VYACHESLAV FINOGEYEV, et. al. v. MERCEDES-BENZ FINANCIAL SERVICES USA, LLC et al.

• Court: District Court, C.D. California
• Decided: July 7, 2026
• Docket: 2:26-cv-02999
• Status: Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 VYACHESLAV FINOGEYEV, Case No. 2:26-cv-02999-WLH- 5 et. al., DMK 6 Plaintiff(s), 7 v. STIPULATED PROTECTIVE 8 MERCEDES-BENZ FINANCIAL ORDER1

9 SERVICES USA, LLC et al.,

10 Defendant(s).

11 12 1. INTRODUCTION 13 1.1 Purposes and Limitations. Discovery in this action is likely to 14 involve production of confidential, proprietary, or private information for 15 which special protection from public disclosure and from use for any 16 purpose other than prosecuting this litigation may be warranted. 17 Accordingly, the parties hereby stipulate to and petition the court to 18 19 enter the following Stipulated Protective Order. The parties 20 acknowledge that this Order does not confer blanket protections on all 21 disclosures or responses to discovery and that the protection it affords 22 from public disclosure and use extends only to the limited information or 23 items that are entitled to confidential treatment under the applicable 24 legal principles. 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Diana M. Kwok’s 1 1.2 Good Cause Statement. This action is likely to involve 2 documents related to an ongoing criminal investigation by Non-Party 3 State of California, acting by and through California Highway Patrol 4 (CHP), which contain information that is generally unavailable to the 5 public and/or privileged or otherwise protected from disclosure under 6 state or federal statues, court rules, case decisions, or common law. CHP 7 may also be producing documents that contain information concerning 8 its confidential internal policies which are generally unavailable to the 9 public. The disclosure of this information may jeopardize the security of 10 CHP’s operations and jeopardize the safety of peace officers. CHP may 11 also be producing documents that contain personal and confidential 12 information regarding individuals which information is generally 13 unavailable to the public, including peace officer personnel records and 14 records related to third parties. The disclosure of this information to the 15 public may violate those individuals’ privacy rights. CHP may also be 16 producing video, audio and still photo images related to the incident at 17 issue in this case, which are generally unavailable to the public. In 18 addition, CHP may be producing investigation reports which are 19 generally unavailable to the public, the disclosure of which could violate 20 individuals’ privacy rights, jeopardize the safety of officers, and 21 22 jeopardize the integrity of the ongoing criminal investigation. 23 Accordingly, to expedite the flow of information, to facilitate the prompt 24 resolution of disputes over confidentiality of discovery materials, to 25 adequately protect information the parties are entitled to keep 26 confidential, to ensure that the parties are permitted reasonable 27 necessary uses of such material in preparation for and in the conduct of 1 ends of justice, a protective order for such information is justified in this 2 matter. It is the intent of the parties that information will not be 3 designated as confidential for tactical reasons and that nothing be so 4 designated without a good faith belief that it has been maintained in a 5 confidential, non-public manner, and there is good cause why it should 6 not be part of the public record of this case. In addition, this Action may 7 involve the production of confidential, proprietary, or commercially 8 sensitive information by other Parties or Non-Parties, including any 9 Non-Party that may be subpoenaed in connection with this Action. Such 10 information may include, without limitation, proprietary commercial or 11 financial information and nonpublic customer or account data, the 12 disclosure of which could cause competitive or other injury. Accordingly, 13 and for the same reasons set forth above, good cause exists for this Order 14 to extend equally to such material upon proper designation in accordance 15 with the terms below. 16 1.3 Acknowledgment of Procedure for Filing Under Seal. The 17 parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential 19 information under seal; Local Rule 79-5 sets forth the procedures that 20 must be followed and the standards that will be applied when a party 21 22 seeks permission from the court to file material under seal. 23 There is a strong presumption that the public has a right of access 24 to judicial proceedings and records in civil cases. In connection with 25 non-dispositive motions, good cause must be shown to support a filing 26 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 27 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 1 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 2 protective orders require good cause showing), and a specific showing of 3 good cause or compelling reasons with proper evidentiary support and 4 legal justification, must be made with respect to Protected Material that 5 a party seeks to file under seal. The parties’ mere designation of 6 Disclosure or Discovery Material as CONFIDENTIAL does not— 7 without the submission of competent evidence by declaration, 8 establishing that the material sought to be filed under seal qualifies as 9 confidential, privileged, or otherwise protectable—constitute good cause. 