1 || David L. Cheng (SBN 240926) dcheng @ fordharrison.com 2 | FORD & HARRISON LLP 350 South Grand Avenue, Suite 2300 3 | Los Angeles, CA 90071 Telephone: (213) 237-2400 4 || Facsimile: (213) 237-2401 5 Attorneys for Defendants, 6 | MARRIOTT INTERNATIONAL, INC.

SHERATON OPERATING

7 | CORPORATION, AND

SHERATON OPERATING, LLC

8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 | JENNY CUELLAR, an individual, CASE NO. 2:24-cv-06389-AB-MAR [Assigned to the Hon. André Birotte Jr] 13 Plaintiff,

STIPULATED PROTECTIVE ORDER

14 VS. 15 | MARRIOTT INTERNATIONAL, INC., a Delaware comoration dba W 16 | HOLLYWOOD; SHERATON Action Filed: June 18, 2024 OPERATING CORPORATION, a Removal Date: July 29, 2024 17 || Delaware corporation dba W

HOLLYWOOD; SHERATON

18 | OPERATING, LLC, a Delaware limited liability company; and DOES 19 || 1 through 20, inclusive 20 Defendants. 21 1. INTRODUCTION 22 33 1.1 PURPOSE AND LIMITATIONS

24 Discovery in this action is likely to involve production of confidential, 25 || proprietary, or private information for which special protection from public 26 || disclosure and from use for any purpose other than prosecuting this litigation may 27 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 2g || enter the following Stipulated Protective Order. The parties acknowledge that this & HARRISON LLP Fee

! | Order does not confer blanket protections on all disclosure or responses to 2 || discovery and that the protection it affords from public disclosure and use extends 3 || only to the limited information or items that are entitled to confidential treatment 4 || under the applicable legal principles. The parties further acknowledge, as set forth 5 || in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 6 || file confidential information under seal; Civil Local Rule 79-5 sets forth the 7 || procedures that must be followed and the standards that will be applied when a 8 | party seeks permission from the court to file material under seal. ° 1.2 GOOD CAUSE STATEMENT 8 This action is likely to involve personal, financial, and/or proprietary " information for which special protection from public disclosure and from use of any purpose other than prosecution of this action is warranted. Such confidential and ° proprietary materials and information consist of, among other things, confidential financial information, information regarding confidential personal information, or ° other information generally unavailable to the public, or which may be privileged or ‘6 otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow of information , to facilitate the prompt resolution of dispute over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep °° confidential, to ensure that the parties are permitted reasonably necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of litigation, and serve the ends of justice, a protective order for such information is justified in this matter. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief it has been maintained in a confidential, non- public manner, and there is good cause why it should not be part of the public 28

! || record of this case. 2 3 2. DEFINITIONS 4 5 2.1 Action: Jenny Cuellar v. Marriott International, Inc., et al., United 6 States District Court, Central District of California, Case No. 2:24-cv-06389-AB- 7 MAR. 8 2.2 Challenging Party: a Party or Non-Party that challenges the 9 || designations of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 | how it is generated, stored, or maintained) or tangible things that qualify for 12 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 | the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 | CONFIDENTIAL.” 20 2.6 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 23 || or generated in disclosures or responses to discovery in this matter, 24 2.7 Expert: a person with specialized knowledge or experience in a matter 29 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 I an expert witness or a consultant in this Action. 27 38 2.8 House Counsel: attorneys who are employees of a party to this Action. & HARRISON

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! || House Counsel does not include Outside Counsel of Record or any other outside 2 || counsel. 2.9 Non-Party: any natural person, partnership, corporation, association, or ‘ other legal entity not named as a Party to this action. 5 6 2.10 Outside Counsel of Record: attorneys who are not employees of a 7 || Party to this Action but are retained to represent or advise a party to this Action and 3 have appeared in this action on behalf of that party, including their support staff. 9 2.11 Party: any party to this Action, including all of its officers, directors, 10 || employees, consultants, retained experts, and Outside Counsel of Record (and their 11 || support staffs). 12 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 13 Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation ° support services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

19 2.14 Protected Material: any Disclosure or Discovery Material that is 0 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery 22 || Material from a Producing Party. 23 24 3. SCOPE 25 6 The protections conferred by this Stipulation and Order cover not only 47 || Protected Material (as defined above), but also (1) information copied or extracted 28 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

