1 Steven W. Ritcheson Amy Simpson 2 SBN:174062 SBN: 241090 INSIGHT, PLC Holland & Knight LLP 3 578 Washington Blvd. #503 1901 Avenue of the Stars, Suite 1200 4 Marina del Rey, California 90292 Los Angeles, California 90067 5 Sadie Mlika (pro hac vice) 6 Jessica H. Zafonte (pro hac vice) Holland & Knight LLP CHIESA SHAHINIAN & 10 St. James Avenue, 11th Floor 7 GIANTOMASI PC Boston, Massachusetts 02116 8 11 Times Square, 34th Floor New York, NY 10036 Attorneys for Workwear Outfitters, 9

LLC

10 Attorney for Plaintiff Careismatic Brands, LLC 11 12

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

14 15 CAREISMATIC BRANDS, LLC, Case No. 2-23-cv-09570-GW-JC 16 Plaintiff, 17 v. STIPULATED PROTECTIVE 18 ORDER

WORKWEAR OUTFITTERS, LLC,

19 [CHANGES MADE BY COURT 20 Defendant. TO PARAGRAPHS 3, 8.4, 9.3] 21

WORKWEAR OUTFITTERS, LLC,

22 23 Counter-Claimant, 24 v. 25 CAREISMATIC BRANDS, LLC, 26 Counter-Defendant. 27 1 Pursuant to Local Civil Rule 37, Plaintiff and Counter-Defendant Careismatic 2 Brands, LLC (“Plaintiff”) and Defendant and Counter-Claimant Workwear 3 Outfitters, LLC (“Defendant”) (collectively, the “Parties”), in the above-captioned 4 matter, through their counsel of record, hereby submit this stipulated protective order 5 and stipulate and agree as follows: 6 1. INITIAL MATTERS 7 1.1 Purposes and Limitations 8 Discovery in this action is likely to involve production of confidential, 9 proprietary, or private information for which special protection from public 10 disclosure and from use for any purpose other than prosecuting this litigation may 11 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 12 enter the following Stipulated Protective Order. The parties acknowledge that this 13 Order does not confer blanket protections on all disclosures or responses to 14 discovery and that the protection it affords from public disclosure and use extends 15 only to the limited information or items that are entitled to confidential treatment 16 under the applicable legal principles. The parties further acknowledge, as set forth 17 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 18 file confidential information under seal; Civil Local Rule 79-5 sets forth the 19 procedures that must be followed and the standards that will be applied when a party 20 seeks permission from the court to file material under seal. 21 1.2. Good Cause Statement 22 This action is likely to involve trade secrets, customer and pricing lists and 23 other valuable research, development, commercial, financial, technical and/or 24 proprietary information for which special protection from public disclosure and from 25 use for any purpose other than prosecution of this action is warranted. Such 26 confidential and proprietary materials and information consist of, among other 27 2 1 things, confidential business or financial information, information regarding 2 confidential business practices, or other confidential research, development, or 3 commercial information (including information implicating privacy rights of third 4 parties), information otherwise generally unavailable to the public, or which may be 5 privileged or otherwise protected from disclosure under state or federal statutes, 6 court rules, case decisions, or common law. Accordingly, to expedite the flow of 7 information, facilitate the prompt resolution of disputes over confidentiality of 8 discovery materials, adequately protect information the parties are entitled to keep 9 confidential, ensure that the Parties are permitted reasonable necessary uses of such 10 material in preparation for and in the conduct of trial, address their handling at the 11 end of the litigation, and serve the ends of justice, a protective order for such 12 information is justified in this matter. It is the intent of the Parties that information 13 will not be designated as confidential for tactical reasons and that nothing be so 14 designated without a good faith belief that it has been maintained in a confidential, 15 non-public manner, and there is good cause why it should not be part of the public 16 record of this case. 17 1.3 Acknowledgement of Procedure for Filing Under Seal 18 The parties further acknowledge, as set forth in Section 12.3, below, that this 19 Stipulated Protective Order does not entitle them to file confidential information 20 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 21 and the standards that will be applied when a party seeks permission from the court 22 to file material under seal. 23 There is a strong presumption that the public has a right of access to judicial 24 proceedings and records in civil cases. In connection with non-dispositive motions, 25 good cause must be shown to support a filing under seal. See Kamakana v. City and 26 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 27 3 1 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 2 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 3 good cause showing), and a specific showing of good cause or compelling reasons 4 with proper evidentiary support and legal justification, must be made with respect to 5 Protected Material that a party seeks to file under seal. The parties’ mere designation 6 of Disclosure or Discovery Material as “CONFIDENTIAL” or “HIGHLY 7 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” does not—without the 8 submission of competent evidence by declaration, establishing that the material 9 sought to be filed under seal qualifies as confidential, privileged, or otherwise 10 protectable—constitute good cause. 11 Further, if a party requests sealing related to a dispositive motion or trial, then 12 compelling reasons, not only good cause, for the sealing must be shown, and the 13 relief sought shall be narrowly tailored to serve the specific interest to be protected. 14 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 15 each item or type of information, document, or thing sought to be filed or introduced 16 under seal in connection with a dispositive motion or trial, the party seeking 17 protection must articulate compelling reasons, supported by specific facts and legal 18 justification, for the requested sealing order. Again, competent evidence supporting 19 the application to file documents under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable in 21 its entirety will not be filed under seal if the confidential portions can be redacted. 22 If documents can be redacted, then a redacted version for public viewing, omitting 23 only the confidential, privileged, or otherwise protectable portions of the document 24 shall be filed. Any application that seeks to file documents under seal in their 25 entirety should include an explanation of why redaction is not feasible. 26 /// 27 4 1 2. DEFINITIONS 2 2.1 Action: Careismatic Brands, LLC v. Workwear Outfitters, LLC, Case 3 No. 2-23-cv-09570 (C.D. Cal.). 4 2.2 Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 10 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 11 Information or Items: Highly sensitive confidential information or items that 12 contains sensitive financial, technical, research and development, business strategy, 13 or other competitive information that the designating party believes, in good faith, 14 could cause it to suffer competitive harm if known by entities or persons who would 15 otherwise have access to it under this Order. 16 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.6 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” or as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 21 ONLY.” 22 2.7 Disclosure or Discovery Material: all items or information, regardless 23 of the medium or manner in which they are generated, stored, or maintained 24 (including, among other things, testimony, transcripts, and tangible things), that are 25 produced or generated in disclosures or responses to discovery in this matter. /// 26

