1 Kevin M. Loew (SBN 238080) kloew@waterskraus.com 2 Susan M. Ulrich (SBN 302253) sulrich@waterskraus.com 3 Nicole R. Poursalimi (SBN 248440) npoursalimi@waterskraus.com 4 WATERS KRAUS PAUL & SIEGEL 11601 Wilshire Boulevard, Suite 1900 5 Los Angeles, CA 90025 Telephone: (310) 414-8146 6 Facsimile: (310) 414-8156

7 Attorneys for Plaintiff John DM Doe 8 Rick Richmond (SBN 194962) 9 rrichmond@larsonllp.com Andrew E. Calderón (SBN 316673) 10 acalderon@larsonllp.com Tyler J. Franklin (SBN 324281) 11 tfranklin@larsonllp.com

LARSON LLP

12 555 South Flower Street, 30th Floor Los Angeles, California 90071 13 Telephone:(213) 436-4888 Facsimile: (213) 623-2000 14 Attorneys for Defendants The Church of 15 Jesus Christ of Latter-day Saints and Temple Corporation of The Church of 16 Jesus Christ of Latter-day Saints

17 UNITED STATES DISTRICT COURT 18 CENTRAL DISTRICT OF CALIFORNIA 19 JOHN DM DOE, Case No. 2:24-cv-11053-SB (SSCx)

20 Plaintiff, Judge: Hon. Stanley Blumenfeld, Jr.

21 vs. [Discovery Document: Referred to Magistrate Judge Stephanie S. Christensen] 22 THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a nonprofit [PROPOSED] STIPULATED 23 corporation; TEMPLE PROTECTIVE ORDER

