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DISMISSING ACTION [DKT. 50]\n                                                AND DENYING DEFENDANT\u2019S\n14                                              MOTION TO DISMISS AS MOOT\n       NIKE, INC., et al.,                      [DKT. 20]\n15\n                                Defendants.\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n                                               1\n\f     Case 2:24-cv-08093-FLA-E     Document 52 Filed 07/07/25        Page 2 of 2 Page ID\n                                         #:695\n\n\n1            On June 16, 2025, Plaintiff Lillian Jurdi (\u201cPlaintiff\u201d) filed a Notice of\n2      Dismissal, dismissing the action in its entirety without prejudice pursuant to Fed. R.\n3      Civ. P. 41(a)(1)(A)(i). Dkt. 49. On June 17, 2025, the court issued an Order\n4      Dismissing Action, Dkt. 50, in error as no order of dismissal was required as\n5      Defendant Nike, Inc. (\u201cDefendant\u201d) had neither filed an answer nor a motion for\n6      summary judgment. Fed. R. Civ. P. 41(a)(1)(A)(i).\n7            Accordingly, the court VACATES the Order Dismissing Action, Dkt. 50,\n8      consistent with Fed. R. Civ. P. 41(a)(1)(A)(i). All dates and deadlines governing this\n9      action are VACATED. Defendant\u2019s Motion to Dismiss, Dkt. 20, is DENIED as moot.\n10\n11           IT IS SO ORDERED.\n12\n13     Dated: July 7, 2025                           _______________________________\n                                                     FERNANDO L. AENLLE-ROCHA\n14\n                                                     United States District Judge\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n                                                 2\n\f","ocr_status":2,"date_upload":"2026-09-24T19:06:32.911057-07:00","document_number":"52","attachment_number":null,"pacer_doc_id":"031045331253","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2025-07-08T09:03:29.149190-07:00","date_modified":"2025-07-08T09:03:29.152729-07:00","date_filed":"2025-07-08","time_filed":"08:53:13","entry_number":52,"recap_sequence_number":"2025-07-08.001","pacer_sequence_number":173,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/429307861/","id":429307861,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69182289/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/443559581/","id":443559581,"tags":[],"absolute_url":"/docket/69182289/51/lillian-jurdi-v-nike-inc/","date_created":"2025-06-23T16:05:29.036458-07:00","date_modified":"2025-06-23T16:05:29.039292-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"51","attachment_number":null,"pacer_doc_id":"031045224061","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Objection","acms_document_guid":""}],"date_created":"2025-06-23T16:05:29.026439-07:00","date_modified":"2025-06-23T16:05:29.028725-07:00","date_filed":"2025-06-23","time_filed":"15:31:29","entry_number":51,"recap_sequence_number":"2025-06-23.001","pacer_sequence_number":170,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/428787813/","id":428787813,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69182289/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/443025158/","id":443025158,"tags":[],"absolute_url":"/docket/69182289/50/lillian-jurdi-v-nike-inc/","date_created":"2025-06-17T13:34:16.094805-07:00","date_modified":"2026-10-20T13:48:01.822076-07:00","sha1":"dfbd86a05661e59c85c2240cde15a9d58626d5e8","page_count":2,"file_size":153500,"filepath_local":"recap/gov.uscourts.cacd.941690/gov.uscourts.cacd.941690.50.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.941690/gov.uscourts.cacd.941690.50.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"     Case 2:24-cv-08093-FLA-E    Document 50 Filed 06/17/25   Page 1 of 2 Page ID\n                                        #:689\n\n\n1                                                                        JS-6\n2\n3\n4\n5\n6\n7\n8                            UNITED STATES DISTRICT COURT\n9                           CENTRAL DISTRICT OF CALIFORNIA\n10\n11     LILLIAN JURDI,                           Case No. 2:24-cv-08093-FLA (Ex)\n12                              Plaintiff,\n                                                ORDER DISMISSING ACTION\n13                v.                            [DKT. 49] AND DENYING AS\n                                                MOOT DEFENDANT\u2019S MOTION\n14                                              TO DISMISS [DKT. 20]\n       NIKE INC., et al.,\n15\n                                Defendants.\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n                                               1\n\f     Case 2:24-cv-08093-FLA-E      Document 50 Filed 06/17/25        Page 2 of 2 Page ID\n                                          #:690\n\n\n1            On June 16, 2025, Plaintiff Lillian Jurdi (\u201cPlaintiff\u201d) filed a Notice of\n2      Voluntary Dismissal (Dkt. 49), requesting the court dismiss the action without\n3      prejudice pursuant to Fed. R. Civ. P. 41(a)(1) (\u201cRule 41(a)(1)\u201d), which allows a\n4      plaintiff to dismiss an action voluntarily without a court order by filing: \u201c(i) a notice\n5      of dismissal before the opposing party serves either an answer or a motion for\n6      summary judgment; or (ii) a stipulation of dismissal signed by all parties who have\n7      appeared.\u201d\n8            Plaintiff is not entitled to dismissal under Rule 41(a)(1)(A)(i) because\n9      Defendant Nike Inc. (\u201cDefendant\u201d) filed its Answer on December 19, 2024. See Dkt.\n10     20. Further, as Plaintiff did not submit a stipulation of dismissal signed by all parties\n11     who appeared, Plaintiff is not entitled to dismissal under Rule 41(a)(1)(A)(ii). The\n12     court, therefore, DENIES Plaintiff\u2019s request for dismissal.\n13           Nevertheless, as Defendant has not filed an opposition to the Notice of\n14     Voluntary Dismissal, the court, on its own motion, hereby VACATES all pending\n15     dates and deadlines and DISMISSES the action without prejudice. See Fed. R. Civ. P.\n16     41(a)(2). Defendant\u2019s Motion to Dismiss, Dkt. 20, is DENIED as moot. The court\n17     retains jurisdiction to vacate this Order and to reopen the action within thirty (30) days\n18     from the date of this Order, should Defendant file timely an objection to the dismissal.\n19\n20           IT IS SO ORDERED.\n21\n22     Dated: June 17, 2025\n23                                                     _______________________________\n                                                       FERNANDO L. AENLLE-ROCHA\n24\n                                                       United States District Judge\n25\n26\n27\n28\n\n                                                   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Case 2:24-cv-08093-FLA-E        Document 46 Filed 05/09/25   Page 1 of 6 Page ID\n                                        #:673\n\n\n\n1    LIVIA M. KISER (SBN 285411)\n     lkiser@kslaw.com\n2    MICHAEL D. ROTH (SBN 217464)\n     mroth@kslaw.com\n3    LENNETTE W. LEE (SBN 263023)\n      llee@kslaw.com\n4    SAMUEL C. CORTINA (SBN 310778)\n     scortina@kslaw.com\n5    KING & SPALDING LLP\n     633 West Fifth Street, Suite 1600\n6    Los Angeles, CA 90071\n     Telephone: (213) 443-4355\n7    Facsimile: (213) 443-4310\n8    Attorneys for Defendant\n     NIKE, INC.\n9\n10\n                           UNITED STATES DISTRICT COURT\n11\n                         CENTRAL DISTRICT OF CALIFORNIA\n12\n13     LILLIAN JURDI, an individual              Case No. 2:24-cv-08093-FLA(Ex)\n14     and on behalf of all others\n       similarly situated,                       DEFENDANT NIKE, INC.\u2019S\n15                                               SUPPLEMENTAL MEMORANDUM\n                    Plaintiff,                   IN OPPOSITION TO PLAINTIFF\u2019S\n16                                               MOTION TO COMPEL\n             v.\n17\n                                                 Date: May 23, 2025\n       NIKE, INC., an Oregon company;            Time: 9:30 am\n18     DOES 1 through 25, inclusive,             Courtroom: 750\n19\n                    Defendant.\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n           SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n\f Case 2:24-cv-08093-FLA-E      Document 46 Filed 05/09/25         Page 2 of 6 Page ID\n                                      #:674\n\n\n\n1          Pursuant to Local Rule 37-2.3, Defendant Nike, Inc. (\u201cDefendant\u201d) submits this\n2    supplemental memorandum in opposition to Plaintiff\u2019s Motion to Compel Further\n3    Reponses to Special Interrogatories and Requests for Production, Set One. Dkt. 40.\n4    I.    