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NELSON MULLINS RILEY &
SCARBOROUGH LLP
Michael J. HurVitz (SBN 249050)
mike.hurvitz@nelsonmullins.com 34,.)
BE ‘
é‘l’mzfifi
Ian G. Schuler (SBN 275052) ”nvwrmn
"‘
EjgrmmhoyRIv/A
""V/L
DIVIa’yON
UI-bUJN
ian.schuler@nelsonmullins.com '
,
Ariel N. Redfern (SBN 34 1 3 14)
ariel.redfern@nelsonmullins.com 8,,
'
750 B Street, Suite 2200
San Diego, CA 92101
Telephone: 619.489.61 10
Facsimile: 619.821.2834
\DOOQON Attorneys for Defendant
AMERICAN HONDA MOTOR CO., INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
LLP
10 COUNTY OF SAN BERNARDINO
11 EDUARDO ESPINOSA and CELIA Case No.: CIVSB2207097
SCARBOROUGH
ESPINOSA,
LAW
v—i
N STIPULATED RROBOS-ED PROTECTIVE
8c
AT
DIEGO Plaintiff, ORDER; EXHIBIT "A"
b.)
r—I
vs.
JUDGE: Hon. Winston Keh
RILEY
ATTORNEYS
SAN
r—‘
h AMERICAN HONDA MOTOR C0., INC. DEPT: S33
MULLINS
a California corporation, and DOES 1 ,
Tnal Date: Not Yet Set
h 0'
'
r—l UI
”oug
h ’mc “Slve’
1 1
Action Filed: Apri16,2022
NELSON
r—t Ox Defendant.
r—d
q
v-d 00 IT IS HEREBY STIPULATED by and between the Parties to Eduardo Espinosa and Celia
Espinosa v. American Honda Motor C0., Ina, by and through their respective counsel of record, that
H \D
in order to facilitate the exchange of information and documents Which may be subject t0
NO
the Parties
N r—I confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights,
NN stipulate as follows:
1. In this Stipulation and Protective Order, the words set forth below shall have the
N b)
NA following meanings:
a. "Proceeding" means the above-entitled proceeding CIVSB2207097.
N U1
b. "Court" means the Hon. Winston Keh 0r any other judge to Which this
N Ox
Proceeding may be assigned, including Court staff participating in such
Nfl
proceedings.
N 00
1
STIPULATED WPROTECTIVE ORDER; EXHIBIT “A”
V ' ‘
V
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
\DOOQONUlhbJN
Stipulation and Protective Order.
e. "Designating Party" means the Party that designates Materials as
"Confidential."
f. "Disclose" or "Disclosed" or "Disclosure" means t0 reveal, divulge, give, 0r
LLP
10 make available Materials, or any part thereof, or any information contained
11 therein.
SCARBOROUGH
"Documents" means any "Writing," "Original," and "Duplicate" as those
LAW
p—n
N g. (i)
AT
8t DIEGO
RILEY H DJ terms are defined by California Evidence Code Sections 250, 255, and 260,
ATTORNEYS
SAN
MULLINS
y—A
.b Which have been produced in discovery in this Proceeding by any person, and
b—d LI]
(ii) any copies, reproductions, or summaries of all or any part ofthe foregoing.
NELSON
b—l
a h. "Information" means the content of Documents or Testimony.
H
\l i. "Testimony" means all depositions, declarations or other testimony taken or
H m used in this Proceeding.
F—‘
\o 2. The Designating Party shall have the right to designate as "Confidential" any
NO Documents, Testimony or Information that the Designating Party in good faith believes to contain
NH non-public information that is entitled to confidential treatment under applicable law.
NN 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or
N U3 abridge any right, privilege or protection otherwise available t0 any Party with respect to the
NA discovery of matters, including but not limited to any Party’s right to assert the attorney-client
N LII
privilege, the attorney work product doctrine, or other privileges, or any Party's right to contest any
NQ such assertion.