27 5 1 2.8 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 2.9 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 2.10 Non-Party: any natural person, partnership, corporation, association, 8 or other legal entity not named as a Party to this action. 9 2.11 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, including support staff. 13 2.12 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 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.14 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 2.15 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL” or as “HIGHLY CONFIDENTIAL – 24 ATTORNEYS’ EYES ONLY.” 25 2.16 Receiving Party: a Party that receives Disclosure or Discovery 26 Material from a Producing Party. 27 6 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 other 7 than during a court hearing or at trial. 8 Any use of Protected Material during a court hearing or at trial shall be 9 governed by the orders of the presiding judge. This Order does not govern the use 10 of Protected Material during a court hearing or at trial. 11 4. DURATION 12 Even after final disposition of this litigation, the confidentiality obligations 13 imposed by this Order shall remain in effect until a Designating Party agrees 14 otherwise in writing or a court order otherwise directs. Final disposition shall be 15 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 16 or without prejudice; and (2) final judgment herein after the completion and 17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 18 including the time limits for filing any motions or applications for extension of time 19 pursuant to applicable law. 20 5. DESIGNATING 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 any such designation to specific material that 24 qualifies 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, items, 27 7 1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 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 5.2.1 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: 17 5.2.1 for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or trial 19 proceedings), that the Producing Party affix at a minimum, the legend 20 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 21 EYES ONLY” (hereinafter, “Legend”), to each page that contains protected 22 material. If only a portion or portions of the material on a page qualifies for 23 protection, the Producing Party also must clearly identify the protected 24 portion(s) (e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for 26 inspection need not designate them for protection until after the inspecting 27 8 1 Party has indicated which documents it would like copied and produced. 2 During the inspection and before the designation, all of the material made 3 available for inspection shall be deemed “HIGHLY CONFIDENTIAL – 4 ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the 5 documents it wants copied and produced, the Producing Party must determine 6 which documents, or portions thereof, qualify for protection under this Order. 7 Then, before producing the specified documents, the Producing Party must 8 affix the appropriate Legend to each page that contains Protected Material. If 9 only a portion or portions of the material on a page qualifies for protection, 10 the Producing Party also must clearly identify the protected portion(s) (e.g., 11 by making appropriate markings in the margins). 12 5.2.2 for testimony given in depositions that the Designating Party 13 identify the Disclosure or Discovery Material on the record, before the close 14 of the deposition all protected testimony. 15 5.2.3 for information produced in some form other than documentary 16 and for any other tangible items, that the Producing Party affix in a prominent 17 place on the exterior of the container or containers in which the information 18 is stored the CONFIDENTIAL legend. If only a portion or portions of the 19 information warrants protection, the Producing Party, to the extent 20 practicable, shall identify the protected portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure to designate qualified information or items does not, standing alone, waive 23 the Designating Party’s right to secure protection under this Order for such material. 24 Upon timely correction of a designation, the Receiving Party must make reasonable 25 efforts to assure that the material is treated in accordance with the provisions of this 26 Order. 27 9 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. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper 9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 10 parties) may expose the Challenging Party to sanctions. Similarly, frivolous 11 designations of documents as CONFIDENTIAL or HIGHLY CONFIDENTIAL – 12 ATTORNEYS’ EYES ONLY, as determined by the Court, may expose the 13 Designating Party to sanctions. Unless the Designating Party has waived or 14 withdrawn the confidentiality designation, all parties shall continue to afford the 15 material in question the level of protection to which it is entitled under the Producing 16 Party’s designation until the Court rules on the challenge. 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending, or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a 23 Receiving Party must comply with the provisions of Section 14 below (FINAL 24 DISPOSITION). /// 25

