Strange v. Jaguar Land Rover North America, LLC

• Court: District Court, E.D. California
• Decided: June 24, 2024
• Docket: 2:24-cv-00382
• Status: Unknown

Opinion

1 Tionna Carvalho (SBN 299010) tcarvalho@slpattorney.com 2 Elizabeth A LaRocque (SBN 219977) elarocque@slpattorney.com 3 STRATEGIC LEGAL PRACTICES, APC 1888 Century Park East, Floor 19 4 Los Angeles, CA 90067 Tel: (310)929-4900 5 Fax: (310)943-3838 Attorneys for Plaintiffs, 6 NICOLE MARIE STRANGE and WILLIAM MICHAEL STRANGE 7

8 SPENCER P. HUGRET (SBN: 240424) shugret@grsm.com 9 JEANETTE SUAREZ (SBN: 255141) jsuarez@grsm.com 10 SARAH CARLSON LAMBERT (SBN: 247360) slambert@grsm.com 11 GORDON REES SCULLY MANSUKHANI, LLP 315 Pacific Avenue 12 San Francisco, CA 94111 Telephone: (415) 986-5900 13 Facsimile: (415) 986-8054 Attorneys for Defendant 14 JAGUAR LAND ROVER NORTH AMERICA, LLC

15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17 18 NICOLE MARIE STRANGE and ) No. 2:24-cv-0382 TLN DB WILLIAM MICHAEL STRANGE, ) 19 ) Plaintiffs, ) 20 ) STIPULATED PROTECTIVE 21 vs. ) ORDER – DISCOVERY ONLY ) JAGUAR LAND ROVER NORTH 22 AMERICA LLC; and DOES 1 ) through 10, inclusive ) 23 ) Defendants. ) 24

