1 Heather L. Mills, Esq. (SBN 190950) Diana M. Rivera, Esq. (SBN 222025) 2

SKANE MILLS LLP

3 550 South Hope Street, Suite 410 4 Los Angeles, CA 90071

T: (213) 452-1200 / F: (213) 452-1201

5 drivera@skanemills.com / iyee@skanemills.com 6 Attorneys for Defendant, 7 TARGET CORPORATION, a Minnesota Corporation 8

UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

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12 M

ARTHA RUELAS, an individual; CASE NO.: 2:25-cv-1648 CV (KSx) [Los Angeles County Superior Court Case

13 25VECV00242] Plaintiff, 14 [Assigned to Hon. Cynthia Valenzuela, 15 v . District Judge; Hon. Karen L. Stevenson, TARGET CORPORATION; a Magistrate Judge] 16 Minnesota Corporation; and DOES 1 to 20, inclusive, STIPULATION AND PROTECTIVE 17 Defendants. ORDER 18 Complaint Filed: January 13, 2025 19 20 21 1. A. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation may be 25 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 26 the following Stipulated Protective Order. The parties acknowledge that this Order 27 does not confer blanket protections on all disclosures or responses to discovery and 28 that the protection it affords from public disclosure and use extends only to the 1 limited information or items that are entitled to confidential treatment under the 2 applicable legal principles. The parties further acknowledge, as set forth in Section 3 12.3, below, that this Stipulated Protective Order does not entitle them to file 4 confidential information under seal; Civil Local Rule 79-5.1 sets forth the 5 procedures that must be followed and the standards that will be applied when a party 6 seeks permission from the court to file material under seal. 7 B. GOOD CAUSE STATEMENT 8 Federal Rules of Civil Procedure, Rule 26(c)(1) states in pertinent part, that 9 the Court, upon a showing of good cause may “issue an order to protect a party from 10 annoyance, embarrassment, oppression, or undue burden or expense.” Fed.R.Civ.P. 11 26(c)(1). In the instant matter, Defendant Target Corporation’s Confidential 12 Documents contain proprietary and confidential trade secret information relating to 13 Defendant Target Corporation’s business practices, its safety protocol, and 14 surveillance videos. Defendant Target Corporation (“Defendant” or “Target”) 15 derives independent economic value from maintaining the confidentiality of the 16 policies and procedures set forth in these Confidential Documents. 17 Defendant is a retailer and has conducted business in California for over 30 18 years. The retail industry is very competitive. As a result of years of investing time 19 and money in research and investigation, Defendant developed the policies 20 contained in the Confidential Documents for the purposes of maintaining the 21 security of its facilities, providing quality customer service, and ensuring the safety 22 of its employees, customers, and other invitees. These policies and procedures, as 23 memorialized in the Confidential Documents, were created and generated by Target 24 for Target, and are used for the purposes of maintaining safety at its stores and 25 creating efficient and organized work environments for its employees. As a result, 26 Defendant is able to minimize the waste of any resources, which is a key factor in 27 generating profitability for its business. 28 Defendant derives economic value from maintaining the secrecy of its 1 Confidential Documents. If disclosed to the public, the trade secret information 2 contained in Defendant’s Confidential Documents would reveal Defendant’s internal 3 operations and could potentially be used by competitors as a means to compete for 4 its customers, interfere with its business plans and thereby gain unfair business 5 advantages. If Defendant’s safety protocol were revealed to the general public, it 6 would hinder Defendant’s ability to effectively resolve and minimize liability 7 claims, and its goal of protecting its customers and employees from theft and other 8 crimes. Unrestricted or unprotected disclosure of such information would result in 9 prejudice or harm to Defendant by revealing Target’s competitive confidential 10 information, which has been developed at the expense of Target and which 11 represents valuable tangible and intangible assets. Accordingly, the parties 12 respectfully submit that there is good cause for the entry of this Protective Order. 13 2. DEFINITIONS 14 2.1 “Action” means the above-entitled proceeding with case number 2:25- 15 cv-1648 CV (KSx). 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 21 Good Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 23 their support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless 28 of the medium or manner in which it is generated, stored, or maintained (including, 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a 12 party to this Action but are retained to represent or advise a party to this Action and 13 have appeared in this Action on behalf of that party or are affiliated with a law firm 14 which has appeared on behalf of that party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 28 /// 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Once a case proceeds to trial, all of the information that was designated as 11 confidential or maintained pursuant to this protective order becomes public and will 12 be presumptively available to all members of the public, including the press, unless 13 compelling reasons supported by specific factual findings to proceed otherwise are 14 made to the trial judge in advance of the trial. See Kamakana v. City and County of 15 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record). Accordingly, the 18 terms of this protective order do not extend beyond the commencement of the trial. 19 The Designating Party shall have the right to designate as “Confidential” any 20 form of disclosure which may contain Confidential Material, including any 21 Document, Pleading, Motion, Exhibit, Declaration, Affidavit, Deposition Transcript, 22 Inspection and all other tangible items (electronic media, photographs, 23 videocassettes, etc.), Testimony or Information that the Designating Party in good 24 faith believes to contain non-public information that is entitled to confidential 25 treatment under applicable law, such as asset protection videos, material, documents, 26 information, or policies. 27 /// 28 /// 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection 3 Each Party or Non-Party that designates information or items for protection 4 under this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate for 6 protection only those parts of material, documents, items, or oral or written 7 communications that qualify so that other portions of the material, documents, items, 8 or communications for which protection is not warranted are not swept unjustifiably 9 within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 The entry of this Stipulation and Protective Order does not alter, waive, 19 modify, or abridge any right, privilege or protection otherwise available to any Party 20 with respect to the discovery of matters, including but not limited to any Party’s 21 right to assert the attorney-client privilege, the attorney work product doctrine, or 22 other privileges, or any Party’s right to contest any such assertion. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in this 24 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 28 /// 1 Designation in conformity with this Order requires: 2 (a) For information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that 4 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and 12 before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must determine which 15 documents, or portions thereof, qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 18 portion or portions of the material on a page qualifies for protection, the Producing 19 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 20 markings in the margins). 