10 Further, if a party requests sealing related to a dispositive motion 11 or trial, then compelling reasons, not only good cause, for the sealing 12 must be shown, and the relief sought shall be narrowly tailored to serve 13 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 14 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 15 information, document, or thing sought to be filed or introduced under 16 seal in connection with a dispositive motion or trial, the party seeking 17 protection must articulate compelling reasons, supported by specific 18 facts and legal justification, for the requested sealing order. Again, 19 competent evidence supporting the application to file documents under 20 seal must be provided by declaration. 21 22 Any document that is not confidential, privileged, or otherwise 23 protectable in its entirety will not be filed under seal if the confidential 24 portions can be redacted. If documents can be redacted, then a redacted 25 version for public viewing, omitting only the confidential, privileged, or 26 otherwise protectable portions of the document, shall be filed. Any 27 application that seeks to file documents under seal in their entirety 1 2 2. DEFINITIONS 3 2.1 Action: this pending federal lawsuit. 4 2.2 Challenging Party: a Party or Non-Party that challenges the 5 designation of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information 7 (regardless of how it is generated, stored or maintained) or tangible 8 things that qualify for protection under Rule 26(c) of the Federal Rules of 9 Civil Procedure, and as specified above in the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and In-House Counsel (as 11 well as their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates 13 information or items that it produces in disclosures or in responses to 14 discovery as “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, 16 regardless of the medium or manner in which it is generated, stored, or 17 18 maintained (including, among other things, testimony, transcripts, and 19 tangible things), that are produced or generated in disclosures or 20 responses to discovery in this matter. 21 2.7 Expert: a person with specialized knowledge or experience in 22 a matter pertinent to the litigation who has been retained by a Party or 23 its counsel to serve as an expert witness or as a consultant in this Action. 24 2.8 Final Disposition: the later of (1) dismissal of all claims and 25 defenses in this Action, with or without prejudice; and (2) final judgment 26 herein after the completion and exhaustion of all appeals, rehearings, 27 remands, trials, or reviews of this Action, including the time limits for 1 filing any motions or applications for extension of time pursuant to 2 applicable law. 3 2.9 In-House Counsel: attorneys who are employees of a party to 4 this Action. In-House Counsel does not include Outside Counsel of 5 Record or any other outside counsel. 6 2.10 Non-Party: any natural person, partnership, corporation, 7 association, or other legal entity not named as a Party to this action. 8 2.11 Outside Counsel of Record: attorneys who are not employees 9 of a party to this Action but are retained to represent or advise a party to 10 this Action and have appeared in this Action on behalf of that party or 11 are affiliated with a law firm which has appeared on behalf of that party, 12 and includes support staff. 13 2.12 Party: any party to this Action, including all of its officers, 14 directors, employees, consultants, retained experts, and Outside Counsel 15 of Record (and their support staffs). 16 2.13 Producing Party: a Party or Non-Party that produces 17 Disclosure or Discovery Material in this Action. 18 2.14 Professional Vendors: persons or entities that provide 19 litigation-support services (e.g., photocopying, videotaping, translating, 20 preparing exhibits or demonstrations, and organizing, storing, or 21 22 retrieving data in any form or medium) and their employees and 23 subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material that 25 is designated as “CONFIDENTIAL.” 26 2.16 Receiving Party: a Party that receives Disclosure or Discovery 27 Material from a Producing Party. 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not 3 only Protected Material (as defined above), but also (1) any information 4 copied or extracted from Protected Material; (2) all copies, excerpts, 5 summaries, or compilations of Protected Material; and (3) any 6 testimony, conversations, or presentations by Parties or their Counsel 7 that might reveal Protected Material. 8 // 9 Any use of Protected Material at trial shall be governed by the 10 orders of the trial judge. This Stipulated Protective Order does not 11 govern the use of Protected Material at trial. 12

