MAJCO LLC v. JACKSON TIRE SERVICE, a California corporation; PHILLIP BOVERO, an individual

• Court: District Court, E.D. California
• Decided: December 9, 2025
• Docket: 2:25-cv-01967
• Status: Unknown

Opinion

1 RYAN T. WAGGONER (BAR NO. 251694) ERIC C. PETTIS (BAR NO. 313492) 2 NATHAN T. JAMIESON (BAR NO. 333304) ALLEN MATKINS LECK GAMBLE 3 MALLORY & NATSIS LLP 865 South Figueroa Street, Suite 2800 4 Los Angeles, California 90017-2543 Phone: (213) 622-5555 5 Fax: (213) 620-8816 E-Mail: rwaggoner@allenmatkins.com 6 epettis@allenmatkins.com njamieson@allenmatkins.com 7 Attorneys for Plaintiff 8 MAJCO LLC

9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 SACRAMENTO DIVISION 12 MAJCO LLC, a California limited liability Case No. 2:25-cv-1967-DC-JDP company, 13 Judge Hon. Dena M. Coggins Plaintiff, 14 STIPULATION AND [PROPOSED] vs. PROTECTIVE ORDER 15 JACKSON TIRE SERVICE, a California Complaint Filed: July 14, 2025 16 corporation; PHILLIP BOVERO, an FAC: October 14, 2025 individual; KURST BOVERO, an 17 individual; SIERRA TIRE CO., a California limited liability company; and DOES 1 18 through 10,

19 Defendants.

20 21 22 23 24 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, proprietary or 3 private information for which special protection from public disclosure and from use for any 4 purpose other than pursuing this litigation may be warranted. Accordingly, the parties 5 hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. 6 The parties acknowledge that this Order does not confer blanket protections on all 7 disclosures or responses to discovery and that the protection it affords from public disclosure 8 and use extends only to the limited information or items that are entitled to confidential 9 treatment under the applicable legal principles. 10 2. GOOD CAUSE STATEMENT 11 This action is likely to involve trade secrets, customer and pricing lists and other 12 valuable research, development, commercial, financial, technical and/or proprietary 13 information for which special protection from public disclosure and from use for any 14 purpose other than prosecution of this action is warranted. Such confidential and proprietary 15 materials and information consist of, among other things, confidential business or financial 16 information, information regarding confidential business practices, or other confidential 17 research, development, or commercial information (including information implicating 18 privacy rights of third parties), information otherwise generally unavailable to the public, or 19 which may be privileged or otherwise protected from disclosure under state or federal 20 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow of 21 information, to facilitate the prompt resolution of disputes over confidentiality of discovery 22 materials, to adequately protect information the parties are entitled to keep confidential, to 23 ensure that the parties are permitted reasonable necessary uses of such material in 24 preparation for and in the conduct of trial, to address their handling at the end of the 25 litigation, and to serve the ends of justice, a protective order for such information is justified 26 in this matter. 27 28 1 3. DEFINITIONS 2 3.1. Action: Majco LLC v. Jackson Tire Service, et al., Case No. 2:25-cv-01967- 3 DC-JDP (E.D. Cal.) 4 3.2. Challenging Party: a Party or Non-Party that challenges the designation of 5 information or items under this Order. 6 3.3. “CONFIDENTIAL” Information or Items: information (regardless of how it 7 is generated, stored or maintained) or tangible things that qualify for protection under 8 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement. 9 3.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 11 3.5. Designating Party: a Party or Non-Party that designates information or items 12 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 13 3.6. Disclosure or Discovery Material: all items or information, regardless of the 14 medium or manner in which it is generated, stored, or maintained (including, among other 15 things, testimony, transcripts, and tangible things), that are produced or generated in 16 disclosures or responses to discovery. 17 3.7. Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert 19 witness or as a consultant in this Action. 20 3.8. House Counsel: attorneys who are employees of a party to this Action. House 21 Counsel does not include Outside Counsel of Record or any other outside counsel. 22 3.9. Non-Party: any natural person, partnership, corporation, association or other 23 legal entity not named as a Party to this action. 24 3.10. Outside Counsel of Record: attorneys who are not employees of a party to this 25 Action but are retained to represent a party to this Action and have appeared in this Action 26 on behalf of that party or are affiliated with a law firm that has appeared on behalf of that 27 party, and includes support staff. 28 1 3.11. Party: any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their support 3 staffs). 4 3.12. Producing Party: a Party or Non-Party that produces Disclosure or Discovery 5 Material in this Action. 6 3.13. Professional Vendors: persons or entities that provide litigation support 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, 8 and organizing, storing, or retrieving data in any form or medium) and their employees and 9 subcontractors. 10 3.14. Protected Material: any Disclosure or Discovery Material that is designated as 11 “CONFIDENTIAL.” 12 3.15. Receiving Party: a Party that receives Disclosure or Discovery Material from 13 a Producing Party. 