1 Mmsohhiahmabmi@adf oBrd. Shahrirhiasboin .(cSoBmN 337819) 2 Hilda Aguilar (SBN 276459) haguilar@fordharrison.com 3 Julie Bachert (SBN 328752) jbachert@fordharrison.com 4 FORD & HARRISON LLP 350 South Grand Avenue, Suite 2300 5 Los Angeles, CA 90071 Telephone: (213) 237-2400 6 Facsimile: (213) 237-2401 7 Attorneys for Defendant

WAL-MART ASSOCIATES, INC.

8 David Angeloff (SBN 272929) 9 david@stalwartlaw.com Cindy Hickox (SBN 323016) 10 cindy@stalwartlaw.com

STALWART LAW GROUP

11 8752 Holloway Drive West Hollywood, CA 90069 12 Telephone: (310) 954-2000 13 Attorneys for Plaintiff

NENITA JULIAN

14

UNITED STATES DISTRICT COURT

15

CENTRAL DISTRICT OF CALIFORNIA – SOUTHERN DIVISION

16 17 NENITA JULIAN, an individual, CASE NO. 8:24-cv-01878-JWH-AGR [Assigned to Hon. John W. Holcomb, 18 Plaintiff, Courtroom 9D] 19 v. STIPULATED PROTECTIVE

