1 Alex Farzan (SBN 312771)

THE LAW OFFICE OF ALEX FARZAN

2 10940 Wilshire Blvd., Suite 2010 Los Angeles, CA 90024 3 (424) 325-3112 4 (424) 325-6311 fax Alex@Farzanlaw.com 5 Attorney for Plaintiff, 6

SWAN STEGEMANN

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8 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN DIVISION

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11 SWAN STEGEMANN, Case No.: 8:25-cv-01357-DOC-ADS 12 Plaintiff, 13 v. STIPULATED PROTECTIVE 14 ORDER

JOHNSON & JOHNSON, MENTOR

15 WORLDWIDE LLC; and DOES 1 through 100, inclusive, 16

17 Defendants.

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I. PURPOSES AND LIMITATIONS

2 A. Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to 5 and petition the Court to enter the following Stipulated Protective Order. 6 The parties acknowledge that this Order does not confer blanket protections 7 on all disclosures or responses to discovery and that the protection it affords 8 from public disclosure and use extends only to the limited information or 9 items that are entitled to confidential treatment under the applicable legal 10 principles. The parties further acknowledge, as set forth in Section XIII(C), 11 below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 12 procedures that must be followed and the standards that will be applied 13 when a party seeks permission from the Court to file material under seal. 14

II. GOOD CAUSE STATEMENT

15 A. This action is likely to involve sensitive personal information 16 regarding Swan Stegemann, as well as trade secrets, customer and pricing 17 lists and other valuable research, development, commercial, financial, 18 technical and/or proprietary information for which special protection from 19 public disclosure and from use for any purpose other than prosecution of this action is warranted. Such confidential and proprietary materials and 20 information consist of, among other things, confidential business or 21 financial information, information regarding confidential business practices, 22 or other confidential research, development, or commercial information 23 (including information implicating privacy rights of third parties), 24 information otherwise generally unavailable to the public, or which may be 1 privileged or otherwise protected from disclosure under state or federal 2 statutes, court rules, case decisions, or common law. Accordingly, to 3 expedite the flow of information, to facilitate the prompt resolution of 4 disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the 5 parties are permitted reasonable necessary uses of such material in 6 preparation for and in the conduct of trial, to address their handling at the 7 end of the litigation, and serve the ends of justice, a protective order for 8 such information is justified in this matter. It is the intent of the parties that 9 information will not be designated as confidential for tactical reasons and 10 that nothing be so designated without a good faith belief that it has been 11 maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case. 12

III. DEFINITIONS

13 A. Action: This pending federal law suit. 14 B. Challenging Party: A Party or Non-Party that challenges the 15 designation of information or items under this Order. 16 C. “CONFIDENTIAL” Information or Items: Information (regardless 17 of how it is generated, stored or maintained) or tangible things that qualify 18 for protection under Federal Rule of Civil Procedure 26(c) and 26(c)(1)(g), 19 and as specified above in the Good Cause Statement. D. Counsel: Outside Counsel of Record and House Counsel (as well as 20 their support staff). 21 E. Designating Party: A Party or Non-Party that designates information 22 or items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 1 F. Disclosure or Discovery Material: All items or information, 2 regardless of the medium or manner in which it is generated, stored, or 3 maintained (including, among other things, testimony, transcripts, and 4 tangible things), that are produced or generated in disclosures or responses to discovery in this matter. 5 G. Expert: A person with specialized knowledge or experience in a 6 matter pertinent to the litigation who has been retained by a Party or its 7 counsel to serve as an expert witness or as a consultant in this Action. 8 H. House Counsel: Attorneys who are employees of a party to this 9 Action. House Counsel does not include Outside Counsel of Record or any 10 other outside counsel. 11 I. Non-Party: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 12 J. Outside Counsel of Record: Attorneys who are not employees of a 13 party to this Action but are retained to represent or advise a party to this 14 Action and have appeared in this Action on behalf of that party or are 15 affiliated with a law firm which has appeared on behalf of that party, and 16 includes support staff. 17 K. Party: Any party to this Action, including all of its officers, 18 directors, employees, consultants, retained experts, and Outside Counsel of 19 Record (and their support staffs). L. Producing Party: A Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 M. Professional Vendors: Persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing 23 exhibits or demonstrations, and organizing, storing, or retrieving data in any 24 form or medium) and their employees and subcontractors. 1 N. Protected Material: Any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 O. Receiving Party: A Party that receives Disclosure or Discovery 4 Material from a Producing Party.