14 4. SCOPE 15 The protections conferred by this Stipulation and Order cover not only Protected 16 Material (as defined above), but also (1) any information copied or extracted from Protected 17 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) 18 any testimony, conversations, or presentations by Parties or their Counsel that might reveal 19 Protected Material. 20 Any use of Protected Material at trial shall be governed by the orders of the trial judge 21 and other applicable authorities. This Order does not govern the use of Protected Material 22 at trial. 23 5. DURATION 24 Once a case proceeds to trial, information that was designated as CONFIDENTIAL 25 or maintained pursuant to this protective order used or introduced as an exhibit at trial 26 becomes public and will be presumptively available to all members of the public, including 27 the press, unless the Court has granted a motion to seal such material. See Kamakana v. City 28 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good 1 cause” showing for sealing documents produced in discovery from “compelling reasons” 2 standard when merits-related documents are part of court record). Accordingly, the terms 3 of this protective order do not extend to any Protected Material used as an exhibit at trial or 4 hearing if the Court has either rejected or granted the request to seal such Protected Material. 5 If the Court has granted the request to seal such Protected Material, the terms of the order 6 sealing such material or the Local Rules govern the subsequent use and dissemination of 7 such material. 8 6. DESIGNATING PROTECTED MATERIAL 9 6.1. Each Party’s Requirement of Due Care. All Parties acknowledge that 10 discovery in this Action may involve documents and information that contain trade secrets 11 of one or more of the Parties or other Protected Material. Each Producing Party agrees to 12 undertake efforts to designate all documents and information that it will produce as 13 Confidential to the extent such documents and information contain the trade secrets of other 14 Parties. 15 If any Party discovers information or documents containing its trade secrets were 16 produced by the Producing Party that the Producing Party failed to designate, that other Party 17 may re-produce such documents with “CONFIDENTIAL” as outlined below and, thereafter, 18 all Parties shall treat such material as Protected Material subject to this Protective Order as 19 though the Producing Party had so designated. 20 6.2. Manner and Timing of Designations. Except as otherwise provided in this 21 Order, or as otherwise stipulated or ordered, Discovery Material that qualifies for protection 22 under this Order must be clearly so designated before the material is disclosed or produced. 23 Designation in conformity with this Order requires: 24 a) for information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 26 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 27 “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion 28 1 of the material on a page qualifies for protection, the Producing Party also must clearly 2 identify the protected 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 4 not designate them for protection until after the inspecting Party has indicated which 5 documents it would like copied and produced. During the inspection and before the 6 designation, all of the material made available for inspection shall be deemed 7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied 8 and produced, the Producing Party must determine which documents, or portions thereof, 9 qualify for protection under this Order. Then, before producing the specified documents, 10 the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains 11 Protected Material. If only a portion of the material on a page qualifies for protection, the 12 Producing Party also must clearly identify the protected portion(s) (e.g., by making 13 appropriate markings in the margins). 14 b) for testimony given in depositions that the Designating Party either: (1) 15 identifies on the record as confidential; or (2) identifies in writing by line and page number 16 as Protected Material on or before fourteen (14) days from the date on which any corrections 17 to the transcript are due. 18 c) for information produced in some form other than documentary and for 19 any other tangible items, that the Producing Party affix in a prominent place on the exterior 20 of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 22 the Producing Party, to the extent practicable, shall identify the protected portion(s). 23 6.2. Inadvertent Failures to Designate. If promptly corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. Upon 26 timely correction of a designation, the Receiving Party must make reasonable efforts to 27 assure that the material is treated in accordance with the provisions of this Order. 28 1 7. PARTY’S USE OF PROTECTED MATERIAL IN THIS ACTION 2 7.1. Filing Protected Material Designated by Filing Party. Any Party or Non-Party 3 may file any Protected Material provisionally under seal contemporaneously with the filing 4 of a motion to seal in conformance with Local Rules 140-141.1. 