govinfo:USCOURTS-caed-2_24-cv-03384-9

STIPULATION REGARDING PROTECTIVE ORDER RE PLAINTIFF’S IDENTITY 
Case No. 2:24-cv-03384 
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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA 
J.M., an individual, 
Plaintiff, 
v. 
RED ROOF FRANCHISING, LLC, et al., 
Defendants. 
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Case No. 2:24-cv-03384-KJM-JDP 
 
Hon. Kimberly J. Mueller 
 
STIPULATION REGARDING PROTECTIVE 
ORDER RE PLAINTIFF’S IDENTITY 
 
 
  
Case 2:24-cv-03384-DC-JDP     Document 60     Filed 11/04/25     Page 1 of 6
 
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Pursuant to Fed. R. Civ. P. 26(c), Fed. R. Civ. P. 5.2, and its inherent authority, the Court hereby 
orders the entry of the following Stipulated Protective Order in this matter. 
1. Counsel for Plaintiff shall provide to the respective c ounsel for the Defendants the 
Plaintiff’s true identity and identifying information (“True Identity”) upon the entry of this Stipulated 
Protective Order by the Court. As used herein, True Identity includes, but is not limited to, information such 
as: 
a) Name and any alias names used at any time; 
b) Date of birth; 
c) Social Security Number; and 
d) Current address and any prior addresses from 2010 to present. 
The Parties may also designate as “True Identity” any documents, testimony, written responses, or 
other materials produced in this case if the producing Party has a good faith basis for asserting that they 
contain information, data, or  tangible items that refl ect Plaintiff’s True Identity, including identifying 
physical attributes such as biometric data or photographs showing unique physical attributes of Plaintiff, 
her voice, physical address of residence or workplace, or other personal private identification information 
which by a reasonable probability could be used to identify or locate Plaintiff. 
Notwithstanding the foregoing, Defendants expressly reserve their respective rights to request from 
Plaintiff during the course of discovery any other information that is linked or linkable to the True Identity 
of Plaintiff, such as, but not lim ited to, any medical, educational, financial, employment, or other 
information. The Plaintiff is permitted to proceed pseudonymously throughout the pre-trial course of these 
proceedings. The Parties excl usively will reference the Plaintiff through the pseud onym “J.M.” or as 
“Plaintiff” in all pre-trial public filings, throughout the course of discovery, and in all pre-trial public Court 
proceedings. 
2. Parties shall clearly mark any materials or information that contain Plaintiff’s True Identity 
with the term “CONFIDENTIAL TR UE IDENTITY” and the Parties sh all follow the procedures and 
requirements of this Protective Orde r concerning any materials or info rmation containing references to 
Plaintiff’s True Identity. 
3. The Parties may disclose Plaintiff’s True Identity to the following:  
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a. The Parties to this litigation, including any employees, agents, and representatives of the 
Parties, as needed to litigate any claims or defenses;  
b. Counsel for the Parties and employees, agents, and representatives of counsel as needed to 
litigate any claims or defenses; 
c. The Court, court personnel, and members of the jury; 
d. Court reporters, recorders, and videographe rs engaged for depositions. Before any 
disclosure to such persons, the person must sign the acknowledgement and agreement to be bound; 
e. Any mediator appointed by the Court or jointly selected by the Parties; 
f. Any expert witness, outside consultant, or inve stigator retained specifically in connection 
with this litigation and Plaintiff’s True Identity may be disclosed to them only to the extent that Plaintiff’s 
True Identity will assist the indivi dual(s) in the scope of their work w ith counsel in connection with this 
case; 
g. Any custodian of records, but only to the extent that Plaintiff’s True Identity will assist the 
custodian in obtaining and producing records; 
h. Independent providers of document reproduction, electronic discovery, translation, or other 
litigation services, including focu s groups, mock jurors, and jury consultants, retained or employed 
specifically in connection with this litigation. Before any disclosure to such persons, the person must sign 
the acknowledgement and agreement to be bound; 
i. Government agencies and agency  personnel, but only to the exte nt that the disclosure of 
Plaintiffs True Identity is necessary to litigate any claims or defenses or to comply with any obligations 
or requirements; 
j. Insurers and indemnitors for any of the Parties, including coverage counsel for the insurers, 
who may provide indemnity or other coverage in connection with claims asserted in this case. Before any 
disclosure to such persons, the person must sign the acknowledgement and agreement to be bound; 
k. Any potential, anticipated, or actual fact witn ess, and their counsel, but only to the extent 
Plaintiff’s True Identity will assist  the witness in recalling, relating or explaining facts -- except that 
Plaintiff’s True Identity must not be  disclosed to Plaintiff’s known trafficker(s) or Plaintiff’s traffickers’ 
known affiliate(s), unless the Parties follow the procedures in paragraph (l) below; 
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l. Plaintiff’s known traffi cker(s) or plain tiff’s traffickers’ known affiliate(s) and their 
counsel, but only to the extent Plai ntiff’s True Identity will assist the witness in recalling, relating or 
explaining facts; provided, however, that disclosure of Plaintiff’s True Identity information is permitted 
only if the party requests and obtains a Court order before making any disclosure. The moving party must 
file a motion describing the circumstances to the Court. The motion shall not include any information 
revealing Plaintiff’s True Identity and shall list only the reasons why Defendants believe it is necessary to 
reveal Plaintiff’s True Identity to Plaintiff’s alleged trafficker(s) or Plaint iff’s trafficker’s known 
associates. Before filing a conteste d motion, the parties must  first meet and confer , and if they reach 
agreement, they may submit a stipulated motion to the Court requesting such an order; 
m. The Parties are prohibited from disclosing Plaintiff’s True Identity to any person or entity 
other than those listed in this Stip ulated Protective Order. If the Part ies believe they have good cause to 
make a disclosure that is not aut horized under the terms of this Stip ulated Protective Order, they may 
bring a motion to the Court for an order allowing disclosure. 
4. The Court highly discourages the manual filing of any pleadings or documents under seal. 
Nothing in this Stipulated Protec tive Order authorizes the filing of protected materials under seal. This 
means that documents may not be filed with the Court under seal without prior permission as to each such 
filing, upon motion and for good cause shown, includi ng the legal basis for filing under seal. See Procter 
& Gamble Co. v. Bankers Trust Co. , 78 F.3d 219 (6th Cir. 1996). Thus, the Parties may seek the Court's 
permission to file documents that are necessarily unredacted under seal in accordance with this process. 
5. All Parties and any third parties appearing or submitting filings in this case are required to 
redact the True Identity and any identifying information (for example, full name, social security number, 
date of birth, address, medical records number) of Plaintiff in their filings with the Court. 
6. To the extent any Party or non-party has questions or concerns about whether any 
forthcoming filing complies with the requirements of this Order, such party or nonparty should seek leave 
of Court prior to submitting any such filing. 
7. The failure to identify Plaintiff in the Comp laint need not be addressed on the pleadings 
stage motions. 
/ / / 
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8. The Parties agree that Plaintiff’s medical records and medical billing will be identified and 
treated as confidential material and will be marked clearly with “Confidential - True Identity”. 
9. The Parties will comply with the good faith m eet-and-confer requirement in Fed. R. Civ. 
P. 37(a)(1) prior to seeking judicial  intervention if there are any disputes relating to this Stipulated 
Protective Order. 
 