13 14 4. TRIAL AND DURATION 15 The terms of this Stipulated Protective Order apply through Final 16 Disposition of the Action. 17 Once a case proceeds to trial, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 19 Order and used or introduced as an exhibit at trial becomes public and 20 will be presumptively available to all members of the public, including 21 the press, unless compelling reasons supported by specific factual 22 findings to proceed otherwise are made to the trial judge in advance of 23 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 24 cause” showing for sealing documents produced in discovery from 25 “compelling reasons” standard when merits-related documents are part 26 of court record). Accordingly, for such materials, the terms of this 27 1 the trial. 2 Even after Final Disposition of this litigation, the confidentiality 3 obligations imposed by this Stipulated Protective Order shall remain in 4 effect until a Designating Party agrees otherwise in writing or a court 5 order otherwise directs. 6 // 7 // 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for 10 Protection. Each Party or Non-Party that designates information or 11 items for protection under this Order must take care to limit any such 12 designation to specific material that qualifies under the appropriate 13 standards. The Designating Party must designate for protection only 14 those parts of material, documents, items, or oral or written 15 communications that qualify so that other portions of the material, 16 documents, items, or communications for which protection is not 17 18 warranted are not swept unjustifiably within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. 20 Designations that are shown to be clearly unjustified or that have been 21 made for an improper purpose (e.g., to unnecessarily encumber the case 22 development process or to impose unnecessary expenses and burdens on 23 other parties) may expose the Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or 25 items that it designated for protection do not qualify for protection, that 26 Designating Party must promptly notify all other Parties that it is 27 withdrawing the inapplicable designation. 1 5.2 Manner and Timing of Designations. Except as otherwise 2 provided in this Stipulated Protective Order (see, e.g., second paragraph 3 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 4 or Discovery Material that qualifies for protection under this Stipulated 5 Protective Order must be clearly so designated before the material is 6 disclosed or produced. 7 // 8 Designation in conformity with this Stipulated Protective Order 9 requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or 12 trial proceedings), that the Producing Party affix at a minimum, the 13 legend “CONFIDENTIAL” to each page that contains protected 14 material. If only a portion or portions of the material on a page 15 qualifies for protection, the Producing Party also must clearly identify 16 17 the protected portion(s) (e.g., by making appropriate markings in the 18 margins). 19 A Party or Non-Party that makes original documents available for 20 inspection need not designate them for protection until after the 21 inspecting Party has indicated which documents it would like copied 22 and produced. During the inspection and before the designation, all of 23 the material made available for inspection shall be deemed 24 CONFIDENTIAL. After the inspecting Party has identified the 25 documents it wants copied and produced, the Producing Party must 26 determine which documents, or portions thereof, qualify for protection 27 under this Stipulated Protective Order. Then, before producing the 1 specified documents, the Producing Party must affix the 2 “CONFIDENTIAL” legend to each page that contains Protected 3 Material. If only a portion or portions of the material on a page 4 qualifies for protection, the Producing Party also must clearly identify 5 the protected portion(s) (e.g., by making appropriate markings in the 6 margins). 7 (b) for testimony given in depositions that the Designating Party 8 identify the Disclosure or Discovery Material on the record, before the 9 close of the deposition all protected testimony. 10 (c) for information produced in some form other than 11 documentary and for any other tangible items, that the Producing Party 12 affix in a prominent place on the exterior of the container or containers 13 in which the information is stored the “CONFIDENTIAL” legend. If only 14 a portion or portions of the information warrants protection, the 15 Producing Party, to the extent practicable, shall identify the protected 16 portion(s). 17 18 5.3 Inadvertent Failures to Designate. If timely corrected, an 19 inadvertent failure to designate qualified information or items does not, 20 standing alone, waive the Designating Party’s right to secure protection 21 under this Order for such material. Upon timely correction of a 22 designation, the Receiving Party must make reasonable efforts to assure 23 that the material is treated in accordance with the provisions of this 24 Stipulated Protective Order. 25 26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 27 6.1 Timing of Challenges. Any Party or Non-Party may 1 challenge a designation of confidentiality at any time that is consistent 2 with the court’s Scheduling Order. 3 6.2 Meet and Confer. The Challenging Party shall initiate the 4 dispute resolution process under Local Rule 37.1 et seq. 5 6.3 The burden of persuasion in any such challenge proceeding 6 shall be on the Designating Party. Frivolous challenges, and those 7 made for an improper purpose (e.g., to harass or impose unnecessary 8 expenses and burdens on other parties) may expose the Challenging 9 Party to sanctions. Unless the Designating Party has waived or 10 withdrawn the confidentiality designation, all parties shall continue to 11 afford the material in question the level of protection to which it is 12 entitled under the Producing Party’s designation until the court rules on 13 the challenge. 14