5 7.2. Filing Protected Material Designated by Non-Filing Party. Without written 6 permission from the designating party or a Court order secured after appropriate 7 notice to all interested persons, a party may not file in the public record in this action 8 any Protected Material. A Party that seeks to file under seal any Confidential Material 9 must comply with Eastern District Local Rule 141. Protected Material may only be 10 filed under seal pursuant to a Court order authorizing the sealing of the specific 11 Protected Material at issue. Any Party or Non-Party may file Protected Material designated 12 by a different party provisionally under seal. Once filed provisionally under seal, the 13 Designating Party (or any other party) may choose to file a motion to seal such Protected 14 Material within 14 days after the Protected Material was filed provisionally under seal. 15 Alternatively, at At the filing party’s option, the filing party may notify the 16 Designating Party at least 7 days in advance of the filing date at which point the Designating 17 Party is required to notify the filing party 3 days thereafter whether the Designating Party 18 will either withdraw the designation or intends to maintain the designation. If the 19 Designating Party intends to maintain the confidential designation, the filing party will file 20 such Protected Material provisionally under seal and the Designating Party must file a 21 motion to seal within 2 days of the date on which the Protected Material was filed 22 provisionally under seal. 23 7.3. Filing Protected Material Designated by Filing Party. Should any Party or 24 Non-Party decide to file its Protected Material, that Party or Non-Party must file a motion 25 to seal concurrently. 26 7.4. Local Rules. The Local Rules will govern any request and motion to seal 27 unless such Local Rules directly conflict with this Protective Order in which case the rules 28 in this Protective Order will govern. 1 8. ACCESS TO AND USE OF PROTECTED MATERIAL 2 8.1. Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this Action 4 only for prosecuting, defending or attempting to settle this Action. Such Protected Material 5 may be disclosed only to the categories of persons and under the conditions described in this 6 Order. When the Action has been terminated, a Receiving Party must comply with the 7 provisions of section 15 below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a location 9 and in a secure manner that ensures that access is limited to the persons authorized under 10 this Order. 11 8.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 12 ordered by the court or permitted in writing by the Designating Party, a Receiving Party may 13 disclose any information or item designated “CONFIDENTIAL” only to: 14 a) the Receiving Party’s Outside Counsel of Record in this Action, as well 15 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this Action; 17 b) the officers, directors, and employees (including House Counsel) of the 18 Receiving Party to whom disclosure is reasonably necessary for this Action; 19 c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 d) the court and its personnel; 23 e) court reporters and their staff; 24 f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 26 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 g) the author or recipient of a document containing the information or a 28 custodian or other person who otherwise possessed or knew the information; 1 h) during their depositions, witnesses and attorneys for witnesses (other 2 than Parties or signatory Non-Parties), in the Action to whom disclosure is reasonably 3 necessary provided: they will not be permitted to keep any confidential information unless 4 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 5 agreed by the Designating Party or ordered by the court. Pages of transcribed deposition 6 testimony or exhibits to depositions that reveal Protected Material may be separately bound 7 by the court reporter and may not be disclosed to anyone except as permitted under this 8 Stipulated Protective Order; and 9 i) any mediators or settlement officers and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement discussions. 11 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 12 OTHER LITIGATION 13 If a Party is served with a subpoena or a court order issued in other litigation that 14 compels disclosure of any information or items designated in this Action as 15 “CONFIDENTIAL” by a different Party or Non-Party, that Party must: 16 a) promptly notify in writing the Designating Party. Such notification 17 shall include a copy of the subpoena or court order; 18 b) promptly notify in writing the party who caused the subpoena or order 19 to issue in the other litigation that some or all of the material covered by the subpoena or 20 order is subject to this Protective Order. Such notification shall include a copy of this 21 Stipulated Protective Order; and 22 c) cooperate with respect to all reasonable procedures sought to be 23 pursued by the Designating Party whose Protected Material may be affected. If the 24 Designating Party timely seeks a protective order, the Party served with the subpoena or 25 court order shall not produce any information designated in this action as 26 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 27 issued, unless the Party has obtained the Designating Party’s permission. The Designating 28 Party shall bear the burden and expense of seeking protection in that court of its confidential 1 material and nothing in these provisions should be construed as authorizing or encouraging 2 a Receiving Party in this Action to disobey a lawful directive from another court. 3 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 The terms of this Order are applicable to information produced by a Non-Party in this 6 Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties 7 in connection with this litigation is protected by the remedies and relief provided by this 8 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from 9 seeking additional protections. 