1 Gregory Sogoyan (SBN 316832) 2 [email protected] STRATEGIC LEGAL PRACTICES, APC 3 1840 Century Park East, Suite 430 Los Angeles, CA 90067 4 Tel: (310) 929-4900 Fax: (310)943-3838 5 Michael H. Rosenstein (SBN 169091) 6 [email protected] LAW OFFICES OF MICHAEL H. ROSENSTEIN 7 1900 Wilshire Blvd., Suite 300 Los Angeles, CA 90024 8 Tel: (310) 286-0275 Fax: (310) 286-0274 9 Dara Tabesh (SBN 230434) 10 [email protected] ECOTECH LAW GROUP, P.C. 11 5 Third St., Ste. 700 San Francisco, CA 94103 12 Tel: (415) 503-9164 Fax: (415) 651-8639 13 Attorneys for Plaintiff 14 DON THOMPSON 15 Kate S. Lehrman (SBN 123050) [email protected] 16 Robert A. Philipson (SBN 108940) [email protected] 17 LEHRMAN LAW GROUP 12121 Wilshire Boulevard Suite 1300 18 Los Angeles, CA 90025 Tel: (310) 917-4500 19 Fax: (310) 917-5677 20 Attorneys for Defendant BMW OF NORTH AMERICA, LLC 21 22 23 UNITED STATES DISTRICT COURT 24 CENTRAL DISTRICT OF CALIFORNIA 25 26 27 DON THOMPSON, Case No.: 8:17-cv-01912-CJC-KS 28 [PROPOSED] ORDER RE 1 Plaintiff, STIPULATED PROTECTIVE ORDER 2 vs. 3 | BMW OF NORTH AMERICA, LLC; and DOES 1 through 10, inclusive, Defendant. 5 ° Having considered the papers, and finding that good cause exists, the Parties’ Stipulated ’ Protective Order is granted. IT IS SO ORDERED. ” | DATED: February 28, 2020 f Min □ □□□ 10 KAREN L. STEVENSON UNITED STATES MAGISTRATE JUDGE

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1 Gregory Sogoyan (SBN 316832) [email protected] 2 STRATEGIC LEGAL PRACTICES, APC 1840 Century Park East, Suite 430 3 Los Angeles, CA 90067 Tel: (310) 929-4900 4 Fax: (310)943-3838 5 Michael H. Rosenstein (SBN 169091) [email protected] 6 LAW OFFICES OF MICHAEL H. ROSENSTEIN 1900 Wilshire Blvd., Suite 300 7 Los Angeles, CA 90024 Tel: (310) 286-0275 8 Fax: (310) 286-0274 9 Dara Tabesh (SBN 230434) [email protected] 10 ECOTECH LAW GROUP, P.C. 5 Third St., Ste. 700 11 San Francisco, CA 94103 Tel: (415) 503-9164 12 Fax: (415) 651-8639 13 Attorneys for Plaintiff DON THOMPSON 14 Kate S. Lehrman (SBN 123050) 15 [email protected] Robert A. Philipson (SBN 108940) 16 [email protected] LEHRMAN LAW GROUP 17 12121 Wilshire Boulevard Suite 1300 Los Angeles, CA 90025 18 Tel: (310) 917-4500 Fax: (310) 917-5677 19 Attorneys for Defendant 20 BMW OF NORTH AMERICA, LLC 21 22 UNITED STATES DISTRICT COURT 23 CENTRAL DISTRICT OF CALIFORNIA 24 25 DON THOMPSON, Case No. 8:17-cv-01912-CJC-KS 26 Plaintiff, [PROPOSED] STIPULATED PROTECTIVE ORDER 27 vs. 28 BMW OF NORTH AMERICA, LLC; and 1 DOES 1 through 10, inclusive, 2 Defendant. 3 4 1. GENERAL 5 1.1 Purposes and Limitations. Discovery in this action is likely to involve production of 6 confidential, proprietary, or private information for which special protection from public disclosure 7 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 8 the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective 9 Order. The parties acknowledge that this Order does not confer blanket protections on all 10 disclosures or responses to discovery and that the protection it affords from public disclosure and 11 use extends only to the limited information or items that are entitled to confidential treatment under 12 the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 13 that this Stipulated Protective Order does not entitle them to file confidential information under 14 seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that 15 will be applied when a party seeks permission from the court to file material under seal. 16 1.2 Good Cause Statement. 17 This action may involve trade secrets, customer information and other valuable research, 18 development, commercial, financial, technical and/or proprietary information for which special 19 protection from public disclosure and from use for any purpose other than prosecution of this action 20 is warranted. Such confidential and proprietary materials and information consist of, among other 21 things, confidential business or financial information, information regarding confidential business 22 practices, or other confidential research, development, or commercial information (including 23 information implicating privacy rights of third parties), information otherwise generally 24 unavailable to the public, or which may be privileged or otherwise protected from disclosure under 25 state or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite the 26 flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery 27 materials, to adequately protect information the parties are entitled to keep confidential, to ensure 28 that the parties are permitted reasonable necessary uses of such material in preparation for and in 1 the conduct of trial, to address their handling at the end of the litigation, and serve the ends of 2 justice, a protective order for such information is justified in this matter. It is the intent of the parties 3 that information will not be designated as confidential for tactical reasons and that nothing be so 4 designated without a good faith belief that it has been maintained in a confidential, non-public 5 manner, and there is good cause why it should not be part of the public record of this case. 6 2. DEFINITIONS 7 2.1 Action: Don Thompson vs. BMW of North America, LLC (Case No.: 8:17-cv- 8 01912-CJC-KS). 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 10 information or items under this Order. 