! || Protected Material; and (3) any testimony, conversations, or presentations by 2 | Parties or their Counsel that might reveal Protected Material. ° Any use of Protected Material at trial will be governed by the orders of the ‘ trial judge. This Order does not govern the use of Protected Material at trial. 5 6 7 | 4. DURATION 8 Once a case proceeds to trial, information that was designated as ? | CONFIDENTIAL or maintained pursuant to this protective order used or 10 | introduced as an exhibit at trial becomes public and will be presumptively available | to all members of the public, including the press, unless compelling reasons 12 supported by specific factual findings to proceed otherwise are made to the trial 13 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 14 “good cause” showing for sealing documents produced in discovery from 15 “compelling reasons” standard when merits-related documents are part of court 16 record). Accordingly, the terms of this protective order do not extend beyond the 17 | commencement of the trial. 18 19 99 | >. DESIGNATED PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 || Each Party or Non-Party that designates information or items for protection under 23 || this Order must take care to limit such designation to specific material that qualifies 24 || under the appropriate standards. The Designating Party must designate for 25 || protection only those parts of material, documents, items, or oral or written 26 || communications that qualify so that other portions of the material, documents, 27 || items, or communications for which protection is not warranted are not swept 28

! | unjustifiably within the ambit of this Order. ° Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper ‘ purpose (e.g., to unnecessarily encumber the case development process or to ° impose unnecessary expenses and burdens on other parties) may expose the ° Designating Party to sanctions. 7 3 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 || under this Order must be clearly so designated before the material is disclosed or 15 || produced. 16 Designation in conformity with this Order requires: " (a) For information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial proceedings, that the Producing Party affix at a minimum, the legend *° “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion or portions of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins).

5 A Party or Non-Party that makes original documents available for inspection 26 || need not designate them for protection until after the inspecting Party has indicated 57 || which documents it would like copied and produced. During the inspection and 4g || before the designation, all of the material made available for inspection will be

! || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 2 | documents it wants copied and produced, the Producing Party must determine 3 || which documents, or portions thereof, qualify for protection under this Order. Then, 4 || before producing the specified documents, the Producing Party must affix the 5 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 6 || portion or portions of the material on a page qualifies for protection, the Producing 7 | Party also must clearly identify the protected portion(s) (e.g., by making 8 | appropriate markings in the margins). ° (b) for testimony given in depositions that the Designating Party identify the '0 disclosure or Discovery Material on the record, before the close of the deposition " all protected testimony. 12 13 (c) for information produced in some form other than documentary and for 14 || any other tangible items, that the Producing Party affix in a prominent place on the 15 || exterior of the container or containers in which the information is stored the legend 16 | “CONFIDENTIAL.” If only a portion or portions of the information warrants 17 || protection, the Producing Party, to the extent practicable, will identify the protected 18 || portion(s). 19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent °° failure to designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon timely correction of a designation, the Receiving Party must make reasonable efforts to assure that the material is treated in accordance with the provisions of this Order.

26 | /// 27 /// 28

1 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1. Timing of Challenges. Any Party or Non-Party may challenge a ° designation of confidentiality at any time that is consistent with the Court’s ‘ Scheduling Order. 6.2 Meet and Confer. The Challenging Party will initiate the dispute 7 resolution process under Local Rule 37.1 et seq. 8 6.3. The burden of persuasion in any such challenge proceeding will be on 9 || the Designating Party. Frivolous challenges, and those made for an improper 10 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 || parties) may expose the Challenging Party to sanctions. Unless the Designating 12 || Party has waived or withdrawn the confidentiality designation, all parties will 13 || continue to afford the material in question the level of protection to which it 1s 14 || entitled under the Producing Party’s designation until the Court rules on the 15 || challenge. 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL

19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 0 disclosed or produced by another Party or by a Non-Party in connection with this 41 || Action only for prosecuting, defending, or attempting to settle this Action. Such 49 || Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a 44 || Receiving Party must comply with the provisions of section 13 below (FINAL 45 || 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 1s limited to the persons 28

! || authorized under this Order. 2 72 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 otherwise ordered by the court or permitted in writing by the Designating Party, a 4 Receiving Party may disclose any information or item designated 5 “CONFIDENTIAL?” only to: 6 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 3 well as employees of said Outside Counsel of Record to whom it is reasonably g || Necessary to disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of 11 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 | disclosure is reasonably necessary for this Action 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; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 || Vendors to whom disclosure is reasonably necessary for this Action and who have 20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 71 (g) the author or recipient of a document containing the information or 22 ll a custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in 24 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 25 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 26 5 they will not be permitted to keep any confidential information unless they sign the 7 38 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise & HARRISON

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! || agreed by the Designating Party or ordered by the court. Pages of transcribed 2 || deposition testimony or exhibits to depositions that reveal Protected Material may 3 || be separately bound by the court reporter and may not be disclosed to anyone 4 |’ except as permitted under this Stipulated Protective Order; and 5 (i) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 8 9 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 10 | INOTHER LITIGATION If a Party 1s served with a subpoena or a court order issued in other litigation 12 | that compels disclosure of any information or items designated in this Action as 13 | “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification 15 will include a copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or 18 order to issue in the other litigation that some or all of the material covered by the 19 subpoena or order is subject to this Protective Order. Such notification will include || copy of this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be 22 || pursued by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order will not produce any information designated in this 2° | action as “CONFIDENTIAL.” before a determination by the court from which the 26 subpoena or order issued, unless the Party has obtained the Designating Party’s 27 permission. The Designating Party will bear the burden and expense of seeking 28 & HARRISON