10 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this Stipulated 13 Protective Order, the Receiving Party must immediately (a) notify in writing the Designating 14 Party of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized 15 copies of the Protected Material, (c) inform the person or persons to whom unauthorized 16 disclosures were made of all the terms of this Order, and (d) request such person or persons 17 to execute the “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A. 18 12. PRIVILEGE LOG 19 Any Party or Non-Party that has withheld any material, document, or information on 20 the basis of any legal privilege or has otherwise redacted a portion of any document on the 21 basis of any legal privilege shall provide to all other Parties a Privilege Log within thirty 22 (30) days after substantial completion of their respective document productions or, in the 23 case of rolling productions, within thirty (30) days after each document production batch, 24 unless the Parties agree otherwise. 25 The Privilege Log must meet the requirements set forth in Rule 26(b)(5) of the 26 Federal Rules of Civil Procedure or, in the case of documents produced pursuant to 27 subpoena, Rule 45(e)(2) of the Federal Rules of Civil Procedure to allow each Party and the 28 Court to meaningfully assess the claim of privilege. At a minimum, the Privilege Log must 1 include: “[1] a description of responsive material withheld, [2] the identity and position of 2 its author, [3] the date it was written, [4] the identity and position of all addressees and 3 recipients, [5] the material's present location, [6] and specific reasons for its being withheld, 4 including the privilege invoked and grounds thereof.” Friends of Hope Valley v. Frederick 5 Co., 268 F.R.D. 643, 650-51 (E.D. Cal. 2010). 6 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 The Parties may be required to produce large volumes of documents and, to comply 9 with discovery deadlines in the case, wish to complete discovery as expeditiously as 10 possible, while preserving and without waiving any evidentiary protections or privileges 11 applicable to the information contained in the documents produced, including as against 12 third parties and potentially in other Federal and State proceedings. The Parties having 13 agreed to a clawback agreement, and good cause appearing therefore, the Court hereby 14 orders as follows: 15 13.1. The inadvertent production of any document in this action shall be without 16 prejudice to any claim that such material is protected by any legally cognizable privilege or 17 evidentiary protection including, but not limited to the attorney-client privilege, or the work 18 product doctrine, and no party shall be held to have waived any rights by such inadvertent 19 production. For purposes of this stipulated protective order, an “Inadvertently Produced 20 Document” is a document produced to a party in this litigation that could have been withheld, 21 in whole or in part, based on a legitimate claim of attorney-client privilege, work-product 22 protection, or other applicable privilege. 23 13.2. If any document produced by another party is on its face subject to a legally 24 recognizable privilege or evidentiary protection, the receiving party shall: (a) refrain from 25 reading the document any more closely than is necessary to ascertain that it is privileged; 26 (b) immediately notify the producing party in writing that it has discovered documents 27 believed to be privileged or protected; (c) specifically identify the documents by Bates 28 number range or hash value range, and, (d) where possible, sequester or destroy all copies 1 of such documents, along with any notes, abstracts or compilations of the content thereof, 2 within five (5) days of discovery by the receiving party. Where such documents cannot be 3 destroyed or separated it shall not be reviewed, disclosed, or otherwise used by the receiving 4 party. Notwithstanding, the receiving party is under no obligation to search or review the 5 producing party’s documents to identify potentially privileged or work product protected 6 documents. 7 13.3. Upon written notice of an unintentional production by the Producing Party or 8 oral notice if notice is delivered on the record at a deposition, the receiving party must 9 promptly sequester or destroy the specified document and any hard copies the receiving 10 party has and may not use or disclose the information until the privilege claim has been 11 resolved. The Producing Party shall also provide an updated privilege log for such 12 documents in compliance with Section 12 of this Order. To the extent that the Producing 13 Party insists on the return or destruction of electronic copies, rather than disabling the 14 documents from further use or otherwise rendering them inaccessible to the receiving party, 15 the Producing Party shall bear the costs of the return or destruction of such electronic copies. 16 13.4. To the extent that the information contained in a document subject to a claim 17 has already been used in or described in other documents generated or maintained by the 18 receiving party, then the receiving party will sequester such documents until the claim has 19 been resolved. If the receiving party disclosed the specified documents before being notified 20 of its inadvertent production, it must take reasonable steps to ensure it is sequestered or 21 destroyed. The producing party shall preserve the specified documents until the claim is 22 resolved. 23 13.5. The receiving party shall have ten (10) days from receipt of notification of the 24 inadvertent production to determine in good faith whether to contest such claim and to notify 25 the Producing Party in writing of an objection to the claim of privilege and the grounds for 26 that objection, and, thereafter, Counsel shall meet and confer in a good faith effort, within 27 five (5) days of receiving the written objection, to resolve their differences. 