1 LlcOaoN@Gqu CillAarOro w(SlaBwN.co 3m2 3453) 2 e-service@quillarrowlaw.com 3 QUILL & ARROW, LLP 10880 Wilshire Blvd., Suite 1600 4 Los Angeles, California 90024 5 Telephone: (310) 933-4271 Facsimile: (310) 889-0645 6 7 Attorneys for Plaintiff,

DANILO CALDERON

8 9 AMIR NASSIHI (SBN 235936) anassihi@shb.com 10 MOHAMMAD U. TARIQ (SBN 350423) mtariq@shb.com 11 SHOOK, HARDY & BACON L.L.P. 555 Mission Street, Suite 2300 12 San Francisco, CA 94105 13 TEL: (415) 544-1900 | FAX: (415) 391-0281

14 SARAH GARBUZOV (SBN 345909) sgarbuzov@shb.com 15

SHOOK, HARDY & BACON L.L.P.

16 5 Park Plaza, Suite 1600 Irvine, CA 92614 17 Tel: (949) 475-1500 | Fax: (949) 475-0016

18 Attorneys for Defendant,

NISSAN NORTH AMERICA, INC.

19

UNITED STATES DISTRICT COURT

20

CENTRAL DISTRICT OF CALIFORNIA

21 DANILO CALDERON, an individual, Case No. 2:25-cv-04804-SSC 22 Plaintiff, Assigned to the Honorable Stephanie S. 23 Christensen 24 vs. [PROPOSED] STIPULATED 25 NISSAN NORTH AMERICA, INC., a PROTECTIVE ORDER Delaware Corporation, 26