NQ 4. Any Documents, Testimony or Information to be designated as "Confidential" must
be clearly so designated before the Document, Testimony or Information Disclosed or produced.
m
Nm is
2
STIPULATED PROTECTIVE ORDER; EXHIBIT “A”
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NELSON MULLINS RILEY & SCARBOROUGH LLP Michael J. HurVitz (SBN 249050) mike.hurvitz@nelsonmullins.com 34,.) BE ‘ é‘l’mzfifi Ian G. Schuler (SBN 275052) ”nvwrmn "‘ EjgrmmhoyRIv/A ""V/L DIVIa’yON UI-bUJN ian.schuler@nelsonmullins.com ' , Ariel N. Redfern (SBN 34 1 3 14) ariel.redfern@nelsonmullins.com 8,, ' 750 B Street, Suite 2200 San Diego, CA 92101 Telephone: 619.489.61 10 Facsimile: 619.821.2834 \DOOQON Attorneys for Defendant AMERICAN HONDA MOTOR CO., INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA LLP 10 COUNTY OF SAN BERNARDINO 11 EDUARDO ESPINOSA and CELIA Case No.: CIVSB2207097 SCARBOROUGH ESPINOSA, LAW v—i N STIPULATED RROBOS-ED PROTECTIVE 8c AT DIEGO Plaintiff, ORDER; EXHIBIT "A" b.) r—I vs. JUDGE: Hon. Winston Keh RILEY ATTORNEYS SAN r—‘ h AMERICAN HONDA MOTOR C0., INC. DEPT: S33 MULLINS a California corporation, and DOES 1 , Tnal Date: Not Yet Set h 0' ' r—l UI ”oug h ’mc “Slve’ 1 1 Action Filed: Apri16,2022 NELSON r—t Ox Defendant. r—d q v-d 00 IT IS HEREBY STIPULATED by and between the Parties to Eduardo Espinosa and Celia Espinosa v. American Honda Motor C0., Ina, by and through their respective counsel of record, that H \D in order to facilitate the exchange of information and documents Which may be subject t0 NO the Parties N r—I confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, NN stipulate as follows: 1. In this Stipulation and Protective Order, the words set forth below shall have the N b) NA following meanings: a. "Proceeding" means the above-entitled proceeding CIVSB2207097. N U1 b. "Court" means the Hon. Winston Keh 0r any other judge to Which this N Ox Proceeding may be assigned, including Court staff participating in such Nfl proceedings. N 00 1 STIPULATED WPROTECTIVE ORDER; EXHIBIT “A” V ' ‘ V 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 \DOOQONUlhbJN Stipulation and Protective Order. e. "Designating Party" means the Party that designates Materials as "Confidential." f. "Disclose" or "Disclosed" or "Disclosure" means t0 reveal, divulge, give, 0r LLP 10 make available Materials, or any part thereof, or any information contained 11 therein. SCARBOROUGH "Documents" means any "Writing," "Original," and "Duplicate" as those LAW p—n N g. (i) AT 8t DIEGO RILEY H DJ terms are defined by California Evidence Code Sections 250, 255, and 260, ATTORNEYS SAN MULLINS y—A .b Which have been produced in discovery in this Proceeding by any person, and b—d LI] (ii) any copies, reproductions, or summaries of all or any part ofthe foregoing. NELSON b—l a h. "Information" means the content of Documents or Testimony. H \l i. "Testimony" means all depositions, declarations or other testimony taken or H m used in this Proceeding. F—‘ \o 2. The Designating Party shall have the right to designate as "Confidential" any NO Documents, Testimony or Information that the Designating Party in good faith believes to contain NH non-public information that is entitled to confidential treatment under applicable law. NN 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or N U3 abridge any right, privilege or protection otherwise available t0 any Party with respect to the NA discovery of matters, including but not limited to any Party’s right to assert the attorney-client N LII privilege, the attorney work product doctrine, or other privileges, or any Party's right to contest any NQ such assertion. NQ 4. Any Documents, Testimony or Information to be designated as "Confidential" must be clearly so designated before the Document, Testimony or Information Disclosed or produced. m Nm is 2 STIPULATED PROTECTIVE ORDER; EXHIBIT “A”