28 1 13.6. The receiving party’s sequestering or destruction of such privileged or 2 protected documents as provided herein will not act as a waiver of the requesting party’s 3 right to move for the production of the sequestered or destroyed documents on the grounds 4 that the documents are not in fact subject to a viable claim of privilege or protection. 5 However, the receiving party is prohibited and estopped from arguing that the production of 6 the documents in this matter acts as a waiver of an applicable privilege or evidentiary 7 protection, that the disclosure of the documents was not inadvertent, that the producing party 8 did not take reasonable steps to prevent the disclosure of the privileged documents or that 9 the producing party failed to take reasonable steps to rectify the error as set forth in CCP § 10 2031.285. The producing party need make no showing with respect to measures taken to 11 prevent the inadvertent production of the documents in question in order to be entitled to 12 their sequestering or destruction. 13 13.7. Either party may submit the specified documents for a determination of the 14 claim by making a motion within 30 days of the meet and confer described in Section 13.5, 15 above, and presenting the information to the court conditionally under seal as permitted by 16 the Protective Order and/or the Local Rules. The receiving party may not use the documents 17 for any purpose absent this Court’s Order. Any party may request expedited treatment of 18 any request for the Court's determination of the claim. 19 13.8. Upon a determination by the Court that the specified documents are protected 20 by the applicable privilege or evidentiary protection, and if the specified documents have 21 been sequestered rather than destroyed, the specified documents shall be destroyed. The 22 Court may also order, the identification and/or review of documents that have been identified 23 as being potentially subject to a legally recognized claim by search terms or other means. 24 14. MISCELLANEOUS 25 14.1. Right to Further Relief. Nothing in this Order abridges the right of any person 26 to seek its modification by the Court in the future. 27 14.2. Right to Assert Other Objections. By stipulating to the entry of this Protective 28 Order, no Party waives any right it otherwise would have to object to disclosing or producing 1 any information or item on any ground not addressed in this Stipulated Protective Order. 2 Similarly, no Party waives any right to object on any ground to use in evidence of any of the 3 material covered by this Protective Order. 4 14.3. Filing Protected Material. A Party that seeks to file under seal any Protected 5 Material must comply with Local Rules 140, 141 and 141.1, except as otherwise specified 6 in this Protective Order. Protected Material may only be filed under seal pursuant to a court 7 order authorizing the sealing of the specific Protected Material. If a Party’s request to file 8 Protected Material under seal is denied by the court, then the Receiving Party may file the 9 information in the public record unless otherwise instructed by the court. 10 15. FINAL DISPOSITION 11 Within sixty (60) days after the expiration of any appeal period, the final resolution 12 after an appellate ruling (assuming the appellate ruling does not require any further 13 proceedings) or after all obligations imposed by any settlement agreement are fully 14 performed, each Party or Non-Party possessing Protected Material shall either (1) return all 15 such material to the Party or Non-Party that produced it or furnished it; or (2) destroy such 16 material. 17 16. VIOLATION 18 Any violation of this Order may be punished by appropriate measures including, 19 without limitation, contempt proceedings and/or monetary sanctions. 20 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 22 23 24 25 26 27 28 1 | Dated: December 8, 2025 ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP 2 RYAN T. WAGGONER ERIC C. PETTIS 3 NATHAN T. JAMIESON By: /s/ Ryan T. Waggoner 5 RYAN T. WAGGONER Attorneys for Plaintiff 6 MAJCO LLC 8 | DATED: December 5, 2025 BUCHALTER, APC JOSH H. ESCOVEDO 9 EMILY G. MALHIOT 10 By: /s/ Josh H. Escovedo 1 JOSH H. ESCOVEDO 12 Attorneys for Defendants KURST BOVERO AND SIERRA TIRE 13 Co. 14 15 | DATED: December 5, 2025 MOHAN HARRIS RUIZ LLP 16 /S/ §. Dean Ruiz S. Dean Ruiz, Esq. 17 Attorneys for Defendants, Philip Bovero and 18 Jackson Tire Service 19 20 | rr Is SO ORDERED. 21 / 22 ||Dated: _ December 9, 2025 Q_—— JEREMY D, PETERSON 23 UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name], of _________________ 4 [print or type full address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States District 6 Court for the Eastern District of California in the case of Majco LLC v. Jackson Tire 7 Services, et al., Case No. 2:25-cv-01967-DC-JDP. I agree to comply with and to be bound 8 by all 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 contempt. 10 I solemnly promise that I will not disclose in any manner any information or item that is 11 subject to this Stipulated Protective Order to any person or entity except in strict compliance 12 with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Eastern District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. I hereby appoint ________________________ [print or type full name] of 17 _________ [print or type full address and telephone number] as my California agent for 18 service of process in connection with this action or any proceedings related to enforcement 19 of this Stipulated Protective Order. 20 21 Date: ___________________________ 22 23 City and State where sworn and signed: ___________________________ 24 25 Printed name: ___________________________ 26 27 Signature: ___________________________ 28