Case 8:22-cv-00109-JVS-JDE Document 64 Filed 10/26/22 Pagelofi7 Page #:1484 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 | KIA AMERICA, INC., Case No. 8:22-cv-00109-JVS-JDE 12 Plaintiff, Assigned to the Hon. James V. Selna 13 || v. STIPULATED PROTECTIVE 14 | RALLY AUTO GROUP, INC. d/b/a ORDER is] RREEEIRRS PRIA AUTO RORS | Someta leon 3 22

16 PROPERTIES AND HOLDINGS

17 Defendants. 18 19 Based on the parties’ Stipulation (Dkt. 63), and good cause appearing, the 20 || Court finds and orders as follows. 21 1. INTRODUCTION 22 Plaintiff Kia America, Inc. and Defendants Rally Auto Group Inc. d/b/a Rally 23 || Kia, Dalia Auto Group, Inc., Alam Z. Khan, and Dalia K Properties and Holdings 24 || LLC, by and through their respective counsel of record, stipulated to the following 25 || protective order. 26 1.1 PURPOSES AND LIMITATIONS 27 Discovery in this action is likely to involve production of confidential, 28 || proprietary and/or private information for which special protection from public

STIPULATED PROTECTIVE ORDER

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1 || disclosure and from use for any purpose other than prosecuting this litigation may be 2 || warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 3 | the following Stipulated Protective Order. The parties acknowledge that this Order 4 || does not confer blanket protections on all disclosures or responses to discovery and 5 || that the protection it affords from public disclosure and use extends only to the 6 | limited information or items that are entitled to confidential treatment under the 7 || applicable legal principles. 8 1.2 GOOD CAUSE STATEMENT 9 This action is likely to involve trade secrets, customer and pricing lists and 10 || other valuable research, development, commercial, financial, technical and/or 11 || proprietary information for which special protection from public disclosure and from 12 | use for any purpose other than prosecution of this action is warranted. Such 13 || confidential and proprietary materials and information consist of, among other 14 || things, confidential business or financial information, information regarding 15 || confidential business practices, or other confidential research, development, or 16 || commercial information (including information implicating privacy rights of third 17 || parties), information otherwise generally unavailable to the public, or which may be 18 || privileged or otherwise protected from disclosure under state or federal statutes, court 19 || rules, case decisions, or common law. Accordingly, to expedite the flow of 20 || information, to facilitate the prompt resolution of disputes over confidentiality of 21 || discovery materials, to adequately protect information the parties are entitled to keep 22 || confidential, to ensure that the parties are permitted reasonable necessary uses of such 23 || material in preparation for and in the conduct of trial, to address their handling at the 24 || end of the litigation, and serve the ends of justice, a protective order for such 25 || information is justified in this matter. It is the intent of the parties that information 26 || will not be designated as confidential for tactical reasons and that nothing be so 27 || designated without a good faith belief that it has been maintained in a confidential, 28 STIPULATED PROTECTIVE ORDER

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1 || non-public manner, and there is good cause why it should not be part of the public 2 || record of this case. 3 1.3 ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 4 SEAL 5 The parties further acknowledge, as set forth in Section 12.3, below, that this 6 || Stipulated Protective Order does not entitle them to file confidential information 7 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 8 | the standards that will be applied when a party seeks permission from the court to 9 || file material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 || proceedings and records in civil cases. In connection with non-dispositive motions, 12 || good cause must be shown to support a filing under seal. See Kamakana v. City and 13 || County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 14 || Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 13 || Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 16 || good cause showing), and a specific showing of good cause or compelling reasons 17 || with proper evidentiary support and legal justification, must be made with respect to 18 || Protected Material that a party seeks to file under seal. The parties’ mere designation 19 || of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 20 || submission of competent evidence by declaration, establishing that the material 21 || sought to be filed under seal qualifies as confidential, privileged, or otherwise 22 || protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 || compelling reasons, not only good cause, for the sealing must be shown, and the 25 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 || See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 27 || item or type of information, document, or thing sought to be filed or introduced under 28 || seal in connection with a dispositive motion or trial, the party seeking protection must STIPULATED PROTECTIVE ORDER

