Stipulation and Order

Cal. Super. - 6th Dist.September 18, 2020

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 20CV371054. I 0n 12/1 3/2021 5207 PM same C'ara‘C'V” Reviewed By: R. Aragon Vincent Galvin #104448 EnvelOpe' 7854809 R' Arag‘ Neil M. Kliebenstein #226060 Lauren O. Miller #279448 BOWMAN AND BROOKE LLP 1741 Technology Drive, Suite 200 Filed San Jose, California 951 10-1364 December 15’ 2021 Telephone: (408) 279-5393 Facsimile: (408) 279-5845 Clerk of the Court vincentqalvin@bowmanandbrooke.com SUperior court Of CA neil.kliebenstein@bowmanandbr00ke.com county 0f santa Clara lauren.mi|Ier@bowmanandbrooke.com 20CV371 054 By: raragon Attorneys for Defendant Tesla, Inc. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA KRISTIAN EDWARDS and JASON EDWARDS Case No. 20CV371054 ADDENDUM TO PROTECTIVE ORDER REGARDING DISCOVERY MATERIALS EXEMPTING INFORMATION PRODUCED BY BOSCH FROM SHARING PROVISION ) ) ) ) Plaintiffs, ) ) vs. i AND fP-RGPGS-E-Bi-ORDER THEREON ) ) ) ) ) ) Assigned to: Hon. Christopher G. Rudy; Dept. 7 TESLA, |NC., Defendant. Whereas a Protective Order Regarding Discovery Materials was entered on March 18, 2021 (“Protective Order”) that applies to information produced by parties and third parties; Whereas Plaintiffs subpoenaed information from Robert Bosch LLC (“Bosch”); Whereas Bosch requests that the information it produces in response to the subpoena be exempted from the Sharing Provisions in the Protective Order. NOW, THEREFORE, in order to protect such information, as may be entitled to protection, and which is produced by Bosch in connection with this case including documents, deposition testimony, deposition exhibits, interrogatory responses, responses to request for admission, responses to request 1 ADDENDUM TO PROTECTIVE ORDER REGARDING DISCOVERY MATERIALS EXEMPTING INFORMATION 25509987“ ZOCV371 054 PRODUCED BY BOSCH FROM SHARING PROVISION 3 STIPULATION REGARDING 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 for production of documents, and all other discovery obtained pursuant to the California Code of Civil Procedure in connection with this Action (“Bosch Discovery Material”), the Parties, by and through their respective undersigned counsel and subject to the approval of the Court, agree as follows: Bosch Discovery Material will be subject to the terms of the Protective Order except the Sharing Provision at Paragraph i. The Bosch Discovery Material shall not be shared with the persons described in the Sharing Provision which is copied below: other attorneys of record in other pending lawsuits against Tesla, Inc. in the United States of America involving a claim that a defect in the front seat restraint system and/or airbag system of a 2012- 2020 Tesla Model 3, X or S vehicle resulted in a claim of personal injuries and/or death (“Sharing Attorneys”). Dated: BOWMAN AND BROOKE LLP Neil M. Kliebenstein Attorneys for Defendant Tesla, Inc. Dated: December 13, 2021 COHEN MILSTEIN SELLERS & TOLL PLLC Adam J. Langino Attorneys for Plaintiffs Kristian Edwards and Jason Edwards Dated: December 13, 2021 ARIAS SANGUINETTI WANG & TORRIJOS, LLP WEMum Elise Sanguhétti Attorneys for Plaintiffs Kristian Edwards and Jason Edwards 2 ADDENDUM TO PROTECTIVE ORDER REGARDING DISCOVERY MATERIALS EXEMPTING INFORMATION PRODUCED BY BOSCH FROM SHARING PROVISION 25509987V1 20CV371054 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: IT IS SO ORDERED. Honorable Christopher G. Rudy 3 ADDENDUM TO PROTECTIVE ORDER REGARDING DISCOVERY MATERIALS EXEMPTING INFORMATION PRODUCED BY BOSCH FROM SHARING PROVISION 25509987v1 December 15, 2021 Signed: 12/15/2021 10:22 AM 20CV371054 1O 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Kristen Edwards and Jason Edwards v. Tesla. Inc. Case No. 200V371054 PROOF OF SERVICE | am over 18 years of age, not a party to this action and employed in San Jose, California at 1741 Technology Drive, Suite 200, San Jose, California 951 10-1355. On the date indicated below, | served the foregoing documents described as ADDENDUM TO PROTECTIVE ORDER REGARDING DISCOVERY MATERIALS EXEMPTING INFORMATION PRODUCED BY BOSCH FROM SHARING PROVISION on all interested parties, or through their attorneys of record. in the manner noted, addressed as follows: Attorneys for Plaintiffs Theodore J. Leopold Cohen Milstein Sellers & Toll PLLC 11780 U.S. Highway One, Suite 500 Palm Beach Gardens, FL 33408 tleopold@cohenmilstein.com prazavi@cohenmilstein.com mhartnett@cohenmilstein.com pcasper@cohenmilstein.com Adam J. Langino Cohen Milstein Sellers & Toll PLLC 150 Fayetteville Street, Suite 980 Raleigh, NC 27601 alanqino©cohenmilstein.com Elise R. Sanguinetti Arias Sanguinetti Wang & Torrijos, LLP 2200 Powell Street, Suite 740 Emeryville, CA 94608 elise aswtlaw ers.com iamie@aswtlawyers.com assa|@aswtlawyers.com deborah@aswtlawvers.com _ VIA FIRST CLASS MAIL. | caused such envelope to be deposited in the mail at San Jose, California, in a sealed envelope with postage fully prepaid thereof. | am readily familiar with the firms business practice for collection and processing of correspondence for mailing with the United States Postal Service. The mail is deposited with the U.S. Postal Service on that same day in the ordinary course of business. | am aware that on motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. _ VIA OVERNIGHT DELIVERY SERVICE. The documents were enveloped, properly labeled, and caused to be deposited into an overnight delivery (Federal Express, United Parcel Service, etc.) receptacle or delivered to an authorized courier or driver authorized by the express service carrier to receive documents, in an envelope or a package designated by the express service carrier with delivery fees paid or provided for, addressed to the person on whom it is to be served, at the office address as last given by that person on any document filed in the case and served on that person; otherwise, at that person's place of residence. 1 22858824 1O 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 X BY ELECTRONIC SERVICE. The document was served electronically and the transmission was reported as complete and without error. The document was served on the above parties in this action by causing a true copy of said document to be transmitted by email pursuant to Emergency Rule 12 of Appendix | of the California Rules of Court. _ VIA FACSIMILE TRANSMISSION. The document was served on the above party in this action by causing a true copy of said document to be transmitted by facsimile to the number listed adjacent to the name on this Proof of Service. The transmission was reported as complete and without error. VIA PERSONAL SERVICE. | caused such envelope(s) to be delivered by hand this date to the offices of the addressee(s). | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed on December 13, 2021, at San Jose, California. Rebe‘cga A. Fuller 22858824