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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

10 11 RASHEED RAVELL LEVI, an individual, Case No.: 5:25-cv-01344-KK-DTBx 12

13 Plaintiff, STIPULATED PROTECTIVE v. ORDER 14 Judge: Honorable Kenly Kiya Kato 15 WALMART INC. f/k/a WAL-MART Magistrate Judge: David T. Barstow STORES, INC., an Arkansas Corporation; 16 and DOES 1-100, inclusive, 17 Defendants. 18 19 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public disclosure 23 and from use for any purpose other than pursuing this litigation may be warranted. 24 Accordingly, the parties hereby stipulate and petition the Court to enter the following 25 Stipulated Protective Order. The parties acknowledge that this Order does not confer 26 blanket protections on all disclosures or responses to discovery and that the protection 27 it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 1 2. GOOD CAUSE STATEMENT 2 This action is likely to involve customer and employees’ personal information 3 and personnel file, medical records, health information, and other valuable research, 4 development, commercial, financial, technical and/or proprietary information for 5 which special protection from public disclosure and from use for any purpose other 6 than prosecution of this action is warranted. Such confidential and proprietary materials 7 and information consist of, among other things, confidential employees’ information 8 and personnel files, health and medical records, confidential business practices, or 9 other confidential research, development, or commercial information (including 10 information implicating privacy rights of third parties), information otherwise 11 generally unavailable to the public, or which may be privileged or otherwise protected 12 from disclosure under state or federal statutes, court rules, case decisions, or common 13 law. Accordingly, to expedite the flow of information, to facilitate the prompt 14 resolution of disputes over confidentiality of discovery materials, to adequately protect 15 information the parties are entitled to keep confidential, to ensure that the parties are 16 permitted reasonable necessary uses of such material in preparation for and in the 17 conduct of trial, to address their handling at the end of the litigation, and serve the ends 18 of justice, a protective order for such information is justified in this matter. It is the 19 intent of the parties that information will not be designated as confidential for tactical 20 reasons and that nothing be so designated without a good faith belief that it has been 21 maintained in a confidential, non-public manner, and there is good cause why it should 22 not be part of the public record of this case. 23 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 24 The parties further acknowledge, as set forth in Section 14.3, below, that this Stipulated 25 Protective Order does not entitle them to file confidential information under seal; Local 26 Civil Rule 79-5 sets forth the procedures that must be followed and the standards that 27 will be applied when a party seeks permission from the court to file material under seal. 1 proceedings and records in civil cases. In connection with non-dispositive motions, 2 good cause must be shown to support a filing under seal. See Kamakana v. City and 3 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 4 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 5 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 6 cause showing), and a specific showing of good cause or compelling reasons with 7 proper evidentiary support and legal justification, must be made with respect to 8 Protected Material that a party seeks to file under seal. The parties’ mere designation 9 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 10 submission of competent evidence by declaration, establishing that the material sought 11 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 12 constitute good cause. Further, if a party requests sealing related to a dispositive motion 13 or trial, then compelling reasons, not only good cause, for the sealing must be shown, 14 and the relief sought shall be narrowly tailored to serve the specific interest to be 15 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). 16 For each item or type of information, document, or thing sought to be filed or 17 introduced under seal, the party seeking protection must articulate compelling reasons, 18 supported by specific facts and legal justification, for the requested sealing order. 19 Again, competent evidence supporting the application to file documents under seal 20 must be provided by declaration. Any document that is not confidential, privileged, or 21 otherwise protectable in its entirety will not be filed under seal if the confidential 22 portions can be redacted. If documents can be redacted, then a redacted version for 23 public viewing, omitting only the confidential, privileged, or otherwise protectable 24 portions of the document, shall be filed. Any application that seeks to file documents 25 under seal in their entirety should include an explanation of why redaction is not 26 feasible. 27 // 1 4. DEFINITIONS 2 4.1 Action: Rasheed Ravell Levi v. Walmart Inc f/k/a Wal-Mart Stores, Inc. 3 bearing case caption: 5:25-cv-01344-KK-DTBx. 4 4.2 Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how 7 it is generated, stored or maintained) or tangible things that qualify for protection under 8 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 9 Statement. 10 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 11 support staff). 12 4.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 4.6 Disclosure or Discovery Material: all items or information, regardless of 16 the medium or manner in which it is generated, stored, or maintained (including, among 17 other things, testimony, transcripts, and tangible things), that are produced or generated 18 in disclosures or responses to discovery. 19 4.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 21 expert witness or as a consultant in this Action. 22 4.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 4.9 Non-Party: any natural person, partnership, corporation, association or 26 other legal entity not named as a Party to this action. 27 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 1 Action on behalf of that party or are affiliated with a law firm that has appeared on 2 behalf of that party, and includes support staff. 3 4.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 4.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 11 their employees and subcontractors. 12 4.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 5. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected 18 Material (as defined above), but also (1) any information copied or extracted from 19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 20 Material; and (3) any testimony, conversations, or presentations by Parties or their 21 Counsel that might reveal Protected Material. Any use of Protected Material at trial 22 shall be governed by the orders of the trial judge and other applicable authorities. This 23 Order does not govern the use of Protected Material at trial. 24 6. DURATION 25 Once a case proceeds to trial, information that was designated as 26 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 27 as an exhibit at trial becomes public and will be presumptively available to all members 1 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 2 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 3 documents produced in discovery from “compelling reasons” standard when merits- 4 related documents are part of court record). Accordingly, the terms of this protective 5 order do not extend beyond the commencement of the trial. 6 7. DESIGNATING PROTECTED MATERIAL 7 7.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection 9 under this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items or oral or written 12 communications that qualify so that other portions of the material, documents, items or 13 communications for which protection is not warranted are not swept unjustifiably 14 within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations that 16 are shown to be clearly unjustified or that have been made for an improper purpose 17 (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating Party 19 to sanctions. If it comes to a Designating Party’s attention that information or items 20 that it designated for protection do not qualify for protection, that Designating Party 21 must promptly notify all other Parties that it is withdrawing the inapplicable 22 designation. 23 7.2 Manner and Timing of Designations. 24 Except as otherwise provided in this Order, or as otherwise stipulated or ordered, 25 Disclosure of Discovery Material that qualifies for protection under this Order must be 26 clearly so designated before the material is disclosed or produced. 27 Designation in conformity with this Order requires: 1 (a) for information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 3 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion of the material on a page qualifies for protection, the Producing Party also must 6 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 7 margins). A Party or Non-Party that makes original documents available for inspection 8 need not designate them for protection until after the inspecting Party has indicated 9 which documents it would like copied and produced. 10 During the inspection and before the designation, all of the material made 11 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting 12 Party has identified the documents it wants copied and produced, the Producing Party 13 must determine which documents, or portions thereof, qualify for protection under this 14 Order. Then, before producing the specified documents, the Producing Party must affix 15 the “CONFIDENTIAL legend” to each page that contains Protected Material. If only 16 a portion of the material on a page qualifies for protection, the Producing Party also 17 must clearly identify the protected portion(s) (e.g., by making appropriate markings in 18 the margins). 19 (b) Confidential Material disclosed at a deposition may be designated as 20 confidential by indicating on the record that the information is confidential or by 21 notifying the court reporter and other parties in writing, within fifteen (15) business 22 days of receipt of the transcript, of the specific pages and lines of the transcript which 23 are designated as confidential. Until the expiration of such 15-business-day period, the 24 entire transcript shall receive confidential treatment. 25 (c) for information produced in some form other than documentary and for any 26 other tangible items, that the Producing Party affix in a prominent place on the exterior 27 of the container or containers in which the information is stored the legend 1 protection, the Producing Party, to the extent practicable, shall identify the protected 2 portion(s). 3 7.3 Inadvertent Failures to Designate. 4 If timely corrected, an inadvertent failure to designate qualified information or 5 items does not, standing alone, waive the Designating Party’s right to secure protection 6 under this Order for such material. Upon timely correction of a designation, the 7 Receiving Party must make reasonable efforts to assure that the material is treated in 8 accordance with the provisions of this Order. 9 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 11 designation of confidentiality at any time that is consistent with the Court’s Scheduling 12 Order. 13 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 14 resolution process under Local Rule 37-1 et seq. 15 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 16 stipulation pursuant to Local Rule 37-2. 17 8.4 The burden of persuasion in any such challenge proceeding shall be on the 18 party seeking to modify the designation. Frivolous challenges, and those made for an 19 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other 20 parties) may expose the Challenging Party to sanctions. Unless the Designating Party 21 has waived or withdrawn the confidentiality designation, all parties shall continue to 22 afford the material in question the level of protection to which it is entitled under the 23 Producing Party’s designation until the Court rules on the challenge. 24 9. ACCESS TO AND USE OF PROTECTED MATERIAL 25 9.1 Basic Principles. A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending or attempting to settle this Action. Such 1 conditions described in this Order. When the Action has been terminated, a Receiving 2 Party must comply with the provisions of section 15 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 9.2 Disclosure of “CONFIDENTIAL” Information or Items. 7 Unless otherwise ordered by the court or permitted in writing by the Designating 8 Party, a Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 11 employees of said Outside Counsel of Record to whom it is reasonably necessary to 12 disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 16 is reasonably necessary for this Action and who have signed the “Acknowledgment 17 and Agreement to Be Bound” (Exhibit A) 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 21 to whom disclosure is reasonably necessary for this Action and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 2 by the Designating Party or ordered by the court. Pages of transcribed deposition 3 testimony or exhibits to depositions that reveal Protected Material may be separately 4 bound by the court reporter and may not be disclosed to anyone except as permitted 5 under this Stipulated Protective Order; and 6 (i) any mediators or settlement officers and their supporting personnel, mutually 7 agreed upon by any of the parties engaged in settlement discussions. 