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San Francisco, CA 94104 

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STIPULATED PROTECTIVE ORDER - 2 - 

other official committee has been appointed in the Debtor’s bankruptcy case.

4. The United States Bankruptcy Court for the Northern District of California (the 

“Court”) has jurisdiction over the Case.

5. The Debtor and the Committee intend for this Order to govern the production of 

documents and information between the Parties, including with respect to the Committee’s 

pending ex parte application for the examination of and production of documents by the Debtor 

pursuant to Federal Rule of Bankruptcy Procedure 2004. 

AGREEMENT 

Based on the foregoing recitals, the Parties agree as follows:

1. PURPOSES AND LIMITATIONS 

Disclosure and discovery activity in this Case are likely to involve production of 

confidential, proprietary, or private information for which special protection from public disclosure 

and from use for any purpose other than this Case may be warranted. Accordingly, the Parties 

hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The 

Parties acknowledge that this Order does not confer blanket protections on all disclosures or 

responses to discovery and that the protection it affords from public disclosure and use extends only 

to the limited information or items that are entitled to confidential treatment under the applicable 

legal principles. The Parties further acknowledge, as set forth in Section 12.3, below, that this Order 

does not entitle them to file confidential information under seal; Civil Local Rule 79-5 (applicable 

pursuant to Bankruptcy Local Rule 1001-2(a)) sets forth the procedures that must be followed and 

the standards that will be applied when a Party seeks permission from the Court to file material 

under seal. 

2. DEFINITIONS 

2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or 

items under this Order. 

2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 

generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 

Civil Procedure 26(c) or Federal Rule of Bankruptcy Procedure 9018. 

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2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well 

as their support staff). 

2.4 Designating Party: a Party or Non-Party that designates information or items that it 

produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 

2.5 Disclosure or Discovery Material: all items or information, regardless of the 

medium or manner in which it is generated, stored, or maintained (including, among other things, 

testimony, transcripts, and tangible things), that are produced or generated in disclosures or 

responses to discovery in this matter. 

2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to 

this Case who has been retained by a Party or its counsel to serve as an expert witness or as a 

consultant in this Case. 

2.7 House Counsel: attorneys who are employees of a Party in this Case. House Counsel 

does not include Outside Counsel of Record or any other outside counsel. 

2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 

entity not named as a Party in this Case. 

2.9 Outside Counsel of Record: attorneys who are not employees of a Party in this Case 

but are retained to represent or advise a Party in this Case and have appeared in this Case on behalf 

of that Party or are affiliated with a law firm which has appeared on behalf of that Party. 

2.10 Party: any Party in this Case, including all of its officers, directors, employees, 

members, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 

2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 

Material in this Case. 

2.12 Professional Vendors: persons or entities that provide litigation support services 

(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 

storing, or retrieving data in any form or medium) and their employees and subcontractors. 

2.13 Protected Material: any Disclosure or Discovery Material that is designated as 

“CONFIDENTIAL.” 

2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 

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Producing Party. 

3. SCOPE 

The protections conferred by this Stipulation and Order cover not only Protected Material 

(as defined above), but also (1) any information copied or extracted from Protected Material; (2) all 

copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 

conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 

However, the protections conferred by this Stipulation and Order do not cover the following 

information: (a) any information that is in the public domain at the time of disclosure to a Receiving 

Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 

publication not involving a violation of this Order, including becoming part of the public record 

through trial or otherwise; and (b) any information known to the Receiving Party prior to the 

disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 

information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 

Protected Material at trial or hearing shall be governed by a separate agreement or order. 

4. DURATION 

Even after final disposition of this Case, the confidentiality obligations imposed by this 

Order shall remain in effect until a Designating Party agrees otherwise in writing or a Court order 

otherwise directs. Final disposition shall be deemed to be the later of (1) conversion or dismissal of 

this Case; and (2) the closing of this Case. 