25 1. PURPOSES AND LIMITATIONS 26 Disclosure and discovery activity in this action are likely to involve 27 production of confidential, proprietary, or private information for which special 1 prosecuting this litigation may be warranted. Accordingly, the parties hereby 2 stipulate to and petition the court to enter the following Stipulated Protective 3 Order. The parties acknowledge that this Order does not confer blanket protections 4 on all disclosures or responses to discovery and that the protection it affords from 5 public disclosure and use extends only to the limited information or items that are 6 entitled to confidential treatment under the applicable legal principles. The parties 7 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 8 Protective Order does not entitle them to file confidential information under seal; 9 Civil Local Rule 141 sets forth the procedures that must be followed and the 10 standards that will be applied when a party seeks permission from the court to file 11 material under seal. 12 13 2. DEFINITIONS 14 2.1 Challenging Party: a Party or Non-Party that challenges the 15 designation of information or items under this Order. 16 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c). 19 2.3 Counsel (without qualifier): Outside Counsel of Record and House 20 Counsel (as well as their support staff). 21 2.4 Designating Party: a Party or Non-Party that designates information 22 or items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.5 Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that are produced 27 or generated in disclosures or responses to discovery in this matter. 1 2.6 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve 3 as an expert witness or as a consultant in this action. 4 2.7 House Counsel: attorneys who are employees of a party to this action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.8 Non-Party: any natural person, partnership, corporation, association, 8 or other legal entity not named as a Party to this action. 9 2.9 Outside Counsel of Record: attorneys who are not employees of a 10 party to this action but are retained to represent or advise a party to this action and 11 have appeared in this action on behalf of that party or are affiliated with a law firm 12 which has appeared on behalf of that party. 13 2.10 Party: any party to this action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and 15 their support staffs). 16 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this action. 18 2.12 Professional Vendors: persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits 20 or demonstrations, and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 22 2.13 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.14 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 // 27 // // 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 However, the protections conferred by this Stipulation and Order do not cover the 8 following information: (a) any information that is in the public domain at the time 9 of disclosure to a Receiving Party or becomes part of the public domain after its 10 disclosure to a Receiving Party as a result of publication not involving a violation 11 of this Order, including becoming part of the public record through trial or 12 otherwise; and (b) any information known to the Receiving Party prior to the 13 disclosure or obtained by the Receiving Party after the disclosure from a source 14 who obtained the information lawfully and under no obligation of confidentiality 15 to the Designating Party. Any use of Protected Material at trial shall be governed 16 by a separate agreement or order. 17 18 4. DURATION 19 Even after final disposition of this litigation, the confidentiality obligations 20 imposed by this Order shall remain in effect until a Designating Party agrees 21 otherwise in writing or a court order otherwise directs. Final disposition shall be 22 deemed to be the later of (1) dismissal of all claims and defenses in this action, 23 with or without prejudice; and (2) final judgment herein after the completion and 24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 25 including the time limits for filing any motions or applications for extension of 26 time pursuant to applicable law. 27 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate 6 for protection only those parts of material, documents, items, or oral or written 7 communications that qualify – so that other portions of the material, documents, 8 items, or communications for which protection is not warranted are not swept 9 unjustifiably within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. 11 Designations that are shown to be clearly unjustified or that have been made for 12 an improper purpose (e.g., to unnecessarily encumber or retard the case 13 development process or to impose unnecessary expenses and burdens on other 14 parties) expose the Designating Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that 16 it designated for protection do not qualify for protection, that Designating Party 17 must promptly notify all other Parties that it is withdrawing the mistaken 18 designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for 22 protection under this Order must be clearly so designated before the material is 23 disclosed or produced. 24 Designation in conformity with this Order requires: 25 (a) For information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion or portions of the 1 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 3 margins). 4 A Party or Non-Party that makes original documents or materials available 5 for inspection need not designate them for protection until after the inspecting 6 Party has indicated which material it would like copied and produced. During the 7 inspection and before the designation, all of the material made available for 8 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 9 identified the documents it wants copied and produced, the Producing Party must 10 determine which documents, or portions thereof, qualify for protection under this 11 Order. Then, before producing the specified documents, the Producing Party must 12 affix the “CONFIDENTIAL” legend to each page that contains Protected 13 Material. If only a portion or portions of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portion(s) 15 (e.g., by making appropriate markings in the margins). 16 (b) for testimony given in deposition or in other pretrial or trial 17 proceedings, that the Designating Party identify on the record, before the close of 18 the deposition, hearing, or other proceeding, all protected testimony. 19 (c) for information produced in some form other than documentary 20 and for any other tangible items, that the Producing Party affix in a prominent 21 place on the exterior of the container or containers in which the information or 22 item is stored the legend “CONFIDENTIAL.” If only a portion or portions of the 23 information or item warrant protection, the Producing Party, to the extent 24 practicable, shall identify the protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive 27 the Designating Party’s right to secure protection under this Order for such material. Upon timely correction of a designation, the Receiving Party must make 1 reasonable efforts to assure that the material is treated in accordance with the 2 provisions of this Order. 3 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 designation of confidentiality at any time. Unless a prompt challenge to a 7 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 8 substantial unfairness, unnecessary economic burdens, or a significant disruption 9 or delay of the litigation, a Party does not waive its right to challenge a 10 confidentiality designation by electing not to mount a challenge promptly after the 11 original designation is disclosed. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process by providing written notice of each designation it is challenging 14 and describing the basis for each challenge. To avoid ambiguity as to whether a 15 challenge has been made, the written notice must recite that the challenge to 16 confidentiality is being made in accordance with this specific paragraph of the 17 Protective Order. The parties shall attempt to resolve each challenge in good faith 18 and must begin the process by conferring directly (in voice to voice dialogue; other 19 forms of communication are not sufficient) within 14 days of the date of service 20 of notice. In conferring, the Challenging Party must explain the basis for its belief 21 that the confidentiality designation was not proper and must give the Designating 22 Party an opportunity to review the designated material, to reconsider the 23 circumstances, and, if no change in designation is offered, to explain the basis for 24 the chosen designation. A Challenging Party may proceed to the next stage of the 25 challenge process only if it has engaged in this meet and confer process first or 26 establishes that the Designating Party is unwilling to participate in the meet and 27 confer process in a timely manner. 