8 (j) Notwithstanding the foregoing, Confidential Material shall not be disclosed 9 to any current or former employees of, or current or former consultants, advisors, or 10 agents of, a direct competitor of any party named in the litigation. The parties may 11 redact information that is privileged or protected from discovery, Confidential 12 Material, and sensitive, non-relevant information, including non-relevant financial and 13 personally identifiable information. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation that 17 compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party within five (5) business 20 days. Such notification shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order to 22 issue in the other litigation that some or all of the material covered by the subpoena or 23 order is subject to this Protective Order. Such notification shall include a copy of this 24 Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be pursued by 26 the Designating Party whose Protected Material may be affected. If the Designating 27 Party timely seeks a protective order, the Party served with the subpoena or court order 1 before a determination by the court from which the subpoena or order issued, unless 2 the Party has obtained the Designating Party’s permission. The Designating Party shall 3 bear the burden and expense of seeking protection in that court of its confidential 4 material and nothing in these provisions should be construed as authorizing or 5 encouraging a Receiving Party in this Action to disobey a lawful directive from another 6 court. 7 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a Non- 10 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 11 by Non-Parties in connection with this litigation is protected by the remedies and relief 12 provided by this Order. Nothing in these provisions should be construed as prohibiting 13 a Non-Party from seeking additional protections. 14 (b) 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 confidential 17 information, then the Party shall: 18 (1) promptly notify in writing the Requesting Party and the Non-Party that some 19 or all of the information requested is subject to a confidentiality agreement with a Non- 20 Party; 21 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 22 Order in this Action, the relevant discovery request(s), and a reasonably specific 23 description of the information requested; and (3) make the information requested 24 available for inspection by the Non-Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. 1 any information in its possession or control that is subject to the confidentiality 2 agreement with the Non-Party before a determination by the court. Absent a court order 3 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 4 in this court of its Protected Material. 5 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 9 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 10 all unauthorized copies of the Protected Material, (c) inform the person or persons to 11 whom unauthorized disclosures were made of all the terms of this Order, and (d) 12 request such person or persons to execute the “Acknowledgment an Agreement to Be 13 Bound” attached hereto as Exhibit A. 14 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 13.1 Scope: The production of Confidential Material, privileged or work- 17 product protected material, whether inadvertent or otherwise, is not a waiver of 18 confidentiality, privilege, or protection from discovery. When a Producing Party gives 19 notice to Receiving Parties that certain inadvertently produced material is subject to a 20 claim of privilege or other protection, the obligations of the Receiving Parties are those 21 set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended 22 to modify what-ever procedure may be established in an e-discovery order that 23 provides for production without prior privilege review. 24 13.2 Clawback: This Order shall be interpreted to provide the maximum 25 protection allowed by Federal Rule of Evidence (FRE) 502(d). A producing party may 26 give written notice asserting a claim of confidentiality, privilege, work-product 27 protection, or other ground for reclaiming documents or information (a “clawback 1 sequester the document and shall not review or use that document, or any work product 2 containing information taken from that document, for any purpose. 3 14. MISCELLANEOUS 4 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 14.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 14.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 13 only be filed under seal pursuant to a court order authorizing the sealing of the specific 14 Protected Material. If a Party’s request to file Protected Material under seal is denied 15 by the court, then the Receiving Party may file the information in the public record 16 unless otherwise instructed by the court. 17 15. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 6, within 30 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 24 must submit a written certification to the Producing Party (and, if not the same person 25 or entity, to the Designating Party) by the 30-day deadline that (1) identifies (by 26 category, where appropriate) all the Protected Material that was returned or destroyed 27 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 1 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 2 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 3 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 4 attorney work product, and consultant and expert work product, even if such materials 5 contain Protected Material. Any such archival copies that contain or constitute 6 Protected Material remain subject to this Protective Order as set forth in Section 6 7 (DURATION). 8 16. VIOLATION 9 Any violation of this Order may be punished by appropriate measures including, 10 without limitation, contempt proceedings and/or monetary sanctions. 11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 12 Dated: October 21, 2025 DINSMORE & SHOHL LLP 13 14 By:/s/ Varun Sabharwal Caroline G. Massey 15 Varun Sabharwal 16 Attorneys for Defendant