26 /// 27 10 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only to: 8 7.2.1 the Receiving Party’s Outside Counsel of Record in this Action, 9 as well as employees of said Outside Counsel of Record to whom it is 10 reasonably necessary to disclose the information for this Action; 11 7.2.2 one (1) officer, director, or employee (including House Counsel) 12 of the Receiving Party to whom disclosure is required for the disposition (e.g., 13 settlement) of this Action; 14 7.2.3 Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this Action, provided that: (1) such 16 Experts are not presently employed by the Parties or an affiliate of a Party 17 hereto for purposes other than this Action and (2) before access is given, any 18 such Expert has signed the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A) and the same has been served upon the Producing Party, along 20 with (i) a current curriculum vitae of the Expert, (ii) a list of other cases in 21 which the Expert has provided a report or testified (at trial or deposition) and 22 (iii) a list of companies that the Expert has worked or consulted for in the field 23 of the invention of the patents-in-suit or the accused products in the last four 24 years and a brief description of the subject matter of such employment or 25 consultancy, at least ten (10) days before access to the Protected Material is 26 to be given to that Expert in order to allow the Producing Party to object to 27 11 1 and notify the Receiving Party in writing that it objects to the disclosure of 2 Protected Material to the Expert (“Notice”). The Parties agree to promptly 3 confer and use good faith to resolve any such objection. If the Parties are 4 unable to resolve any objection, the objecting Party may file a motion with 5 the Court within fifteen (15) days of receipt of the Notice of the Producing 6 Party’s objection, or within such other time as the Parties may agree, seeking a 7 protective order with respect to the proposed disclosure. The objecting Party 8 shall have the burden of proving the need for a protective order. No disclosure 9 shall occur until all such objections are resolved by agreement or Court order. 10 7.2.4 the Court and its personnel; 11 7.2.5 Court reporters and their staff; 12 7.2.6 professional jury or trial consultants, mock jurors, and 13 Professional Vendors to whom disclosure is reasonably necessary for this 14 Action and who have signed the “Acknowledgment and Agreement to Be 15 Bound” (Exhibit A); 16 7.2.7 the author or recipient of a document containing the information 17 or a custodian or other person who otherwise possessed or knew the 18 information; 19 7.2.8 during their depositions, witnesses, and attorneys for witnesses, 20 in the Action to whom disclosure is reasonably necessary provided: (1) the 21 deposing party requests that the witness sign the form attached as Exhibit A 22 hereto; and (2) they will not be permitted to keep any confidential information 23 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 24 A), unless otherwise agreed by the Designating Party or ordered by the court. 25 Pages of transcribed deposition testimony or exhibits to depositions that 26 reveal Protected Material may be separately bound by the court reporter and 27 12 1 may not be disclosed to anyone except as permitted under this Stipulated 2 Protective Order; and 3 7.2.9 any mediator or settlement officer, and their supporting 4 personnel, mutually agreed upon by any of the parties engaged in settlement 5 discussions. 6 For Protected Material designed “HIGHLY CONFIDENTIAL – ATTORNEYS’ 7 EYES ONLY,” access to, and disclosure of, such Protected Material shall be limited 8 to the individuals listed in Sections 7.2.1 and 7.2.3 – 7.2.9. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 10 IN OTHER LITIGATION 11 If a Party is 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” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 14 ONLY,” that Party must: 15 8.1 promptly notify in writing the Designating Party. Such notification 16 shall include a copy of the subpoena or court order; 17 8.2 promptly notify in writing the party who caused the subpoena or order 18 to issue in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to this Protective Order. Such notification shall include a copy of 20 this Stipulated Protective Order; and 21 8.3 cooperate with respect to all reasonable procedures sought to be 22 pursued by the Designating Party whose Protected Material may be affected. 23 8.4 If the Designating Party timely seeks a protective order, the Party 24 served with the subpoena or court order shall not produce any information 25 designated in this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 26 ATTORNEYS’ EYES ONLY” before a determination by the court from which the 27 13 1 subpoena or order issued, unless the Party has obtained the Designating Party’s 2 permission or unless otherwise required by the law or court order. The Designating 3 Party shall bear the burden and expense of seeking protection in that court of its 4 confidential material and nothing in these provisions should be construed as 5 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 6 directive from another court. 