1 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 2 court intervention, the Designating Party shall file and serve a motion to retain 3 confidentiality within 21 days of the initial notice of challenge or within 14 days 4 of the parties agreeing that the meet and confer process will not resolve their 5 dispute, whichever is earlier. Each such motion must be accompanied by a 6 competent declaration affirming that the movant has complied with the meet and 7 confer requirements imposed in the preceding paragraph. Failure by the 8 Designating Party to make such a motion including the required declaration within 9 21 days (or 14 days, if applicable) shall automatically waive the confidentiality 10 designation for each challenged designation. In addition, the Challenging Party 11 may file a motion challenging a confidentiality designation at any time if there is 12 good cause for doing so, including a challenge to the designation of a deposition 13 transcript or any portions thereof. Any motion brought pursuant to this provision 14 must be accompanied by a competent declaration affirming that the movant has 15 complied with the meet and confer requirements imposed by the preceding 16 paragraph. 17 The burden of persuasion in any such challenge proceeding shall be on the 18 Designating Party. Frivolous challenges, and those made for an improper purpose 19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 20 expose the Challenging Party to sanctions. Unless the Designating Party has 21 waived the confidentiality designation by failing to file a motion to retain 22 confidentiality as described above, all parties shall continue to afford the material 23 in question the level of protection to which it is entitled under the Producing 24 Party’s designation until the court rules on the challenge. 25 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with 1 this case only for prosecuting, defending, or attempting to settle this litigation. 2 Such Protected Material may be disclosed only to the categories of persons and 3 under the conditions described in this Order. When the litigation has been 4 terminated, a Receiving Party must comply with the provisions of section 13 below 5 (FINAL DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this action, as 14 well as employees of said Outside Counsel of Record to whom it is reasonably 15 necessary to disclose the information for this litigation and who have signed the 16 Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 17 A; 18 (b) the officers, directors, and employees (including House Counsel) 19 of the Receiving Party to whom disclosure is reasonably necessary for this 20 litigation and who have signed the “Acknowledgment and Agreement to Be 21 Bound” (Exhibit A); 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 disclosure is reasonably necessary for this litigation 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, professional jury or trial consultants, 27 mock jurors, and Professional Vendors to whom disclosure is reasonably 1 necessary for this litigation and who have signed the “Acknowledgment and 2 Agreement to Be Bound” (Exhibit A); 3 (f) during their depositions, witnesses in the action to whom disclosure 4 is reasonably necessary and who have signed the “Acknowledgment and 5 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 6 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits 7 to depositions that reveal Protected Material must be separately bound by the court 8 reporter and may not be disclosed to anyone except as permitted under this 9 Stipulated Protective Order. 10 (g) the author or recipient of a document containing the information 11 or a custodian or other person who otherwise possessed or knew the information. 12 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification 19 shall include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or 21 order to issue in the other litigation that some or all of the material covered by the 22 subpoena or order is subject to this Protective Order. Such notification shall 23 include a copy of this Stipulated Protective 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 affected. 26 If the Designating Party timely seeks a protective order, the Party served 27 with the subpoena or court order shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the court from which 1 the subpoena or order issued, unless the Party has obtained the Designating Party’s 2 permission. The Designating Party shall bear the burden and expense of seeking 3 protection in that court of its confidential material – and nothing in these 4 provisions should be construed as authorizing or encouraging a Receiving Party in 5 this action to disobey a lawful directive from another court. 6 7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a Non- 10 Party in this action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party shall: 18 (1) promptly notify in writing the Requesting Party and the Non-Party 19 that some or all of the information requested is subject to a confidentiality 20 agreement with a Non-Party; 21 (2) promptly provide the Non-Party with a copy of the Stipulated 22 Protective Order in this litigation, the relevant discovery request(s), and a 23 reasonably specific description of the information requested; and 24 (3) make the information requested available for inspection by the 25 Non-Party. 26 (c) If the Non-Party fails to object or seek a protective order from this court 27 within 14 days of receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential information responsive 1 to the discovery request. If the Non-Party timely seeks a protective order, the 2 Receiving Party shall not produce any information in its possession or control that 3 is subject to the confidentiality agreement with the Non-Party before a 4 determination by the court. Absent a court order to the contrary, the Non-Party 5 shall bear the burden and expense of seeking protection in this court of its 6 Protected Material. 7 8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 9 If a Receiving Party learns that, by inadvertence or otherwise, it has 10 disclosed Protected Material to any person or in any circumstance not authorized 11 under this Stipulated Protective Order, the Receiving Party must immediately (a) 12 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 13 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 14 the person or persons to whom unauthorized disclosures were made of all the terms 15 of this Order, and (d) request such person or persons to execute the 16 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 17 A. 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other 23 protection, the obligations of the Receiving Parties are those set forth in Federal 24 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 25 whatever procedure may be established in an e-discovery order that provides for 26 production without prior privilege review. Pursuant to Federal Rule of Evidence 27 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or information covered by the attorney-client privilege or 1 work product protection, the parties may incorporate their agreement in the 2 stipulated protective order submitted to the court. 3 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in 10 this Stipulated Protective Order. Similarly, no Party waives any right to object on 11 any ground to use in evidence of any of the material covered by this Protective 12 Order. 13 12.3 Filing Protected Material. Without written permission from the 14 Designating Party or a court order secured after appropriate notice to all interested 15 persons, a Party may not file in the public record in this action any Protected 16 Material. A Party that seeks to file under seal any Protected Material must comply 17 with Local Rule 141. Protected Material may only be filed under seal pursuant to 18 a court order authorizing the sealing of the specific Protected Material at issue. A 19 sealing order will issue only upon a request establishing that the Protected Material 20 at issue is privileged, protectable as a trade secret, or otherwise entitled to 21 protection under the law. If a Receiving Party's request to file Protected Material 22 under seal is denied by the court, then the Receiving Party may file the information 23 in the public record unless otherwise instructed by the court. 24 25 13. FINAL DISPOSITION 26 Upon final termination of this action, including any and all appeals, counsel 27 for each party must, upon request of the producing party, return all confidential information to the party that produced the information, including any copies, 1 excerpts, and summaries of that information, or must destroy same at the option 2 of the receiving party, and must purge all such information from all machine- 3 readable media on which it resides. Notwithstanding the foregoing, counsel for 4 each party may retain all pleadings, briefs, memoranda, motions, and other 5 documents filed with the Court that refer to or incorporate confidential 6 information, and will continue to be bound by this Order with respect to all such 7 retained information. Further, attorney work product materials that contain 8 confidential information need not be destroyed, but, if they are not destroyed, the 9 person in possession of the attorney work product will continue to be bound by 10 this Order with respect to all such retained information. 11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 DATED: June 20, 2024 STRATEGIC LEGAL PRACTICES, APC 13

