1

UNITED STATES DISTRICT COURT

2

CENTRAL DISTRICT OF CALIFORNIA

3

4 Case No. 2:25-cv-04799 5 SEAN LEONARD

6 Plaintiff,

STIPULATED PROTECTIVE

7 v. ORDER1

8 NAVY FEDERAL CREDIT 9 UNION; EARLY WARNING

SERVICES, LLC,

10 Defendants. 11 12 13 1. INTRODUCTION 14 1.1 Purposes and Limitations. Discovery in this action is likely to 15 involve production of confidential, proprietary, or private information for 16 which special protection from public disclosure and from use for any 17 purpose other than prosecuting this litigation may be warranted. 18 Accordingly, the parties hereby stipulate to and petition the court to 19 enter the following Stipulated Protective Order. The parties 20 acknowledge that this Order does not confer blanket protections on all 21 disclosures or responses to discovery and that the protection it affords 22 from public disclosure and use extends only to the limited information or 23 24 25 26 1 This Stipulated Protective Order is substantially based on the model 27 protective order provided under Magistrate Judge Stephanie S. 1 items that are entitled to confidential treatment under the applicable 2 legal principles. 3 1.2 Good Cause Statement. This action is likely to involve trade 4 secrets, customer and pricing lists and other valuable research, 5 development, commercial, financial, technical and/or proprietary 6 information for which special protection from public disclosure and from 7 use for any purpose other than prosecution of this action is warranted. 8 Such confidential and proprietary materials and information consist of, 9 among other things, confidential business or financial information, 10 information regarding confidential business practices, or other 11 confidential research, development, or commercial information (including 12 information implicating privacy rights of third parties), information 13 otherwise generally unavailable to the public, or which may be privileged 14 or otherwise protected from disclosure under state or federal statutes, 15 court rules, case decisions, or common law. Accordingly, to expedite the 16 flow of information, to facilitate the prompt resolution of disputes over 17 confidentiality of discovery materials, to adequately protect information 18 the parties are entitled to keep confidential, to ensure that the parties 19 are permitted reasonable necessary uses of such material in preparation 20 for and in the conduct of trial, to address their handling at the end of the 21 22 litigation, and serve the ends of justice, a protective order for such 23 information is justified in this matter. It is the intent of the parties that 24 information will not be designated as confidential for tactical reasons 25 and that nothing be so designated without a good faith belief that it has 26 been maintained in a confidential, non-public manner, and there is good 27 cause why it should not be part of the public record of this case. 1 1.3 Acknowledgment of Procedure for Filing Under Seal. The 2 parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential 4 information under seal; Local Rule 79-5 sets forth the procedures that 5 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 There is a strong presumption that the public has a right of access 8 to judicial proceedings and records in civil cases. In connection with 9 non-dispositive motions, good cause must be shown to support a filing 10 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 11 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 12 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of 15 good cause or compelling reasons with proper evidentiary support and 16 legal justification, must be made with respect to Protected Material that 17 a party seeks to file under seal. The parties’ mere designation of 18 Disclosure or Discovery Material as “Confidential” or “Confidential- 19 Attorneys’ Eyes Only” does not—without the submission of competent 20 evidence by declaration, establishing that the material sought to be filed 21 22 under seal qualifies as confidential, privileged, or otherwise 23 protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion 25 or trial, then compelling reasons, not only good cause, for the sealing 26 must be shown, and the relief sought shall be narrowly tailored to serve 27 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 1 information, document, or thing sought to be filed or introduced under 2 seal in connection with a dispositive motion or trial, the party seeking 3 protection must articulate compelling reasons, supported by specific 4 facts and legal justification, for the requested sealing order. Again, 5 competent evidence supporting the application to file documents under 6 seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise 8 protectable in its entirety will not be filed under seal if the confidential 9 portions can be redacted. If documents can be redacted, then a redacted 10 version for public viewing, omitting only the confidential, privileged, or 11 otherwise protectable portions of the document, shall be filed. Any 12 application that seeks to file documents under seal in their entirety 13 should include an explanation of why redaction is not feasible. 14

