CROSNER LEGAL, P.C.

1 Michael T. Houchin (SBN 305541) 2 mhouchin@crosnerlegal.com 3 Craig W. Straub (SBN 249032) craig@crosnerlegal.com 4 Zachary M. Crosner (SBN 272295) 5 zach@crosnerlegal.com 9440 Santa Monica Blvd. Suite 301 6 Beverly Hills, CA 90210 7 Tel: (866) 276-7637 8 Fax: (310) 510-6429

9 Attorneys for Plaintiff and the Proposed Class 10

11

UNITED STATES DISTRICT COURT

12 FOR THE CENTRAL DISTRICT OF CALIFORNIA

13 14 JESSICA ROBERTSON, individually Case No. 5:24-cv-1478-SSS (DBTx) and on behalf of all others similarly 15 situated, STIPULATED PROTECTIVE 16 ORDER Plaintiff, 17

DISCOVERY MATTER

18 v. 19

CLEAN CONTROL CORPORATION,

20

21 Defendant. 22 23 24 25 26 27 28 1 1. 2 A. PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth 12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 13 file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve trade secrets, customer and pricing lists and 18 other valuable research, development, commercial, financial, technical and/or 19 proprietary information for which special protection from public disclosure and from 20 use for any purpose other than prosecution of this action is warranted. Such 21 confidential and proprietary materials and information consist of, among other 22 things, confidential business or financial information, information regarding 23 confidential business practices, or other confidential research, development, or 24 commercial information (including information implicating privacy rights of third 25 parties), information otherwise generally unavailable to the public, or which may be 26 privileged or otherwise protected from disclosure under state or federal statutes, 27 court rules, case decisions, or common law. Accordingly, to expedite the flow of 28 information, to facilitate the prompt resolution of disputes over confidentiality of 1 discovery materials, to adequately protect information the parties are entitled to keep 2 confidential, to ensure that the parties are permitted reasonable necessary uses of 3 such material in preparation for and in the conduct of trial, to address their handling 4 at the end of the litigation, and serve the ends of justice, a protective order for such 5 information is justified in this matter. It is the intent of the parties that information 6 will not be designated as confidential for tactical reasons and that nothing be so 7 designated without a good faith belief that it has been maintained in a confidential, 8 non-public manner, and there is good cause why it should not be part of the public 9 record of this case. 10 2. DEFINITIONS 11 2.1 Action: This pending federal law suit. 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 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 Designating Party: A Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: All items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced 26 or generated in disclosures or responses to discovery in this matter. 27 28 1 2.7 Expert: A person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 House Counsel: Attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: Any natural person, partnership, corporation, association, 8 or other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: Attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm which 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: Any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: Persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: Any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: A Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 27 28 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 Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Once a case proceeds to trial, all of the information that was designated as 11 confidential or maintained pursuant to this protective order becomes public and will 12 be presumptively available to all members of the public, including the press, unless 13 compelling reasons supported by specific factual findings to proceed otherwise are 14 made to the trial judge in advance of the trial. See Kamakana v. City and County of 15 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record). Accordingly, the 18 terms of this protective order do not extend beyond the commencement of the trial. 19 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. 21 Each Party or Non-Party that designates information or items for protection under 22 this Order must take care to limit any such designation to specific material that 23 qualifies under the appropriate standards. The Designating Party must designate for 24 protection only those parts of material, documents, items, or oral or written 25 communications that qualify so that other portions of the material, documents, items, 26 or communications for which protection is not warranted are not swept unjustifiably 27 within the ambit of this Order. 28 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating 5 Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 a) For information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or trial 17 proceedings), that the Producing Party affix at a minimum, the legend 18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 19 contains protected material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection shall be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine which 28 documents, or portions thereof, qualify for protection under this Order. Then, before 1 producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 3 portion or portions of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 5 markings in the margins). 6 b) for testimony given in depositions that the Designating Party identify 7 the Disclosure or Discovery Material on the record, before the close of the deposition 8 all protected testimony. 9 c) for information produced in some form other than documentary andfor 10 any other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, shall identify the protected 14 portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the Court’s 24 Scheduling Order. 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 26 resolution process under Local Rule 37.1 et seq. 27 6.3 The burden of persuasion in any such challenge proceeding shall be on 28 the Designating Party. Frivolous challenges, and those made for an improper 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating Party 3 has waived or withdrawn the confidentiality designation, all parties shall continue to 4 afford the material in question the level of protection to which it is entitled under the 5 Producing Party’s designation until the Court rules on the challenge. 