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1 || articulate compelling reasons, supported by specific facts and legal justification, for 2 || the requested sealing order. Again, competent evidence supporting the application 3 |) to file documents under seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in 5 || its entirety will not be filed under seal if the confidential portions can be redacted. If 6 | documents can be redacted, then a redacted version for public viewing, omitting only 7 || the confidential, privileged, or otherwise protectable portions of the document shall 8 | be filed. Any application that seeks to file documents under seal in their entirety 9 | should include an explanation of why redaction is not feasible. 10 || 2. DEFINITIONS 1] 2.1. Action: Civil Action Case Number 8:22-cv-00109-JVS-JDE, pending 12 in the United States District Court, Central District of California. 13 2.2 Challenging Party: A Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c), and as specified above 18 in the Good Cause Statement. This material should be shielded from public 19 access and may only be disclosed as set forth in Section 7.2(b), et seq. 20 2.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as 21 their support staff). 22 2.5 Designating Party: A Party or Non-Party that designates information 23 or items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure_or Discovery Material: All items or information, 26 regardless of the medium or manner in which they are generated, stored, or 27 maintained (including, among other things, testimony, transcripts, and tangible 28 STIPULATED PROTECTIVE ORDER

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l things) that are produced or generated in disclosures or responses to discovery 2 in this matter. 3 27 ‘Expert: A person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to 5 serve as an expert witness or as a consultant in this Action. 6 2.8 In-House Counsel: Attorneys who are employees of a party to this 7 Action. In-House Counsel does not include Outside Counsel of Record or any 8 other outside counsel. 9 2.9 Non-Party: Any natural person, partnership, corporation, association 10 or other legal entity not named as a Party to this action. 1] 2.10 Outside Counsel of Record: Attorneys who are not employees of a 12 party to this Action but who are retained to represent or advise a party to this 13 Action and have appeared in this Action on behalf of that party or are affiliated 14 with a law firm that has appeared on behalf of that party, including support 15 staff. 16 2.11 Party: Any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, In-House Counsel, and Outside 18 Counsel of Record (and their support staffs). 19 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.13 Professional Vendors: Persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing 23 exhibits or demonstrations, and organizing, storing, or retrieving data in any 24 form or medium) and their employees and subcontractors. 25 2.14 Protected Material: Any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 2.15 Receiving Party: A Party that receives Disclosure or Discovery 28 Material from a Producing Party. STIPULATED PROTECTIVE ORDER

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1/3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 || Protected Material (as defined above), but also (1) any information copied or 4 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 || compilations of Protected Material; and (3) any testimony, conversations, or 6 || presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 || trial judge. This Order does not govern the use of Protected Material at trial. 9|/4. DURATION 10 Once a case proceeds to trial, information that was designated as 11 |) CONFIDENTIAL or maintained pursuant to this protective order used or introduced 12 || as an exhibit at trial becomes public and will be presumptively available to all 13 || members of the public, including the press, unless compelling reasons supported by 14 || specific factual findings to proceed otherwise are made to the trial judge in advance 15 || of the trial. See Kamakana,

(distinguishing “good cause” 16 || showing for sealing documents produced in discovery from “compelling reasons” 17 || standard when merits-related documents are part of court record). Accordingly, the 18 || terms of this protective order do not extend beyond the commencement of the trial. 19 | 5, DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for 21 Protection. 22 Each Party or Non-Party that designates information or items for protection 23 || under this Order must take care to limit any such designation to specific material that 24 || qualifies under the appropriate standards. The Designating Party must designate for 25 || protection only those parts of material, documents, items or oral or written 26 || communications that qualify so that other portions of the material, documents, items 27 || or communications for which protection is not warranted are not swept unjustifiably 28 || within the ambit of this Order. STIPULATED PROTECTIVE ORDER

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

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| documents it wants copied and produced, the Producing Party must 2 determine which documents, or portions thereof, qualify for protection 3 under this Order. Then, before producing the specified documents, the 4 Producing Party must affix the “CONFIDENTIALITY legend” to each 5 page that contains Protected Material. If only a portion of the material 6 on a page qualifies for protection, the Producing Party also must clearly 7 identify the protected portion(s) (e.g., by making appropriate markings 8 in the margins). 9 (b) for testimony given in depositions that the Designating Party 10 identifies the Disclosure or Discovery Material on the record, before the 1] close of the deposition all protected testimony, subject to later 12 amendments by Counsel of Record within 30 days upon receipt of the 13 transcripts. 14 (c) for information produced in some form other than documentary and 15 for any other tangible items, that the Producing Party affix in a 16 prominent place on the exterior of the container or containers in which 17 the information is stored the legend “ “CONFIDENTIAL.” If only a 18 portion or portions of the information warrants protection, the Producing 19 Party, to the extent practicable, shall identify the protected portion(s). 20 || The Parties further agree that in the event that discovery requires the production of 21 || highly sensitive trade secret and/or confidential information, either Party may move 22 || the Court, subject to the requirements of Local Rule 37-1, for further protection from 23 || disclosure as to the documents in question, above and beyond the restriction provided 24 |! herein. 25 5.3. Inadvertent Failures to Designate. 26 If timely corrected, an inadvertent failure to designate qualified information or 27 || items does not, standing alone, waive the Designating Party’s right to secure 28 || protection under this Order for such material. Upon timely correction of a STIPULATED PROTECTIVE ORDER