5. DESIGNATING PROTECTED MATERIAL 

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 

Non-Party that designates information or items for protection under this Order must take care to 

limit any such designation to specific material that qualifies under the appropriate standards. The 

Designating Party must designate for protection only those parts of material, documents, items, or 

oral or written communications that qualify – so that other portions of the material, documents, 

items, or communications for which protection is not warranted are not swept unjustifiably within 

the ambit of this Order. 

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Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 

to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 

encumber or retard the case development process or to impose unnecessary expenses and burdens 

on other parties) expose the Designating Party to sanctions. 

If it comes to a Designating Party’s attention that information or items that it designated for 

protection do not qualify for protection, that Designating Party must promptly notify all other 

Parties that it is withdrawing the mistaken designation. 

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 

(see, e.g., Section 2.13 above and second paragraph of section 5.2(a) below), or as otherwise 

stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under this Order 

must be clearly so designated before the material is disclosed or produced. 

Designation in conformity with this Order requires: 

(a) for information in documentary form (e.g., paper or electronic documents, but 

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 

affix the legend “CONFIDENTIAL” to the first page (if applicable to the entire document) or to the 

particular pages that contains protected material. If only a portion or portions of the material on a 

page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) 

(e.g., by making appropriate markings in the margins). 

A Party or Non-Party that makes original documents or materials available for inspection need not 

designate them for protection until after the inspecting Party has indicated which material it would 

like copied and produced. During the inspection and before the designation, all of the material made 

available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 

identified the documents it wants copied and produced, the Producing Party must determine which 

documents, or portions thereof, qualify for protection under this Order. Then, before producing the 

specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 

that contains Protected Material. If only a portion or portions of the material on a page qualifies for 

protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 

appropriate markings in the margins). 

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(b) for testimony given in deposition or in other pretrial or trial proceedings, that the 

Designating Party identify on the record, before the close of the deposition, hearing, or other 

proceeding, all protected testimony. 

(c) for information produced in some form other than documentary and for any other 

tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 

containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 

portion or portions of the information or item warrant protection, the Producing Party, to the extent 

practicable, shall identify the protected portion(s). 

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 

designate qualified information or items does not, standing alone, waive the Designating Party’s 

right to secure protection under this Order for such material. Upon timely correction of a 

designation, the Receiving Party must make reasonable efforts to assure that the material is treated 

in accordance with the provisions of this Order. 

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 

6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 

confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 

designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 

burdens, or a significant disruption or delay of the Case, a Party does not waive its right to 

challenge a confidentiality designation by electing not to mount a challenge promptly after the 

original designation is disclosed. 

6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 

by providing written notice of each designation it is challenging and describing the basis for each 

challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 

recite that the challenge to confidentiality is being made in accordance with this specific paragraph 

of this Order. The Parties shall attempt to resolve each challenge in good faith and must begin the 

process by conferring directly (in voice to voice dialogue; other forms of communication are not 

sufficient) within 14 days of the date of service of notice. In conferring, the Challenging Party must 

explain the basis for its belief that the confidentiality designation was not proper and must give the 

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Designating Party an opportunity to review the designated material, to reconsider the circumstances, 

and, if no change in designation is offered, to explain the basis for the chosen designation. A 

Challenging Party may proceed to the next stage of the challenge process only if it has engaged in 

this meet and confer process first or establishes that the Designating Party is unwilling to participate 

in the meet and confer process in a timely manner. 

6.3 Judicial Intervention. If the Parties cannot resolve a challenge without Court 

intervention, the Designating Party shall file and serve a motion to retain confidentiality under 

Bankruptcy Local Rules 9013 and 9014 (and in compliance with Civil Local Rule 79-5, if 

applicable) within 21 days of the initial notice of challenge or within 14 days of the Parties agreeing 

that the meet and confer process will not resolve their dispute, whichever is earlier. Each such 

motion must be accompanied by a competent declaration affirming that the movant has complied 

with the meet and confer requirements imposed in the preceding paragraph. Failure by the 

Designating Party to make such a motion including the required declaration within 21 days (or 14 

days, if applicable) shall automatically waive the confidentiality designation for each challenged 

designation. In addition, the Challenging Party may file a motion challenging a confidentiality 

designation at any time if there is good cause for doing so, including a challenge to the designation 

of a deposition transcript or any portions thereof. Any motion brought pursuant to this provision 

must be accompanied by a competent declaration affirming that the movant has complied with the 

meet and confer requirements imposed by the preceding paragraph. 