The Court Should Determine Whether It Has Subject Matter\n5          Jurisdiction Before Adjudicating Plaintiff\u2019s Motion to Compel\n6          The Court should deny Plaintiff\u2019s motion to compel discovery, as the threshold\n7    question of whether subject matter jurisdiction exists has not been decided.\n8          As Defendant argued in its pending Motion to Dismiss\u2014and has been asserting\n9    in Court since November 2024 1\u2014this Court lacks subject matter jurisdiction because\n10   Plaintiff has not alleged, and cannot allege, any jurisdictionally required injury in fact.\n11   Dkt. 20, 32 & 39. Courts have an independent duty to consider subject matter\n12   jurisdiction at every stage of the litigation, \u201ceven in the absence of a challenge from a\n13   party.\u201d Arbaugh v. Y&H Corp., 546 U.S. 500, 514 (2006); see also Augustine v.\n14   United States, 704 F.2d 1074, 1077 (9th Cir. 1983) (there is a \u201ccontinuing duty to\n15   dismiss an action whenever it appears that the court lacks jurisdiction.\u201d).\n16         Because the Court\u2019s subject matter jurisdiction is still undecided, the Court\n17   should refrain from adjudicating the Motion to Compel: \u201cWithout jurisdiction the\n18   court cannot proceed at all in any cause. Jurisdiction is power to declare the law, and\n19   when it ceases to exist, the only function remaining to the court is that of announcing\n20   the fact and dismissing the cause.\u201d Steel Co. v. Citizens for a Better Env\u2019t, 523 U.S.\n21   83, 94 (1998) (quoting Ex parte McCardle, 7 Wall. 506, 514, 19 L.Ed. 264 (1868)).\n22   Courts routinely deny motions to compel or stay discovery while they assess subject\n23   matter jurisdiction. See Dkt. 40 at 19 (citing cases where courts denied motions to\n24   compel because subject matter jurisdiction was unresolved).\n25         To be clear, Plaintiff\u2019s Motion does not seek to compel any jurisdictional\n26\n     1\n       Defendant filed its first Motion to Dismiss challenging subject matter jurisdiction\n27   on November 15, 2024. Dkt. 11. Rather than defend her pleadings, Plaintiff filed an\n     Amended Complaint, thus requiring Defendant to file a subsequent Motion to Dismiss\n28   the Amended Complaint on the same basis. Dkt. 20.\n           SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n                                                -1-\n\f Case 2:24-cv-08093-FLA-E      Document 46 Filed 05/09/25        Page 3 of 6 Page ID\n                                      #:675\n\n\n\n 1   discovery that might be appropriate at this juncture. Apparent from the requests\n 2   themselves, Dkt. 40-1, and also confirmed by her counsel, see Dkt. 40-18 at 3,\n 3   Plaintiff\u2019s requests seek only merits-based discovery. And without subject matter\n 4   jurisdiction, the Court should not decide this merits-based discovery dispute.\n 5         The Court should thus deny Plaintiff\u2019s Motion to Compel as premature.\n 6   Resolution of discovery disputes in this matter would be appropriate only if and after\n 7   the Court determines it has subject matter jurisdiction for this case (it does not).\n 8   II.   No Sanctions Should Be Entered Against Defendant\n 9         Plaintiff\u2019s repeated (but passing) demand for sanctions\u2014made without\n10   identification of any sanctionable conduct by Defendant, or providing the required\n11   notice, evidence, or legal support justifying sanctions\u2014also should be denied.\n12         A.     Sanctions Against Defendant are not Justified Under the FRCP\n13         Federal Rule of Civil Procedure 37(a)(5) only permits imposing sanctions\n14   against the non-moving party if (a) the movant made a good faith attempt to obtain\n15   the disclosure or discovery without court action, and (b) the non-moving party\u2019s\n16   position was not substantially justified. Even then, sanctions should be denied if\n17   \u201cother circumstances make an award of expenses unjust.\u201d Id. Here, Plaintiff\u2019s request\n18   for sanctions fails under all prongs.\n19         First, Plaintiff did not make a good faith attempt to obtain discovery without\n20   court action. She did the opposite. Specifically, for Issues 1 and 2, Plaintiff asks for\n21   an order compelling production of responsive documents by a date that Defendant\n22   already agreed to. There is thus nothing to compel. Issue 3 is a manufactured\n23   discovery dispute: Defendant agreed to produce responsive documents reflecting\n24   Plaintiff\u2019s consent to the conduct about which she now complains. Plaintiff is simply\n25   unwilling to provide basic information about herself to facilitate Defendant\u2019s search\n26   for the very records she requests. For Issue 4, Plaintiff seeks to compel responses to\n27   interrogatories with no legal justification, several of which she agreed were\n28   impermissible. For Issue 5, Plaintiff asks for an order compelling responses without\n\n           SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n                                               -2-\n\f Case 2:24-cv-08093-FLA-E     Document 46 Filed 05/09/25       Page 4 of 6 Page ID\n                                     #:676\n\n\n\n 1   general objections, but that too would provide Plaintiff with no relief. Defendant is\n 2   not withholding documents or information based on general objections, and Plaintiff\n 3   has not identified any general objections that require court intervention. Rather than\n 4   avoid court action, as the Federal Rules demand, Plaintiff has actively sought it out.\n 5         Second, Defendant\u2019s responses to Plaintiff\u2019s unnecessary motion are\n 6   substantially justified. Defendant agreed to produce documents responsive to every\n 7   Request for Production (except for RFP No. 4, which Plaintiff has since abandoned)\n 8   and responded to four of Plaintiff\u2019s nine interrogatories. Defendant properly objected\n 9   to the other five interrogatories, as evidenced by the meet and confer: Plaintiff\n10   abandoned one of them (Interrogatory No. 6); the parties agreed to Defendant\u2019s\n11   compromise proposal for one of them (Interrogatory No. 1); Plaintiff proposed\n12   amending another one but cut the meet and confer process off before agreement\n13   (Interrogatory No. 7); and Plaintiff did not provide any legal or evidentiary authority\n14   supporting her two remaining interrogatories (Interrogatory Nos. 4 and 5).\n15         Defendant was also substantially justified in its proposals for when it will\n16   substantially complete its document production. During the parties\u2019 meet and confer\n17   efforts, Defendant agreed to substantially complete its production of documents\n18   responsive to RFP Nos. 1, 6, 9, and 10 by May 15 and RFP Nos. 2, 5, 8, and 11 by\n19   June 15. 2 That is more than four months before the October 31, 2025 deadline to hear\n20   a motion for class certification, and more than eleven months before the May 22, 2026\n21   fact discovery cut-off, and is unquestionably a \u201creasonable time\u201d for production under\n22   Rule 34. See Patagonia, Inc. v. Anheuser Busch, LLC, 2020 WL 6260018, at *2 (C.D.\n23   Cal. Feb. 19, 2020) (ordering a date certain for production of documents more than\n24   eight months after the requests were served in consideration of the discovery cut-off,\n25   upcoming motions and depositions, and expert discovery). Plaintiff, moreover, has\n26   never identified any prejudice from the proposed schedule\u2014there is none.\n27\n     2\n      Defendant inadvertently omitted a reference to RFP No. 3 in its meet and confer\n28   correspondence but has since confirmed that it should have been included in the June\n     15 deadline.\n           SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n                                              -3-\n\f Case 2:24-cv-08093-FLA-E     Document 46 Filed 05/09/25        Page 5 of 6 Page ID\n                                     #:677\n\n\n\n 1         Finally, other circumstances make an award of expenses unjust. This case is\n 2   not at issue, and Defendant has challenged the Court\u2019s subject matter jurisdiction and\n 3   the applicability of California\u2019s trap and trace statute to Defendant\u2019s entirely out of\n 4   state conduct. Dkt. 20, 32. While Defendant has participated in discovery in good\n 5   faith during the pendency of its motion to dismiss, Plaintiff has pursued a course of\n 6   conduct with the sole purpose of bringing a motion to compel.              Under these\n 7   circumstances, an award of any expenses to Plaintiff would be unjust and reward bad\n 8   faith conduct.\n 9         B.     Plaintiff Did Not Provide Support for Her Sanctions Request\n10         Furthermore, neither Plaintiff\u2019s Motion nor her Joint Stipulation include any\n11   legal or evidentiary support for a request for sanctions. Her passing request for\n12   sanctions fails to establish her entitlement to any monetary sanctions. See Fed. R.