ORDER

20 WAL-MART ASSOCIATES, INC., a Delaware corporation; and DOES 1 21 through 10, inclusive, 22 Defendants. Date Filed: July 18, 2024 Trial Date: TBD 23 24 1. A. PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary, or private information for which special protection from public disclosure 27 and from use for any purpose other than prosecuting this litigation may be warranted. 28 Accordingly, the parties hereby stipulate to and petition the Court to enter the 1 following Stipulated Protective Order. The parties acknowledge that this Order does 2 not confer blanket protections on all disclosures or responses to discovery and that the 3 protection it affords from public disclosure and use extends only to the limited 4 information or items that are entitled to confidential treatment under the applicable 5 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 6 that this Stipulated Protective Order does not entitle them to e confidential 7 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 8 followed and the standards that will be applied when a party seeks permission from 9 the court to file material under seal. 10 B. GOOD CAUSE STATEMENT 11 This action is likely to involve trade secrets, customer and pricing lists and other 12 valuable research, development, commercial, financial, technical and/or proprietary 13 information for which special protection from public disclosure and from use for any 14 purpose other than prosecution of this action is warranted. Such confidential and 15 proprietary materials and information consist of, among other things, confidential 16 business or financial information, information regarding confidential business 17 practices, or other confidential research, development, or commercial information 18 (including information implicating privacy rights of third parties), information 19 otherwise generally unavailable to the public, or which may be privileged or otherwise 20 protected from disclosure under state or federal statutes, court rules, case decisions, 21 or common law. Among other things, the Parties anticipate that this action will likely 22 involve sensitive and private medical records of Plaintiff; confidential email 23 correspondence and other communications involving the operation of Walmart’s 24 stores; and confidential and proprietary documents relating to Walmart’s confidential 25 business or financial information, such as confidential information relating to 26 associate compensation and benefits. 27 Accordingly, to expedite the flow of information, to facilitate the prompt 28 resolution of disputes over confidentiality of discovery materials, to adequately 1 protect information the parties are entitled to keep confidential, to ensure that the 2 parties are permitted reasonable necessary uses of such material in preparation for and 3 in the conduct of trial, to address their handling at the end of the litigation, and serve 4 the ends of justice, a protective order for such information is justified in this matter. 5 It is the intent of the parties that information will not be designated as confidential for 6 tactical reasons and that nothing be so designated without a good faith belief that it 7 has been maintained in a confidential, non-public manner, and there is good cause 8 why it should not be part of the public record of this case. 9 2. DEFINITIONS 10 2.1 Action: this pending federal lawsuit entitled Nenita Julian v. Wal- 11 Mart Associates, Inc., et. al., Case No. 8:24-cv-01878-JWH-AGR. 12 2.2 Challenging Party: a Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for protection 16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 17 Cause Statement. “Confidential” Information or Items shall include materialsrelating 18 to any privileged, confidential, or nonpublic information, including, but not limited 19 to, trade secrets, research, design, development, financial, technical, marketing, 20 planning, personal, or commercial information, as such terms are used in the Federal 21 Rules of Civil Procedure (Fed. R. Civ.) and any applicable case law interpreting Fed. 22 R. Civ. 26(c)(1)(G); contracts; non-public compilations of retail prices; proprietary 23 information; vendor agreements; personnel files; claim/litigation information; and 24 nonpublic policies and procedures shall be deemed Confidential. 25 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 26 Information or Items: Materials containing corporate trade secrets, nonpublic 27 research and development data, including, but not limited to, cost data, pricing 28 formulas, inventory management programs, and other sales or business information 1 not known to the public; information obtained from a non-party pursuant to a non- 2 disclosure agreement; and customer-related Protected Data shall be deemed Highly 3 Confidential – Attorneys’ Eyes Only. 4 2.5 Protected Data: “Protected Data” shall refer to any information that a 5 party believes in good faith to be subject to federal, state or foreign data protection 6 laws or other privacy obligations. Examples of such data protection laws include but 7 are not limited to The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq. (financial 8 information); and, The Health Insurance Portability and Accountability Act and the 9 regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164 (medical 10 information). Certain Protected Data may compel alternative or additional 11 protections beyond those afforded Highly Confidential – Attorneys’ Eyes Only 12 material, in which event the parties shall meet and confer in good faith, and, if 13 unsuccessful, shall move the Court for appropriate relief. 14 2.6 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.7 Designating Party: a Party or Non-Party that designates information 17 or items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 19 ONLY.” 20 2.8 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.9 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 2.10 House Counsel: attorneys who are employees of a party to this Action. 28 House Counsel does not include Outside Counsel of Record or any other outside 1 counsel. 2 2.11 Non-Party: any natural person, partnership, corporation, association, 3 or other legal entity not named as a Party to this action. 4 2.12 Outside Counsel of Record: attorneys who are not employees of a 5 party to this Action but are retained to represent or advise a party to this Action and 6 have appeared in this Action on behalf of that party or are affiliated with a law firm 7 which has appeared on behalf of that party, and includes support staff. 8 2.13 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Outside Counsel of Record (and their 10 support staffs). 11 2.14 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.15 Professional Vendors: persons or entities that provide litigation 14 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) 16 and their employees and subcontractors. 17 2.16 Protected Material: any Disclosure or Discovery Material that is 18 designated as “CONFIDENTIAL.” 19 2.17 Receiving Party: a Party that receives Disclosure or Discovery 20 Material from a Producing Party. 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 trial judge. This Order does not govern the use of Protected Material at trial. 1 4. DURATION 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will 4 be presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are 6 made to the trial judge in advance of the trial. See Kamakana v. City and County of 7 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial. 