l LOUISE JFRUONG (SBN 293811) tans .com 2 | REBECCA BENY AMIN (SBN 334130) pe peel Deny dai uk com 3 | MITCHELL SILBERBERG & KNUPP LLP 2049 Century Park East, 18th Floor 4 | Los Angeles, CA 90067-3120 Telephone: GC 10) 312-2000 5 | Facsimile: (310) 312-3100 6 | Attorneys for Defendant Universal Content Productions LLC 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 | ANGELA SMITH, an individual, Case No. 2:25-cv-05524 AH (MBKx) 12 Plaintiff, Judge Anne Hwang, Courtroom 7D 13 V. [PROPOSED] STIPULATED

PROTECTIVE ORDER

14 | UNIVERSAL CONTENT PRODUCTIONS LLC, a Delaware 15 | limited liability company; and DOES 1- 50, inclusive, 16 Defendants. 17 18 19 20 21 22 23 24 25 26 27 D& berberg &

LLP

1} 1. GENERAL 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 7 | Order. The parties acknowledge that this Order does not confer blanket protections 8 | on all disclosures or responses to discovery and that the protection it affords from 9 | public disclosure and use extends only to the limited information or items that are 10 | entitled to confidential treatment under the applicable legal principles. The parties 11 | further acknowledge, as set forth in Section 12.3, below, that this Stipulated 12 | Protective Order does not entitle them to file confidential information under seal; 13 | Civil Local Rule 79-5 sets forth the procedures that must be followed and the 14 | standards that will be applied when a party seeks permission from the court to file 15 | material under seal. 16 1.2 Good Cause Statement. 17 This action is likely to involve commercial, financial, technical and/or 18 | proprietary information for which special protection from public disclosure and 19 | from use for any purpose other than prosecution of this action is warranted. Such 20 | confidential and proprietary materials and information consist of, among other 21 | things, confidential business or financial information, information regarding 22 | confidential business practices, or other confidential research, development, or 23 | commercial information (including information implicating privacy rights of third 24 | parties), information otherwise generally unavailable to the public, or which may 25 | be privileged or otherwise protected from disclosure under state or federal statutes, 26 | court rules, case decisions, or common law. Accordingly, to expedite the flow of 27 | information, to facilitate the prompt resolution of disputes over confidentiality of 28 | discovery materials, to adequately protect information the parties are entitled to

LLP

1 | keep confidential, to ensure that the parties are permitted reasonable necessary uses 2 | of such material in preparation for and in the conduct of trial, to address their 3 | handling at the end of the litigation, and serve the ends of justice, a protective order 4 | for such information is justified in this matter. It is the intent of the parties that 5 | information will not be designated as confidential for tactical reasons and that 6 | nothing be so designated without a good faith belief that it has been maintained in 7 | □ confidential, non-public manner, and there is good cause why it should not be 8 | part of the public record of this case. 9 | 2. DEFINITIONS 10 2.1 Action: The above-entitled lawsuit, Case No. 2:25-cv-05524 AH 11 | (MBKx). 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 21 | or 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, 24 | regardless of the medium or manner in which it 1s generated, stored, or maintained 25 | (including, among other things, testimony, transcripts, and tangible things), that are 26 | produced or generated in disclosures or responses to discovery in this matter. 27 28

l 2.7. Expert: A person with specialized knowledge or experience in a 2 | matter pertinent to the litigation who has been retained by a Party or its counsel to 3 | serve as an expert witness or as a consultant in this Action. 4 2.8 In-House Counsel: Attorneys who are employees of a party to this 5 | Action. House Counsel does not include Outside Counsel of Record or any other 6 | outside 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 Qutside Counsel of Record: Attorneys who are not employees of a 10 | party to this Action but are retained to represent or advise a party to this Action 11 | and have appeared in this Action on behalf of that party or are affiliated with a law 12 | firm that has appeared on behalf of that party, including 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 19 | support 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|3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 | Protected Material (as defined above), but also (1) any information copied or