21 (b) For testimony given in depositions that the Designating Party identify 22 the Disclosure or Discovery Material on the record, before the close of the 23 deposition all protected testimony. 24 (c) For information produced in some form other than documentary and for 25 any other tangible items, that the Producing Party affix in a prominent place on the 26 exterior of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 28 protection, the Producing Party, to the extent practicable, shall identify the protected 1 portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items does not, standing alone, waive 4 the Designating Party’s right to secure protection under this Order for such material. 5 Upon timely correction of a designation, the Receiving Party must make reasonable 6 efforts to assure that the material is treated in accordance with the provisions of this 7 Order. 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37.1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on the 15 Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 or withdrawn the confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the Court rules on the challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending, or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. When the Action has been terminated, a 27 Receiving Party must comply with the provisions of section 13 below (FINAL 28 DISPOSITION). 1 Protected Material must be stored and maintained by a Receiving Party at a location 2 and in a secure manner that ensures that access is limited to the persons authorized 3 under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 5 ordered by the court or permitted in writing by the Designating Party, a Receiving 6 Party may disclose any information or item designated “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 8 employees of said Outside Counsel of Record to whom it is reasonably necessary to 9 disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of the 11 Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the information or a 21 custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in 23 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 24 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 25 they will not be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 27 agreed by the Designating Party or ordered by the court. Pages of transcribed 28 deposition testimony or exhibits to depositions that reveal Protected Material may be 1 separately bound by the court reporter and may not be disclosed to anyone except as 2 permitted under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 8. PROTECTED MATERIAL SUPOENAED OR ORDERED PRODUCED 6 IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification shall include 15 a copy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued 17 by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with the 19 subpoena or court order shall not produce any information designated in this action 20 as “CONFIDENTIAL” before a determination by the court from which the subpoena 21 or order issued, unless the Party has obtained the Designating Party’s permission. 22 The Designating Party shall bear the burden and expense of seeking protection in 23 that court of its confidential material and nothing in these provisions should be 24 construed as authorizing or encouraging a Receiving Party in this Action to disobey 25 a lawful directive from another court. 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a Non- 1 Party in this Action and designated as “CONFIDENTIAL.” Such information 2 produced by Non-Parties in connection with this litigation is protected by the 3 remedies and relief provided by this Order. Nothing in these provisions should be 4 construed as prohibiting a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to 6 produce a Non-Party’s confidential information in its possession, and the Party is 7 subject to an agreement with the Non-Party not to produce the Non-Party’s 8 confidential information, then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non-Party 10 that some or all of the information requested is subject to a 11 confidentiality agreement with a Non-Party; 12 (2) promptly provide the Non-Party with a copy of the Stipulated 13 Protective Order in this Action, the relevant discovery request(s), and a 14 reasonably specific description of the information requested; and 15 (3) make the information requested available for inspection by the 16 Non-Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this court within 14 18 days of receiving the notice and accompanying information, the Receiving Party 19 may produce the Non-Party’s confidential information responsive to the discovery 20 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 21 not produce any information in its possession or control that is subject to the 22 confidentiality agreement with the Non-Party before a determination by the court. 23 Absent a court order to the contrary, the Non-Party shall bear the burden and 24 expense of seeking protection in this court of its Protected Material. 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” that is attached hereto as Exhibit A. 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 may be established in an e-discovery order that provides for production without prior 13 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 parties reach an agreement on the effect of disclosure of a communication or 15 information covered by the attorney-client privilege or work product protection, the 16 parties may incorporate their agreement in the stipulated protective order submitted 17 to the court. 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this Protective Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 28 only be filed under seal pursuant to a court order authorizing the sealing of the 1 specific Protected Material at issue. If a Party's request to file Protected Material 2 under seal is denied by the court, then the Receiving Party may file the information 3 in the public record unless otherwise instructed by the court. 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, as defined in paragraph 4, within 60 6 days of a written request by the Designating Party, each Receiving Party must return 7 all Protected Material to the Producing Party or destroy such material. As used in 8 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 summaries, and any other format reproducing or capturing any of the Protected 10 Material. Whether the Protected Material is returned or destroyed, the Receiving 11 Party must submit a written certification to the Producing Party (and, if not the same 12 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 13 (by category, where appropriate) all the Protected Material that was returned or 14 destroyed and (2)affirms that the Receiving Party has not retained any copies, 15 abstracts, compilations, summaries or any other format reproducing or capturing any 16 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 17 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 19 reports, attorney work product, and consultant and expert work product, even if such 20 materials contain Protected Material. Any such archival copies that contain or 21 constitute Protected Material remain subject to this Protective Order as set forth in 22 Section 4 (DURATION). 23 14. 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 /// ! || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 2 3 || DATED: November 26, 2025 CASADO LAW FIRM, APLC 4 5 By: LL 6 Kelly L. Casado, Esq. 7 Attorneys for Plaintiff,