WALMART, INC.

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18 The filer of this document attests that all signatories listed and on whose behalf the 19 filing is submitted concur in the filing’s content and have authorized the filing.

20 Dated: October 21, 2025 JOHNSON BECKER, PLLC 21

22 By:/s/ Anna R. Rick, Esq. 23 Anna R. Rick 24 Attorneys for Plaintiff

RASHEED RAVELL LEVI

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27 1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. October 21, 2025 . : 3 || Dated: hf = bit 4 onorable David/V. Barstow United States District Court 5 Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 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 perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of Rasheed Ravell Levi v. Walmart Inc., bearing Case No. 5:25-cv- 8 01344-KK-DTBx 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 promise 12 that I 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 with 14 the provisions of this Order. I further agree to submit to the jurisdiction of the United 15 States District Court for the Central District of California for the purpose of enforcing 16 the terms of this Stipulated Protective Order, even if such enforcement proceedings 17 occur after termination of this action. 18 I hereby appoint ________________________ [print or type full name] of 19 _________ [print or type full address and telephone number] as my California agent 20 for service of process in connection with this action or any proceedings related to 21 enforcement of this Stipulated Protective 22 Order. 23 Date: ___________________________ 24 City and State where sworn and 25 signed: ___________________________ 26 Printed name: ___________________________ 27 Signature: ___________________________