LLP

1 | extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 | compilations of Protected Material; and (3) any testimony, conversations, or 3 | presentations by Parties or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 | trial judge. This Order does not govern the use of Protected Material at trial. 6 | 4. DURATION 7 Once a case proceeds to trial, all of the court-filed information to be 8 | introduced that was previously designated as confidential or maintained pursuant 9 | to this protective order becomes public and will be presumptively available to all 10 | members of the public, including the press, unless compelling reasons supported 11 | by specific factual findings to proceed otherwise are made to the trial judge in 12 | advance of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 13 | 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing 14 | documents produced in discovery from “compelling reasons” standard when 15 | merits-related documents are part of court record). Accordingly, the terms of this 16 | protective order do not extend beyond the commencement of the trial. 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 | Each Party or Non-Party that designates information or items for protection under 20 | this Order must take care to limit any such designation to specific material that 21 | qualifies under the appropriate standards. The Designating Party must designate for 22 | protection only those parts of material, documents, items, or oral or written 23 | communications that qualify so that other portions of the material, documents, 24 | items, or communications for which protection is not warranted are not swept 25 | unjustifiably within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. 27 | Designations that are shown to be clearly unjustified or that have been made for an 28 | improper purpose (e.g., to unnecessarily encumber the case development process

LLP

1 | or to impose unnecessary expenses and burdens on other parties) may expose the 2 | Designating Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 | designated for protection do not qualify for protection, that Designating Party must 5 | promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 | this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 | stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 | under this Order must be clearly so designated before the material is disclosed or 10 | produced. 11 Designation in conformity with this Order requires: 12 (a) For information in documentary form (e.g., paper or electronic 13 | documents, but excluding transcripts of depositions or other pretrial or trial 14 | proceedings), that the Producing Party affix, at a minimum, the legend 15 | “CONFIDENTIAL” to each page that contains Protected Material. If only a 16 | portion or portions of the material on a page qualifies for protection, the Producing 17 | Party also must clearly identify the protected portion(s) (e.g., by making 18 | appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for 20 | inspection need not designate them for protection until after the inspecting Party 21 | has indicated which documents it would like copied and produced. During the 22 | inspection and before the designation, all of the material made available for 23 | inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 24 | identified the documents it wants copied and produced, the Producing Party must 25 | determine which documents, or portions thereof, qualify for protection under this 26 | Order. Then, before producing the specified documents, the Producing Party must 27 | affix the legend “CONFIDENTIAL” to each page that contains Protected Material. 28 | If only a portion or portions of the material on a page qualifies for protection, the

LLP

1 | Producing Party also must clearly identify the protected portion(s) (e.g., by making 2 | appropriate markings in the margins). 3 (b) For testimony given in depositions or in other pretrial or trial 4 | proceedings, that the Designating Party identify the Disclosure or Discovery 5 | Material on the record, before the close of the deposition, hearing, or other 6 | proceeding, all protected testimony and specify the level of protection being 7 | asserted. Alternatively, when it is impractical to identify separately each portion of 8 | testimony that is entitled to protection, the Designating Party shall have up to 15 9 | days after a deposition, hearing, or other proceeding to identify the specific 10 | portions of the testimony as to which protection is sought and to specify the level 11 | of protection being asserted. Alternatively, a Designating Party may specify, at the 12 | deposition or up to 15 days afterwards, that the entire transcript shall be treated as 13 | “CONFIDENTIAL.” 14 (c) For information produced in some form other than documentary 15 | and for any other tangible items, that the Producing Party affix in a prominent 16 | place on the exterior of the container or containers in which the information is 17 | stored the legend “CONFIDENTIAL.” If only a portion or portions of the 18 | information warrants protection, the Producing Party, to the extent practicable, 19 | shall identify the protected portion(s). 20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 21 | failure to designate qualified information or items does not, standing alone, waive 22 | the Designating Party’s right to secure protection under this Order for such 23 | material. Upon timely correction of a designation, the Receiving Party must make 24 | reasonable efforts to assure that the material is treated in accordance with the 25 | provisions of this Order. 26 27 28

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, as modified by Judge Kaufman’s 7 | Procedures. See https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. 8 | Any discovery motion must strictly comply with these procedures. 9 6.3 Burden. The burden of persuasion in any such challenge proceeding 10 | shall be on the Designating Party. Frivolous challenges, and those made for an 11 | improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 12 | other parties) may expose the Challenging Party to sanctions. Unless the 13 | Designating Party has waived or withdrawn the confidentiality designation, all 14 | parties shall continue to afford the material in question the level of protection to 15 | which it is entitled under the Producing Party’s designation until the Court rules on 16 | the challenge. 17 | 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that 19 | is 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 22 | the conditions described in this Order. When the Action has been terminated, a 23 | Receiving Party must comply with the provisions of section 13 below (FINAL 24 | DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 | location and in a secure manner that ensures that access is limited to the persons 27 | authorized under this Order. 28

