Motion for protective order; request for sanctions
SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA Department 10 Honorable Jeffrey B. El-Hajj Blanca Than, Courtroom Clerk 191 North First Street, San Jose, CA 95113 Telephone: 408-882-2210
DATE: June 30, 2026 TIME: 9:00 A.M. / 9:01 A.M. To contest the ruling, call (408) 808-6856 before 4:00 P.M. Make sure to let the other side know before 4:00 P.M. that you plan to contest the ruling. (Cal. Rules of Court, rule 3.1308(a)(1); Local Rule 8.D.)
**Please specify the issue to be contested when calling the Court and counsel**
Line 8 25CV470666 Megan Valencia et al. Defendant Lyft, Inc.’s (Lyft) motion for protective order and request v. Lyft, Inc. et al. for sanctions. Notice is proper and the motion is opposed by plaintiff Edward Apolinar.
A party may move for a protective order in response to a discovery request. (Code Civ. Proc., § 2031.060.) On a showing of good cause, a court may issue a protective order directing that, among other things, “trade secret or other confidential research, development, or commercial information not be disclosed, or be disclosed only to specified persons or only in a specified way.” (Id., subd. (b)(5).)
Lyft seeks a protective order because discovery requests from plaintiffs seek disclosure of proprietary application data. Lyft’s requested protective order does not prohibit disclosure of information to plaintiffs. It instead merely protects how that information can be used. The request is sufficiently routine that many counties, including Santa Clara, have model protective orders. The court finds good cause for the protective order. Plaintiff Apolinar argues he will be prejudiced by the protective order, but does not persuasively explain that prejudice. The motion is GRANTED.
The court orders that the Model Confidentiality Order published by the Complex Division of the Santa Clara County Superior Court applies to all proceedings in these consolidated cases.
The court finds no substantial justification for plaintiff Apolinar’s refusal to enter into a stipulated protective order. The court acknowledges that Lyft’s notice of motion did not expressly request sanctions, as required by Code of Civil Procedure section 2023.040. But the court finds the supporting memorandum and declaration provided plaintiff adequate notice of the request. The request for sanctions is GRANTED IN PART. Plaintiff Apolinar and his counsel of record are jointly and severally responsible to pay Lyft $1,000 ($60 filing fee plus four hours of attorney fees at $235/hour). The court will prepare the order.
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