1 PATRICIA T. STAMBELOS, Cal Bar No. 166998

STAMBELOS LAW OFFICE

2 543 Country Club Dr., Ste. B209 Simi Valley, CA 93065 3 Telephone: 805.578.3474 E mail patricia@patriciastambelos.com 4

5 Attorneys for Plaintiff AMANDA

BALDINO-MILLER

6

7 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership 8 Including Professional Corporations GREG STEPHEN LABATE, Cal Bar No. 149918 9 KRISTI L. THOMAS, Cal Bar No. 276511 650 Town Center Drive, 10th Floor 10 Costa Mesa, California 92626-1993 Telephone: 714.513.5100 11 Facsimile: 714.513.5130 E mail glabate@sheppardmullin.com 12 kthomas@sheppardmullin.com

13 Attorneys for Defendants COURTYARD 14 MANAGEMENT CORPORATION (now known as COURTYARD 15 MANAGEMENT, LLC) AND

MARRIOTT INTERNATIONAL, INC.

16

17

UNITED STATES DISTRICT COURT

18

EASTERN DISTRICT OF CALIFORNIA

19 AMANDA BALDINO-BMILLER, on Case No. 1:23-CV-01613-BAM 20 behalf of herself and all similarly aggrieved employees, 21 STIPULATED Plaintiff, PROTECTIVE ORDER 22 v. 23 COURTYARD MANAGEMENT District Court Judge: Pending 24 CORPORATION; MARRIOTT Courtroom 8 (6th Floor) INTERNATIONAL, INC.; and DOES 1 25 through 50, inclusive,