14 BY: /s/ Elizabeth A. LaRocque 15 Tionna Carvalho Elizabeth A. LaRocque 16 Attorneys for Plaintiffs, NICOLE MARIE STRANGE and 17 WILLIAM MICHAEL STRANGE

18 DATED: June 18, 2024 GORDON REES SCULLY MASUKHANI, LLP 19

20 BY: /s/ Sarah Carlson Lambert ___________ Spencer P. Hugret 21 Jeanette Suarez Sarah Carlson Lambert 22 Attorneys for Defendant, LAND ROVER NORTH AMERICA, LLC 23

24 ////

25 26 27 1 ORDER 2 Pursuant to the parties’ stipulation, IT IS SO ORDERED. 3 IT IS FURTHER ORDERED THAT: 4 1. Requests to seal documents shall be made by motion before the same judge who will 5 decide the matter related to that request to seal. 6 2. The designation of documents (including transcripts of testimony) as confidential 7 pursuant to this order does not automatically entitle the parties to file such a document with the 8 court under seal. Parties are advised that any request to seal documents in this district is 9 governed by Local Rule 141. In brief, Local Rule 141 provides that documents may only be 10 sealed by a written order of the court after a specific request to seal has been made. L.R. 141(a). 11 However, a mere request to seal is not enough under the local rules. In particular, Local Rule 12 141(b) requires that “[t]he ‘Request to Seal Documents’ shall set forth the statutory or other 13 authority for sealing, the requested duration, the identity, by name or category, of persons to be 14 permitted access to the document, and all relevant information.” L.R. 141(b). 15 3. A request to seal material must normally meet the high threshold of showing that 16 “compelling reasons” support secrecy; however, where the material is, at most, “tangentially 17 related” to the merits of a case, the request to seal may be granted on a showing of “good cause.” 18 Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1096-1102 (9th Cir. 2016); 19 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178-80 (9th Cir. 2006). 20 4. Nothing in this order shall limit the testimony of parties or non-parties, or the use of 21 certain documents, at any court hearing or trial – such determinations will only be made by the 22 court at the hearing or trial, or upon an appropriate motion. 23 5. With respect to motions regarding any disputes concerning this protective order which 24 the parties cannot informally resolve, the parties shall follow the procedures outlined in Local 25 Rule 251. Absent a showing of good cause, the court will not hear discovery disputes on an ex 26 parte basis or on shortened time. 27 1 6. The parties may not modify the terms of this Protective Order without the court’s 2 approval. If the parties agree to a potential modification, they shall submit a stipulation and 3 proposed order for the court’s consideration. 4 7. Pursuant to Local Rule 141.1(f), the court will not retain jurisdiction over enforcement 5 of the terms of this Protective Order after the action is terminated. 6 8. Any provision in the parties’ stipulation that is in conflict with anything in this order 7 is hereby DISAPPROVED. 8 DATED: June 21, 2024 /s/ DEBORAH BARNES UNITED STATES MAGISTRATE JUDGE 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 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 Eastern District of California 7 on [ ] in the case of Nicole Marie Strange and William Michael Strange v. Land 8 Rover North America, LLC; Case No.2:24-cv-00382-TLN-DB. I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Eastern District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. 19 I hereby appoint __________________________ [print or type full name] 20 of _______________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection 22 with this action or any proceedings related to enforcement of this Stipulated 23 Protective Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: __________________________ 26 Printed name: _______________________________ Signature: __________________________________ 27 1 SIGNATURE ATTESTATION 2 Pursuant to Local Rule 131(e), I hereby attest that the other signatory to this document 3 has authorized submission of the document on her behalf. 4 5 6 Dated: June 20, 2024 By: /s/ Elizabeth A. Larocque Elizabeth A. LaRocque 7 Attorneys for Plaintiffs NICOLE MARIE STRANGE and 8 WILLIAM MICHAEL STRANGE 9

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