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1 || designation, the Receiving Party must make reasonable efforts to assure that the 2 || material is treated in accordance with the provisions of this Order. 3 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1. Timing of Challenges. 5 Any Party or Non-Party may challenge a designation of confidentiality at any 6 | time that is consistent with the Court’s Scheduling Order. 7 6.2 Meet and Confer. 8 The Challenging Party shall initiate the dispute resolution process under Local 9 | Rule 37.1 et seq. 10 6.3 Joint Stipulation. 1] Any challenge submitted to the Court shall be via joint stipulation pursuant to 12 || Local Rule 37.2. 13 6.4 Burden of Persuasion. 14 The burden of persuasion in any such challenge proceeding shall be on the 15 || Designating Party. Frivolous challenges, and those made for an improper purpose 16 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 || or withdrawn the confidentiality designation, all parties shall continue to afford the 19 || material in question the level of protection to which it is entitled under the Producing 20 || Party’s designation until the Court rules on the challenge. 21 ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. 23 A Receiving Party may use Protected Material that is disclosed or produced by 24 || another Party or by a Non-Party in connection with this Action only for prosecuting, 25 || defending or attempting to settle this Action. Such Protected Material may be 26 || disclosed only to the categories of persons and under the conditions described in this 27 || Order. When the Action has been terminated, a Receiving Party must comply with 28 || the provisions of Section 13 below (FINAL DISPOSITION). STIPULATED PROTECTIVE ORDER

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l Protected Material must be stored and maintained by a Receiving Party at a 2 || location and in a secure manner that ensures that access is limited to the persons 3 | authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 5 Unless otherwise ordered by the court or permitted in writing by the 6 | Designating Party, a Receiving Party may disclose any information or item 7 || designated “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 9 well as employees of said Outside Counsel of Record to whom it is 10 reasonably necessary to disclose the information for this Action; 1] (b) the officers, directors, and employees (including In-House Counsel) 12 of the Receiving Party to whom disclosure is reasonably necessary for 13 this Action; 14 (c) Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this Action and who have signed 16 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (d) the court and its personnel; 18 (e) court reporters and their staff; 19 (f) professional jury or trial consultants, mock jurors, and Professional 20 Vendors to whom disclosure is reasonably necessary for this Action and 21 who have signed the “Acknowledgment and Agreement to Be Bound” 22 (Exhibit A); 23 (g) the author or recipient of a document containing the information or 24 a custodian or other person who otherwise possessed or knew the 25 information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in 27 the Action to whom disclosure is reasonably necessary provided: (1) the 28 deposing party requests that the witness sign the form attached as 10 STIPULATED PROTECTIVE ORDER

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l Exhibit A hereto; and (2) they will not be permitted to keep any 2 confidential information unless they sign the “Acknowledgment and 3 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 4 Designating Party or ordered by the court. Pages of transcribed 5 deposition testimony or exhibits to depositions that reveal Protected 6 Material may be separately bound by the court reporter and may not be 7 disclosed to anyone except as permitted under this Stipulated Protective 8 Order; and 9 (1) any mediator or settlement officer, and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement 1] discussions. 12 | 8. PROTECTED _MATERIAL SUBPOENAED _OR_ ORDERED 13 | PRODUCED IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 || that compels disclosure of any information or items designated in this Action as 16 | “CONFIDENTIAL,” that Party must: 17 (a) promptly notify in writing the Designating Party. Such notification 18 shall include a copy of the subpoena or court order; 19 (b) promptly notify in writing the party who caused the subpoena or 20 order to issue in the other litigation that some or all of the material 21 covered by the subpoena or order is subject to this Protective Order. 22 Such notification shall include a copy of this Stipulated Protective 23 Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be 25 pursued by the Designating Party whose Protected Material may be 26 affected. If the Designating Party timely seeks a protective order, the 27 Party served with the subpoena or court order shall not produce any 28 information designated in this action as “CONFIDENTIAL” before a 11 STIPULATED PROTECTIVE ORDER

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l determination by the court from which the subpoena or order issued, 2 unless the Party has obtained the Designating Party’s permission. The 3 Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these 5 provisions should be construed as authorizing or encouraging a 6 Receiving Party in this Action to disobey a lawful directive from another 7 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 1] Non-Party in this Action and designated as “CONFIDENTIAL.” Such 12 information produced by Non-Parties in connection with this litigation 13 is protected by the remedies and relief provided by this Order. Nothing 14 in these provisions should be construed as prohibiting a Non-Party from 15 seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and 18 the Party is subject to an agreement with the Non-Party not to produce 19 the Non-Party’s confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non- 21 Party that some or all of the information requested is subject to a 22 confidentiality agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), 25 and a reasonably specific description of the information 26 requested; and 27 (3) make the information requested available for inspection by 28 the Non-Party, if requested. 12 STIPULATED PROTECTIVE ORDER