\n13   Civ. P. 37(a)(5) (elements necessary for imposing sanctions); Sundby v. Marquee\n14   Funding Group, Inc., 2020 WL 5709445, at *13 (S.D. Cal., 2020) (declining to\n15   impose monetary sanctions because \u201cthe Investor Defendants fail to support this\n16   request with adequate information to order such sanctions\u201d where \u201c[n]owhere in the\n17   Investor Defendants\u2019 motion or in the attachments are these fees and costs outlined.\u201d).\n18   If Plaintiff makes arguments in support of sanctions for the first time in a\n19   Supplemental Memorandum, the Court should likewise reject those arguments as\n20   untimely and violative of Defendant\u2019s due process rights. See Fed. R. Civ. P. 37(a)(5)\n21   (\u201copportunity to be heard\u201d required before imposing sanctions). 3\n22         Plaintiff is entitled to no relief, and certainly not an award of attorneys\u2019 fees,\n23   for the ginned-up disputes prompting her motion. Sanctions against Defendant are\n24   not appropriate under these circumstances. See Fed. R. Civ. P. 37(a)(5).\n25\n     3\n       Plaintiff\u2019s failure to comply with procedural requirements is not an isolated incident.\n26   Indeed, Plaintiff\u2019s motion reflects her: (1) failure to include a Notice of Motion, as is\n     required by Local Rule 37-2; (2) failure to submit a proposed order; (3) failure to\n27   notice the hearing before the correct judge; (4) filing an incorrect exhibit to\n     Defendant\u2019s counsel\u2019s declaration; and (5) sending a Local Rule 37-1 meet and confer\n28   letter that did not identify the issues and discovery requests with specificity as\n     required.\n           SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n                                               -4-\n\f Case 2:24-cv-08093-FLA-E     Document 46 Filed 05/09/25        Page 6 of 6 Page ID\n                                     #:678\n\n\n\n 1   III.   Plaintiff Should Be Sanctioned for Filing an Unjustified Motion\n 2          By contrast, if the Court denies any portion of the Motion, then Plaintiff should\n 3   be sanctioned. Fed. R. Civ. P. 37(a)(5)(B); Davis v. Schneider, 2020 WL 9074713,\n 4   at *10 (C.D. Cal., 2020) (\u201cwhere a motion is granted in part and denied in part, as is\n 5   the case here, the Court may apportion the reasonable expenses for the motion\u201d).\n 6          Plaintiff includes five \u201cissues\u201d in her Motion. None of them have merit or\n 7   substantial justification. Four of the \u201cissues\u201d request relief that Defendant already\n 8   agreed to before Plaintiff brought her motion, and those issues should not have been\n 9   included in a motion to compel. See Fed. R. Civ. P. 37(a)(3) (permitting motion to\n10   compel only if a party \u201cfails to answer a question,\u201d \u201cfails to make a designation,\u201d\n11   \u201cfails to answer an interrogatory,\u201d or \u201cfails to produce documents\u201d).\n12          The only issue that is arguably ripe for the Court is determining whether\n13   Plaintiff\u2019s Interrogatory Nos. 4 & 5\u2014seeking years of information about Defendant\u2019s\n14   global sales transactions in a case about data allegedly collected from California-\n15   based website visitors\u2014are within the permissible scope of discovery. As set forth\n16   in Defendant\u2019s position on Issue 4, they are not. Dkt. 40 at 37-38.\n17          Defendant respectfully requests that the Court deny Plaintiff\u2019s Motion in its\n18   entirety and set a further hearing to determine the appropriate monetary sanctions\n19   against Plaintiff for bringing an unwarranted motion and wasting the Court\u2019s and\n20   Defendant\u2019s resources. See Fed. R. Civ. P. 37(a)(5)(B).\n21    Dated: May 9, 2025              Respectfully submitted,\n                                         KING & SPALDING LLP\n22\n                                         By:   /s/Michael D. Roth\n23\n                                               LIVIA KISER\n24                                             MICHAEL D. ROTH\n                                               LENNETTE W. LEE\n25\n                                               SAMUEL C. CORTINA\n26\n                                               Attorneys for Defendant NIKE, INC.\n27\n\n28\n\n            SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO PLAINTIFF\u2019S MOTION TO COMPEL\n                                               -5-\n\f","ocr_status":2,"date_upload":"2026-09-24T19:06:28.471356-07:00","document_number":"46","attachment_number":null,"pacer_doc_id":"031044899841","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Memorandum in Opposition to Motion","acms_document_guid":""}],"date_created":"2025-05-09T20:35:43.123783-07:00","date_modified":"2025-05-09T20:35:43.126411-07:00","date_filed":"2025-05-09","time_filed":"20:28:58","entry_number":46,"recap_sequence_number":"2025-05-09.001","pacer_sequence_number":148,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/424922248/","id":424922248,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69182289/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/439044636/","id":439044636,"tags":[],"absolute_url":"/docket/69182289/45/lillian-jurdi-v-nike-inc/","date_created":"2025-05-09T08:01:15.222417-07:00","date_modified":"2025-05-09T08:01:15.227235-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"45","attachment_number":null,"pacer_doc_id":"031044890413","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Deficiency in Filed Documents (G-112A) - optional html form","acms_document_guid":""}],"date_created":"2025-05-09T08:01:15.212019-07:00","date_modified":"2025-05-09T08:01:15.214097-07:00","date_filed":"2025-05-09","time_filed":"07:41:37","entry_number":45,"recap_sequence_number":"2025-05-09.001","pacer_sequence_number":145,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/424812126/","id":424812126,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69182289/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/438928422/","id":438928422,"tags":[],"absolute_url":"/docket/69182289/44/lillian-jurdi-v-nike-inc/","date_created":"2025-05-08T10:36:07.438441-07:00","date_modified":"2025-06-07T02:36:42.517848-07:00","sha1":"eb0f04fac7f67c46b923fb4c0092b388be52fca7","page_count":19,"file_size":208814,"filepath_local":"recap/gov.uscourts.cacd.941690/gov.uscourts.cacd.941690.44.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cacd.941690/gov.uscourts.cacd.941690.44.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"     Case 2:24-cv-08093-FLA-E        Document 44 Filed 05/07/25   Page 1 of 19 Page ID\n                                             #:653\n\n\n 1\n\n 2\n\n 3\n\n 4\n\n 5\n\n 6\n\n 7                        UNITED STATES DISTRICT COURT\n 8                       CENTRAL DISTRICT OF CALIFORNIA\n 9\n\n10   LILLIAN JURDI, an individual and on           Case No. 2:24-cv-08093-FLA (Ex)\n     behalf of all others similarly situated,\n11\n\n12\n                        Plaintiff,                 STIPULATED PROTECTIVE\n                                                   ORDER\n13                v.\n\n14   NIKE, INC., an Oregon company;\n     DOES 1 through 25, inclusive,\n15\n                        Defendants.\n16\n\n17\n\n18    1.    A. PURPOSES AND LIMITATIONS\n19          Discovery in this action is likely to involve production of confidential,\n20    proprietary, or private information for which special protection from public\n21    disclosure and from use for any purpose other than prosecuting this litigation may\n22    be warranted. Accordingly, the parties hereby stipulate to and petition the Court to\n23    enter the following Stipulated Protective Order. The parties acknowledge that this\n24    Order does not confer blanket protections on all disclosures or responses to\n25    discovery and that the protection it affords from public disclosure and use extends\n26    only to the limited information or items that are entitled to confidential treatment\n27    under the applicable legal principles. The parties further acknowledge, as set forth\n28    in Section 13.3 (Filing Protected Material), below, that this Stipulated Protective\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25         Page 2 of 19 Page ID\n                                          #:654\n\n\n 1    Order does not entitle them to file confidential information under seal; Civil Local\n 2    Rule 79-5 sets forth the procedures that must be followed and the standards that will\n 3    be applied when a party seeks permission from the court to file material under seal.