CORPORATION OF THE CHURCH

24 OF JESUS CHRIST OF LATTER-DAY Trial Date: None Set SAINTS, nonprofit corporation; THE 25 LONG BEACH CALIFORNIA EAST STAKE, also know as THE CHURCH 26 OF JESUS CHRIST OF LATTER-DAY SAINTS, an entity of unknown form; 27 and DOES 1 to 100 inclusive, 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than 5 prosecuting this litigation may be warranted. Accordingly, the parties hereby 6 stipulate to and petition the court to enter the following Stipulated Protective Order. 7 The parties acknowledge that this Order does not confer blanket protections on all 8 disclosures or responses to discovery and that the protection it affords from public 9 disclosure and use extends only to the limited information or items that are entitled 10 to confidential treatment under the applicable legal principles. 11 1.2 Good Cause Statement. 12 This Action arises from allegations of childhood sexual abuse and is likely to 13 involve medical records, psychiatric records, confidential church membership 14 records, and other private information implicating the privacy rights of third parties 15 for which special protection from public disclosure and from use for any purpose 16 other than prosecution of this action is warranted. Accordingly, to expedite the flow 17 of information, to facilitate the prompt resolution of disputes over confidentiality of 18 discovery materials, to adequately protect information the parties are entitled to keep 19 confidential, to ensure that the parties are permitted reasonable necessary uses of 20 such material in preparation for and in the conduct of trial, to address their handling 21 at the end of the litigation, and serve the ends of justice, a protective order for such 22 information is justified in this matter. It is the intent of the parties that information 23 will not be designated as confidential for tactical reasons and that nothing be so 24 designated without a good faith belief that it has been maintained in a confidential, 25 non-public manner, and there is good cause why it should not be part of the public 26 record of this case. 27 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 1 Protective Order does not entitle them to file confidential information under seal; 2 Local Rule 79-5 sets forth the procedures that must be followed and the standards 3 that will be applied when a party seeks permission from the court to file material 4 under seal. 5 There is a strong presumption that the public has a right of access to judicial 6 proceedings and records in civil cases. In connection with non-dispositive motions, 7 good cause must be shown to support a filing under seal. See Kamakana v. City 8 and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 9 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar- 10 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 11 protective orders require good cause showing), and a specific showing of good 12 cause or compelling reasons with proper evidentiary support and legal justification, 13 must be made with respect to Protected Material that a party seeks to file under 14 seal. The parties’ mere designation of Disclosure or Discovery Material as 15 CONFIDENTIAL does not—without the submission of competent evidence by 16 declaration, establishing that the material sought to be filed under seal qualifies as 17 confidential, privileged, or otherwise protectable—constitute good cause. 18 Further, if a party requests sealing related to a dispositive motion or trial, 19 then compelling reasons, not only good cause, for the sealing must be shown, and 20 the relief sought shall be narrowly tailored to serve the specific interest to be 21 protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 22 2010). For each item or type of information, document, or thing sought to be filed 23 or introduced under seal in connection with a dispositive motion or trial, the party 24 seeking protection must articulate compelling reasons, supported by specific facts 25 and legal justification, for the requested sealing order. Again, competent evidence 26 supporting the application to file documents under seal must be provided by 27 declaration. 1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. 3 If documents can be redacted, then a redacted version for public viewing, omitting 4 only the confidential, privileged, or otherwise protectable portions of the document, 5 shall be filed. Any application that seeks to file documents under seal in their 6 entirety should include an explanation of why redaction is not feasible. 7 2. DEFINITIONS 8 2.1 Action: John DM Doe v. Church of Jesus Christ of Latter-day Saints, et 9 al, No. 2:24-cv-11053-SB (SSCx) 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation 11 of information or items under this Order. 12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 13 how it is generated, stored or maintained) or tangible things that qualify for 14 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified 15 above in the Good Cause Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless 22 of the medium or manner in which it is generated, stored, or maintained (including, 23 among other things, testimony, transcripts, and tangible things), that are produced or 24 generated in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as 27 an expert witness or as a consultant in this Action. 1 in this Action, with or without prejudice; and (2) final judgment herein after the 2 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 3 this Action, including the time limits for filing any motions or applications for 4 extension of time pursuant to applicable law. 5 2.9 In-House Counsel: attorneys who are employees of a party to this 6 Action, and, for purposes of Defendants, attorneys from Kirton McConkie and their 7 staff. In-House Counsel does not include Outside Counsel of Record or any other 8 outside counsel. 