11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 12 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 13 of Civil Procedure 26(c), and as specified above in the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support 15 staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or items that it 17 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless of the 19 medium or manner in which it is generated, stored, or maintained (including, among other things, 20 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 21 responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to 23 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 24 consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a party to this Action. House 26 Counsel does not include Outside Counsel of Record or any other outside counsel. 27 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal 28 entity not named as a Party to this action. 1 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 2 Action but are retained to represent or advise a party to this Action and have appeared in this Action 3 on behalf of that party or are affiliated with a law firm that has appeared on behalf of that party, 4 including support staff. 5 2.11 Party: any party to this Action, including all of its officers, directors, employees, 6 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 8 Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation support services 10 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 11 storing, or retrieving data in any form or medium) and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 13 “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 15 Producing Party. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected Material 18 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) 19 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 20 conversations, or 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 trial judge. This 22 Order does not govern the use of Protected Material at trial. 23 4. DURATION 24 Once a case proceeds to trial, all of the court-filed information to be introduced that was 25 previously designated as confidential or maintained pursuant to this protective order becomes 26 public and will 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 made to the trial 28 judge in advance of the trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 1 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in discovery 2 from “compelling reasons” standard when merits-related documents are part of court record). 3 Accordingly, the terms of this protective order do not extend beyond the commencement of the 4 trial. 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 7 or Non-Party that designates information or items for protection under this Order must take care to 8 limit any such designation to specific material that qualifies under the appropriate standards. The 9 Designating Party must designate for protection only those parts of material, documents, items, or 10 oral or written communications that qualify so that other portions of the material, documents, items, 11 or communications for which protection is not warranted are not swept unjustifiably within the 12 ambit of this Order. 13 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 14 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 15 encumber the case development process or to impose unnecessary expenses and burdens on other 16 parties) may expose the Designating Party to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it designated for 18 protection do not qualify for protection, that Designating Party must promptly notify all other 19 Parties that it is withdrawing the inapplicable designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 21 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 22 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 23 designated before the material is disclosed or produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic documents, 26 but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 27 Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL 28 legend”), to each page that contains protected material. If only a portion or portions of the material 1 on a page qualifies for protection, the Producing Party also must clearly identify the protected 2 portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspection need not 4 designate them for protection until after the inspecting Party has indicated which documents it 5 would like copied and produced. During the inspection and before the designation, all of the 6 material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting 7 Party has identified the documents it wants copied and produced, the Producing Party must 8 determine which documents, or portions thereof, qualify for protection under this Order. Then, 9 before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL 10 legend” to each page that contains Protected Material. If only a portion or portions of the material 11 on a page qualifies for protection, the Producing Party also must clearly identify the protected 12 portion(s) (e.g., by making appropriate markings in the margins). 13 (b) for testimony given in depositions that the Designating Party either identify 14 the Disclosure or Discovery Material on the record, before the close of the deposition, or in writing 15 to the Receiving Party within 10 days after receipt of the transcript. 