\n 4          B. GOOD CAUSE STATEMENT\n 5          This action is likely to involve source code, trade secrets, and other valuable\n 6    research, development, commercial, financial, technical and/or proprietary\n 7    information for which special protection from public disclosure and from use for\n 8    any purpose other than prosecution of this action is warranted. Such confidential\n 9    and proprietary materials and information may consist of, among other things,\n10    Defendant\u2019s confidential customer records (including personal identifiable\n11    information (PII) within those records), proprietary and confidential source code,\n12    confidential contracts and communications with third-parties such as TikTok, Inc.,\n13    confidential business or financial information, information regarding confidential\n14    business practices, or other confidential research, development, or commercial\n15    information (including information implicating privacy rights of putative class\n16    members and third parties), information otherwise generally unavailable to the\n17    public, or which may be privileged or otherwise protected from disclosure under\n18    state or federal statutes, court rules, case decisions, or common law. Accordingly,\n19    to expedite the flow of information, to facilitate the prompt resolution of disputes\n20    over confidentiality of discovery materials, to adequately protect information the\n21    parties are entitled to keep confidential, to ensure that the parties are permitted\n22    reasonable necessary uses of such material in preparation for and in the conduct of\n23    trial, to address their handling at the end of the litigation, and serve the ends of\n24    justice, a protective order for such information is justified in this matter. It is the\n25    intent of the parties that information will not be designated as confidential for\n26    tactical reasons and that nothing be so designated without a good faith belief that it\n27    has been maintained in a confidential, non-public manner, and there is good cause\n28    why it should not be part of the public record of this case.\n\n                                                2\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25       Page 3 of 19 Page ID\n                                          #:655\n\n\n 1    2.     DEFINITIONS\n 2           2.1    Action: Jurdi v. Nike Inc., 2:24-cv-08093 FLA (Ex).\n 3           2.2    Challenging Party: a Party or Non-Party that challenges the\n 4    designation of information or items under this Order.\n 5           2.3    \u201cCONFIDENTIAL\u201d Information or Items: information (regardless of\n 6    how it is generated, stored, or maintained) or tangible things that qualify for\n 7    protection under Federal Rule of Civil Procedure 26(c), and as specified above in\n 8    the Good Cause Statement.\n 9           2.4    \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d\n10    Information or Items: extremely sensitive \u201cConfidential Information or Items,\u201d the\n11    disclosure of which to another Party or Non-Party would create a substantial risk of\n12    serious harm that could not be avoided by less restrictive means. Information\n13    qualifying for \u201cHighly Confidential \u2013 Attorneys\u2019 Eyes Only\u201d may include but is not\n14    limited to: (a) marketing, financial, sales, web traffic, research and development, or\n15    technical, data or information; (b) commercially sensitive competitive information;\n16    (c) information or data relating to future products or product features not yet\n17    commercially released and/or strategic plans; and (d) commercial agreements, the\n18    disclosure of which is likely to cause harm to the competitive position of the\n19    producing party.\n20           2.5    \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE\u201d Information or\n21    Items: extremely sensitive \u201cConfidential Information or Items\u201d representing\n22    computer code and associated comments and revision histories, formulas,\n23    engineering specifications, or schematics that define or otherwise describe in detail\n24    the algorithms or structure of software or hardware designs, the disclosure of which\n25    to another Party or Non-Party would create a substantial risk of serious harm that\n26    could not be avoided by less restrictive means.\n27           2.6    Counsel: Outside Counsel of Record and House Counsel (as well as\n28    their support staff).\n\n                                               3\n\f     Case 2:24-cv-08093-FLA-E      Document 44 Filed 05/07/25       Page 4 of 19 Page ID\n                                           #:656\n\n\n 1          2.7    Designating Party: a Party or Non-Party that designates information\n 2    or items that it produces in disclosures or in responses to discovery as\n 3    \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES\n 4    ONLY\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE.\u201d\n 5          2.8    Disclosure or Discovery Material: all items or information, regardless\n 6    of the medium or manner in which it is generated, stored, or maintained (including,\n 7    among other things, testimony, transcripts, and tangible things), that are produced\n 8    or generated in disclosures or responses to discovery in this matter.\n 9          2.9    Expert: a person with specialized knowledge or experience in a matter\n10    pertinent to the litigation who has been retained by a Party or its counsel to serve as\n11    an expert witness or as a consultant in this Action.\n12          2.10 House Counsel: attorneys who are employees of a party to this Action.\n13    House Counsel does not include Outside Counsel of Record or any other outside\n14    counsel.\n15          2.11 Non-Party: any natural person, partnership, corporation, association,\n16    or other legal entity not named as a Party to this action.\n17          2.12 Outside Counsel of Record: attorneys who are not employees of a\n18    party to this Action but are retained to represent or advise a party to this Action and\n19    have appeared in this Action on behalf of that party or are affiliated with a law firm\n20    which has appeared on behalf of that party, including support staff.\n21          2.13 Party: any party to this Action, including all of its officers, directors,\n22    employees, consultants, retained experts, and Outside Counsel of Record (and their\n23    support staffs).\n24          2.14 Producing Party: a Party or Non-Party that produces Disclosure or\n25    Discovery Material in this Action.\n26          2.15 Professional Vendors:        persons or entities that provide litigation\n27    support services (e.g., photocopying, videotaping, translating, preparing exhibits or\n28    demonstrations, and organizing, storing, or retrieving data in any form or medium)\n\n                                                4\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25       Page 5 of 19 Page ID\n                                          #:657\n\n\n 1    and their employees and subcontractors.\n 2          2.16 Protected Material: any Disclosure or Discovery Material that is\n 3    designated as \u201cCONFIDENTIAL,\u201d \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n 4    EYES ONLY,\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE.\u201d\n 5          2.17 Receiving Party:        a Party that receives Disclosure or Discovery\n 6    Material from a Producing Party.\n 7    3.    SCOPE\n 8          The protections conferred by this Stipulation and Order cover not only\n 9    Protected Material (as defined above), but also (1) any information copied or\n10    extracted from Protected Material; (2) all copies, excerpts, summaries, or\n11    compilations of Protected Material; and (3) any testimony, conversations, or\n12    presentations by Parties or their Counsel that might reveal Protected Material.\n13    However, the protections conferred by this Stipulation and Order do not cover the\n14    following information: (a) any information that is in the public domain at the time\n15    of disclosure to a Receiving Party or becomes part of the public domain after its\n16    disclosure to a Receiving Party as a result of publication not involving a violation\n17    of this Order, including becoming part of the public record through trial or\n18    otherwise; and (b) any information known to the Receiving Party prior to the\n19    disclosure or obtained by the Receiving Party after the disclosure from a source who\n20    obtained the information lawfully and under no obligation of confidentiality to the\n21    Designating Party.\n22          Any use of Protected Material at trial shall be governed by the orders of the\n23    trial judge. This Order does not govern the use of Protected Material at trial.\n24    4.    DURATION\n25          Even after final disposition of this litigation, as defined in Section 14 (FINAL\n26    DISPOSITION), the confidentiality obligations imposed by this Order shall remain\n27    in effect until a Designating Party agrees otherwise in writing or a court order\n28    otherwise directs.