7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 9.1 The terms of this Order are applicable to information produced by a 10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 9.2 In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party shall: 18 9.2.1 promptly notify in writing the Requesting Party and the Non- 19 Party that some or all of the information requested is subject to a 20 confidentiality agreement with a Non-Party; 21 9.2.2 promptly provide the Non-Party with a copy of the Stipulated 22 Protective Order in this Action, the relevant discovery request(s), and a 23 reasonably specific description of the information requested; and 24 9.2.3 make the information requested available for inspection by the 25 Non-Party, if requested. 26 /// 27 14 1 9.3 If the Non-Party fails to seek a protective order from this court within 2 14 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s confidential information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court 7 unless otherwise required by the law or court order. Absent a court order to the 8 contrary, the Non-Party shall bear the burden and expense of seeking protection in 9 this court of its Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 16 or persons to whom unauthorized disclosures were made of all the terms of this 17 Order, and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 25 may be established in an e-discovery order that provides for production without prior 26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 27 15 1 the parties reach an agreement on the effect of disclosure of a communication or 2 information covered by the attorney-client privilege or work product protection, the 3 parties may incorporate their agreement in the stipulated protective order submitted 4 to the court. 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 ground to use in evidence of any of the material covered by this Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 15 only be filed under seal pursuant to a court order authorizing the sealing of the 16 specific Protected Material at issue. If a Party's request to file Protected Material 17 under seal is denied by the court, then the Receiving Party may file the information 18 in the public record unless otherwise instructed by the court. 19 13. PRIVILEGE LOG 20 To the extent that the Parties produce privilege logs for materials withheld for 21 attorney-client privilege or pursuant to the work product doctrine (or other privileges 22 or doctrines), the format and content shall be as follows, absent further Court order: 23 The privilege log shall contain names extracted from the topmost e-mail message or 24 document (To, From, CC, BCC), the date of the topmost e-mail or document, and 25 the basis for the assertion of a privilege or other protection. The Producing Party 26 shall create a single log entry for each e-mail chain or string. A Producing Party’s 27 16 1 logging of the topmost e-mail shall be deemed to assert protection for all of the 2 privileged material in an e-mail string or chain, including multiple redactions or 3 multiple segments. 4 Attorney-client privileged communications and attorney work product created 5 by or on behalf of Counsel for the Parties after the initiation of and/or as part of their 6 representation in this action need not be included in any privilege log. 7 14. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in Section 4, within 60 9 days of a written request by the Designating Party, each Receiving Party must return 10 all Protected Material to the Producing Party or destroy such material. As used in 11 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving 14 Party must submit a written certification to the Producing Party (and, if not the same 15 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 16 (by category, where appropriate) all the Protected Material that was returned or 17 destroyed and (2) affirms that the Receiving Party has not retained any copies, 18 abstracts, compilations, summaries or any other format reproducing or capturing any 19 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 20 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 22 reports, attorney work product, and consultant and expert work product, even if such 23 materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order. 25 /// 26 /// 27 17 1 15. ENFORCEMENT 2 Any violation of this Order may be punished by any and all appropriate 3 measures including, without limitation, contempt proceedings and/or monetary 4 sanctions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 Dated: June 9, 2025 /s/ Jessica H. Zafonte Jessica H. Zafonte (pro hac vice) 7