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! || protection in that court of its confidential material and nothing in these provisions 2 || should be construed as authorizing or encouraging a Receiving Party in this Action 3 || to disobey a lawful directive from another court. 4 5 6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a Non- 9 || Party in this Action and designated as “CONFIDENTIAL.” Such information 10 || produced by Non-Parties in connection with this litigation is protected by the 11 || remedies and relief provided by this Order. Nothing in these provisions should be 12 || construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party’s 16 | confidential information, then the Party will: " (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party;

4 (2) promptly provide the Non-Party with a copy of the Stipulated 49 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 43 || Specific description of the information requested; and 24 (3) make the information requested available for inspection by the 25 || Non-Party, if requested. 26 (c) If the Non-Party fails to seek a protective order from this court within 14 27 days of receiving the notice and accompanying information, the Receiving Party 28 ul

! || may produce the Non-Party’s confidential information responsive to the discovery 2 | request. If the Non-Party timely seeks a protective order, the Receiving Party shall 3 | not produce any information in its possession or control that is subject to the 4 || confidentiality agreement with the Non-Party before a determination by the court. 5 || Absent a court order to the contrary, the Non-Party shall bear the burden and 6 || expense of seeking protection in this court of its Protected Material. 7 8 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 14 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 15 || person or persons to whom unauthorized disclosures were made of all the terms of 16 || this Order, and (d) request such person or persons to execute the “Acknowledgment 17 || and Agreement to Be Bound” that is attached hereto as Exhibit A. 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

9 When a Producing Party gives notice to Receiving Parties that certain 93 || inadvertently produced material is subject to a claim of privilege or other 44 || Protection, the obligations of the Receiving Parties are those set forth in Federal 5 || Rule of Civil Procedure 26(b)\(5)(B). This provision is not intended to modify 46 || Whatever procedure may be established in an e-discovery order that provides for 57 || production without prior privilege review. Pursuant to Federal Rule of Evidence 9g || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

! | of communication or information covered by the attorney-client privilege or work 2 | product protection, the parties may incorporate their agreement in the stipulated 3 || protective order submitted to the court. 4 5 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 || person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 | Protective Order, no Party waives any right it otherwise would have to object to disclosing or producing any information or item on any ground not addressed in 12 | this Stipulated Protective Order. Similarly, no Party waives any right to object on 13 any ground to use in evidence of any of the material covered by this Protective Order, 15 oqe . 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Civil Local Rule 79-5. Protected Material 17 may only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party’s request to file Protected Material 19 under seal is denied by the court, then the Receiving Party may file the information 20 in the public record unless otherwise instructed by the court. 21 99 || /// 23 | /// 7) 25 /// 26 a7 | /// 28 | /// & HARRISON

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1 | 13. FINAL DISPOSITION ° After the final disposition of this Action, as defined in paragraph 4, within 60 ° days of a written request by the Designating Party, each Receiving Party must ‘ return all Protected Material to the Producing Party or destroy such material. As ° used in this subdivision, “all Protected Material” includes all copies, abstracts, ° compilations, summaries, and any other format reproducing or capturing any of the ’ Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if ° not the same person or entity, to the Designating Party) by the 60 day deadline that 8 (1) identifies (by category, where appropriate) all the Protected Material that was " returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or ° capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, ° deposition, and hearing transcripts, legal memoranda, correspondence, deposition 6 and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in Section 4 (DURATION).

5, || 14. Any willful violation of this Order may be punished by appropriate measures 49 || including, without limitation, contempt proceedings and/or monetary sanctions. /// Vr 25 26 || ///

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! IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 |DATED: /s/ Benjamin Juhn 4 Attorneys for Plaintiff 5 6 | DATED: /s/ David L. Cheng 7 Attorneys for Defendant 8 9 |FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 10

2 IDATED: 2/11/2025 United States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28

| ATTESTATION CLAUSE 2 I, David L. Cheng, and ECF user whose ID and password are being used to 3 || 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, Benjamin Juhn of Younessi 5 || Law, concurred with this filing. 6 7 DATED: January 30, 2025 FORD & HARRISON LLP br Lf Daa re — 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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 5 || that I have read in its entirety and understand the Stipulated Protective Order that 6 || was issued by the United States District Court for the Central District of California 7 on [date] in the case of Jenny Cuellar v. Marriott International, Inc., 8 | et al., United States District Court, Central District of California, Case No. ? || 2:24-cv-06389-AB-MAR. I agree to comply with and to be bound by all the terms 10 | of this Stipulated Protective Order and I understand and acknowledge that failure to 1 50 comply could expose me to sanctions and punishment in the nature of contempt. ty solemnly promise that I will not disclose in any manner any information or item 13 I that is subject to this Stipulated Protective Order to any person 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 M7 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 | connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 I Date: 24 City and State where signed: 2° || Printed name: 26 27 Signature: 28