\n\n                                                5\n\f     Case 2:24-cv-08093-FLA-E      Document 44 Filed 05/07/25        Page 6 of 19 Page ID\n                                           #:658\n\n\n 1    5.    DESIGNATING PROTECTED MATERIAL\n 2          5.1     Exercise of Restraint and Care in Designating Material for Protection.\n 3    Each Party or Non-Party that designates information or items for protection under\n 4    this Order must take care to limit any such designation to specific material that\n 5    qualifies under the appropriate standards. The Designating Party must designate for\n 6    protection only those parts of material, documents, items, or oral or written\n 7    communications that qualify so that other portions of the material, documents,\n 8    items, or communications for which protection is not warranted are not swept\n 9    unjustifiably within the ambit of this Order.\n10          Mass, indiscriminate, or routinized designations are prohibited. Designations\n11    that are shown to be clearly unjustified or that have been made for an improper\n12    purpose (e.g., to unnecessarily encumber the case development process or to impose\n13    unnecessary expenses and burdens on other parties) may expose the Designating\n14    Party to sanctions.\n15         If it comes to a Designating Party\u2019s attention that information or items that it\n16    designated for protection do not qualify for protection at all or do not qualify for the\n17    level of protection initially asserted, that Designating Party must promptly notify all\n18    other parties that it is withdrawing the mistaken designation.\n19          5.2    Manner and Timing of Designations. Except as otherwise provided in\n20    this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise\n21    stipulated or ordered, Disclosure or Discovery Material that qualifies for protection\n22    under this Order must be clearly so designated before the material is disclosed or\n23    produced.\n24          Designation in conformity with this Order requires:\n25          (a) for information in documentary form (e.g., paper or electronic documents,\n26    but excluding transcripts of depositions or other pretrial or trial proceedings), that\n27    the Producing Party affix the legend \u201cCONFIDENTIAL\u201d or \u201cHIGHLY\n28    CONFIDENTIAL           \u2013    ATTORNEYS\u2019          EYES      ONLY\u201d       or    \u201cHIGHLY\n\n                                                6\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25       Page 7 of 19 Page ID\n                                          #:659\n\n\n 1    CONFIDENTIAL \u2013 SOURCE CODE\u201d to each page that contains protected\n 2    material. If only a portion or portions of the material on a page qualifies for\n 3    protection, the Producing Party also must clearly identify the protected portion(s)\n 4    (e.g., by making appropriate markings in the margins).\n 5          A Party or Non-Party that makes original documents or materials available\n 6    for inspection need not designate them for protection until after the inspecting Party\n 7    has indicated which material it would like copied and produced. During the\n 8    inspection and before the designation, all of the material made available for\n 9    inspection shall be deemed \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES\n10    ONLY.\u201d After the inspecting Party has identified the documents it wants copied\n11    and produced, the Producing Party must determine which documents, or portions\n12    thereof, qualify for protection under this Order.      Then, before producing the\n13    specified documents, the Producing Party must affix the appropriate legend\n14    (\u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES\n15    ONLY\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE) to each page that\n16    contains Protected Material. If only a portion or portions of the material on a page\n17    qualifies for protection, the Producing Party also must clearly identify the protected\n18    portion(s) (e.g., by making appropriate markings in the margins).\n19          (b) for testimony given in depositions that the Designating Party identify the\n20    Disclosure or Discovery Material on the record before the close of the deposition,\n21    all protected testimony, and specify the level of protection being asserted. When it\n22    is impractical to identify separately each portion of testimony that is entitled to\n23    protection and it appears that substantial portions of the testimony may qualify for\n24    protection, the Designating Party may invoke on the record (before the deposition,\n25    hearing, or other proceeding is concluded) a right to have up to 21 days to identify\n26    the specific portions of the testimony as to which protection is sought and to specify\n27    the level of protection being asserted. Only those portions of the testimony that are\n28    appropriately designated for protection within the 21 days shall be covered by the\n\n                                               7\n\f     Case 2:24-cv-08093-FLA-E        Document 44 Filed 05/07/25      Page 8 of 19 Page ID\n                                             #:660\n\n\n 1    provisions of this Stipulated Protective Order.\n 2          Parties shall give the other parties notice if they reasonably expect a\n 3    deposition to include Protected Material so that the other parties can ensure that only\n 4    authorized individuals who have signed the \u201cAcknowledgment and Agreement to\n 5    Be Bound\u201d (Exhibit A) are present at those proceedings.\n 6          Transcripts containing Protected Material shall have an obvious legend on the\n 7    title page that the transcript contains Protected Material, and the title page shall be\n 8    followed by a list of all pages (including line numbers as appropriate) that have been\n 9    designated as Protected Material and the level of protection being asserted by the\n10    Designating Party. The Designating Party shall inform the court reporter of these\n11    requirements. Any transcript that is prepared before the expiration of a 21-day\n12    period for designation shall be treated during that period as if it had been designated\n13    \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d in its entirety unless\n14    otherwise agreed. After the expiration of that period, the transcript shall be treated\n15    only as actually designated.\n16          (c) for information produced in some form other than documentary and for\n17    any other tangible items, that the Producing Party affix in a prominent place on the\n18    exterior of the container or containers in which the information is stored the\n19    appropriate legend (\u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013\n20    ATTORNEYS\u2019 EYES ONLY\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE\n21    CODE). If only a portion or portions of the information warrants protection, the\n22    Producing Party, to the extent practicable, shall identify the protected portion(s).\n23          5.3    Inadvertent Failures to Designate. If timely corrected, an inadvertent\n24    failure to designate qualified information or items does not, standing alone, waive\n25    the Designating Party\u2019s right to secure protection under this Order for such material.\n26    Upon timely correction of a designation, the Receiving Party must make reasonable\n27    efforts to assure that the material is treated in accordance with the provisions of this\n28    Order.\n\n                                                8\n\f     Case 2:24-cv-08093-FLA-E      Document 44 Filed 05/07/25        Page 9 of 19 Page ID\n                                           #:661\n\n\n 1    6.    CHALLENGING CONFIDENTIALITY DESIGNATIONS\n 2          6.1    Timing of Challenges. Any Party or Non-Party may challenge a\n 3    designation of confidentiality at any time.        Unless a prompt challenge to a\n 4    Designating Party\u2019s confidentiality designation is necessary to avoid foreseeable,\n 5    substantial unfairness, unnecessary economic burdens, or a significant disruption or\n 6    delay of the litigation, a Party does not waive its right to challenge a confidentiality\n 7    designation by electing not to mount a challenge promptly after the original\n 8    designation is disclosed.\n 9          6.2    Meet and Confer. The Challenging Party shall initiate the dispute\n10    resolution process under Civil Local Rule 37-1 et seq.