IV. SCOPE

5 A. The protections conferred by this Stipulation and Order cover not 6 only Protected Material (as defined above), but also (1) any information 7 copied or extracted from Protected Material; (2) all copies, excerpts, 8 summaries, or compilations of Protected Material; and (3) any testimony, 9 conversations, or presentations by Parties or their Counsel that might reveal 10 Protected Material. 11 B. Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern the use of Protected Material at 12 trial. 13

V. DURATION

14 A. Once a case proceeds to trial, information that was designated as 15 confidential and produced as an exhibit during trial may become public and 16 will be presumptively available to all members of the public, including the 17 press, unless compelling reasons supported by specific factual findings to 18 proceed otherwise are made to the trial judge in advance of the trial. See 19 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents 20 produced in discovery from “compelling reasons” standard when merits- 21 related documents are part of court record). Accordingly, the terms of this 22 Protective Order do not extend beyond the commencement of the trial. 23

VI. DESIGNATING PROTECTED MATERIAL

24 A. Exercise of Restraint and Care in Designating Material for Protection 1 1. Each Party or Non-Party that designates information or items 2 for protection under this Order must take care to limit any such 3 designation to specific material that qualifies under the appropriate 4 standards. The Designating Party must designate for protection only those parts of material, documents, items, or oral or written 5 communications that qualify so that other portions of the material, 6 documents, items, or communications for which protection is not 7 warranted are not swept unjustifiably within the ambit of this Order. 8 2. Mass, indiscriminate, or routinized designations are prohibited. 9 Designations that are shown to be clearly unjustified or that have 10 been made for an improper purpose (e.g., to unnecessarily encumber 11 the case development process or to impose unnecessary expenses and burdens on other parties) may expose the Designating Party to 12 sanctions. 13 3. If it comes to a Designating Party’s attention that information 14 or items that it designated for protection do not qualify for protection, 15 that Designating Party must promptly notify all other Parties that it is 16 withdrawing the inapplicable designation. 17 B. Manner and Timing of Designations 18 1. Except as otherwise provided in this Order (see, e.g., Section 19 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection under this Order must 20 be clearly so designated before the material is disclosed or produced. 21 2. Designation in conformity with this Order requires the 22 following: 23 a. For information in documentary form (e.g., paper or 24 electronic documents, but excluding transcripts of depositions 1 or other pretrial or trial proceedings), that the Producing Party 2 affix at a minimum, the legend “CONFIDENTIAL” 3 (hereinafter “CONFIDENTIAL legend”), to each page that 4 contains protected material. b. A Party or Non-Party that makes original documents 5 available for inspection need not designate them for protection 6 until after the inspecting Party has indicated which documents 7 it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for 9 inspection shall be deemed “CONFIDENTIAL.” After the 10 inspecting Party has identified the documents it wants copied 11 and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under 12 this Order. Then, before producing the specified documents, 13 the Producing Party must affix the “CONFIDENTIAL legend” 14 to each page that contains Protected Material. If only a portion 15 or portions of the material on a page qualifies for protection, 16 the Producing Party also must clearly identify the protected 17 portion(s) (e.g., by making appropriate markings in the 18 margins). 19 c. For testimony given in depositions, that the Designating Party identify the Disclosure or Discovery Material on the 20 record, before the close of the deposition all protected 21 testimony. 22 d. For information produced in form other than document 23 and for any other tangible items, that the Producing Party affix 24 in a prominent place on the exterior of the container or 1 containers in which the information is stored the legend 2 “CONFIDENTIAL.” 3 C. Inadvertent Failure to Designate 4 1. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the Designating 5 Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must 7 make reasonable efforts to assure that the material is treated in 8 accordance with the provisions of this Order. 9 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 A. Timing of Challenges 11 1. Any party or Non-Party may challenge a designation of confidentiality at any time that is consistent with the Court’s 12 Scheduling Order. 13 B. Meet and Confer 14 1. The Challenging Party shall initiate the dispute resolution 15 process under Local Rule 37.1 et seq. 16 C. The burden of persuasion in any such challenge proceeding shall be 17 on the Designating Party. Frivolous challenges, and those made for an 18 improper purpose (e.g., to harass or impose unnecessary expenses and 19 burdens on other parties) may expose the Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality 20 designation, all parties shall continue to afford the material in question the 21 level of protection to which it is entitled under the Producing Party’s 22 designation until the Court rules on the challenge. 23