15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 17 7.1 Basic Principles. A Receiving Party may use Protected 18 Material that is disclosed or produced by another Party or by a Non- 19 Party in connection with this Action only for prosecuting, defending, or 20 attempting to settle this Action. Such Protected Material may be 21 disclosed only to the categories of persons and under the conditions 22 described in this Order. When the Action reaches a Final Disposition, a 23 Receiving Party must comply with the provisions of section 13 below. 24 Protected Material must be stored and maintained by a Receiving 25 Party at a location and in a secure manner that ensures that access is 26 limited to the persons authorized under this Stipulated Protective 27 Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 2 Unless otherwise ordered by the court or permitted in writing by the 3 Designating Party, a Receiving Party may disclose any information or 4 item designated “CONFIDENTIAL” only: 5 (a) to the Receiving Party’s Outside Counsel of Record in this 6 Action, as well as employees of said Outside Counsel of Record to whom 7 it is reasonably necessary to disclose the information for this Action; 8 // 9 (b) to the officers, directors, and employees (including In-House 10 Counsel) of the Receiving Party to whom disclosure is reasonably 11 necessary for this Action; 12 (c) to Experts (as defined in this Order) of the Receiving Party to 13 whom disclosure is reasonably necessary for this Action and who have 14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) to the court and its personnel; 16 (e) to court reporters and their staff; 17 (f) to professional jury or trial consultants, mock jurors, and 18 Professional Vendors to whom disclosure is reasonably necessary for 19 this Action and who have signed the “Acknowledgment and Agreement 20 to Be Bound” (Exhibit A); 21 22 (g) to the author or recipient of a document containing the 23 information or a custodian or other person who otherwise possessed or 24 knew the information; 25 (h) during their depositions, to witnesses, and attorneys for 26 witnesses, in the Action to whom disclosure is reasonably necessary, 27 provided: (1) the deposing party requests that the witness sign the 1 witness will not be permitted to keep any confidential information 2 unless they sign the “Acknowledgment and Agreement to Be Bound” 3 (Exhibit A), unless otherwise agreed by the Designating Party or 4 ordered by the court. Pages of transcribed deposition testimony or 5 exhibits to depositions that reveal Protected Material may be separately 6 bound by the court reporter and may not be disclosed to anyone except 7 as permitted under this Stipulated Protective Order; and 8 // 9 (i) to any mediator or settlement officer, and their supporting 10 personnel, mutually agreed upon by any of the parties engaged in 11 settlement discussions. 12 7.3 The parties acknowledge that the Court authorized early 13 discovery, in part, to permit Plaintiffs to identify and substitute Doe 14 defendants. Accordingly, notwithstanding any other provision of this 15 Order, Plaintiffs may use officer-identifying information produced by the 16 California Highway Patrol—including officer names, badge numbers, 17 titles/ranks, agency affiliation, and the officers’ alleged roles in the 18 events at issue—to amend the complaint, substitute Doe defendants, 19 effect service, and prosecute this Action. The filing of such officer- 20 identifying information for those limited purposes shall not constitute a 21 22 violation of this Order and shall not waive confidentiality as to the 23 underlying documents or any other Protected Material. This provision 24 does not permit public disclosure of peace officer personnel records, 25 personal contact information, home addresses, dates of birth, family 26 information, medical or disciplinary information, confidential law- 27 enforcement techniques, criminal-investigation strategy, third-party 1 written agreement of the Designating Party or court order. 2 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 4 PRODUCED IN OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in 6 other litigation that compels disclosure of any information or items 7 designated in this Action as “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such 9 notification shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the 11 subpoena or order to issue in the other litigation that some or all of the 12 material covered by the subpoena or order is subject to this Protective 13 Order. Such notification shall include a copy of this Stipulated 14 Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to 16 be pursued by the Designating Party whose Protected Material may be 17 18 affected. 19 If the Designating Party timely seeks a protective order, the 20 Party served with the subpoena or court order shall not produce any 21 information designated in this action as “CONFIDENTIAL” before a 22 determination by the court from which the subpoena or order issued, 23 unless the Party has obtained the Designating Party’s permission. The 24 Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these 26 provisions should be construed as authorizing or encouraging a 27 Receiving Party in this Action to disobey a lawful directive from another 1 court. 2 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 9.1 Application. The terms of this Stipulated Protective Order 6 are applicable to information produced by a Non-Party in this Action and 7 designated as “CONFIDENTIAL.” Such information produced by Non- 8 Parties in connection with this litigation is protected by the remedies 9 and relief provided by this Order. Nothing in these provisions should be 10 construed as prohibiting a Non-Party from seeking additional 11 protections. 12 9.2 Notification. In the event that a Party is required, by a valid 13 discovery request, to produce a Non-Party’s confidential information in 14 its possession, and the Party is subject to an agreement with the Non- 15 Party not to produce the Non-Party’s confidential information, then the 16 Party shall: 17 (a) promptly notify in writing the Requesting Party and the 18 Non-Party that some or all of the information requested is subject to a 19 confidentiality agreement with a Non-Party; 20 21 (b) make the information requested available for inspection by 22 the Non-Party, if requested. 23 9.3 Conditions of Production. If the Non-Party fails to seek a 24 protective order from this court within 14 days of receiving the notice 25 and accompanying information, the Receiving Party may produce the 26 Non-Party’s confidential information responsive to the discovery request. 27 If the Non-Party timely seeks a protective order, the Receiving Party 1 subject to the confidentiality agreement with the Non-Party before a 2 determination by the court. Absent a court order to the contrary, the 3 Non-Party shall bear the burden and expense of seeking protection in 4 this court of its Protected Material. 5 6 7