\n11          6.3    The burden of persuasion in any such challenge proceeding shall be\n12    on the Designating Party. Frivolous challenges, and those made for an improper\n13    purpose (e.g., to harass or impose unnecessary expenses and burdens on other\n14    parties), may expose the Challenging Party to sanctions. Unless the Designating\n15    Party has waived or withdrawn the confidentiality designation, all parties shall\n16    continue to afford the material in question the level of protection to which it\n17    is entitled under the Producing Party\u2019s designation until the Court rules on the\n18    challenge.\n19    7.    ACCESS TO AND USE OF PROTECTED MATERIAL\n20          7.1    Basic Principles. A Receiving Party may use Protected Material that\n21    is disclosed or produced by another Party or by a Non-Party in connection with\n22    this Action only for prosecuting, defending, or attempting to settle this Action.\n23    Such Protected Material may be disclosed only to the categories of persons and\n24    under the conditions described in this Order.          When the Action has been\n25    terminated, a Receiving Party must comply with the provisions of Section 14 below\n26    (FINAL DISPOSITION).\n27          Protected Material must be stored and maintained by a Receiving Party at\n28    a location and in a secure manner that ensures that access is limited to the\n\n                                                9\n\f     Case 2:24-cv-08093-FLA-E      Document 44 Filed 05/07/25          Page 10 of 19 Page ID\n                                            #:662\n\n\n 1    persons authorized under this Order.\n 2          7.2     Disclosure of \u201cCONFIDENTIAL\u201d Information or Items.                Unless\n 3    otherwise ordered by the Court or permitted in writing by the Designating Party, a\n 4    Receiving    Party    may     disclose    any      information   or   item   designated\n 5    \u201cCONFIDENTIAL\u201d only to:\n 6                (a) the Receiving Party\u2019s Outside Counsel of Record in this Action, as\n 7    well as employees of said Outside Counsel of Record to whom it is reasonably\n 8    necessary to disclose the information for this Action;\n 9                (b) the officers, directors, and employees (including House Counsel) of\n10    the Receiving Party to whom disclosure is reasonably necessary for this Action;\n11                (c) Experts (as defined in this Order) of the Receiving Party to whom\n12    disclosure is reasonably necessary for this Action and who have signed the\n13    \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A);\n14                (d) the Court and its personnel;\n15                (e) court reporters and their staff;\n16                (f) professional jury or trial consultants, mock jurors, and Professional\n17    Vendors to whom disclosure is reasonably necessary for this Action and who have\n18    signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A);\n19                (g) the author or recipient of a document containing the information or a\n20    custodian or other person who otherwise possessed or knew the information;\n21                (h) during their depositions, witnesses, and attorneys for witnesses, in\n22    the Action to whom disclosure is reasonably necessary provided: (1) the deposing\n23    party requests that the witness sign the form attached as Exhibit A hereto; and (2)\n24    they will not be permitted to keep any confidential information unless they sign the\n25    \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), unless otherwise\n26    agreed by the Designating Party or ordered by the Court. Pages of transcribed\n27    deposition testimony or exhibits to depositions that reveal Protected Material may\n28    be separately bound by the court reporter and may not be disclosed to anyone except\n\n                                                10\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25        Page 11 of 19 Page ID\n                                           #:663\n\n\n 1    as permitted under this Stipulated Protective Order; and\n 2                (i) any mediator or settlement officer, and their supporting personnel,\n 3    mutually agreed upon by any of the parties engaged in settlement discussions.\n 4          7.3    Disclosure of \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES\n 5    ONLY\u201d and \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE\u201d Information or\n 6    Items. Unless otherwise ordered by the court or permitted in writing by the\n 7    Designating Party, a Receiving Party may disclose any information or item\n 8    designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d or\n 9    \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE\u201d only to:\n10                (a) the Receiving Party\u2019s Outside Counsel of Record in this Action, as\n11    well as employees of said Outside Counsel of Record to whom it is reasonably\n12    necessary to disclose the information for this Action;\n13                (b) Experts of the Receiving Party (1) to whom disclosure is reasonably\n14    necessary for this litigation, (2) who are not current employees of a Party or of a\n15    Party\u2019s competitor, (3) who, at the time of retention, are not anticipated to become\n16    employees of a Party or of a Party\u2019s competitor, and (4) who have signed the\n17    \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A);\n18                (c) the court and its personnel;\n19                (d) court reporters and their staff, professional jury or trial consultants,\n20    and Professional Vendors to whom disclosure is reasonably necessary for this\n21    litigation and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d\n22    (Exhibit A); and\n23                (e) the author or recipient of a document containing the information or a\n24    custodian or other person who otherwise possessed or knew the information.\n25    8.    SOURCE CODE\n26                (a) To the extent production of source code becomes necessary in this\n27    case, a Producing Party may designate source code as \u201cHIGHLY CONFIDENTIAL\n28    - SOURCE CODE\u201d if it comprises or includes confidential, proprietary or trade\n\n                                                11\n\f     Case 2:24-cv-08093-FLA-E      Document 44 Filed 05/07/25         Page 12 of 19 Page ID\n                                            #:664\n\n\n 1    secret source code. The parties confirm that this agreement does not waive or\n 2    prejudice either party\u2019s right to later challenge such a designation, nor does it\n 3    otherwise shift or alter the burden of establishing that material is protected under the\n 4    law as a trade secret etc.\n 5                (b) Protected Material designated as \u201cHIGHLY CONFIDENTIAL \u2013\n 6    SOURCE CODE\u201d shall be subject to all of the protections afforded to \u201cHIGHLY\n 7    CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d information and may be\n 8    disclosed only to the individuals set forth in Paragraph 7.3.\n 9                (c) To the extent production of source code becomes necessary in this\n10    case, the parties agree to cooperate in good faith to facilitate the production of such\n11    source code, and, if necessary, to amend this Stipulated Protective Order to facilitate\n12    the production of source code.\n13    9.    PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED\n14    IN OTHER LITIGATION\n15          If a Party is served with a subpoena or a court order issued in other litigation\n16    that compels disclosure of any information or items designated in this Action as\n17    \u201cCONFIDENTIAL,\u201d \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES\n18    ONLY\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE\u201d that Party must:\n19                (a) promptly notify in writing the Designating Party. Such notification\n20    shall include a copy of the subpoena or court order;\n21                (b) promptly notify in writing the party who caused the subpoena or order\n22    to issue in the other litigation that some or all of the material covered by the\n23    subpoena or order is subject to this Protective Order. Such notification shall include\n24    a copy of this Stipulated Protective Order; and\n25                (c) cooperate with respect to all reasonable procedures sought to be\n26    pursued by the Designating Party whose Protected Material may be affected.\n27          If the Designating Party timely seeks a protective order, the Party served with\n28    the subpoena or court order shall not produce any information designated in this\n\n                                                12\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25        Page 13 of 19 Page ID\n                                           #:665\n\n\n 1    action as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n 2    EYES ONLY\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 SOURCE CODE\u201d before a\n 3    determination by the court from which the subpoena or order issued, unless the Party\n 4    has obtained the Designating Party\u2019s permission. The Designating Party shall bear\n 5    the burden and expense of seeking protection in that court of its confidential\n 6    material, and nothing in these provisions should be construed as authorizing or\n 7    encouraging a Receiving Party in this Action to disobey a lawful directive from\n 8    another court.