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under 14 this Order must take care to limit any such designation to specific material that 15 qualifies under the appropriate standards. The Designating Party must designate for 16 protection only those parts of material, documents, items, or oral or written 17 communications that qualify so that other portions of the material, documents, items, 18 or communications for which protection is not warranted are not swept unjustifiably 19 within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating 24 Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 5.2 Manner and Timing of Designations. Except as otherwise provided in 1 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 2 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 3 under this Order must be clearly so designated before the material is disclosed or 4 produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other pretrial or trial 8 proceedings), that the Producing Party affix at a minimum, the legend 9 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 10 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains 11 protected material. If only a portion or portions of the material on a page qualifies for 12 protection, the Producing Party also must clearly identify the protected portion(s) 13 (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ 19 EYES ONLY.” After the inspecting Party has identified the documents it wants 20 copied and produced, the Producing Party must determine which documents, or 21 portions thereof, qualify for protection under this Order. Then, before producing the 22 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 23 to each page that contains Protected Material. If only a portion or portions of the 24 material on a page qualifies for protection, the Producing Party also must clearly 25 identify the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 / / / 28 / / / 1 (b) for testimony given in depositions that the Designating Party identify 2 the Disclosure or Discovery Material on the record, before the close of the deposition 3 all protected testimony. 4 (c) for information produced in some form other than documentary and 5 for any other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information is stored the 7 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 8 ONLY.” If only a portion or portions of the information warrants protection, the 9 Producing Party, to the extent practicable, shall identify the protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party’s right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37.1 et seq. 22 6.3 The burden of persuasion in any such challenge proceeding shall be 23 on the Designating Party. Frivolous challenges, and those made for an improper 24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 25 parties) may expose the Challenging Party to sanctions. Unless the Designating 26 Party has waived or withdrawn the confidentiality designation, all parties shall 27 continue to afford the material in question the level of protection to which it is 28 entitled under the Producing Party’s designation until the Court rules on the 1 challenge. 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 7.1 Basic Principles. A Receiving Party may use Protected Material that 4 is disclosed or produced by another Party or by a Non-Party in connection with this 5 Action only for prosecuting, defending, or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 conditions described in this Order. When the Action has been terminated, a Receiving 8 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 13 ATTORNEYS’ EYES ONLY” Information or Items. Unless otherwise ordered by 14 the court or permitted in writing by the Designating Party, a Receiving Party may 15 disclose any information or item designated “CONFIDENTIAL” or “HIGHLY 16 CONFIDENTIAL- ATTORNEYS’ EYES ONLY” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, 18 as well as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) 21 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 disclosure is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and 28 Professional Vendors to whom disclosure is reasonably necessary for this Action and 1 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (g) the author or recipient of a document containing the information 3 or a custodian or other person who otherwise possessed or knew the information; 4 (h) during their depositions, witnesses ,and attorneys for witnesses, 5 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 6 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 7 will not be permitted to keep any confidential information unless they sign the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 9 agreed by the Designating Party or ordered by the court. Pages of transcribed 10 deposition testimony or exhibits to depositions that reveal Protected Material may be 11 separately bound by the court reporter and may not be disclosed to anyone except as 12 permitted under this Stipulated Protective Order; and 13 (i) any mediator or settlement officer, and their supporting 14 personnel, mutually agreed upon by any of the parties engaged in settlement 15 discussions. 16 7.3 Non-Relevant Attachments. The Parties will not produce non-relevant 17 attachments that are attached to relevant emails. When an attachment is withheld, 18 either for privilege or non-responsiveness, the Producing Party shall produce a one- 19 page TIFF image (or PDF if production format dictates) in place of the withheld 20 attachment, correspondingly stating “Attachment Withheld-Privileged” or 21 “Attachment Withheld-Nonresponsive” and bearing a sequential BATES number 22 within the family BATES range. If any attachment to an email contains responsive 23 content, then the cover email shall be produced for context, regardless of the cover 24 email’s responsiveness. The cover email may be redacted in part to remove sensitive 25 information, as described below. 26 7.4 Redactions. The Parties may redact (1) information that is privileged or 27 protected from discovery as work product or by reason of any other applicable 28 privilege or immunity; (2) information subject to non-disclosure obligations imposed 1 by governmental authorities, law or regulation (e.g., protected personal information); 2 and (3) sensitive, non-relevant information, including but not limited to personally 3 identifiable information, trade secrets, or information regarding products, data, or 4 people. Privilege redactions will state, over the redacted portion, “Redacted– 5 Privileged,” and all other redactions will state, “Redacted–Nonresponsive.” 6 Redactions of emails will not redact the names of recipients or the subject line of the 7 emails, unless the subject line is itself privileged or contains the sensitive information 8 described above, in which case only so much of the subject line will be redacted as 9 may be needed. The parties will produce redacted documents in TIFF format (or 10 searchable PDF if production format dictates; or in native format for file types that 11 do not convert well to TIFF/PDF, such as Excel files) with corresponding searchable 12 OCR text and the associated metadata for the document, ensuring the redacted 13 content is fully protected from disclosure. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 15 IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 19 ONLY,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification 21 shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or 23 order to issue in the other litigation that some or all of the material covered by the 24 subpoena or order is subject to this Protective Order. Such notification shall include 25 a copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be 27 pursued by the Designating Party whose Protected Material may be affected. 