VIII. ACCESS TO AND USE OF PROTECTED MATERIAL

24 A. Basic Principles 1 1. A Receiving Party may use Protected Material that is disclosed 2 or produced by another Party or by a Non-Party in connection with 3 this Action only for prosecuting, defending, or attempting to settle 4 this Action. Such Protected Material may be disclosed only to the categories of persons and under the conditions described in this 5 Order. When the Action has been terminated, a Receiving Party must 6 comply with the provisions of Section XIV below. 7 2. Protected Material must be stored and maintained by a 8 Receiving Party at a location and in a secure manner that ensures that 9 access is limited to the persons authorized under this Order. Materials 10 must be kept following industry-standard data-security practices 11 including encryption, access controls and malware protection. B. Disclosure of “CONFIDENTIAL” Information or Items 12 1. Unless otherwise ordered by the Court or permitted in writing 13 by the Designating Party, a Receiving Party may disclose any 14 information or item designated “CONFIDENTIAL” only to: 15 a. The Receiving Party’s Outside Counsel of Record in this 16 Action, as well as employees of said Outside Counsel of 17 Record to whom it is reasonably necessary to disclose the 18 information for this Action; 19 b. The officers, directors, and employees (including House Counsel) of the Receiving Party to whom disclosure is 20 reasonably necessary for this Action; 21 c. Experts (as defined in this Order) of the Receiving Party 22 to whom disclosure is reasonably necessary for this Action and 23 who have signed the “Acknowledgment and Agreement to Be 24 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 4 Professional Vendors (collectively “Consultants”) to whom disclosure is reasonably necessary for this Action only if 1) 5 the Consultant has signed the “Acknowledgment and 6 Agreement to be Bound” attached as Exhibit A hereto, 2) the 7 Consultant is not a Competitor of the Designating Party, and 3) 8 Counsel for the party retaining the Consultant, after duly 9 diligent inquiry, does not know of any instance in which they 10 have been found to be in violation of the terms of a protective 11 order in any legal proceeding; i. As used in this Order, “Competitor” means any 12 manufacturer of, or entity involved in the sale of breast 13 implants and/or breast tissue expanders who, upon 14 reasonable and good faith inquiry, could be determined 15 to be employed by, to be a consultant doing research for, 16 or otherwise to be retained by any manufacturer of, or 17 entity involved in the sale of breast implants and/or 18 breast tissue expanders. 19 g. The author or recipient of a document containing the information or a custodian or other person who otherwise 20 possessed or knew the information; 21 h. During their depositions, witnesses, and attorneys for 22 witnesses, in the Action to whom disclosure is reasonably 23 necessary provided: (i) the deposing party requests that the 24 witness sign the “Acknowledgment and Agreement to Be 1 Bound;” and (ii) they will not be permitted to keep any 2 confidential information unless they sign the 3 “Acknowledgment and Agreement to Be Bound,” unless 4 otherwise agreed by the Designating Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to 5 depositions that reveal Protected Material may be separately 6 bound by the court reporter and may not be disclosed to 7 anyone except as permitted under this Stipulated Protective 8 Order; and 9 i. Any mediator or settlement officer, and their supporting 10 personnel, mutually agreed upon by any of the parties engaged 11 in settlement discussions.

IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED

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PRODUCED IN OTHER LITIGATION

13 A. If a Party is served with a subpoena or a court order issued in other 14 litigation that compels disclosure of any information or items designated in 15 this Action as “CONFIDENTIAL,” that Party must: 16 1. Promptly notify in writing the Designating Party. Such 17 notification shall include a copy of the subpoena or court order; 18 2. Promptly notify in writing the party who caused the subpoena 19 or order to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this Protective Order. 20 Such notification shall include a copy of this Stipulated Protective 21 Order; and 22 3. Cooperate with respect to all reasonable procedures sought to 23 be pursued by the Designating Party whose Protected Material may 24 be affected. 1 B. If the Designating Party timely seeks a protective order, the Party 2 served with the subpoena or court order shall not produce any information 3 designated in this action as “CONFIDENTIAL” before a determination by 4 the Court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. The Designating Party shall 5 bear the burden and expense of seeking protection in that court of its 6 confidential material and nothing in these provisions should be construed as 7 authorizing or encouraging a Receiving Party in this Action to disobey a 8 lawful directive from another court. 9 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 A. The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 12 information produced by Non-Parties in connection with this litigation is 13 protected by the remedies and relief provided by this Order. Nothing in 14 these provisions should be construed as prohibiting a Non-Party from 15 seeking additional protections. 16 B. In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and the 18 Party is subject to an agreement with the Non-Party not to produce the Non- 19 Party’s confidential information, then the Party shall: 1. Promptly notify in writing the Requesting Party and the Non- 20 Party that some or all of the information requested is subject to a 21 confidentiality agreement with a Non-Party; 22 2. Promptly provide the Non-Party with a copy of the Stipulated 23 Protective Order in this Action, the relevant discovery request(s), and 24 a reasonably specific description of the information requested; and 1 3. Make the information requested available for inspection by the 2 Non-Party, if requested. 3 C. If the Non-Party fails to seek a protective order from this court within 4 14 days of receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential information 5 responsive to the discovery request. If the Non-Party timely seeks a 6 protective order, the Receiving Party shall not produce any information in 7 its possession or control that is subject to the confidentiality agreement with 8 the Non-Party before a determination by the court. Absent a court order to 9 the contrary, the Non-Party shall bear the burden and expense of seeking 10 protection in this court of its Protected Material. 11 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL A. If a Receiving Party learns that, by inadvertence or otherwise, it has 12 disclosed Protected Material to any person or in any circumstance not 13 authorized under this Stipulated Protective Order, the Receiving Party must 14 immediately (1) notify in writing the Designating Party of the unauthorized 15 disclosures, (2) use its best efforts to retrieve all unauthorized copies of the 16 Protected Material, (3) inform the person or persons to whom unauthorized 17 disclosures were made of all the terms of this Order, and (4) request such 18 person or persons to execute the “Acknowledgment and Agreement to be 19 Bound” that is attached hereto as Exhibit A.

XII. INADVERTENT PRODUCTION OF PRIVILEGED OR

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OTHERWISE PROTECTED MATERIAL

21 A. When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other 23 protection, the obligations of the Receiving Parties are those set forth in 24 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended 1 to modify whatever procedure may be established in an e-discovery order 2 that provides for production without prior privilege review. Pursuant to 3 Federal Rule of Evidence 502(d), insofar as the parties reach an agreement 4 on the effect of disclosure of a communication or information covered by the attorney-client privilege or work product protection, the parties may 5 incorporate their agreement in the Stipulated Protective Order submitted to 6 the Court. 7