\n 9    10.   A NON-PARTY\u2019S PROTECTED MATERIAL SOUGHT TO BE\n10    PRODUCED IN THIS LITIGATION\n11               (a) The terms of this Order are applicable to information produced by a\n12    Non-Party in this Action and designated as \u201cCONFIDENTIAL,\u201d \u201cHIGHLY\n13    CONFIDENTIAL          \u2013    ATTORNEYS\u2019          EYES      ONLY,\u201d       or   \u201cHIGHLY\n14    CONFIDENTIAL \u2013 SOURCE CODE.\u201d Such information produced by Non-Parties\n15    in connection with this litigation is protected by the remedies and relief provided by\n16    this Order. Nothing in these provisions should be construed as prohibiting a Non-\n17    Party from seeking additional protections.\n18               (b) In the event that a Party is required, by a valid discovery request, to\n19    produce a Non-Party\u2019s confidential information in its possession, and the Party is\n20    subject to an agreement with the Non-Party not to produce the Non-Party\u2019s\n21    confidential information, then the Party shall:\n22                 (1) promptly notify in writing the Requesting Party and the Non-Party\n23    that some or all of the information requested is subject to a confidentiality agreement\n24    with a Non-Party;\n25                 (2) promptly provide the Non-Party with a copy of the Stipulated\n26    Protective Order in this Action, the relevant discovery request(s), and a reasonably\n27    specific description of the information requested; and\n28                 (3) make the information requested available for inspection by the Non-\n\n                                               13\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25        Page 14 of 19 Page ID\n                                           #:666\n\n\n 1    Party, if requested.\n 2               (c) If the Non-Party fails to seek a protective order from this Court within\n 3    14 days of receiving the notice and accompanying information, the Receiving Party\n 4    may produce the Non-Party\u2019s confidential information responsive to the discovery\n 5    request. If the Non-Party timely seeks a protective order, the Receiving Party shall\n 6    not produce any information in its possession or control that is subject to the\n 7    confidentiality agreement with the Non-Party before a determination by the Court.\n 8    Absent a court order to the contrary, the Non-Party shall bear the burden and\n 9    expense of seeking protection in this Court of its Protected Material.\n10    11.   UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL\n11          If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed\n12    Protected Material to any person or in any circumstance not authorized under this\n13    Stipulated Protective Order, the Receiving Party must immediately (a) notify in\n14    writing the Designating Party of the unauthorized disclosures, (b) use its best efforts\n15    to retrieve all unauthorized copies of the Protected Material, (c) inform the person\n16    or persons to whom unauthorized disclosures were made of all the terms of this\n17    Order, and (d) request such person or persons to execute the \u201cAcknowledgment and\n18    Agreement to Be Bound\u201d that is attached hereto as Exhibit A.\n19    12.   INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE\n20          PROTECTED MATERIAL\n21          When a Producing Party gives notice to Receiving Parties that certain\n22    inadvertently produced material is subject to a claim of privilege or other protection,\n23    the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\n24    Procedure 26(b)(5)(B).      This provision is not intended to modify whatever\n25    procedure may be established in an e-discovery order that provides for production\n26    without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and\n27    (e), insofar as the parties reach an agreement on the effect of disclosure of a\n28    communication or information covered by the attorney-client privilege or work\n\n                                               14\n\f     Case 2:24-cv-08093-FLA-E    Document 44 Filed 05/07/25         Page 15 of 19 Page ID\n                                          #:667\n\n\n 1    product protection, the parties may incorporate their agreement in the stipulated\n 2    protective order submitted to the Court.\n 3    13.   MISCELLANEOUS\n 4          13.1 Right to Further Relief. Nothing in this Order abridges the right of any\n 5    person to seek its modification by the Court in the future.\n 6          13.2 Right to Assert Other Objections. By stipulating to the entry of this\n 7    Protective Order, no Party waives any right it otherwise would have to object to\n 8    disclosing or producing any information or item on any ground not addressed in this\n 9    Stipulated Protective Order. Similarly, no Party waives any right to object on any\n10    ground to use in evidence of any of the material covered by this Protective Order.\n11          13.3 Filing Protected Material. A Party that seeks to file under seal any\n12    Protected Material must comply with Civil Local Rule 79-5. Protected Material\n13    may only be filed under seal pursuant to a court order authorizing the sealing of the\n14    specific Protected Material at issue. If a Party\u2019s request to file Protected Material\n15    under seal is denied by the court, then the Receiving Party may file the information\n16    in the public record unless otherwise instructed by the court.\n17    14.   FINAL DISPOSITION\n18          Final disposition shall be deemed to be the later of (1) dismissal of all claims\n19    and defenses in this Action, with or without prejudice; and (2) final judgment herein\n20    after the completion and exhaustion of all appeals, rehearings, remands, trials, or\n21    reviews of this Action, including the time limits for filing any motions or\n22    applications for extension of time pursuant to applicable law. After the final\n23    disposition of this Action, within 60 days of a written request by the Designating\n24    Party, each Receiving Party must return all Protected Material to the Producing\n25    Party or destroy such material. As used in this subdivision, \u201call Protected Material\u201d\n26    includes all copies, abstracts, compilations, summaries, and any other format\n27    reproducing or capturing any of the Protected Material. Whether the Protected\n28    Material is returned or destroyed, the Receiving Party must submit a written\n\n                                                 15\n\f     Case 2:24-cv-08093-FLA-E       Document 44 Filed 05/07/25        Page 16 of 19 Page ID\n                                             #:668\n\n\n 1      certification to the Producing Party (and, if not the same person or entity, to the\n 2      Designating Party) by the 60 day deadline that (1) identifies (by category, where\n 3      appropriate) all the Protected Material that was returned or destroyed; and (2)\n 4      affirms that the Receiving Party has not retained any copies, abstracts, compilations,\n 5      summaries, or any other format reproducing or capturing any of the Protected\n 6      Material. Notwithstanding this provision, Counsel are entitled to retain an archival\n 7      copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal\n 8      memoranda, correspondence, deposition and trial exhibits, expert reports, attorney\n 9      work product, and consultant and expert work product, even if such materials\n10      contain Protected Material. Any such archival copies that contain or constitute\n11      Protected Material remain subject to this Protective Order as set forth in Section 4\n12      (DURATION).\n13 //\n\n14 //\n\n15 //\n\n16 //\n\n17 //\n\n18 //\n\n19 //\n\n20 //\n\n21 //\n\n22 //\n\n23 //\n\n24 //\n\n25 //\n\n26 //\n\n27 //\n\n28 //\n\n                                                 16\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25     Page 17 of 19 Page ID\n                                           #:669\n\n\n 1       15.    VIOLATION\n 2             Any violation of this Order may be punished by any and all appropriate\n 3       measures including, without limitation, contempt proceedings and/or monetary\n 4       sanctions. 1\n 5\n\n 6       IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.