28 If the Designating Party timely seeks a protective order, the Party served with 1 the subpoena or court order shall not produce any information designated in this 2 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ 3 EYES ONLY” before a determination by the court from which the subpoena or order 4 issued, unless the Party has obtained the Designating Party’s permission. The 5 Designating Party shall bear the burden and expense of seeking protection in that 6 court of its confidential material and nothing in these provisions should be construed 7 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 8 directive from another court. 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a 12 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 13 CONFIDENTIAL- ATTORNEYS’ EYES ONLY.” Such information produced by 14 Non-Parties in connection with this litigation is protected by the remedies and relief 15 provided by this Order. Nothing in these provisions should be construed as 16 prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 produce a Non-Party’s confidential information in its possession, and the Party is 19 subject to an agreement with the Non-Party not to produce the Non-Party’s 20 confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non- 22 Party that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 specific description of the information requested; and 27 (3) make the information requested available for inspection by the 28 Non-Party, if requested. 1 (c) If the Non-Party fails to seek a protective order from this court within 2 14 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s confidential information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court. 7 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 8 of seeking protection in this court of its Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A. 18 Information designated as “CONFIDENTIAL” or “HIGHLY 19 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” shall not be disclosed to any 20 current or former employees of, or current or former consultants, advisors, or agents 21 of, a direct competitor of any party named in the litigation. If a Receiving Party is in 22 doubt about whether a particular entity is a direct competitor of a party named in this 23 lawsuit, then before disclosing any Confidential Material to a current or former 24 employee, consultant, advisor, or agent of that entity, the Receiving Party’s counsel 25 must confer with counsel for the Producing Party. 26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 27 PROTECTED MATERIAL 28 When a Producing Party gives notice to Receiving Parties asserting a claim of 1 privilege, work-product protection, or other ground for reclaiming documents or 2 information (a “clawback request”), the obligations of the Receiving Parties are those 3 set forth in Federal Rule of Civil Procedure 26(b)(5)(B) and this Order. After a 4 clawback request is received, the Receiving Party shall immediately sequester the 5 document (if not already sequestered) and shall not review or use that document, or 6 any work product containing information taken from that document, for any purpose. 7 The Parties shall meet and confer regarding any clawback request. 8 This provision is not intended to modify whatever procedure may be established 9 in an e-discovery order that provides for production without prior privilege review. 10 Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an 11 agreement on the effect of disclosure of a communication or information covered by 12 the attorney-client privilege or work product protection, the parties may incorporate 13 their agreement in the stipulated protective order submitted to the court. 14 If the Receiving Party has reason to believe that a produced document or other 15 information may reasonably be subject to a claim of privilege, then the receiving 16 party shall immediately sequester the document or information, cease using the 17 document or information and cease using any work product containing the 18 information, and shall inform the Producing Party of the beginning BATES number 19 of the document or, if no BATES number is available, shall otherwise inform the 20 producing party of the information. 21 Further, the production of privileged or work-product protected documents, 22 electronically stored information (ESI) or information, whether inadvertent or 23 otherwise, is not a waiver of the privilege or protection from discovery in this case 24 or in any other federal or state proceeding. 25 This Order shall be interpreted to provide the maximum protection allowed by 26 Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and granted full 27 faith and credit in all other state and federal proceedings by 28 U.S. Code § 1738. In 28 the event of any subsequent conflict of law, the law that is most protective of privilege 1 and work product shall apply. Nothing contained herein is intended to or shall serve 2 to limit a party’s right to conduct a review of documents, ESI or information 3 (including metadata) for relevance, responsiveness and/or segregation of privileged 4 and/or protected information before production. 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 ground to use in evidence of any of the material covered by this Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 79-5, including Local Rule 15 79-5.2.2. Protected Material may only be filed under seal pursuant to a court order 16 authorizing the sealing of the specific Protected Material at issue. If a Party's request 17 to file Protected Material under seal is denied by the court, then the Receiving Party 18 may file the information in the public record unless otherwise instructed by the court. 19 12.4 Data Security. The Parties agree to provide adequate security to protect 20 data produced by the other party(ies) or by non-parties. This includes secure data 21 storage systems, established security policies, and security training for employees, 22 contractors and experts. Adequate security also includes such measures as data 23 encryption in transit, data encryption at rest, data access controls, and physical 24 security, whether hosted/outsourced to a vendor or on premises. At a minimum, any 25 receiving party subject to the terms of this Order, will provide reasonable measures 26 to protect non-client data consistent with the American Bar Association Standing 27 Committee on Ethics and Professional Responsibility, Formal Opinion 477R. 28 / / / 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 16 attorney work product, and consultant and expert work product, even if such materials 17 contain Protected Material. Any such archival copies that contain or constitute 18 Protected Material remain subject to this Protective Order as set forth in Section 4 19 (DURATION). 20 14. Any violation of this Order may be punished by any and all appropriate 21 measures including, without limitation, contempt proceedings and/or monetary 22 sanctions. 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 / / / 25 26 / / / 27 28 / / / 1 || Dated: October 17, 2024 Respectfully submitted, > FORD & HARRISON LLP 3 By: /s/ Mohammad B. Shihabi 4 MOHAMMAD B. SHIHABI 5 JULIE BACHERT Attorneys for Defendant 6 WAL-MART ASSOCIATES, INC. 7 8 || Dated: October 17, 2024 STALWART LAW GROUP 9 10 By: /s/ Cindy Hickox 11 DAVID ANGELOFF