CHIESA SHAHINIAN & GIANTOMASI PC

8 11 Times Square, 34th Floor New York, NY 10036 9

10 Attorney for Plaintiff, 11 CAREISMATIC BRANDS, LLC 12 13 Dated: June 9, 2025 /s/ Amy Simpson Amy Simpson 14

SBN: 241090

15 Holland & Knight LLP 1901 Avenue of the Stars, Suite 1200 16 Los Angeles, California 90067 17 Sadie Mlika (pro hac vice) 18 Holland & Knight LLP 19 10 St. James Avenue, 11th Floor Boston, Massachusetts 02116 20

21 Attorneys for Defendant, Workwear Outfitters, 22 LLC

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED.

24 DATED: June 17, 2025 ______________/s/_______________________ 25 Honorable Jacqueline Chooljian 26

UNITED STATES MAGISTRATE JUDGE

27 18

EXHIBIT A

1 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 5 perjury that I have read in its entirety and understand the Stipulated Protective Order 6 that was issued by the United States District Court for the Central District of 7 California on June 17, 2025 in the case of Careismatic Brands, LLC v. Workwear 8 Outfitters, LLC, Case No. 2-23-cv-09570 (C.D. Cal.). I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ___________________[print or type 18 full name] of _______________[print or type full address and telephone number] as 19 my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 Date: 22 City and State where sworn and signed: 23 Printed name: 24 Signature: 25 26 27 19 1 Multiple Signature Attestation 2 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I attest that all other signatories listed, 3 and on whose behalf the filing is submitted, concur in the content of this stipulation 4 and have authorized the filing of this stipulation. 5 6 7 DATED: June 9, 2025 Holland & Knight LLP 8 By: /s/ Amy Simpson 9 Amy Simpson (SBN 241090) Sadie Mlika (pro hac vice) 10

11 Attorneys for Defendant Workwear Outfitters, LLC 12 13

14 15 16 17 18 19 20 21 22 23 24 25 26 27 20