27 Defendant.

28 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 prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. 11 1.2 Good Cause Statement. 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and from 15 use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other things, 17 confidential business or financial information, information regarding confidential 18 business practices, or other confidential research, development, or commercial 19 information (including information implicating privacy rights of third parties), 20 information otherwise generally unavailable to the public, or which may be privileged 21 or otherwise protected from disclosure under state or federal statutes, court rules, case 22 decisions, or common law. Accordingly, to expedite the flow of information, to 23 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 24 to adequately protect information the parties are entitled to keep confidential, to 25 ensure that the parties are permitted reasonable necessary uses of such material in 26 preparation for and in the conduct of trial, to address their handling at the end of the 27 litigation, and serve the ends of justice, a protective order for such information is 28 justified in this matter. It is the intent of the parties that information will not be 1 designated as confidential for tactical reasons and that nothing be so designated 2 without a good faith belief that it has been maintained in a confidential, non-public 3 manner, and there is good cause why it should not be part of the public record of this 4 case. 5 2. DEFINITIONS 6 2.1 Action: this pending federal lawsuit, Case no. 2:25-cv-04804-SSC. 7 2.2 Challenging Party: a Party or Non-Party that challenges the designation 8 of information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 10 how it is generated, stored or maintained) or tangible things that qualify for protection 11 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 12 Cause Statement. 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 14 support staff). 15 2.5 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless 19 of the medium or manner in which it is generated, stored, or maintained (including, 20 among other things, testimony, transcripts, and tangible things), that are produced or 21 generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as 24 an expert witness or as a consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other outside 27 counsel. 28 2.9 Non-Party: any natural person, partnership, corporation, association, or 1 other legal entity not named as a Party to this action. 2 2.10 Outside Counsel of Record: attorneys who are not employees of a party 3 to this Action but are retained to represent or advise a party to this Action and have 4 appeared in this Action on behalf of that party or are affiliated with a law firm that 5 has appeared on behalf of that party, including support staff. 6 2.11 Party: any party to this Action, including all of its officers, directors, 7 employees, consultants, retained experts, and Outside Counsel of Record (and their 8 support staffs). 9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 10 Discovery Material in this Action. 11 2.13 Professional Vendors: persons or entities that provide litigation support 12 services (e.g., photocopying, videotaping, translating, preparing exhibits or 13 demonstrations, and organizing, storing, or retrieving data in any form or medium) 14 and their employees and subcontractors. 15 2.14 Protected Material: any Disclosure or Discovery Material that is 16 designated as “CONFIDENTIAL.” 17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 18 from a Producing Party. 19 3. SCOPE 20 The protections conferred by this Stipulation and Order cover not only 21 Protected Material (as defined above), but also (1) any information copied or extracted 22 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 23 Protected Material; and (3) any testimony, conversations, or presentations by Parties 24 or their Counsel that might reveal Protected Material. 25 Any use of Protected Material at trial shall be governed by the orders of the 26 trial judge. This Order does not govern the use of Protected Material at trial. 27 /// 28 /// 1 4. DURATION 2 Once a case proceeds to trial, all of the court-filed information to be introduced 3 that was previously designated as confidential or maintained pursuant to this 4 protective order becomes public and will be presumptively available to all members 5 of the public, including the press, unless compelling reasons supported by specific 6 factual findings to proceed otherwise are made to the trial judge in advance of the 7 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 8 2006) (distinguishing “good cause” showing for sealing documents produced in 9 discovery from “compelling reasons” standard when merits-related documents are 10 part of court record). Accordingly, the terms of this protective order do not extend 11 beyond the commencement of the trial. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under this 15 Order must take care to limit any such designation to specific material that qualifies 16 under the appropriate standards. The Designating Party must designate for protection 17 only those parts of material, documents, items, or oral or written communications that 18 qualify so that other portions of the material, documents, items, or communications 19 for which protection is not warranted are not swept unjustifiably within the ambit of 20 this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating Party 25 to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the inapplicable designation. 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix, at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 11 contains protected material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 19 it wants copied and produced, the Producing Party must determine which documents, 20 or portions thereof, qualify for protection under this Order. Then, before producing 21 the specified documents, the Producing Party must affix the “CONFIDENTIAL 22 legend” to each page that contains Protected Material. If only a portion or portions 23 of the material on a page qualifies for protection, the Producing Party also must clearly 24 identify the protected portion(s) (e.g., by making appropriate markings in the 25 margins). 26 (b) for testimony given in depositions that the Designating Party identify 27 the Disclosure or Discovery Material on the record, before the close of the deposition. 28 (c) for information produced in some form other than documentary and 1 for any other tangible items, that the Producing Party affix in a prominent place on 2 the exterior of the container or containers in which the information is stored the legend 3 “CONFIDENTIAL.” If only a portion or portions of the information warrants 4 protection, the Producing Party, to the extent practicable, shall identify the protected 5 portion(s). 6 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 failure to designate qualified information or items does not, standing alone, waive the 8 Designating Party’s right to secure protection under this Order for such material. 9 Upon timely correction of a designation, the Receiving Party must make reasonable 10 efforts to assure that the material is treated in accordance with the provisions of this 11 Order. 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process. Any discovery motion must comply with local rules. 18 6.3 Burden. The burden of persuasion in any such challenge proceeding 19 shall be on the Designating Party. Frivolous challenges, and those made for an 20 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 21 other parties) may expose the Challenging Party to sanctions. Unless the Designating 22 Party has waived or withdrawn the confidentiality designation, all parties shall 23 continue to afford the material in question the level of protection to which it is entitled 24 under the Producing Party’s designation until the Court rules on the challenge. 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this 28 Action only for prosecuting, defending, or attempting to settle this Action. Such 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions described in this Order. When the Action has been terminated, a Receiving 3 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the Court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated 10 “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 12 well as employees of said Outside Counsel of Record to whom it is reasonably 13 necessary to disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of 15 the Receiving Party to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the Court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or 25 a custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in 27 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 28 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 1 will not be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 agreed by the Designating Party or ordered by the Court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material may be 5 separately bound by the court reporter and may not be disclosed to anyone except as 6 permitted under this Stipulated Protective Order; and 7 (i) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions. 9 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 11 PRODUCED IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification shall 16 include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to 18 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 (c) cooperate with respect to all reasonable procedures sought to be pursued 22 by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with 24 the subpoena or court order shall not produce any information designated in this action 25 as “CONFIDENTIAL” before a determination by the court from which the subpoena 26 or order issued, unless the Party has obtained the Designating Party’s permission. The 27 Designating Party shall bear the burden and expense of seeking protection in that court 28 of its confidential material and nothing in these provisions should be construed as 1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a Non- 6 Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to produce 11 a Non-Party’s confidential information in its possession, and the Party is subject to an 12 agreement with the Non-Party not to produce the Non-Party’s confidential 13 information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this Court within 14 23 days of receiving the notice and accompanying information, the Receiving Party may 24 produce the Non-Party’s confidential information responsive to the discovery request. 25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 26 any information in its possession or control that is subject to the confidentiality 27 agreement with the Non-Party before a determination by the Court. Absent a court 28 1 order to the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this Court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of this Order, 10 and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other protection, 16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 18 may be established in an e-discovery order that provides for production without prior 19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 20 parties reach an agreement on the effect of disclosure of a communication or 21 information covered by the attorney-client privilege or work product protection, the 22 parties may incorporate their agreement in the stipulated protective order submitted 23 to the Court. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 28 Protective Order, no Party waives any right it otherwise would have to object to 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, within 60 days of a written request by 6 the Designating Party, each Receiving Party must return all Protected Material to the 7 Producing Party or destroy such material. As used in this subdivision, “all Protected 8 Material” includes all copies, abstracts, compilations, summaries, and any other 9 format reproducing or capturing any of the Protected Material. Whether the Protected 10 Material is returned or destroyed, the Receiving Party must submit a written 11 certification to the Producing Party (and, if not the same person or entity, to the 12 Designating Party) by the 60 day deadline that (1) identifies (by category, where 13 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 14 that the Receiving Party has not retained any copies, abstracts, compilations, 15 summaries or any other format reproducing or capturing any of the Protected Material. 16 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 17 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 18 correspondence, deposition and trial exhibits, expert reports, attorney work product, 19 and consultant and expert work product, even if such materials contain Protected 20 Material. Any such archival copies that contain or constitute Protected Material 21 remain subject to this Protective Order as set forth in Section 4 (DURATION). 22 14. VIOLATION OF ORDER 23 Any violation of this Order may be punished by any and all appropriate 24 measures including, without limitation, contempt proceedings and/or monetary 25 sanctions. 26 /// 27 /// 28 /// 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 || Dated: November 10, 2025 QUILL & ARROW, LLP 4 5 By /s/ Long Cao 6 LONG CAO 7 Attorneys for Plaintiff

DANILO CALDERON

8 9 10 Dated: November 10, 2025 SHOOK, HARDY & BACON L.L.P. 11 12 By /s/ Mohammad Tariq 13 AMIR NASSIHI 14 MOHAMMAD JU. TARIQ

SARAH GARBUZOV

15 Attorneys for Defendant 16 NISSAN NORTH AMERICA, INC. 17 18 19 || □□ ISSO ORDERED. 20 || Dated: November 12, 2025 Z—— 21 By fae 2 HON. STEPHANIE S. CHRISTENSEN 73 UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28

1 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 8 case of Danilo Calderon v. Nissan North America, Inc., Case No. 2:25-cv-04804- 9 SSC. 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. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Date: ______________________________________ 25 City and State where signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28