\n 7\n\n 8 Dated: May 6, 2025                      TAULER SMITH LLP\n\n 9                                         By:     /s/ Narain Kumar\n10                                                 NARAIN KUMAR, Esq.\n                                                   Attorney for Plaintiff\n11\n\n12 Dated: May 6, 2025                      KING & SPALDING LLP\n13\n\n14\n                                           By: /s/ Michael D. Roth\n                                              MICHAEL D. ROTH\n15\n                                           Attorney for Defendant NIKE, INC.\n16\n\n17\n\n18\n         FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.\n19\n\n20\n         DATED: 5/7/2025                           ______________________________\n                                                   ___________________________    ____\n21                                                 Honorable\n                                                   H      bl Charles\n                                                              Ch l F.F Eick\n                                                                        Ei k\n22                                                 United States Magistrate Judge\n\n23\n\n24\n\n25\n\n26\n     1\n27   Nothing in this Protective Order shall be construed to mean that either party has\n   waived any arguments regarding the validity of redacting documents produced in\n28\n   this case.\n                                              17\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25       Page 18 of 19 Page ID\n                                           #:670\n\n\n 1                                        EXHIBIT A\n 2             ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND\n 3         I, _____________________________ [print or type full name], of\n 4    _________________ [print or type full address], declare under penalty of perjury\n 5    that I have read in its entirety and understand the Stipulated Protective Order that\n 6    was issued by the United States District Court for the Central District of California\n 7    on [date] in the case of Jurdi v. Nike Inc., 2:24-cv-08093-FLA (Ex). I agree to\n 8    comply with and to be bound by all the terms of this Stipulated Protective Order,\n 9    and I understand and acknowledge that failure to so comply could expose me to\n10    sanctions and punishment in the nature of contempt. I solemnly promise that I will\n11    not disclose in any manner any information or item that is subject to this Stipulated\n12    Protective Order to any person or entity except in strict compliance with the\n13    provisions of this Order.\n14         I further agree to submit to the jurisdiction of the United States District Court\n15    for the Central District of California for the purpose of enforcing the terms of this\n16    Stipulated Protective Order, even if such enforcement proceedings occur after\n17    termination of this action. I hereby appoint __________________________ [print\n18    or type full name] of _______________________________________ [print or type\n19    full address and telephone number] as my California agent for service of process in\n20    connection with this action or any proceedings related to enforcement of this\n21    Stipulated Protective Order.\n22    Date: ______________________________________\n23    City and State where sworn and signed: _________________________________\n24\n\n25    Printed name: _______________________________\n26\n\n27    Signature: __________________________________\n28\n\n                                               18\n\f     Case 2:24-cv-08093-FLA-E     Document 44 Filed 05/07/25         Page 19 of 19 Page ID\n                                           #:671\n\n\n 1                                     ATTESTATION\n 2         Pursuant to Civil L.R. 5-4.3.4(a)(2)(i), I hereby attest that all signatories\n 3 listed, and on whose behalf this filing is submitted, concur in the filing\u2019s content and\n\n 4 have authorized the filing.\n\n 5\n\n 6    Dated: May 6, 2025                            KING & SPALDING LLP\n 7\n                                                    By: /s/ Michael D. Roth\n 8                                                     MICHAEL D. ROTH\n 9                                                 Attorney for Defendant NIKE, INC.\n10\n\n11\n\n12\n\n13\n\n14\n\n15\n\n16\n\n17\n\n18\n\n19\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\n26\n\n27\n\n28\n\f","ocr_status":2,"date_upload":"2025-05-09T01:59:48.799922-07:00","document_number":"44","attachment_number":null,"pacer_doc_id":"031044882289","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Protective Order","acms_document_guid":""}],"date_created":"2025-05-08T10:36:07.426194-07:00","date_modified":"2025-06-07T02:36:42.506079-07:00","date_filed":"2025-05-07","time_filed":"10:03:33","entry_number":44,"recap_sequence_number":"2025-05-08.001","pacer_sequence_number":142,"description":"STIPLATED PROTECTIVE ORDER  by Magistrate Judge Charles F. Eick re: Notice of Joint Protective Order 43 . FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.  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PLAINTIFF LILLIAN JURDI\u2019S\n                                               NOTICE OF ERRATA RE DKT. 40-\n15    NIKE, INC.                               31\n16\n                                Defendants.\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n\n     PTF\u2019S NOTICE OF ERRATA                             2:24-CV-08093-GW-SK\n\f     Case 2:24-cv-08093-FLA-E     Document 42 Filed 05/05/25       Page 2 of 2 Page ID\n                                         #:627\n\n\n\n1         TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:\n2         Please take notice that Plaintiff Lillian Jurdi hereby submits this Notice of Errata to\n3 Dkt. 40-31 (Exhibit B to the Declaration of Samuel Cortina in Support of Defendant\n4 Nike, Inc.\u2019s Opposition to Plaintiff Lillian Jurdi\u2019s Motion to Compel Further Responses\n5 to Special Interrogatories and Requests for Production of Documents, Set One).\n6         The wrong document was inadvertently uploaded while filing Dkt. 40-31.\n7 Submitted with this Errata is the proper Exhibit B to the Declaration of Samuel Cortina.\n8\n9\n10 DATED: May 5, 2025                      TAULER SMITH LLP\n11\n12                                         By:    /s/ Narain Kumar\n13                                                Narain Kumar, Esq.\n                                                  Attorneys for Plaintiff\n14                                                Lillian Jurdi\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n                                                 -1-\n     PTF\u2019S NOTICE OF ERRATA                                  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CHAMBERS) ORDER TAKING MOTION OF DEFENDANT NICKE, INC. TO DISMISS FIRST AMENDED COMPLAINT (DKT. 20 ) UNDER SUBMISSION by Judge Fernando L. Aenlle-Rocha: The court finds that the Motion to Dismiss First Amended Complaint currently scheduled for hearing on February 7, 2025, is appropriate for decision without oral argument. Fed. R. Civ. P. 78(b); C.D. L.R. 7-15. Accordingly, this motion is taken UNDER SUBMISSION and the hearing is vacated. The court expects the parties to continue litigating this action diligently, while awaiting the court's ruling on this motion. No appearances are necessary. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (tf) TEXT ONLY ENTRY (Entered: 02/04/2025)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/419238957/","id":419238957,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/69182289/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/433151281/","id":433151281,"tags":[],"absolute_url":"/docket/69182289/33/lillian-jurdi-v-nike-inc/","date_created":"2025-03-13T16:43:56.053126-07:00","date_modified":"2025-03-13T16:43:56.059468-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"33","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2025-03-13T16:43:56.034344-07:00","date_modified":"2025-03-13T16:43:56.038675-07:00","date_filed":"2025-01-30","time_filed":null,"entry_number":33,"recap_sequence_number":"2025-01-30.001","pacer_sequence_number":null,"description":"(IN CHAMBERS) ORDER by Fernando L. Aenlle-Rocha: The court has reviewed the Joint Rule 26(f) Report submitted by the parties, and determines that an in-person Scheduling Conference is unnecessary. Accordingly, the court VACATES the January 31, 2025, Scheduling Conference. Order re Jury/Court Trial to issue.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. 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Aenlle-Rocha: In light of Plaintiff's filing of a first amended complaint (Dkt. 16 ), the Motion to Dismiss Plaintiff's Complaint (Dkt. 11 ) is DENIED as moot. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. 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