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WILSON TURNER KOSMO LLP
ELIZABETH C. REIN (297593)
402 West Broadway, Suite 1600 SUPERIO R
F I
LE D
San Diego, California 92101 cguw c9”?
AN BERNARDINO $5353"
3F.
Telephone: (619) 236-9600 Dssrmcr
Facsimile: (619) 236-9669
E-mail: erein@wilsontumerkosmo.com DEC 2 1 2022
E-mail: hondaeservice@wilsonturnerkosmo.com
BY
SANDRA PORTILLO, DEP UTY
Attorneys for Defendants
AMERICAN HONDA MOTOR CO., INC
(erroneously sued herein as a California
Corporation)
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
10 COUNTY 0F SAN BERNARDINO
11
12 RHONDA MCDOWELL, an individual, Case No. CIVSB221 1661
13 Plaintiffs, STIPULATION AND PROTECTIVE
ORDER — CONFIDENTIAL
14 v. DESIGNATION ONLY
15 AMERICAN HONDA MOTOR CO., INC., a Complaint Filed: June 9, 2022
California Corporation, and DOES through 10,
1
16 inclusive, Dept: S30
Judge: Hon. Brian S McCarville
17 Defendants. Trial Date: Not set ,o
$20
so—Zozz—‘laoa‘l
18
19 IT IS HEREBY STIPULATED by and between Plaintiff Rhonda McDowell (“Plaintiff") and
20 Defendant American Honda Motor Co., Inc. (“Defendant”), by and through their respective counsel
21 of record, that in order to facilitate the exchange of information and documents Which may be
22 subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights,
23 the Parties stipulate as follows:
24 1, In this Stipulation and Protective Order, the words set forth below shall have the
25 following meanings:
26 a. “Proceeding” means the above-entitled proceeding Case No. CIVSB221 1661.
27 b. “Court” means the Hon. Brian S. McCarVille, or any other judge to which this
28 Proceeding may be assigned, including Court staff participating in such proceedings.
1
STIPULATION AND PROTECTIVE ORDER — CONFIDENTIAL DESIGNATION ONLY
c. “Confidential” means any information which is in the possession of a Designating
Party Who believes in good faith that such information is entitled to confidential treatment under
applicable law.
d. “Confidential Materials” means any Documents, Testimony or Information as defined
below designated as “Confidential” pursuant to the provisions of this Stipulation and Protective
Order.
OO\IO\
e. “Designating Party” means the Party that designates Materials as “Confidential.”
f. “Disclose” or “Disclosed” 0r “Disclosure” means to reveal, divulge, give, or make
KO available Materials, or any part thereof, or any information contained therein.
10 g. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those terms are
11 defined by California Evidence Code Sections 250, 255, and 260, which have been produced in
12 discovery in this Proceeding by any person, and (ii) any copies, reproductions, or summaries of all or
13 any part of the foregoing.
14 h. “Information” means the content of Documents or Testimony.
15 i. “Testimony” means all depositions, declarations 0r other testimony taken or used in
16 this Proceeding.
17 2. The Designating Party shall have the right to designate as “Confidential” any
18 Documents, Testimony or Information that the Designating Patty in good faith believes to contain
19 non-public information that is entitled to confidential treatment under applicable law.
20 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or
21 abridge any right, privilege or protection otherwise available to any Party with respect to the
22 discovery of matters, including but not limited to any Party’s right to assert the attorney-client
23 privilege, the attorney work product doctrine, or other privileges, or any Party’s right to contest any
24 such assertion.
25 4. Any Documents, Testimony or Information to be designated as “Confidential” must
26 be clearly so designated before the Document, Testimony or Information is Disclosed 0r produced.
27 The parties may agree that the case name and number are t0 be part of the “Confidential”
28
2
STIPULATION AND PROTECTIVE ORDER — CONFIDENTIAL DESIGNATION ONLY
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WILSON TURNER KOSMO LLP ELIZABETH C. REIN (297593) 402 West Broadway, Suite 1600 SUPERIO R F I LE D San Diego, California 92101 cguw c9”? AN BERNARDINO $5353" 3F. Telephone: (619) 236-9600 Dssrmcr Facsimile: (619) 236-9669 E-mail: erein@wilsontumerkosmo.com DEC 2 1 2022 E-mail: hondaeservice@wilsonturnerkosmo.com BY SANDRA PORTILLO, DEP UTY Attorneys for Defendants AMERICAN HONDA MOTOR CO., INC (erroneously sued herein as a California Corporation) SUPERIOR COURT OF THE STATE 0F CALIFORNIA 10 COUNTY 0F SAN BERNARDINO 11 12 RHONDA MCDOWELL, an individual, Case No. CIVSB221 1661 13 Plaintiffs, STIPULATION AND PROTECTIVE ORDER — CONFIDENTIAL 14 v. DESIGNATION ONLY 15 AMERICAN HONDA MOTOR CO., INC., a Complaint Filed: June 9, 2022 California Corporation, and DOES through 10, 1 16 inclusive, Dept: S30 Judge: Hon. Brian S McCarville 17 Defendants. Trial Date: Not set ,o $20 so—Zozz—‘laoa‘l 18 19 IT IS HEREBY STIPULATED by and between Plaintiff Rhonda McDowell (“Plaintiff") and 20 Defendant American Honda Motor Co., Inc. (“Defendant”), by and through their respective counsel 21 of record, that in order to facilitate the exchange of information and documents Which may be 22 subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, 23 the Parties stipulate as follows: 24 1, In this Stipulation and Protective Order, the words set forth below shall have the 25 following meanings: 26 a. “Proceeding” means the above-entitled proceeding Case No. CIVSB221 1661. 27 b. “Court” means the Hon. Brian S. McCarVille, or any other judge to which this 28 Proceeding may be assigned, including Court staff participating in such proceedings. 1 STIPULATION AND PROTECTIVE ORDER — CONFIDENTIAL DESIGNATION ONLY c. “Confidential” means any information which is in the possession of a Designating Party Who believes in good faith that such information is entitled to confidential treatment under applicable law. d. “Confidential Materials” means any Documents, Testimony or Information as defined below designated as “Confidential” pursuant to the provisions of this Stipulation and Protective Order. OO\IO\ e. “Designating Party” means the Party that designates Materials as “Confidential.” f. “Disclose” or “Disclosed” 0r “Disclosure” means to reveal, divulge, give, or make KO available Materials, or any part thereof, or any information contained therein. 10 g. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those terms are 11 defined by California Evidence Code Sections 250, 255, and 260, which have been produced in 12 discovery in this Proceeding by any person, and (ii) any copies, reproductions, or summaries of all or 13 any part of the foregoing. 14 h. “Information” means the content of Documents or Testimony. 15 i. “Testimony” means all depositions, declarations 0r other testimony taken or used in 16 this Proceeding. 17 2. The Designating Party shall have the right to designate as “Confidential” any 18 Documents, Testimony or Information that the Designating Patty in good faith believes to contain 19 non-public information that is entitled to confidential treatment under applicable law. 20 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or 21 abridge any right, privilege or protection otherwise available to any Party with respect to the 22 discovery of matters, including but not limited to any Party’s right to assert the attorney-client 23 privilege, the attorney work product doctrine, or other privileges, or any Party’s right to contest any 24 such assertion. 25 4. Any Documents, Testimony or Information to be designated as “Confidential” must 26 be clearly so designated before the Document, Testimony or Information is Disclosed 0r produced. 27 The parties may agree that the case name and number are t0 be part of the “Confidential” 28 2 STIPULATION AND PROTECTIVE ORDER — CONFIDENTIAL DESIGNATION ONLY