26 Defendants.

27 1 Plaintiff AMANDA BALDINO-MILLER (“Plaintiff”) and Defendants 2 COURTYARD MANAGEMENT CORPORATION (now known as COURTYARD 3 MANAGEMENT, LLC) AND MARRIOTT INTERNATIONAL, INC. 4 (“Defendants”), (collectively, the “Parties,” and separately, a “Party”), through their 5 respective counsel, hereby agree to the following Stipulated Protective Order: 6 1. PURPOSES AND LIMITATIONS 7 Disclosure and discovery activity in this action are likely to involve production 8 of confidential, proprietary, or private information for which special protection from 9 public disclosure and from use for any purpose other than prosecuting this litigation 10 may be warranted. Accordingly, the Parties hereby stipulate to and petition the court 11 to enter the following Stipulated Protective Order. The Parties acknowledge that this 12 Order does not confer blanket protections on all disclosures or responses to discovery 13 and that the protection it affords from public disclosure and use extends only to the 14 limited information or items that are entitled to confidential treatment under the 15 applicable legal principles. The Parties further acknowledge, as set forth in Section 16 12.3, below, that this Stipulated Protective Order does not entitle them to file 17 confidential information under seal; Civil Local Rule 141 sets forth the procedures 18 that must be followed and the standards that will be applied when a party seeks 19 permission from the court to file material under seal. 20 2. DEFINITIONS 21 2.1 Challenging Party: a Party or Non-Party that challenges the designation 22 of information or items under this Order. 23 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 24 how it is generated, stored or maintained) or tangible things that qualify for protection 25 under Federal Rule of Civil Procedure 26(c). 26 2.3 Counsel (without qualifier): Outside Counsel of Record and House 27 Counsel (as well as their support staff). 1 items that it produces in disclosures or in responses to discovery as 2 “CONFIDENTIAL.” 3 2.5 Disclosure or Discovery Material: all items or information, regardless of 4 the medium or manner in which it is generated, stored, or maintained (including, 5 among other things, testimony, transcripts, and tangible things), that are produced or 6 generated in disclosures or responses to discovery in this matter. 7 2.6 Expert: a person with specialized knowledge or experience in a matter 8 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 9 expert witness or as a consultant in this action. 10 2.7 House Counsel: attorneys who are employees of a Party to this action. 11 House Counsel does not include Outside Counsel of Record or any other outside 12 counsel. 13 2.8 Non-Party: any natural person, partnership, corporation, association, or 14 other legal entity not named as a Party to this action. 15 2.9 Outside Counsel of Record: attorneys who are not employees of a Party 16 to this action but are retained to represent or advise a Party to this action and have 17 appeared in this action on behalf of that Party or are affiliated with a law firm which 18 has appeared on behalf of that Party. 19 2.10 Party: any party to this action, including all of its officers, directors, 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 23 Discovery Material in this action. 24 2.12 Professional Vendors: persons or entities that provide litigation support 25 services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 and their employees and subcontractors. 1 designated as “CONFIDENTIAL.” 2 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material 3 from a Producing Party. 4 3. SCOPE 5 The protections conferred by this Stipulation and Order cover not only 6 Protected Material (as defined above), but also (1) any information copied or extracted 7 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 8 Protected Material; and (3) any testimony, conversations, or presentations by Parties 9 or their Counsel that might reveal Protected Material. However, the protections 10 conferred by this Stipulation and Order do not cover the following information: (a) 11 any information that is in the public domain at the time of disclosure to a Receiving 12 Party or becomes part of the public domain after its disclosure to a Receiving Party as 13 a result of publication not involving a violation of this Order, including becoming part 14 of the public record through trial or otherwise; and (b) any information known to the 15 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 16 disclosure from a source who obtained the information lawfully and under no 17 obligation of confidentiality to the Designating Party. Any use of Protected Material 18 at trial shall be governed by a separate agreement or order. 19 4. DURATION 20 Even after final disposition of this litigation, the confidentiality obligations 21 imposed by this Order shall remain in effect until a Designating Party agrees 22 otherwise in writing or a court order otherwise directs. Final disposition shall be 23 deemed to be the later of (1) dismissal of all claims and defenses in this action, with or 24 without prejudice; and (2) final judgment herein after the completion and exhaustion 25 of all appeals, rehearings, remands, trials, or reviews of this action, including the time 26 limits for filing any motions or applications for extension of time pursuant to 27 applicable law. 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under this 4 Order must take care to limit any such designation to specific material that qualifies 5 under the appropriate standards. The Designating Party must designate for protection 6 only those parts of material, documents, items, or oral or written communications that 7 qualify – so that other portions of the material, documents, items, or communications 8 for which protection is not warranted are not swept unjustifiably within the ambit of 9 this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber or retard the case development process or to 13 impose unnecessary expenses and burdens on other parties) expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the mistaken designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) For information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each 27 page that contains protected material. If only a portion or portions of the material on a 1 protected portion(s) (e.g., by making appropriate markings in the margins). 2 A Party or Non-Party that makes original documents or materials available for 3 inspection need not designate them for protection until after the inspecting Party has 4 indicated which material it would like copied and produced. During the inspection 5 and before the designation, all of the material made available for inspection shall be 6 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 7 it wants copied and produced, the Producing Party must determine which documents, 8 or portions thereof, qualify for protection under this Order. Then, before producing 9 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 10 legend to each page that contains Protected Material. If only a portion or portions of 11 the material on a page qualifies for protection, the Producing Party also must clearly 12 identify the protected portion(s) (e.g., by making appropriate markings in the 13 margins). 14 (b) for testimony given in deposition or in other pretrial or trial proceedings, 15 that the Designating Party identify on the record, before the close of the deposition, 16 hearing, or other proceeding, all protected testimony. 17 (c) for information produced in some form other than documentary and for 18 any other tangible items, that the Producing Party affix in a prominent place on the 19 exterior of the container or containers in which the information or item is stored the 20 legend “CONFIDENTIAL.” If only a portion or portions of the information or item 21 warrant protection, the Producing Party, to the extent practicable, shall identify the 22 protected portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. 26 Upon timely correction of a designation, the Receiving Party must make reasonable 27 efforts to assure that the material is treated in accordance with the provisions of this 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time. Unless a prompt challenge to a Designating 4 Party’s confidentiality designation is necessary to avoid foreseeable, substantial 5 unfairness, unnecessary economic burdens, or a significant disruption or delay of the 6 litigation, a Party does not waive its right to challenge a confidentiality designation by 7 electing not to mount a challenge promptly after the original designation is disclosed. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 9 resolution process by providing written notice of each designation it is challenging 10 and describing the basis for each challenge. To avoid ambiguity as to whether a 11 challenge has been made, the written notice must recite that the challenge to 12 confidentiality is being made in accordance with this specific paragraph of the 13 Protective Order. The Parties shall attempt to resolve each challenge in good faith and 14 must begin the process by conferring directly (in voice to voice dialogue; other forms 15 of communication are not sufficient) within 14 days of the date of service of notice. 