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l (c) If the Non-Party fails to seek a protective order from this court 2 within fourteen (14) days of receiving the notice and accompanying 3 information, the Receiving Party may produce the Non-Party’s 4 confidential information responsive to the discovery request. If the 5 Non-Party timely seeks a protective order, the Receiving Party shall not 6 produce any information in its possession or control that is subject to the 7 confidentiality agreement with the Non-Party before a determination by 8 the court. Absent a court order to the contrary, the Non-Party shall bear 9 the burden and expense of seeking protection in this court of its 10 Protected Material. 11 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 || Protected Material to any person or in any circumstance not authorized under this 14 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 || to retrieve all unauthorized copies of the Protected Material or ensure that the party 17 || receiving such unauthorized copies destroys or deletes them, (c) inform the person 18 || or persons to whom unauthorized disclosures were made of all the terms of this 19 || 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 24 || inadvertently produced material is subject to a claim of privilege or other protection, 25 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 26 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 27 || may be established in an e-discovery order that provides for production without prior 28 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 STIPULATED PROTECTIVE ORDER

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1 || parties reach an agreement on the effect of disclosure of a communication or 2 || information covered by the attorney-client privilege or work product protection, the 3 || parties may incorporate their agreement in the stipulated protective order submitted 4 || to the court. 5 || 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of 7 any person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order, no Party waives any right it otherwise would have to object 10 to disclosing or producing any information or item on any ground not 1 addressed in this Stipulated Protective Order. Similarly, no Party waives any 12 right to object on any ground to use in evidence of any of the material covered 13 by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Local Civil Rule 79-5. Protected 16 Material may only be filed under seal pursuant to a court order authorizing the 17 sealing of the specific Protected Material at issue. If a Party’s request to file 18 Protected Material under seal is denied by the court, then the Receiving Party 19 may file the information in the public record unless otherwise instructed by the 20 court. 21 | 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 || days of a written request by the Designating Party, each Receiving Party must return 24 |! all Protected Material to the Producing Party or destroy such material. As used in 25 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 || summaries, and any other format reproducing or capturing any of the Protected 27 || Material. Whether the Protected Material is returned or destroyed, the Receiving 28 || Party must submit a written certification to the Producing Party (and, if not the same 14 STIPULATED PROTECTIVE ORDER

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1 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 2 || (by category, where appropriate) all the Protected Material that was returned or 3 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 4 || abstracts, compilations, summaries or any other format reproducing or capturing any 5 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 6 | retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 7 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 8 || reports, attorney work product, and consultant and expert work product, even if such 9 || materials contain Protected Material. Any such archival copies that contain or 10 || constitute Protected Material remain subject to this Protective Order as set forth in 11 |) Section 4 (DURATION). 12 | 14. VIOLATION 13 Any violation of this Order may be punished by appropriate measures 14 || including, without limitation, contempt proceedings and/or monetary sanctions. 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 || Dated: October 26, 2022 Li a6 19 J D. EARLY 50 nited States Magistrate Judge 21 22 23 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER

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I EXHIBIT A 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that was 7 || issued by the United States District Court for the Central District of California 8 in the case of Kia America, Inc. v. Rally Auto Group Inc. d/b/a Rally g || Kia, Dalia Auto Group, Inc., Alam Z. Khan, and Dalia K Properties and Holdings 10 || LLC, Case Number 8:22-cv-00109-JVS-JDE. 11 I agree to comply with and to be bound by all the terms of this Stipulated 12 || Protective Order and I understand and acknowledge that failure to so comply could 13 || expose me to sanctions and punishment in the nature of contempt. I solemnly 14 || promise that I will not disclose in any manner any information or item that is subject 15 || to this Stipulated Protective Order to any person or entity except in strict compliance 16 || with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States District Court 1g || for the Central District of California for enforcing the terms of this Stipulated 19 || Protective Order, even if such enforcement proceedings occur after termination of 209 || this action. I hereby appoint [print or 31 || type full name] of 22 | ——__ 23 || _____ [print or type full address and telephone number] as my California agent for 34 || service of process in connection with this action or any proceedings related to 25 || enforcement of this Stipulated Protective Order. 26 || Dated: 27 28 16 STIPULATED PROTECTIVE ORDER

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5 City and State where sworn and signed: ; Printed Name: 3 Signature: 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17 STIPULATED PROTECTIVE ORDER