8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 9 MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it 11 has disclosed Protected Material to any person or in any circumstance 12 not authorized under this Stipulated Protective Order, the Receiving 13 Party must immediately (a) notify in writing the Designating Party of 14 the unauthorized disclosures, (b) use its best efforts to retrieve all 15 16 unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of 18 this Order, and (d) request such person or persons to execute the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 20 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 22 OTHERWISE PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that 24 certain inadvertently produced material is subject to a claim of privilege 25 or other protection, the obligations of the Receiving Parties are those set 26 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 27 1 established in an e-discovery order that provides for production without 2 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 3 Rules of Evidence, insofar as the parties reach an agreement on the 4 effect of disclosure of a communication or information covered by the 5 attorney-client privilege or work product protection, the parties may 6 incorporate their agreement in the stipulated protective order 7 submitted to the court. 8 12. MISCELLANEOUS 9 12.1 Right to Further Relief. Nothing in this Stipulated 10 Protective Order abridges the right of any person to seek its 11 modification by the court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry 13 of this Stipulated Protective Order no Party waives any right it 14 otherwise would have to object to disclosing or producing any 15 information or item on any ground not addressed in this Stipulated 16 Protective Order. Similarly, no Party waives any right to object on any 17 18 ground to use in evidence of any of the material covered by this 19 Stipulated Protective Order. 20 12.3 Filing Protected Material. A Party that seeks to file under 21 seal any Protected Material must comply with Local Rule 79-5. 22 Protected Material may only be filed under seal pursuant to a court 23 order authorizing the sealing of the specific Protected Material at issue. 24 If a Party's request to file Protected Material under seal is denied by the 25 court, then the Receiving Party may file the information in the public 26 record unless otherwise instructed by the court. 27 1 13. FINAL DISPOSITION 2 After the Final Disposition of this Action, as defined in paragraph 3 4, within 60 days of a written request by the Designating Party, each 4 Receiving Party must return all Protected Material to the Producing 5 Party or destroy such material. As used in this subdivision, “all 6 Protected Material” includes all copies, abstracts, compilations, 7 summaries, and any other format reproducing or capturing any of the 8 Protected Material. Whether the Protected Material is returned or 9 destroyed, the Receiving Party must submit a written certification to 10 the Producing Party (and, if not the same person or entity, to the 11 Designating Party) by the 60 day deadline that (1) identifies (by 12 category, where appropriate) all the Protected Material that was 13 returned or destroyed and (2) affirms that the Receiving Party has not 14 retained any copies, abstracts, compilations, summaries or any other 15 format reproducing or capturing any of the Protected Material. 16 Notwithstanding this provision, Counsel is entitled to retain an archival 17 18 copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial 20 exhibits, expert reports, attorney work product, and consultant and 21 expert work product, even if such materials contain Protected Material. 22 Any such archival copies that contain or constitute Protected Material 23 remain subject to this Protective Order as set forth in Section 4. 24