9 2.10 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.11 Outside Counsel of Record: attorneys who are not employees of a party 12 to this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party, and includes support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.14 Professional Vendors: persons or entities that provide litigation- 21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Stipulated Protective Order does not govern the use of Protected 9 Material at trial. 10 4. TRIAL AND DURATION 11 The terms of this Stipulated Protective Order apply through Final Disposition 12 of the Action. 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 15 used or introduced as an exhibit at trial becomes public and will be presumptively 16 available to all members of the public, including the press, unless compelling 17 reasons supported by specific factual findings to proceed otherwise are made to the 18 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 19 (distinguishing “good cause” showing for sealing documents produced in discovery 20 from “compelling reasons” standard when merits-related documents are part of 21 court record). Accordingly, for such materials, the terms of this Stipulated 22 Protective Order do not extend beyond the commencement of the trial. 23 Even after Final Disposition of this litigation, the confidentiality obligations 24 imposed by this Stipulated Protective Order shall remain in effect until a 25 Designating Party agrees otherwise in writing or a court order otherwise directs. 26 5. DESIGNATING PROTECTED MATERIAL 27 5.1 Exercise of Restraint and Care in Designating Material for 1 protection under this Order must take care to limit any such designation to 2 specific material that qualifies under the appropriate standards. The 3 Designating Party must designate for protection only those parts of material, 4 documents, items, or oral or written communications that qualify so that other 5 portions of the material, documents, items, or communications for which 6 protection is not warranted are not swept unjustifiably within the ambit of this 7 Order. 8 Mass, indiscriminate, or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber the case development process or to 11 impose unnecessary expenses and burdens on other parties) may expose the 12 Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 5.2 Manner and Timing of Designations. Except as otherwise 17 provided in this Stipulated Protective Order (see, e.g., second paragraph of 18 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 19 Discovery Material that qualifies for protection under this Stipulated 20 Protective Order must be clearly so designated before the material is disclosed 21 or produced. 22 Designation in conformity with this Stipulated Protective Order requires: 23 (a) for information in documentary form (e.g., paper or electronic 24 documents, but excluding transcripts of depositions or other pretrial or trial 25 proceedings), that the Producing Party affix at a minimum, the legend 26 “CONFIDENTIAL” to each page that contains protected material. If only a 27 portion or portions of the material on a page qualifies for protection, the Producing 1 appropriate markings in the margins). 2 A Party or Non-Party that makes original documents available for inspection 3 need not designate them for protection until after the inspecting Party has indicated 4 which documents it would like copied and produced. During the inspection and 5 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 8 documents, or portions thereof, qualify for protection under this Stipulated 9 Protective Order. Then, before producing the specified documents, the Producing 10 Party must affix the “CONFIDENTIAL” legend to each page that contains 11 Protected Material. If only a portion or portions of the material on a page qualifies 12 for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party identify 15 the Disclosure or Discovery Material on the record, before the close of the 16 deposition all protected testimony. 17 (c) for information produced in some form other than documentary and 18 for any other tangible items, that the Producing Party affix in a prominent place on 19 the exterior of the container or containers in which the information is stored the 20 “CONFIDENTIAL” legend. If only a portion or portions of the information 21 warrants 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 24 inadvertent failure to designate qualified information or items does not, 25 standing alone, waive the Designating Party’s right to secure protection under 26 this Order for such material. Upon timely correction of a designation, the 27 Receiving Party must make reasonable efforts to assure that the material is 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 that is consistent with the court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 7 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”1 8 6.3 The burden of persuasion in any such challenge proceeding shall 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 shall 13 continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the court rules on the 15 challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that 18 is disclosed or produced by another Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending, or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Order. When the Action reaches a Final Disposition, a 22 Receiving Party must comply with the provisions of section 13 below. 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Stipulated Protective Order. 26

