors to whom disclosure is reasonably necessary for this Action and who have 1 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 2 (g) the author or recipient of a document containing the information or a 3 custodian or other person who otherwise possessed or knew the information; 4 (h) during their depositions, witnesses, and attorneys for witnesses, in the 5 Action to whom disclosure is reasonably necessary provided: (1) the deposing 6 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 7 they will not be permitted to keep any confidential information unless they sign 8 the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 9 agreed by the Designating Party or ordered by the court. Pages of transcribed 10 deposition testimony or exhibits to depositions that reveal Protected Material may 11 be separately bound by the court reporter and may not be disclosed to anyone 12 except as permitted under this Stipulated Protective Order; and 13 (i) any mediator or settlement officer, and their supporting personnel, 14 mutually agreed upon by any of the parties engaged in settlement discussions. 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 16 IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 that compels disclosure of any information or items designated in this Action as 19 "CONFIDENTIAL," that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification shall 21 include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order to 23 issue in the other litigation that some or all of the material covered by the 24 subpoena or order is subject to this Protective Order. Such notification shall 25 include a copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued 27 by the Designating Party whose Protected Material may be affected. 28 If the Designating Party timely seeks a protective order, the Party served 1 with the subpoena or court order shall not produce any information designated in 2 this action as "CONFIDENTIAL" before a determination by the court from which 3 the subpoena or order issued, unless the Party has obtained the Designating Party's 4 permission. The Designating Party shall bear the burden and expense of seeking 5 protection in that court of its confidential material and nothing in these provisions 6 should be construed as authorizing or encouraging a Receiving Party in this 7 Action to disobey a lawful directive from another court. 8 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 9 PRODUCED IN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced by a 11 Non-Party in this Action and designated as "CONFIDENTIAL." Such information 12 produced by Non-Parties in connection with this litigation is protected by the 13 remedies and relief provided by this Order. Nothing in these provisions should be 14 construed as prohibiting a Non-Party from seeking additional protections. 15 (b) In the event that a Party is required, by a valid discovery request, to 16 produce a Non-Party's confidential information in its possession, and the Party is 17 subject to an agreement with the Non-Party not to produce the Non-Party's 18 confidential information, then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the Non- 20 Party that some or all of the information requested is subject to a confidentiality 21 agreement with a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the Stipulated 23 Protective Order in this Action, the relevant discovery request(s), and a reasonably 24 specific description of the information requested; and 25 (3) make the information requested available for inspection by the 26 Non-Party, if requested. 27 (c) If the Non-Party fails to seek a protective order from this court within 28 14 days of receiving the notice and accompanying information, the Receiving 1 Party may produce the Non-Party's confidential information responsive to the 2 discovery request. If the Non-Party timely seeks a protective order, the Receiving 3 Party shall not produce any information in its possession or control that is subject 4 to the confidentiality agreement with the Non-Party before a determination by the 5 court. Absent a court order to the contrary, the Non-Party shall bear the burden 6 and expense of seeking protection in this court of its Protected Material. 7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 8 If a Receiving Party learns that, by inadvertence or otherwise, it has 9 disclosed Protected Material to any person or in any circumstance not authorized 10 under this Stipulated Protective Order, the Receiving Party must immediately (a) 11 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 12 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 13 the person or persons to whom unauthorized disclosures were made of all the 14 terms of this Order, and (d) request such person or persons to execute the 15 "Acknowledgment and Agreement to Be Bound" that is attached hereto as Exhibit