MARTHA RUELAS

8 9 || DATED: November 26, 2025 SKANE MILLS LLP 10

12 13 By: □□ 4 Diana M. Rivera, Esq. Attorneys for Defendant, 15 TARGET CORPORATION, a 16 Minnesota Corporation 17 18 Diana M. Rivera, the filer of this document, attests that all other signatories listed 19 || above, and on whose behalf this filing is submitted, concur in the filing’s content 79 have authorized the filing, pursuant to L.R. 5-4.3.4(@)(2)(). 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 FS Bewwn 95 ||DATED: _ December 1 _, 2025 men fh: SK Karen L. Stevenson 26 United States Magistrate Judge 27 28

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STIPULATION AND PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ____________________________________________, [print or type full name] of 4 ______________________________________________, [print or type full address] 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for the 7 Central District of California on ________________ [date] in the case of Martha 8 Ruelas v. Target Corporation, Case No.: 2:25-cv-1648 CV (KSx), I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in 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 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 ____________________________ [print 19 20 or type full name] of 21 _______________________________________________________ [print or type 22 full address and telephone number] as my California agent for service of process in 23 connection with this action or any proceedings related to enforcement of this 24 Stipulated Protective Order. 25 Date: _______________________________ 26 City and State where sworn and signed: ________________________________ 27 Printed Name: _________________________________________ 28 Signature: _____________________________________________