XIII. MISCELLANEOUS

8 A. Right to Further Relief 9 1. Nothing in this Order abridges the right of any person to seek 10 its modification by the Court in the future. 11 B. Right to Assert Other Objections 1. By stipulating to the entry of this Protective Order, no Party 12 waives any right it otherwise would have to object to disclosing or 13 producing any information or item on any ground not addressed in 14 this Stipulated Protective Order. Similarly, no Party waives any right 15 to object on any ground to use in evidence of any of the material 16 covered by this Protective Order. 17 C. Filing Protected Material 18 1. A Party that seeks to file under seal any Protected Material 19 must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the 20 sealing of the specific Protected Material at issue. If a Party's request 21 to file Protected Material under seal is denied by the Court, then the 22 Receiving Party may file the information in the public record unless 23 otherwise instructed by the Court. 24 1 D. Use of AI 2 1. The Parties agree that the receiving party shall not use any 3 documents, electronically stored information (“ESI”), or other materials 4 produced or exchanged in the course of this litigation, including but not limited to those designated as “Confidential”, in whole or in part, for 5 prompts (inputs), completion (outputs), or embeddings that are used to train 6 improve, re-train, or otherwise develop any artificial intelligence, 7 foundation model, or large language model (collectively “AI Models”). 8 This prohibition applies regardless of whether the AI Models are 9 proprietary, open-source, or provided by a third party, and regardless of 10 whether the use is for commercial, research, or any other purpose. The 11 Parties further agree to take reasonable steps to ensure that their employees, counsel, agents, consultants, contractors, and any other persons or entities 12 who may have access to such materials comply with this prohibition. Any 13 violation of this provision may be addressed by the Court through 14 appropriate remedies, including but not limited to, sanctions. 15 E. Third-Party Litigation Funding 16 1. Funders of litigation are unauthorized parties and shall be 17 prohibited access to, and denied copies of, any confidential, proprietary, 18 and sensitive commercial information produced in this action through 19 litigation discovery. The term “funders or litigation” shall be applied broadly an include any entity or individual engaged in the business of 20 litigation funding, their employees, counsel, consultants, and other agents, 21 whether foreign or domestic. Parties will comply with the Department of 22 Justice, National Security Division’s Foreign Agents Registration Act, 23 and/or the Data Security Program as may be applicable. 24 1 F. Prior to any discovery-related disclosure or production, the Producing 2 Party may redact information or material that is protected from disclosure 3 by applicable privilege or immunity, that is governed by any applicable 4 privacy law or regulation, that contains commercial sensitive or proprietary non-responsive in, or that any Order entered in this Action allows to be 5 redacted. The Producing Party may also withhold entire non-responsive 6 attachments in a document family and may produce slipsheets in their 7 place. 9 A. After the final disposition of this Action, as defined in Section V, 10 within sixty (60) days of a written request by the Designating Party, each 11 Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” 12 includes all copies, abstracts, compilations, summaries, and any other 13 format reproducing or capturing any of the Protected Material. Whether the 14 Protected Material is returned or destroyed, the Receiving Party must 15 submit a written certification to the Producing Party (and, if not the same 16 person or entity, to the Designating Party) by the 60 day deadline that (1) 17 identifies (by category, where appropriate) all the Protected Material that 18 was returned or destroyed and (2) affirms that the Receiving Party has not 19 retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding 20 this provision, Counsel are entitled to retain an archival copy of all 21 pleadings, motion papers, trial, deposition, and hearing transcripts, legal 22 memoranda, correspondence, deposition and trial exhibits, expert reports, 23 attorney work product, and consultant and expert work product, even if 24 such materials contain Protected Material. Any such archival copies that 1 contain or constitute Protected Material remain subject to this Protective 2 Order as set forth in Section V. 3 B. Any violation of this Order may be punished by any and all 4 appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 5

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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7 Dated: September 30, 2025 LAW OFFICE OF ALEX FARZAN 8

9 By: /s/ Alex Farzan Alex Farzan 10 Attorney for Plaintiff

SWAN STEGEMANN

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12 DATED: October 16, 2025 NELSON MULLINS RILEY &

SCARBOROUGH LLP

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14 By: /s/ Monee Takla Hanna Dustin B. Rawlin (pro hac vice) 15 Monee Takla Hanna Attorneys for Defendants 16 MENTOR WORLDWIDE LLC and 17 JOHNSON & JOHNSON

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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21 Dated: 10/16/2025 /s/ Autumn D. Spaeth 22 HONORABLE AUTUMN D. SPAETH 23 United States Magistrate Judge 24 1

EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issue by the United States District Court for the Central District of California 8 on [DATE] in the case of [insert formal name of 9 the case and the number and initials assigned to it by the Court]. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order 11 and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I 12 will not disclose in any manner any information or item that is subject to this 13 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 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 [print or type full name] of [print or type full address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: 23 City and State where sworn and signed: 24 Printed Name: 1 Signature: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

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