On January 03, 2022 a
Stipulation,Agreement
was filed
involving a dispute between
Mcclain, Ryan,
and
Does 1 To 10,
Kia America, Inc.,
for Other Contract Unlimited
in the District Court of San Bernardino County.
Preview
SJL LAW LLP ~
WON? rt
.1
Julian G. Senior (SBN; 219093) Wfigppfisghoi L;
\
Jonathan Sniderman (SBN: 327718) Wfimxfigffu ¥
841 Apollo Street, Suite 300 "003%?
JU/ "
EISe undo, CA 90245 ‘
f 0r
Tel. 424.290.0720
o.: W 6.
3022
Fax No.: 424.290.0721 j\ gr
(OWNGUIAOJNA
Attorneys for Defendant KIA AMERICA, INC. ”047274;;R
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
COUNTY OF SAN BERNARDINO
RYAN MCCLAIN, CASE No.: CIVSBZ135259
Plaintiff, Assigned to: Hon. Wilfred J. Schneider, Jr.
Department: 832
v.
STIPULATION AND PROTECTIVE
KIA AMERICA, ma; and DOES 1 to ORDER
1o.
Action Filed: January 3, 2022
Defendants. Trial: None
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IT IS HEREBY STIPULATED by and between the Parties to Ryan McClain v. Kia
America, Ina, plaintiff Ryan McClain and defendant Kia America, lnc., by and through
their respective counsel of record, that in order to facilitate the exchange of information
and documents which may be subject to confidentiality limitations on disclosure due to
federal laws, state laws, and privacy rights, the Parties stipulate as follows:
1. In this Stipulation and Protective Order, the words set forth below shall
fie
have the following meanings:
a. “Proceeding" means the above-entitled proceeding (Ryan McClain xea
v. Kia America, Inc., San Bernardino Superior Court case no. CIVSBZ1 35259).
b. “Court" means the Hon. Wilfred J. Schneider. Jr., or any otherjudge
- 1 -
STIPULATION AND PROTECTIVE ORDER
910/300- xva 60=v1 mm zzoz/GI/So
1 to which this Proceeding may be assigned,_ including Court staff participating in
2 such proceedings.
3 c. “Confidential" means any information which is in the possession of
4 a Designating Party who believes in good faith that such information is entitled to
5 confidential treatment under applicable law.
6 d. "Confidential Materials” means any Documents, Testimony or
7 Information as defined below designated as “Confidential" pursuant to the
8 provisions of this Stipulation and Protective Order.
9 e. "Designating Party" means the Party that designates Materials as
10 "Confidential."
11 f. "Disclose" or “Disclosed” or "Disclosure" means to reveal, divulge,
12 give, or make available Materials, or any part thereof, or any information
13 contained therein.
14 g. “Documents" means (i) any “Writing,” “Original,” and “Duplicate" as
15 those terms are defined by California Evidence Code Sections 250, 255, and
16 260, which have been produced in discovery in this Proceeding by any person,
17 and (ii) any copies, reproductions, or summaries of all or any part of the
'
18 foregoing.
19 h. "lnfomation” means the content of Documents or Testimony.
20 i. “Testimony” means all depositions, declarations or other testimony
21 ,
taken or used in this Proceeding.
22 2. The Designating Party shall have the right to designate as “Confidential"
23 any Documents, Testimony or Information that the Designating Party in good faith
24 believes to contain non-public information that is entitled to confidential treatment under
25 applicable law.
25 3. The entry of this Stipuiation and Protective Order does not alter, waive,
27 modify. or abridge any right, privilege or protection otherwise available to any Party with
28 respect to the discovery of matters, including but not limited to any Party's right to assert
.
- 2 -
STIPULATION AND PROTECTIVE ORDER
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Document Filed Date
July 26, 2022
Case Filing Date
January 03, 2022
Category
Other Contract Unlimited
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SJL LAW LLP ~ WON? rt .1 Julian G. Senior (SBN; 219093) Wfigppfisghoi L; \ Jonathan Sniderman (SBN: 327718) Wfimxfigffu ¥ 841 Apollo Street, Suite 300 "003%? JU/ " EISe undo, CA 90245 ‘ f 0r Tel. 424.290.0720 o.: W 6. 3022 Fax No.: 424.290.0721 j\ gr (OWNGUIAOJNA Attorneys for Defendant KIA AMERICA, INC. ”047274;;R SUPERIOR COURT OF THE STATE 0F CALIFORNIA COUNTY OF SAN BERNARDINO RYAN MCCLAIN, CASE No.: CIVSBZ135259 Plaintiff, Assigned to: Hon. Wilfred J. Schneider, Jr. Department: 832 v. STIPULATION AND PROTECTIVE KIA AMERICA, ma; and DOES 1 to ORDER 1o. Action Filed: January 3, 2022 Defendants. Trial: None gflmthNdOOm-dmm#mN—IO NNNNNMNN44444AA444 IT IS HEREBY STIPULATED by and between the Parties to Ryan McClain v. Kia America, Ina, plaintiff Ryan McClain and defendant Kia America, lnc., by and through their respective counsel of record, that in order to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, the Parties stipulate as follows: 1. In this Stipulation and Protective Order, the words set forth below shall fie have the following meanings: a. “Proceeding" means the above-entitled proceeding (Ryan McClain xea v. Kia America, Inc., San Bernardino Superior Court case no. CIVSBZ1 35259). b. “Court" means the Hon. Wilfred J. Schneider. Jr., or any otherjudge - 1 - STIPULATION AND PROTECTIVE ORDER 910/300- xva 60=v1 mm zzoz/GI/So 1 to which this Proceeding may be assigned,_ including Court staff participating in 2 such proceedings. 3 c. “Confidential" means any information which is in the possession of 4 a Designating Party who believes in good faith that such information is entitled to 5 confidential treatment under applicable law. 6 d. "Confidential Materials” means any Documents, Testimony or 7 Information as defined below designated as “Confidential" pursuant to the 8 provisions of this Stipulation and Protective Order. 9 e. "Designating Party" means the Party that designates Materials as 10 "Confidential." 11 f. "Disclose" or “Disclosed” or "Disclosure" means to reveal, divulge, 12 give, or make available Materials, or any part thereof, or any information 13 contained therein. 14 g. “Documents" means (i) any “Writing,” “Original,” and “Duplicate" as 15 those terms are defined by California Evidence Code Sections 250, 255, and 16 260, which have been produced in discovery in this Proceeding by any person, 17 and (ii) any copies, reproductions, or summaries of all or any part of the ' 18 foregoing. 19 h. "lnfomation” means the content of Documents or Testimony. 20 i. “Testimony” means all depositions, declarations or other testimony 21 , taken or used in this Proceeding. 22 2. The Designating Party shall have the right to designate as “Confidential" 23 any Documents, Testimony or Information that the Designating Party in good faith 24 believes to contain non-public information that is entitled to confidential treatment under 25 applicable law. 25 3. The entry of this Stipuiation and Protective Order does not alter, waive, 27 modify. or abridge any right, privilege or protection otherwise available to any Party with 28 respect to the discovery of matters, including but not limited to any Party's right to assert . - 2 - STIPULATION AND PROTECTIVE ORDER QIO/Eool V .. u... v . y.-." . . . V .. ._._.- xva .. . . 60m mm . V”. ‘ ‘...-._. ...._.-_._...—..r.._.__—u. zzoz/sm/so