16 (c) for information produced in some form other than documentary and for any 17 other tangible items, that the Producing Party affix in a prominent place on the exterior of the 18 container or containers in which the information is stored the legend “CONFIDENTIAL.” If only 19 a portion or portions of the information warrants protection, the Producing Party, to the extent 20 practicable, shall identify the protected portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 22 designate qualified information or items does not, standing alone, waive the Designating Party’s 23 right to secure protection under this Order for such material. Upon timely correction of a 24 designation, the Receiving Party must make reasonable efforts to assure that the material is treated 25 in accordance with the provisions of this Order. 26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 28 confidentiality at any time that is consistent with the Court’s Scheduling Order. 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 2 under Local Rule 37-1, et seq. Any discovery motion must strictly comply with the procedures set 3 forth in Local Rules 37-1, 37-2, and 37-3. 4 6.3 Burden. The burden of persuasion in any such challenge proceeding shall be on the 5 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass 6 or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party 7 to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality designation, 8 all parties shall continue to afford the material in question the level of protection to which it is 9 entitled under the Producing 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 disclosed or 12 produced by another Party or by a Non-Party in connection with this Action only for prosecuting, 13 defending, or attempting to settle this Action. Such Protected Material may be disclosed only to the 14 categories of persons and under the conditions described in this Order. When the Action has been 15 terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 16 DISPOSITION). 17 Protected Material must be stored and maintained by a Receiving Party at a location and in 18 a secure manner that ensures that access is limited to the persons authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 20 by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any 21 information or item designated “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 23 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 24 information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of the 26 Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 1 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 2 is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement 3 to Be Bound” (Exhibit A); 4 (d) the Court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 7 to whom disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or a 10 custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 12 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the 13 witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any 14 confidential information unless they sign the “Acknowledgement and Agreement to Be Bound” 15 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the Court. Pages of 16 transcribed deposition testimony or exhibits to depositions that reveal Protected Material may be 17 separately bound by the court reporter and may not be disclosed to anyone except as permitted 18 under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, mutually 20 agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 22 OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation that compels 24 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party 25 must: 26 (a) promptly notify in writing the Designating Party. Such notification shall 27 include a copy of the subpoena or court order; 28 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena or order is 3 subject to this Protective Order. Such notification shall include a copy of this Stipulated Protective 4 Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued by 6 the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with the subpoena 8 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 9 before a determination by the court from which the subpoena or order issued, unless the Party has 10 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 11 expense of seeking protection in that court of its confidential material and nothing in these 12 provisions should be construed as authorizing or encouraging a Receiving Party in this Action to 13 disobey a lawful directive from another court. 14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 15 THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a Non- 17 Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non- 18 Parties in connection with this litigation is protected by the remedies and relief provided by this 19 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 20 additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to produce 22 a Non-Party’s confidential information in its possession, and the Party is subject to an agreement 23 with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the Non-Party 25 that some or all of the information requested is subject to a confidentiality agreement with a Non- 26 Party; 27 28 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably specific 3 description of the information requested; and 4 (3) make the information requested available for inspection by the Non- 5 Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this Court within 14 7 days of receiving the notice and accompanying information, the Receiving Party may produce the 8 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 9 seeks a protective