CINDY HICKOX

12 Attorneys for Plaintiff 13 NENITA JULIAN 14 15

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED

16 17 DATED October 17, 2024 18 Uhaa h Keeinbenge 20 Judge Alicia G. Rosenberg 21 United States Magistrate Judge 22 23 24 25 26 27 28 & HARRISON

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [print or type full name], of 5 __________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 ________________ [date] in the case of Nenita Julian v. Wal-Mart Associates, Inc., 9 et. al., Case No. 8:24-cv-01878-JWH-AGR. I agree to comply with and to be bound 10 by all the terms of this Stipulated Protective Order and I understand and acknowledge 11 that failure to so comply could expose me to sanctions and punishment in the nature 12 of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person 14 or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ___________________________ [print 19 or type full name] of ______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ________________________________________ 24 City and State where sworn and signed: ________________________________ 25 Printed Name: ________________________ 26 Signature:____________________________ 27 28 1 ATTESTATION CLAUSE 2 I, Mohammad B. Shihabi, and the ECF user whose ID and password are being 3 used to file this Stipulated Protective Order, in compliance with Civil Local Rule 5- 4 4.3.4 (a)(2)(i), hereby attest that Attorneys for Plaintiff, Cindy Hickox of Stalwart 5 Law Group, concurred with this filing. 6 7 DATED: October 17, 2024 FORD & HARRISON LLP 8 9 By: /s/ Mohammad B. Shihabi 10 MOHAMMAD B. SHIHABI 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 CERTIFICATE OF SERVICE 2 I, Derek Cruz, declare: __ Iam a citizen of the United States and employed in Los Angeles County, 3 || California. I am over the age of eighteen years and not a party to the within-entitled action. My business address is 350 South Grand Avenue, Suite 2300, Los Angeles, 4 || California 90071. On October 17, 2024, I served a copy of the within document(s): 5 STIPULATED PROTECTIVE ORDER 6 ELECTRONICALLY: I caused a true and correct copy thereof to bs 7 electronically filed using the Court’s Electronic Court Filing ("ECF") □□□□□□ and service was completed by electronic means by transmittal of a Notice □□ 8 Electronic Filing on the registered participants of the ECF System. 9 oO U.S. MAIL: By placing the document(s) listed above in a sealed envelope 10 with postage thereon fully prepaid, in the United States mail at Los Angeles California addressed as set forth above. I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under tha’ 12 practice it would be deposited with the U.S. Postal Service on that same day B with postage thereon fully prepaid in the ordinary course of business. I ar aware that on motion of the party served, service is presumed invalid if posta 14 cancellation date or postage meter date is more than one day after date □□ 15 deposit for mailing in affidavit. 16 David Angcloft Attorneys for Plaintiff, Cindy Hickox NENITA JULIAN 17 STALWART LAW GROUP 8752 Holloway Drive 18 West Hollywood, CA 90069 Telephone: (310) 954-2000 19 SO ear conn cinady@stalwartiaw.com 20 Josh Montoya — josh@stalwartlaw.com 71 I declare under penalty of perjury under the laws of the State of California that 22 || the above is true and correct. 23 Executed on October 17, 2024, at Los Angeles, California. 24 25 26 oh Zz 27 28 & HARRISON

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