l 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 to: 5 (a) The Receiving Party’s Outside Counsel of Record in this 6 | Action, as well as employees of said Outside Counsel of Record to whom it is 7 | reasonably necessary to disclose the information for this Action; 8 (b) The officers, directors, and employees (including House 9 | Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 10 | this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to 12 | whom disclosure is reasonably necessary for this Action and who have signed the 13 | “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) The Court and its personnel; 15 (e) Court reporters and their staff; 16 (f) | Professional jury or trial consultants, mock jurors, and 17 | Professional Vendors to whom disclosure is reasonably necessary for this Action 18 | and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 19 | A); 20 (g) The author or recipient of a document containing the 21 | information or a custodian or other person who otherwise possessed or knew the 22 | information; 23 (h) During their depositions, witnesses, and attorneys for witnesses, 24 | in the Action to whom disclosure is reasonably necessary provided: (1) the 25 | deposing party requests that the witness sign the form attached as Exhibit A hereto; 26 | and (2) they will not be permitted to keep any confidential information unless they 27 | sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 28 | otherwise agreed by the Designating Party or ordered by the Court. Pages of

LLP

1 | transcribed deposition testimony or exhibits to depositions that reveal Protected 2 | Material may be separately bound by the court reporter and may not be disclosed 3 | to anyone except as permitted under this Stipulated Protective Order; and 4 (i) Any mediator or settlement officer, and their supporting 5 | personnel, mutually agreed upon by any of the parties engaged in settlement 6 | discussions. 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 8 PRODUCED IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 | that compels disclosure of any information or items designated in this Action as 11 | “CONFIDENTIAL,” that Party must: 12 (a) Promptly notify in writing the Designating Party. Such 13 | notification shall include a copy of the subpoena or court order; 14 (b) Promptly notify in writing the party who caused the subpoena 15 | or order to issue in the other litigation that some or all of the material covered by 16 | the subpoena or order is subject to this Protective Order. Such notification shall 17 | include a copy of this Stipulated Protective Order; and 18 (c) Cooperate with respect to all reasonable procedures sought to 19 | be pursued by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely secks a protective order, the Party served 21 | with the subpoena or court order shall not produce any information designated in 22 | this action as “CONFIDENTIAL” before a determination by the court from which 23 | the subpoena or order issued, unless the Party has obtained the Designating Party’s 24 | permission. The Designating Party shall bear the burden and expense of seeking 25 | protection in that court of its confidential material and nothing in these provisions 26 | should be construed as authorizing or encouraging a Receiving Party in this Action 27 | to disobey a lawful directive from another court. 28 10

1/9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced 4 | by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 5 | information produced by Non-Parties in connection with this litigation is protected 6 | by the remedies and relief provided by this Order. Nothing in these provisions 7 | should be construed as prohibiting a Non-Party from seeking additional 8 | protections. 9 (b) Inthe event that a Party is required, by a valid discovery 10 | request, to produce a Non-Party’s confidential information in its possession, and 11 | the Party is subject to an agreement with the Non-Party not to produce the Non- 12 | Party’s confidential information, then the Party shall: 13 (1) Promptly notify in writing the Requesting Party and the 14 | Non-Party that some or all of the information requested is subject to a 15 | confidentiality agreement with a Non-Party; 16 (2) Promptly provide the Non-Party with a copy of the 17 | Stipulated Protective Order in this Action, the relevant discovery request(s), and a 18 | reasonably specific description of the information requested; and 19 (3) Make the information requested available for inspection 20 | by the Non-Party, if requested. 21 (c) Ifthe Non-Party fails to seek a protective order from this Court 22 | within 14 days of receiving the notice and accompanying information, the 23 | Receiving Party may produce the Non-Party’s confidential information responsive 24 | to the discovery request. If the Non-Party timely seeks a protective order, the 25 | Receiving Party shall not produce any information in its possession or control that 26 | is subject to the confidentiality agreement with the Non-Party before a 27 | determination by the Court. Absent a court order to the contrary, the Non-Party 28