order, the Receiving Party shall not produce any information in its possession or 10 control that is subject to the confidentiality agreement with the Non-Party before a determination 11 by the Court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense 12 of seeking protection in this Court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 15 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 16 the Receiving Party must immediately (a) notify in writing the Designating Party of the 17 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 18 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the 19 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain inadvertently 24 produced material is subject to a claim of privilege or other protection, the obligations of the 25 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 26 is not intended to modify whatever procedure may be established in an e-discovery order that 27 provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) 28 and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or 1 information covered by the attorney-client privilege or work product protection, the parties may 2 incorporate their agreement in the stipulated protective order submitted to the Court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 5 seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, 7 no Party waives any right it otherwise would have to object to disclosing or producing any 8 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 9 Party waives any right to object on any ground to use in evidence of any of the material covered by 10 this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material 12 must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant 13 to a court order authorizing the sealing of the specific Protected Material at issue; good cause must 14 be shown in the request to file under seal. If a Party’s request to file Protected Material under seal 15 is denied by the Court, then the Receiving Party may file the information in the public record unless 16 otherwise instructed by the Court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, within 60 days of a written request by the 19 Designating Party, each Receiving Party must return all Protected Material to the Producing Party 20 or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, 21 abstracts, compilations, summaries, and any other format reproducing or capturing any of the 22 Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party 23 must submit a written certification to the Producing Party (and, if not the same person or entity, to 24 the Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) 25 all the Protected Material that was returned or destroyed, and (2) affirms that the Receiving Party 26 has not retained any copies, abstracts, compilations, summaries or any other format reproducing or 27 capturing any of the Protected Material. Notwithstanding this provision, counsel are entitled to 28 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 1 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work 2 product, and consultant and expert work product, even if such materials contain Protected Material. 3 Any such archival copies that contain or constitute Protected Material remain subject to this 4 Protective Order as set forth in Section 4 (DURATION). 5 14. VIOLATION OF ORDER 6 Any violation of this Order may be punished by any and all appropriate measures including, 7 without limitation, contempt proceedings and/or monetary sanctions. 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 Dated: February ___, 2020 LEHRMAN LAW GROUP 10 11 12 By Kate Lehrman 13 Robert Philipson Attorneys for Defendant BMW of North America, LLC 14 Dated: February ___, 2020 STRATEGIC LEGAL PRACTICES, APC 15 16 By 17 Gregory Sogoyan Attorneys for Plaintiff 18 Don Thompson 19 Dated: February ___, 2020 LAW OFFICES OF MICHAEL H. ROSENSTEIN 20 21 By Michael H. Rosenstein 22 Attorneys for Plaintiff Don Thompson 23 Dated: February ___, 2020 ECOTECH LAW GROUP, P.C. 24 25 By 26 Dara Tabesh 27 Attorneys for Plaintiff Don Thompson 28 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 I, _____________________________ [print or type full name], of 3 _________________ [print or type full address], declare under penalty of perjury 4 that I have read in its entirety and understand the Stipulated Protective Order that was 5 issued by the United States District Court for the Central District of California on 6 ________ [date] in the case of Don Thompson vs. BMW of North America, LLC 7 (Case No.: 8:17-cv-01912-CJC-KS). I agree to comply with and to be bound by all 8 the terms of this Stipulated Protective Order and I understand and acknowledge that 9 failure to so comply could expose me to sanctions and punishment in the nature of 10 contempt. I solemnly promise that I will not disclose in any manner any information 11 or item that is subject to this Stipulated Protective Order to any person or entity 12 except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court 14 for the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint __________________________ [print 17 or type full name] of _______________________________________ [print or type 18 full 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 Date: ______________________________________ 22 City and State where sworn and signed: _________________________________ 23 Printed name: _______________________________ 24 Signature: ________________________________ 25 26 27 28