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this 9 Action only for prosecuting, defending, or attempting to settle this Action. Such 10 Protected Material may be disclosed only to the categories of persons and under the 11 conditions described in this Order. When the Action has been terminated, a 12 Receiving Party must comply with the provisions of section 13 below (FINAL 13 DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 18 otherwise ordered by the court or permitted in writing by the Designating Party, a 19 Receiving Party may disclose any information or item designated 20 “CONFIDENTIAL” only to: 21 a) The Receiving Party’s Outside Counsel of Record in this Action, as 22 well as employees of said Outside Counsel of Record to whom it is reasonably 23 necessary to disclose the information for this Action; 24 b) the officers, directors, and employees (including House Counsel) of the 25 Receiving Party to whom disclosure is reasonably necessary for this Action; 26 c) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 d) the court and its personnel; 2 e) court reporters and their staff; 3 f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 h) during their depositions, witnesses , and attorneys for witnesses, in the 9 Action to whom disclosure is reasonably necessary provided: (1) The deposing party 10 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 11 will not be permitted to keep any confidential information unless they sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may 15 be separately bound by the court reporter and may not be disclosed to anyone except 16 as permitted under this Stipulated Protective Order; and 17 i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 20 PRODUCED IN OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation 22 that compels disclosure of any information or items designated in this Action as 23 “CONFIDENTIAL,” that Party must: 24 a) Promptly notify in writing the Designating Party. Such notification 25 shall include a copy of the subpoena or court order; 26 b) promptly notify in writing the party who caused the subpoena or order 27 to issue in the other litigation that some or all of the material covered by the subpoena 28 1 or order is subject to this Protective Order. Such notification shall include a copy of 2 this Stipulated Protective Order; and 3 c) cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” before a determination by the court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action 12 to disobey a lawful directive from another court. 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 a) The terms of this Order are applicable to information produced by a 16 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 17 produced by Non-Parties in connection with this litigation is protected by the 18 remedies and relief provided by this Order. Nothing in these provisions should be 19 construed as prohibiting a Non-Party from seeking additional protections. 20 b) In the event that a Party is required, by a valid discovery request, to 21 produce a Non-Party’s confidential information in its possession, and the Party is 22 subject to an agreement with the Non-Party not to produce the Non-Party’s 23 confidential information, then the Party shall: 24 1) Promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement 26 with a Non-Party; 27 28 1 2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 3) make the information requested available for inspection by the Non- 5 Party, if requested. 6 c) If the Non-Party fails to seek a protective order from this court within 7 14 days of receiving the notice and accompanying information, the Receiving Party 8 may produce the Non-Party’s confidential information responsive to the discovery 9 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 10 not produce any information in its possession or control that is subject to the 11 confidentiality agreement with the Non-Party before a determination by the court. 12 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 13 of seeking protection in this court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 18 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 19 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 20 or persons to whom unauthorized disclosures were made of all the terms of this 21 Order, and (d) request such person or persons to execute the “Acknowledgment and 22 Agreement to Be Bound” that is attached hereto as Exhibit A. 23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 24 OTHERWISE PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 1 may be established in an e-discovery order that provides for production without prior 2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 parties reach an agreement on the effect of disclosure of a communication or 4 information covered by the attorney-client privilege or work product protection, the 5 parties may incorporate their agreement in the stipulated protective order submitted 6 to the court. 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 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 may 17 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 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 days of a written request by the Designating Party, each Receiving Party must return 24 all Protected Material to the Producing Party or destroy such material. As used in 25 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected 27 Material. Whether the Protected Material is returned or destroyed, the Receiving 28 Party must submit a written certification to the Producing Party (and, if not the same 1 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 2 (by category, where appropriate) all the Protected Material that was returned or 3 destroyed and (2)affirms that the Receiving Party has not retained any copies, 4 abstracts, compilations, summaries or any other format reproducing or capturing any 5 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 6 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 7 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 8 reports, attorney work product, and consultant and expert work product, even if such 9 materials contain Protected Material. Any such archival copies that contain or 10 constitute Protected Material remain subject to this Protective Order as set forth in 11 Section 4 (DURATION). 12 14. Any violation of this Order may be punished by any and all appropriate 13 measures including, without limitation, contempt proceedings and/or monetary 14 sanctions. 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 17 18 Dated: June 4, 2025 CROSNER LEGAL, P.C. 19

20 By: /s/ Michael T. Houchin 21 MICHAEL T. HOUCHIN

22

23

24 Dated: June 4, 2025 NORTON ROSE FULBRIGHT US LLP

25 By: /s/ Joshua D. Lee 26

JOSHUA D. LEE

27

28 1 |} FOR GOOD CAUSE SHOWN, IT IS SO 9 ORDERED. 4 DATED: June 5, 2025

7 | Hon. David T. Bristow 8 || United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -]3- Robertson v. Clean Control Corporation, Case No. 5:24-cv-1478-SSS (DBTx)

STIPUT. ATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ____________________________________________ [print or type full name], 4 of ________________________________________________________________ 5 [print or type full address], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California in the case of Robertson v. 8 Clean Control Corporation, Case No. 5:24-cv-1478-SSS (DBTx). 9 I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is subject 13 to this Stipulated Protective Order to any person or entity except in strict compliance 14 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 ________________________________ 19 [print or type full name] of 20 __________________________________________________________________ 21 full address and telephone number] as my California agent for service of process in 22 connection with this action or any proceedings related to enforcement of this 23 Stipulated Protective Order. 24 Date: __________________________ 25 City and state where signed:________________________________ 26 Printed name: ___________________________________________ 27 28 Signature:_______________________________________________