16 In conferring, the Challenging Party must explain the basis for its belief that the 17 confidentiality designation was not proper and must give the Designating Party an 18 opportunity to review the designated material, to reconsider the circumstances, and, if 19 no change in designation is offered, to explain the basis for the chosen designation. A 20 Challenging Party may proceed to the next stage of the challenge process only if it has 21 engaged in this meet and confer process first or establishes that the Designating Party 22 is unwilling to participate in the meet and confer process in a timely manner. 23 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 24 court intervention, the Designating Party shall file and serve a motion to retain 25 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 79- 26 5, if applicable) within 21 days of the initial notice of challenge or within 14 days of 27 the parties agreeing that the meet and confer process will not resolve their dispute, 1 declaration affirming that the movant has complied with the meet and confer 2 requirements imposed in the preceding paragraph. Failure by the Designating Party to 3 make such a motion including the required declaration within 21 days (or 14 days, if 4 applicable) shall automatically waive the confidentiality designation for each 5 challenged designation. In addition, the Challenging Party may file a motion 6 challenging a confidentiality designation at any time if there is good cause for doing 7 so, including a challenge to the designation of a deposition transcript or any portions 8 thereof. Any motion brought pursuant to this provision must be accompanied by a 9 competent declaration affirming that the movant has complied with the meet and 10 confer requirements imposed by the preceding paragraph. 11 The burden of persuasion in any such challenge proceeding shall be on the 12 Designating Party. Frivolous challenges, and those made for an improper purpose 13 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 14 expose the Challenging Party to sanctions. Unless the Designating Party has waived 15 the confidentiality designation by failing to file a motion to retain confidentiality as 16 described above, all Parties shall continue to afford the material in question the level 17 of protection to which it is entitled under the Producing Party’s designation until the 18 court rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is 21 disclosed or produced by another Party or by a Non-Party in connection with this case 22 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 23 Material may be disclosed only to the categories of persons and under the conditions 24 described in this Order. When the litigation has been terminated, a Receiving Party 25 must comply with the provisions of section 13 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 location and in a secure manner that ensures that access is limited to the persons 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 4 only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this action, as well 6 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 7 disclose the information for this litigation and who have signed the “Acknowledgment 8 and Agreement to Be Bound” that is attached hereto as Exhibit A; 9 (b) the officers, directors, and employees (including House Counsel) of the 10 Receiving Party to whom disclosure is reasonably necessary for this litigation and 11 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this litigation and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the court and its personnel; 16 (e) court reporters and their staff, professional jury or trial consultants, mock 17 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 18 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); 20 (f) during their depositions, witnesses in the action to whom disclosure is 21 reasonably necessary and who have signed the “Acknowledgment and Agreement to 22 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 23 by the court. Pages of transcribed deposition testimony or exhibits to depositions that 24 reveal Protected Material must be separately bound by the court reporter and may not 25 be disclosed to anyone except as permitted under this Stipulated Protective Order. 26 (g) the author or recipient of a document containing the information or a 27 custodian or other person who otherwise possessed or knew the information. 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena or 10 order is subject to this Protective Order. Such notification shall include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order shall not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material – and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this action to 21 disobey a lawful directive from another court. 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 23 IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the 27 remedies and relief provided by this Order. Nothing in these provisions should be 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality agreement 7 with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this litigation, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the Non- 12 Party. 13 (c) If the Non-Party fails to object or seek a protective order from this court 14 within 14 days of receiving the notice and accompanying information, the Receiving 15 Party may produce the Non-Party’s confidential information responsive to the 16 discovery request. If the Non-Party timely seeks a protective order, the Receiving 17 Party shall not produce any information in its possession or control that is subject to 18 the confidentiality agreement with the Non-Party before a determination by the court. 19 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 20 of seeking protection in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 1 Agreement to Be Bound” that is attached hereto as Exhibit A. 2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 8 may be established in an e-discovery order that provides for production without prior 9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 10 parties reach an agreement on the effect of disclosure of a communication or 11 information covered by the attorney-client privilege or work product protection, the 12 parties may incorporate their agreement in the stipulated protective order submitted to 13 the court. 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. Without written permission from the 23 Designating Party or a court order secured after appropriate notice to all interested 24 persons, a Party may not file in the public record in this action any Protected Material. 25 A Party that seeks to file under seal any Protected Material must comply with Civil 26 Local Rule 141. Protected Material may only be filed under seal pursuant to a court 27 order authorizing the sealing of the specific Protected Material at issue. Pursuant to 1 the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 2 entitled to protection under the law. If a Receiving Party's request to file Protected 3 Material under seal pursuant to Civil Local Rule 141 is denied by the court, then the 4 Receiving Party may file the information in the public record pursuant to Civil Local 5 Rule 141 unless otherwise instructed by the court. 6 13. FINAL DISPOSITION 7 Within 60 days after the final disposition of this action, as defined in paragraph 8 4, each Receiving Party must return all Protected Material to the Producing Party or 9 destroy such material. As used in this subdivision, “all Protected Material” includes 10 all copies, abstracts, compilations, summaries, and any other format reproducing or 11 capturing any of the Protected Material. Whether the Protected Material is returned or 12 destroyed, the Receiving Party must submit a written certification to the Producing 13 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 14 deadline that (1) identifies (by category, where appropriate) all the Protected Material 15 that was returned or destroyed and (2) affirms that the Receiving Party has not 16 retained any copies, abstracts, compilations, summaries or any other format 17 reproducing or capturing any of the Protected Material. Notwithstanding this 18 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 19 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 20 deposition and trial exhibits, expert reports, attorney work product, and consultant and 21 expert work product, even if such materials contain Protected Material. Any such 22 archival copies that contain or constitute Protected Material remain subject to this 23 Protective Order as set forth in Section 4 (DURATION). 24 / / / 25 / / / 26 / / / 27 / / / 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 Dated: September 3, 2024 SHEPPARD, MULLIN, RICHTER &

