Preview
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F4656 7/5/23
Robert C. Hsu,SBN 225437
LEXINT LAW GROUP, APLC
13300 Crossroads Pkwyg #100 3%?)EURACTJ5 gggfikggRNlA
89%;;
gétlégggggusé12%)c;869—17Z)SS SAN BERNARDnNo DISTRIgO
FaCSlmIIEI 62) 999-3321
( FEB 0 6 2023
Attorneys for Defendants,
HONG GUANG LIU, MARCO POLO INT’L TRADING, INC. 5;»
KW TRANSPORT, INC. and NEWLTNE SUPER EXPRESS, IN EY .
ASHLB DAWSON DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN FOR THE COUNTY 0F SAN BERNARDINO
BY FAX
BRYAN ZHAO, an individual; Case N.: CIVSB2126552
[Assigned t0 Honorable Janet M Frangie in
Plaintiff, Department S29]
v. STIPULATED PROTECTIVE ORDER
HONG GUANG LIU, an individual;
WINWAY LOGISTICS, LLC, a California Complaint Filed September 20, 2021
limited liability company; EASY WAY ‘
LOGISTICS, INC., a California corporation;
MARCO POLO INT’L TRADING, INC, a
California comoration; KW TRANSPORT,
INC, a Califomia corporation; NEWLINE
SUPER EXPRESS, INC, a California
corporation; and DOES I through 100,
inclusive,
Defendants.
TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF
RECORD:
IT IS HEREBY STIPULATED by and between the parties BRYAN ZHAO (the
“Plaintiff? and Defendants HONG GUANG LIU, an individual; MARCO POLO INT’L
TRADING, INC., a California corporation, KW TRANSPORT, INC, a California comoration and
NEWLINE SUPER EXPRESS, INC, a California corporation (collectively “Defendants”)
-1 _
STIPULATED PROTECTIVE ORDER
(Plaintiff and Defendants are collectively referred t0 as the “Pa1‘ties”), by and through their
exchange of infonnation and documents
respective counsel of record, that in order t0 facilitate the
to confidentiality limitations on disclosure due t0 federal laws, state laws,
which may be subject
and privacy rights, the Parties stipulate as follows:
words set forth below shall have the
1. In this Stipulation and Protective Order, the
following meanings:
a. “Proceeding” means the above-cntitled action (Bryan Zhao v. Hang Guang
Liu, er 02., San Bernardino County Superior Coult Case N0. CIVSB2I26552).
b. “Court” means the honorable judge to which this Proceeding may be
10
11
assigned, including Court staff paflicipating in such proceedings.
c. “Confidential” means any Documents, Testimony, 01‘ Information which is
12
in the possession of a Designating Party who believes in good faith that such Documents,
13
Testimony, 01‘ Information is entitled t0 confidential treatment under applicable law.
14
d. “Confidential Materials” means any Documents, Testimony, 01‘ Information
15
as defined below designated as “Confidential” pursuant to the provisions of this Stipulation and
16
Protective Order.
17
e. “Highly Confidential” means any infomlation which belongs to a
18
Designating Party who believes in good faith that the Disclosure of such information to another
19
Palty 01' non—Peuty would create a substantial risk of serious financial 0r other injmy that cannot be
20
avoided by less restrictive means.
21 f. “Highly Confidential Materials” means any Documents, Testimony, 01'
22 Information, as defined below, designated as “Highly Confidential” pursuant to the provisions of
23 this Stipulation and Protective Order.
24 g. “Designating Party” means the Party that designates Documents,
25 Testimony, 01' Information, as defined below, as “Confidential” or “Highly Confidential.”
h. “Disclose” or “Disclosed” or “Disclosure” means t0 reveal, divulge, give, or
26
make available Materials, 01' any pan thereof, or any information contained therein.
27
i. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those
28
-2-
STIPULATED PROTECTIVE ORDER
Preview
Ofiynflk . F4656 7/5/23 Robert C. Hsu,SBN 225437 LEXINT LAW GROUP, APLC 13300 Crossroads Pkwyg #100 3%?)EURACTJ5 gggfikggRNlA 89%;; gétlégggggusé12%)c;869—17Z)SS SAN BERNARDnNo DISTRIgO FaCSlmIIEI 62) 999-3321 ( FEB 0 6 2023 Attorneys for Defendants, HONG GUANG LIU, MARCO POLO INT’L TRADING, INC. 5;» KW TRANSPORT, INC. and NEWLTNE SUPER EXPRESS, IN EY . ASHLB DAWSON DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA IN FOR THE COUNTY 0F SAN BERNARDINO BY FAX BRYAN ZHAO, an individual; Case N.: CIVSB2126552 [Assigned t0 Honorable Janet M Frangie in Plaintiff, Department S29] v. STIPULATED PROTECTIVE ORDER HONG GUANG LIU, an individual; WINWAY LOGISTICS, LLC, a California Complaint Filed September 20, 2021 limited liability company; EASY WAY ‘ LOGISTICS, INC., a California corporation; MARCO POLO INT’L TRADING, INC, a California comoration; KW TRANSPORT, INC, a Califomia corporation; NEWLINE SUPER EXPRESS, INC, a California corporation; and DOES I through 100, inclusive, Defendants. TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: IT IS HEREBY STIPULATED by and between the parties BRYAN ZHAO (the “Plaintiff? and Defendants HONG GUANG LIU, an individual; MARCO POLO INT’L TRADING, INC., a California corporation, KW TRANSPORT, INC, a California comoration and NEWLINE SUPER EXPRESS, INC, a California corporation (collectively “Defendants”) -1 _ STIPULATED PROTECTIVE ORDER (Plaintiff and Defendants are collectively referred t0 as the “Pa1‘ties”), by and through their exchange of infonnation and documents respective counsel of record, that in order t0 facilitate the to confidentiality limitations on disclosure due t0 federal laws, state laws, which may be subject and privacy rights, the Parties stipulate as follows: words set forth below shall have the 1. In this Stipulation and Protective Order, the following meanings: a. “Proceeding” means the above-cntitled action (Bryan Zhao v. Hang Guang Liu, er 02., San Bernardino County Superior Coult Case N0. CIVSB2I26552). b. “Court” means the honorable judge to which this Proceeding may be 10 11 assigned, including Court staff paflicipating in such proceedings. c. “Confidential” means any Documents, Testimony, 01‘ Information which is 12 in the possession of a Designating Party who believes in good faith that such Documents, 13 Testimony, 01‘ Information is entitled t0 confidential treatment under applicable law. 14 d. “Confidential Materials” means any Documents, Testimony, 01‘ Information 15 as defined below designated as “Confidential” pursuant to the provisions of this Stipulation and 16 Protective Order. 17 e. “Highly Confidential” means any infomlation which belongs to a 18 Designating Party who believes in good faith that the Disclosure of such information to another 19 Palty 01' non—Peuty would create a substantial risk of serious financial 0r other injmy that cannot be 20 avoided by less restrictive means. 21 f. “Highly Confidential Materials” means any Documents, Testimony, 01' 22 Information, as defined below, designated as “Highly Confidential” pursuant to the provisions of 23 this Stipulation and Protective Order. 24 g. “Designating Party” means the Party that designates Documents, 25 Testimony, 01' Information, as defined below, as “Confidential” or “Highly Confidential.” h. “Disclose” or “Disclosed” or “Disclosure” means t0 reveal, divulge, give, or 26 make available Materials, 01' any pan thereof, or any information contained therein. 27 i. “Documents” means (i) any “Writing,” “Original,” and “Duplicate” as those 28 -2- STIPULATED PROTECTIVE ORDER