The burden of persuasion in any such challenge proceeding shall be on the Designating 

Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 

unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. 

Unless the Designating Party has waived the confidentiality designation by failing to file a motion 

to retain confidentiality as described above, all Parties shall continue to afford the material in 

question the level of protection to which it is entitled under the Producing Party’s designation until 

the Court rules on the challenge. 

7. ACCESS TO AND USE OF PROTECTED MATERIAL 

7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 

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produced by another Party or by a Non-Party in connection with this case only in connection with 

this Case. Such Protected Material may be disclosed only to the categories of persons and under the 

conditions described in this Order. When the Case has been terminated, a Receiving Party must 

comply with the provisions of section 13 below (FINAL DISPOSITION). 

Protected Material must be stored and maintained by a Receiving Party at a location and in a 

secure manner that ensures that access is limited to the persons authorized under this Order. 

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 

by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any 

information or item designated “CONFIDENTIAL” only to: 

(a) the Receiving Party’s Outside Counsel of Record in this Case, as well as employees 

of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information 

for this Case and who have signed the “Acknowledgment and Agreement to Be Bound” that is 

attached hereto as Exhibit A; 

(b) the officers, directors, members and employees (including House Counsel) of the 

Receiving Party to whom disclosure is reasonably necessary for this Case and who have signed the 

“Acknowledgment and Agreement to Be Bound” (Exhibit A); 

(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 

reasonably necessary for this Case and who have signed the “Acknowledgment and Agreement to 

Be Bound” (Exhibit A); 

(d) the Court and its personnel; 

(e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 

Professional Vendors to whom disclosure is reasonably necessary for this Case and who have 

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 

(f) during their depositions, witnesses in the Case to whom disclosure is reasonably 

necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 

unless otherwise agreed by the Designating Party or ordered by the Court. Pages of transcribed 

deposition testimony or exhibits to depositions that reveal Protected Material must be separately 

bound by the court reporter and may not be disclosed to anyone except as permitted under this 

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Order.

(g) the author or recipient of a document containing the information or a custodian or 

other person who otherwise possessed or knew the information. 

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 

LITIGATION

If a Party is served with a subpoena or a Court order issued in other litigation or another 

proceeding that compels disclosure of any information or items designated in this Case as 

“CONFIDENTIAL,” that Party must: 

(a) promptly notify in writing the Designating Party. Such notification shall include a 

copy of the subpoena or Court order;

(b) promptly notify in writing the party who caused the subpoena or order to issue in the 

other litigation or proceeding that some or all of the material covered by the subpoena or order is 

subject to this Order. Such notification shall include a copy of this Order; and

(c) cooperate with respect to all reasonable procedures sought to be pursued by the 

Designating Party whose Protected Material may be affected. 

If the Designating Party timely seeks a protective order, the Party served with the subpoena 

or court order shall not produce any information designated in this Case as “CONFIDENTIAL” 

before a determination by the court from which the subpoena or order issued, unless the Party has 

obtained the Designating Party’s permission. The Designating Party shall bear the burden and 

expense of seeking protection in that court of its confidential material – and nothing in these 

provisions should be construed as authorizing or encouraging a Receiving Party in this Case to 

disobey a lawful directive from another court. 

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 

CASE 

(a) The terms of this Order are applicable to information produced by a Non-Party in 

this Case and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 

connection with this Case is protected by the remedies and relief provided by this Order. Nothing in 

these provisions should be construed as prohibiting a Non-Party from seeking additional 

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protections.