HAMPTON LLP

4

5 6 By /s/ Kristi L. Thomas

GREG LABATE

7

KRISTI L. THOMAS

8 Attorneys for Defendants COURTYARD MANAGEMENT CORPORATION and 9

MARRIOTT INTERNATIONAL, INC.

10 11 Dated: September 3, 2024 STAMBELOS LAW OFFICE

12

13 14 By /s/ Patricia T. Stambelos

PATRICIA T. STAMBELOS

15 Attorneys for Plaintiff 16 AMANDA BALDINO-MILLER

17

18

19

20 21 22 23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Northern District of California on 7 [date] in the case of AMANDA BALDINO-MILLER, on behalf of herself and all 8 similarly aggrieved employees, Plaintiff, v. COURTYARD MANAGEMENT 9 CORPORATION; MARRIOTT INTERNATIONAL, INC.; and DOES 1 through 50, 10 inclusive, Defendants, Case No. 1:23-CV-01613-BAM. 11 I agree to comply with and to be bound by all the terms of this Stipulated 12 Protective Order and I understand and acknowledge that failure to so comply could 13 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 14 that I will not disclose in any manner any information or item that is subject to this 15 Stipulated Protective Order to any person or entity except in strict compliance with the 16 provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States District Court 18 for the Eastern District of California for the purpose of enforcing the terms of this 19 Stipulated Protective Order, even if such enforcement proceedings occur after 20 termination of this action. 21 I hereby appoint __________________________ [print or type full name] of 22 ____________________________________ [print or type full address and telephone 23 number] as my California agent for service of process in connection with this action or 24 any proceedings related to enforcement of this Stipulated Protective Order. 25 Date: ______________________________________ 26 City and State where sworn and signed: _________________________________ 27 Printed name: _______________________________ 1 ORDER 2 Having considered the above stipulation and finding good cause, the Court 3 adopts the signed stipulated protective order with the amendment that a section of 4 paragraph 6.3 is amended from “If the Parties cannot resolve a challenge without court 5 intervention, the Designating Party shall file and serve a motion to retain 6 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 79- 7 5, if applicable)…” to “If the Parties cannot resolve a challenge without court 8 intervention, the Designating Party shall file and serve a motion to retain 9 confidentiality under Civil Local Rule 251…” 10 The parties are advised that pursuant to the Local Rules of the United States 11 District Court, Eastern District of California, any documents subject to the protective 12 order to be filed under seal must be accompanied by a written request which complies 13 with Local Rule 141 prior to sealing. The party making a request to file documents 14 under seal shall be required to show good cause for documents attached to a non- 15 dispositive motion or compelling reasons for documents attached to a dispositive 16 motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009). 17 Within five (5) days of any approved document filed under seal, the party shall file a 18 redacted copy of the sealed document. The redactions shall be narrowly tailored to 19 protect only the information that is confidential or was deemed confidential. 20 Additionally, the parties shall consider resolving any dispute arising under the 21 protective order according to the Court’s informal discovery dispute procedure. 22 23 IT IS SO ORDERED.

24 Dated: September 9, 2024 /s/ Barbara A. McAuliffe _ 25 UNITED STATES MAGISTRATE JUDGE

26 27