27 1 Judge Christensen’s Procedures are available at https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen. 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 4 “CONFIDENTIAL” only: 5 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 6 well as employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) to the officers, directors, and employees (including House Counsel) of 9 the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) to Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) to the court and its personnel; 14 (e) to court reporters and their staff; 15 (f) to professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) to the author or recipient of a document containing the information or 19 a custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, to witnesses, and attorneys for witnesses, in 21 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing 22 party requests that the witness sign the “Acknowledgment and Agreement to Be 23 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any 24 confidential information unless they sign the “Acknowledgment and Agreement to 25 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 26 ordered by the court. Pages of transcribed deposition testimony or exhibits to 27 depositions that reveal Protected Material may be separately bound by the court 1 Stipulated Protective Order; and 2 (i) to any mediator or settlement officer, and their supporting personnel, 3 mutually agreed upon by any of the parties engaged in settlement discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 5 PRODUCED IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification 10 shall include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order 12 to issue in the other litigation that some or all of the material covered by the 13 subpoena or order is subject to this Protective Order. Such notification shall include 14 a copy of this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be 16 pursued by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served 18 with the subpoena or court order shall not produce any information designated in 19 this action as “CONFIDENTIAL” before a determination by the court from which 20 the subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this Action 24 to disobey a lawful directive from another court. 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 9.1 Application. The terms of this Stipulated Protective Order are 1 designated as “CONFIDENTIAL.” Such information produced by Non- 2 Parties in connection with this litigation is protected by the remedies and 3 relief provided by this Order. Nothing in these provisions should be 4 construed as prohibiting a Non-Party from seeking additional protections. 5 9.2 Notification. In the event that a Party is required, by a valid 6 discovery request, to produce a Non-Party’s confidential information in its 7 possession, and the Party is subject to an agreement with the Non-Party not 8 to produce the Non-Party’s confidential information, then the Party shall: 9 (a) promptly notify in writing the Requesting Party and the 10 Non-Party that some or all of the information requested is subject to a 11 confidentiality agreement with a Non-Party; 12 (b) make the information requested available for inspection 13 by the Non-Party, if requested. 14 9.3 Conditions of Production. If the Non-Party fails to seek a 15 protective order from this court within 14 days of receiving the notice and 16 accompanying information, the Receiving Party may produce the Non-Party’s 17 confidential information responsive to the discovery request. If the Non-Party 18 timely seeks a protective order, the Receiving Party shall not produce any 19 information in its possession or control that is subject to the confidentiality 20 agreement with the Non-Party before a determination by the court. Absent a 21 court order to the contrary, the Non-Party shall bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has 25 disclosed Protected Material to any person or in any circumstance not authorized 26 under this Stipulated Protective Order, the Receiving Party must immediately (a) 27 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 1 the person or persons to whom unauthorized disclosures were made of all the terms 2 of this Order, and (d) request such person or persons to execute the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other 8 protection, the obligations of the Receiving Parties are those set forth in Rule 9 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended 10 to modify whatever procedure may be established in an e-discovery order that 11 provides for production without prior privilege review. Pursuant to Rules 502(d) 12 and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement 13 on the effect of disclosure of a communication or information covered by the 14 attorney-client privilege or work product protection, the parties may incorporate 15 their agreement in the stipulated protective order submitted to the court. 16 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 18 abridges the right of any person to seek its modification by the court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 Stipulated Protective Order no Party waives any right it otherwise would have to 21 object to disclosing or producing any information or item on any ground not 22 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 23 to object on any ground to use in evidence of any of the material covered by this 24 Stipulated Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Local Rule 79-5. Protected Material may 27 only be filed under seal pursuant to a court order authorizing the sealing of the 1 under seal is denied by the court, then the Receiving Party may file the information 2 in the public record unless otherwise instructed by the court. 3 13. FINAL DISPOSITION 4 After the Final Disposition of this Action, as defined in paragraph 4, within 5 60 days of a written request by the Designating Party, each Receiving Party must 6 return all Protected Material to the Producing Party or destroy such material. As 7 used in this subdivision, “all Protected Material” includes all copies, abstracts, 8 compilations, summaries, and any other format reproducing or capturing any of the 9 Protected Material. Whether the Protected Material is returned or destroyed, the 10 Receiving Party must submit a written certification to the Producing Party (and, if 11 not the same person or entity, to the Designating Party) by the 60 day deadline that 12 (1) identifies (by category, where appropriate) all the Protected Material that was 13 returned or destroyed and (2) affirms that the Receiving Party has not retained any 14 copies, abstracts, compilations, summaries or any other format reproducing or 15 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 16 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 17 and hearing transcripts, legal memoranda, correspondence, deposition and trial 18 exhibits, expert reports, attorney work product, and consultant and expert work 19 product, even if such materials contain Protected Material. Any such archival 20 copies that contain or constitute Protected Material remain subject to this Protective 21 Order as set forth in Section 4. 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 1}}14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any 3 || and all appropriate measures including, without limitation, contempt proceedings 4 || and/or monetary sanctions. 5|}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 || Dated: February 7, 2025 WATERS KRAUS PAUL & SIEGEL 7 8

Kevin M. Loew 10 Susan M. Ulrich 11 Nicole R. Poursalimi 1D Attorneys for Plaintiff John DM Doe

13 14 Dated: February 13, 2025 LARSON LLP

15 16 By: Wad y hf f 17 Rick Richmond 18 Andrew E. Calderon Tyler J. Franklin 19 Attorneys for Defendants The Church of 20 Jesus Christ of Latter-day Saints and Temple Corporation of The Church of 21 Jesus Christ of Latter-day Saints 22 23

IT IS SO ORDERED.

24 L— DATED: February 14, 2025 26 STEPHANIE S. CHRISTENSEN 17 UNITED STATES MAGISTRATE JUDGE 28