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 18 PROTECTED MATERIAL 19 When a Producing Party gives notice to Receiving Parties that certain 20 inadvertently produced material is subject to a claim of privilege or other 21 protection, the obligations of the Receiving Parties are those set forth in Federal 22 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 23 whatever procedure may be established in an e-discovery order that provides for 24 production without prior privilege review. Pursuant to Federal Rule of Evidence 25 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 26 of a communication or information covered by the attorney-client privilege or 27 work product protection, the parties may incorporate their agreement in the 28 stipulated protective order submitted to the court. 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of 3 any person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in 7 this Stipulated Protective Order. Similarly, no Party waives any right to object on 8 any ground to use in evidence of any of the material covered by this Protective 9 Order. 10 12.3 Filing Protected Material. A Party that seeks to file under seal any 11 Protected Material must comply with Local Civil Rule 79-5. Protected Material 12 may only be filed under seal pursuant to a court order authorizing the sealing of 13 the specific Protected Material at issue. If a Party's request to file Protected 14 Material under seal is denied by the court, then the Receiving Party may file the 15 information in the public record unless otherwise instructed by the court. Filing 16 Protected Material. A Party that seeks to file under seal any Protected Material 17 must comply with Local Civil Rule 79-5. Protected Material may only be filed 18 under seal pursuant to a court order authorizing the sealing of the specific 19 Protected Material at issue. If a Party's request to file Protected Material under 20 seal is denied by the court, then the Receiving Party may file the information in 21 the public record unless otherwise instructed by the court. 22 13. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 24 60 days of a written request by the Designating Party, each Receiving Party must 25 return all Protected Material to the Producing Party or destroy such material. As 26 used in this subdivision, "all Protected Material" includes all copies, abstracts, 27 compilations, summaries, and any other format reproducing or capturing any of 28 the Protected Material. Whether the Protected Material is returned or destroyed, 1 || the Receiving Party must submit a written certification to the Producing Party 2 || (and, if not the same person or entity, to the Designating Party) by the 60 day 3 || deadline that (1) identifies (by category, where appropriate) all the Protected 4 || Material that was returned or destroyed and (2) affirms that the Receiving Party 5 ||} has not retained any copies, abstracts, compilations, summaries or any other 6 || format reproducing or capturing any of the Protected Material. Notwithstanding 7 || this provision, Counsel are entitled to retain an archival copy of all pleadings, 8 || motion papers, trial, deposition, and hearing transcripts, legal memoranda, 9 || correspondence, deposition and trial exhibits, expert reports, attorney work 10 || product, and consultant and expert work product, even if such materials contain 11 || Protected Material. Any such archival copies that contain or constitute Protected 12 || Material remain subject to this Protective Order as set forth in Section 4 13 || (DURATION). 14. VIOLATION 15 Any violation of this Order may be punished by appropriate measures 16 || including, without limitation, contempt proceedings and/or monetary sanctions. 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 || DATED: February 18, 2020 THE LAW OFFICE OF ROBERT L. STARR 20 By: /s/ Robert L. Starr 21 Robert L. Starr, Esq. 0 Adam M. Rose, Esq. Attorneys for Plaintiff ROBERT LOBL 74 DATED: February 18, 2020 BOWMAN AND BROOKE LLP 25 By: /s/Bryan A. Reynolds Brian Takahashi 26 Theodore Dorenkamp III Brian A. Reynolds 27 Attorneys for Defendant JAGUAR LAND ROVER NORTH 28 AMERICA, LLC

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 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Robert Lobl v. Jaguar Land Rover North America, LLC, et. 8 al., United States District Court — Central District, Case No. 2:19-cv-04828 ODW 9 (SKx). I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order and I understand and acknowledge that failure to so comply 11 could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item 13 that is subject to this Stipulated Protective Order to any person or entity except in 14 strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or 20 type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement 22 of this Stipulated Protective Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature:_______________________________ 28 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 10 11 || ROBERT LOBL, CASE NO: 2:19-cv-04828 ODW (SKx) 12 Plaintiff, District Judge: Otis D. Wright, II Magistrate Judge: Steve Kim 13 VS. 14 || JAGUAR LAND ROVER NORTH ORDER RE STIPULATED AMERICA, LLC, a Limited Liability ) PROTECTIVE ORDER 15 || Company; and DOES 1 through 100, inclusive, 16 Trial: June 2, 2020 Defendants. 17 18 19 Having considered the papers, and finding that good cause exists, the Parties’ 20 || Stipulated Protective Order is granted. 2] IT IS SO ORDERED.

93 || Dated: February 24 2020 Steve Kim 24 United States Magistrate Judge 25 26 27 28