25 26 27 1 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 by any and all appropriate measures including, without limitation, 4 contempt proceedings and/or monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 DATED: July 7, 2026 LAW OFFICE OF LOUIS P. DELL 8 /s/ Louis P. Dell 9 John-Louis H. Dell 10 Louis P. Dell Attorneys for Plaintiffs 11 VYACHESLAV FINOGEYEV and 12 NATALYA FINOGEYEVA 13

14 DATED: July 7, 2026 WOMBLE BOND DICKINSON (US) 15 LLP 16 /s/ Alisa A. Givental 17 Alisa A. Givental 18 Attorneys for Defendant MERCEDES-BENZ FINANCIAL 19 SERVICES USA LLC 20 21 22 DATED: July 7, 2026 SIDRAN LAW CORP.

23 /s/ David R. Sidran 24 David R. Sidran Thomas M. Crowell 25 Attorneys for Defendant 26 URT KEYSTONE, INC.

27 1 2 || DATED: July 7, 2026 ROB BONTA 3 Attorney General of California 4 /s/ Donna M. Dean 5 DONNA M. DEAN Supervising Deputy Attorney 6 General 7 Attorneys for Non-Party STATE OF CALIFORNIA, by and 8 through CALIFORNIA HIGHWAY 9 PATROL 10 1] □ □ Attestation of Signatures 12 I, Louis P. Dell, attest that all other signatories listed, and on 13 14 whose behalf the filing is submitted, concur in the filing’s content and

15 have authorized the filing. 16 /s/ Louis P. Dell Louis P. Dell 18 19 20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

22 33 DATED: July 7, 2026

54 DIANA M. Kwok United States Magistrate Judge 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the 8 case of __________ [insert formal name of the case and the 9 number and initials assigned to it by the court]. I agree to 10 comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so 12 comply could expose me to sanctions and punishment in the nature of 13 14 contempt. I solemnly promise that I will not disclose in any manner 15 any information or item that is subject to this Stipulated Protective 16 Order to any person or entity except in strict compliance with the 17 provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such 21 enforcement proceedings occur after termination of this action. I 22 hereby appoint ________________________ [print or type full name] 23 of _________ [print or type full address and telephone number] as 24 25 26 27 1 my California agent for service of process in connection with this action 2 or any proceedings related to enforcement of this Stipulated Protective 3 Order. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10

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