(b) In the event that a Party is required, by a valid discovery request, to produce a NonParty’s confidential information in its possession, and the Party is subject to an agreement with the 

Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 

(1) promptly notify in writing the Requesting Party and the Non-Party that some or 

all of the information requested is subject to a confidentiality agreement with a Non-Party; 

(2) promptly provide the Non-Party with a copy of the Order in this Case, the 

relevant discovery request(s), and a reasonably specific description of the information requested; 

and

(3) make the information requested available for inspection by the Non-Party.

(c) If the Non-Party fails to object or seek a protective order from this Court within 14 

days of receiving the notice and accompanying information, the Receiving Party may produce the 

Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 

seeks a protective order, the Receiving Party shall not produce any information in its possession or 

control that is subject to the confidentiality agreement with the Non-Party before a determination by 

the Court. Absent a Court order to the contrary, the Non-Party shall bear the burden and expense of 

seeking protection in this Court of its Protected Material. 

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 

Material to any person or in any circumstance not authorized under this Order, the Receiving Party 

must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) 

use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 

person or persons to whom unauthorized disclosures were made of all the terms of this Order, and 

(d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 

that is attached hereto as Exhibit A. 

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 

MATERIAL

When a Producing Party gives notice to Receiving Parties that certain inadvertently 

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produced material is subject to a claim of privilege or other protection, the obligations of the 

Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 

is not intended to modify whatever procedure may be established in an e-discovery order that 

provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) 

and (e), insofar as the Parties reach an agreement on the effect of disclosure of a communication or 

information covered by the attorney-client privilege or work product protection, the Parties may 

incorporate their agreement in the stipulated protective order submitted to the Court. 

12. MISCELLANEOUS 

12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 

seek its modification by the Court in the future. 

12.2 Right to Assert Other Objections. By stipulating to the entry of this Order no Party 

waives any right it otherwise would have to object to disclosing or producing any information or 

item on any ground not addressed in this Order. Similarly, no Party waives any right to object on 

any ground to use in evidence of any of the material covered by this Order. 

12.3 Filing Protected Material. Without written permission from the Designating Party or 

a Court order secured after appropriate notice to all interested persons, a Party may not file in the 

public record in this Case any Protected Material. A Party that seeks to file under seal any Protected 

Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 

pursuant to a Court order authorizing the sealing of the specific Protected Material at issue. 

Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that 

the Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to 

protection under the law. If a Receiving Party's request to file Protected Material under seal 

pursuant to Civil Local Rule 79-5(d) is denied by the Court, then the Receiving Party may file the 

information in the public record pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by 

the Court. 

13. FINAL DISPOSITION 

Within 60 days after the final disposition of this Case, as defined in paragraph 4, each 

Receiving Party must return all Protected Material to the Producing Party or destroy such material. 

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EXHIBIT A 

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 

I, _____________________________ [print or type full name], of _________________ [print or 

type full address], declare under penalty of perjury that I have read in its entirety and understand the 

Stipulated Protective Order that was issued by the United States Bankruptcy Court for the Northern 

District of California on [date] in the case of In re Yellow Cab Cooperative, Inc., Case No. 16-

30063-DM. I agree to comply with and to be bound by all the terms of this Stipulated Protective 

Order and I understand and acknowledge that failure to so comply could expose me to sanctions and 

punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any 

information or item that is subject to this Stipulated Protective Order to any person or entity except 

in strict compliance with the provisions of this Order. 

I further agree to submit to the jurisdiction of the United States Bankruptcy Court for the Northern 

District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even 

if such enforcement proceedings occur after termination of this Case. 

I hereby appoint __________________________ [print or type full name] of 

_______________________________________ [print or type full address and telephone number] 

as my California agent for service of process in connection with this Case or any proceedings 

related to enforcement of this Stipulated Protective Order. 

Date: ______________________________________ 

City and State where sworn and signed: _________________________________ 

Printed name: _______________________________ 

Signature: __________________________________ 

32416\5464682.3

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