1 | shall bear the burden and expense of seeking protection in this Court of its 2 | Protected Material. 3/10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has 5 | disclosed Protected Material to any person or in any circumstance not authorized 6 | under this Stipulated Protective Order, the Receiving Party must immediately (a) 7 | notify in writing the Designating Party of the unauthorized disclosures, (b) use its 8 | best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 9 | the person or persons to whom unauthorized disclosures were made of all the terms 10 | of this Order, and (d) request such person or persons to execute the 11 | “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 12] A. 13/11. INADVERTENT PRODUCTION OF PRIVILEGED OR 14 OTHERWISE PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 | inadvertently produced material is subject to a claim of privilege or other 17 | protection, the obligations of the Receiving Parties are those set forth in Federal 18 | Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 19 | whatever procedure may be established in an e-discovery order that provides for 20 | production without prior privilege review. Pursuant to Federal Rule of Evidence 21 | 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 22 | of a communication or information covered by the attorney-client privilege or 23 | work product protection, the parties may incorporate their agreement in the 24 | stipulated protective order submitted to the Court. 25/12. MISCELLANEOUS 26 12.1 Right to Further Relief. Nothing in this Order abridges the right of 27 | any person to seek its modification by the Court in the future. 28 1D

1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 | Protective Order, no Party waives any right it otherwise would have to object to 3 | disclosing or producing any information or item on any ground not addressed in 4 | this Stipulated Protective Order. Similarly, no Party waives any right to object on 5 | any ground to use in evidence of any of the material covered by this Protective 6 | Order. 7 12.3 Filing Protected Material. A Party that seeks to file under seal any 8 | Protected Material must comply with Civil Local Rule 79-5. Protected Material 9 | may only be filed under seal pursuant to a court order authorizing the sealing of the 10 | specific Protected Material at issue; good cause must be shown in the request to 11 | file under seal. Ifa Party’s request to file Protected Material under seal is denied 12 | by the Court, then the Receiving Party may file the information in the public record 13 | unless otherwise instructed by the Court. 13. FINAL DISPOSITION 15 After the final disposition of this Action, within 60 days of a written request 16 | by the Designating Party, each Receiving Party must return all Protected Material 17 | to the Producing Party or destroy such material. As used in this subdivision, “all 18 | Protected Material” includes all copies, abstracts, compilations, summaries, and 19 | any other format reproducing or capturing any of the Protected Material. Whether 20 | the Protected Material is returned or destroyed, the Receiving Party must submit a 21 | written certification to the Producing Party (and, if not the same person or entity, to 22 | the Designating Party) by the 60 day deadline that (1) identifies (by category, 23 | where appropriate) all the Protected Material that was returned or destroyed, and 24 | (2) affirms that the Receiving Party has not retained any copies, abstracts, 25 | compilations, summaries or any other format reproducing or capturing any of the 26 | Protected Material. Notwithstanding this provision, counsel are entitled to retain 27 | an archival copy of all pleadings, motion papers, trial, deposition, and hearing 28 | transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

LLP 13

1 | reports, attorney work product, and consultant and expert work product, even if 2 | such materials contain Protected Material. Any such archival copies that contain 3 | or constitute Protected Material remain subject to this Protective Order as set forth 4 | in Section 4 (DURATION). 5|14. VIOLATION OF ORDER 6 Any violation of this Order may be punished by any and all appropriate 7 | measures including, without limitation, contempt proceedings and/or monetary 8 | sanctions.

ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

10 11 12 13 | DATED: October 3, 2025 JML LAW 14 15 /s/ Adriana Garrido 16 Cathryn G. Fund Adriana Garrido 17 Attorneys for Plaintiff 18 Angela Smith 19 20 21 | DATED: October 3, 2025 MITCHELL SILBERBERG & KNUPP LLP 22 23 /s/ Louise Truong 4 Louise Truong Rebecca Benyamin 25 Attorneys for Defendant %6 Universal Content Productions LLC 27 2 berberg &

LLP 14

1 | IT ISSO ORDERED. 2 ; 3 | DATED: _ 10/03/2025 ft CZ tf: — 4 MICHAEL B. KAUFMAN ; UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 2

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [full name], of 5 | [full address], declare under penalty of perjury that I have read in its entirety and 6 | understand the Stipulated Protective Order that was issued by the United States 7 | District Court for the Central District of California on [date] in the case of 8 [insert case name and number]. | agree to comply with and to be 9 | 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 11 | punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 | any manner any information or item that is subject to this Stipulated Protective 13 | Order to any person or entity except in strict compliance with the provisions of this 14 | Order. 15 I further agree to submit to the jurisdiction of the United States District 16 | Court for the Central District of California for the purpose of enforcing the terms 17 | of this Stipulated Protective Order, even if such enforcement proceedings occur 18 | after termination of this action. I hereby appoint 19 | [full name] of [full address and 20 | telephone number] as my California agent for service of process in connection 21 | with this action or any proceedings related to enforcement of this Stipulated 22 | Protective Order. 23 | Date: 24 | City and State where signed: 25 26 | Printed name: 27 28 | Signature:

LLP 16