IT IS SO STIPULATED. 
  
Dated:  November 4, 2025 
 
TUCKER ELLIS LLP 
 
 
By: /s/ Amanda Villalobos   
Amanda Villalobos (SBN 262176) 
amanda.villalobos@tuckerellis.com  
Nicholas Janizeh (SBN 307816) 
nicholas.janizeh@tuckerellis.com  
Roylance L. Bird IV (SBN 358102) 
roylance.bird@tuckerellis.com  
TUCKER ELLIS LLP 
515 South Flower St., 42nd Floor 
Los Angeles, CA  90071-2223 
Telephone: 213.430.3400 
Facsimile: 213.430.3409  
  
Chelsea Mikula (SBN 289330) 
chelsea.mikula@tuckerellis.com  
TUCKER ELLIS LLP 
950 Main Avenue, Suite 1100 
Cleveland, OH 44113 
Telephone: 216.592.5000 
Facsimile: 216.592.5009 
 
Attorneys for Defendant Red Roof Franchising, 
LLC 
 
 
DATED:  October 30, 2025 BABIN LAW LLC 
 
By: /s/ Penny L. Barrick   
Penny Barrick (admitted pro hac vice) 
penny.barrick@babinlaws.com  
10 West Broad Street, Ste. 900 
Telephone:  614.761.8800 
 
Attorneys for Plaintiff 
 
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IT IS SO ORDERED. 
 
 
Date:  November 4, 2025.   
 
 
 
 
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