15 2. DEFINITIONS 16 2.1 Action: this pending federal lawsuit. 17 2.2 Challenging Party: a Party or Non-Party that challenges the 18 19 designation of information or items under this Order. 20 2.3 “Confidential Material”: information (regardless of how it is 21 generated, stored or maintained) or tangible things that qualify for 22 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and 23 as specified above in the Good Cause Statement. 24 2.4 “Confidential-Attorneys’ Eyes Only” information means 25 Confidential Material that falls within one or more of the following 26 categories: 27 1 a. Trade secrets information, including a formula, pattern, 2 compilation, program, device, method, technique, process, financial data, 3 or list of actual or potential customers or suppliers, that derives 4 independent economic value, actual or potential, from not being generally 5 known to, and not being readily ascertainable by proper means by, other 6 persons who can obtain economic value from its disclosure or use; 7 b. Highly sensitive financial, commercial, and marketing 8 information relating to the Parties’ respective products and/or business 9 activities. 10 2.5 “Confidential” information means all other Confidential 11 Material that does not constitute Confidential-Attorneys’ Eyes Only 12 information, including but not limited to: 13 (a) Research and development information; 14 (b) Information prohibited from disclosure by statute; 15 (c) Medical information concerning any individual; 16 (d) Personal identity information; 17 (e) Income tax returns (including attached schedules and 18 forms, W-2 forms and 1099 forms); or 19 (f) Personnel or employment records of a person who is not 20 a Party to the case. 21 2.6 Counsel: Outside Counsel of Record and House Counsel (as 22 well as their support staff). 23 2.7 Designating Party: a Party or Non-Party that designates 24 information or items that it produces in disclosures or in responses to 25 discovery as “Confidential” or “Confidential-Attorneys’ Eyes Only.” 26 2.8 Disclosure or Discovery Material: all items or information, 27 regardless of the medium or manner in which it is generated, stored, or 1 maintained (including, among other things, testimony, transcripts, and 2 tangible things), that are produced or generated in disclosures or 3 responses to discovery in this matter. 4 2.9 Expert: a person with specialized knowledge or experience in 5 a matter pertinent to the litigation who has been retained by a Party or 6 its counsel to serve as an expert witness or as a consultant in this Action. 7 2.10 Final Disposition: the later of (1) dismissal of all claims and 8 defenses in this Action, with or without prejudice; and (2) final judgment 9 herein after the completion and exhaustion of all appeals, rehearings, 10 remands, trials, or reviews of this Action, including the time limits for 11 filing any motions or applications for extension of time pursuant to 12 applicable law. 13 2.11 In-House Counsel: attorneys who are employees of a party to 14 this Action. In-House Counsel does not include Outside Counsel of 15 Record or any other outside counsel. 16 2.12 Non-Party: any natural person, partnership, corporation, 17 association, or other legal entity not named as a Party to this action. 18 2.13 Outside Counsel of Record: attorneys who are not employees 19 of a party to this Action but are retained to represent or advise a party to 20 this Action and have appeared in this Action on behalf of that party or 21 22 are affiliated with a law firm which has appeared on behalf of that party, 23 and includes support staff. 24 2.14 Party: any party to this Action, including all of its officers, 25 directors, employees, consultants, retained experts, and Outside Counsel 26 of Record (and their support staffs). 27 2.15 Producing Party: a Party or Non-Party that produces 1 2.16 Professional Vendors: persons or entities that provide 2 litigation- support services (e.g., photocopying, videotaping, translating, 3 preparing exhibits or demonstrations, and organizing, storing, or 4 retrieving data in any form or medium) and their employees and 5 subcontractors. 6 2.17 Protected Material: any Disclosure or Discovery Material that 7 is designated as “Confidential” or “Confidential-Attorneys’ Eyes Only.” 8 2.18 Receiving Party: a Party that receives Disclosure or Discovery 9 Material from a Producing Party. 10

11 3. SCOPE 12 The protections conferred by this Stipulation and Order cover not 13 only Protected Material (as defined above), but also (1) any information 14 copied or extracted from Protected Material; (2) all copies, excerpts, 15 summaries, or compilations of Protected Material; and (3) any 16 testimony, conversations, or presentations by Parties or their Counsel 17 that might reveal Protected Material. 18 19 Any use of Protected Material at trial shall be governed by the 20 orders of the trial judge. This Stipulated Protective Order does not 21 govern the use of Protected Material at trial. 22 23 4. TRIAL AND DURATION 24 The terms of this Stipulated Protective Order apply through Final 25 Disposition of the Action. 26 Once a case proceeds to trial, information that was designated as 27 “Confidential” or “Confidential-Attorneys’ Eyes Only” or maintained 1 pursuant to this Stipulated Protective Order and used or introduced as 2 an exhibit at trial becomes public and will be presumptively available to 3 all members of the public, including the press, unless compelling 4 reasons supported by specific factual findings to proceed otherwise are 5 made to the trial judge in advance of the trial. See Kamakana, 447 F.3d 6 at 1180–81 (distinguishing “good cause” showing for sealing documents 7 produced in discovery from “compelling reasons” standard when merits- 8 related documents are part of court record). Accordingly, for such 9 materials, the terms of this Stipulated Protective Order do not extend 10 beyond the commencement of the trial. 11 Even after Final Disposition of this litigation, the confidentiality 12 obligations imposed by this Stipulated Protective Order shall remain in 13 effect until a Designating Party agrees otherwise in writing or a court 14 order otherwise directs. 15

16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for 18 19 Protection. Each Party or Non-Party that designates information or 20 items for protection under this Order must take care to limit any such 21 designation to specific material that qualifies under the appropriate 22 standards. The Designating Party must designate for protection only 23 those parts of material, documents, items, or oral or written 24 communications that qualify so that other portions of the material, 25 documents, items, or communications for which protection is not 26 warranted are not swept unjustifiably within the ambit of this Order. 27 Mass, indiscriminate, or routinized designations are prohibited. 1 Designations that are shown to be clearly unjustified or that have been 2 made for an improper purpose (e.g., to unnecessarily encumber the case 3 development process or to impose unnecessary expenses and burdens on 4 other parties) may expose the Designating Party to sanctions. 5 If it comes to a Designating Party’s attention that information or 6 items that it designated for protection do not qualify for protection, that 7 Designating Party must promptly notify all other Parties that it is 8 withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise 10 provided in this Stipulated Protective Order (see, e.g., second paragraph 11 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 12 or Discovery Material that qualifies for protection under this Stipulated 13 Protective Order must be clearly so designated before the material is 14 disclosed or produced. 15 Designation in conformity with this Stipulated Protective Order 16 requires: 17 18 (a) for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or 20 trial proceedings), that the Producing Party affix at a minimum, the 21 legend “Confidential” or “Confidential-Attorneys’ Eyes Only” to each 22 page that contains protected material. If only a portion or portions of 23 the material on a page qualifies for protection, the Producing Party also 24 must clearly identify the protected portion(s) (e.g., by making 25 appropriate markings in the margins). 26 A Party or Non-Party that makes original documents available for 27 inspection need not designate them for protection until after the 1 inspecting Party has indicated which documents it would like copied 2 and produced. During the inspection and before the designation, all of 3 the material made available for inspection shall be deemed Confidential 4 or Confidential-Attorneys’ Eyes Only. After the inspecting Party has 5 identified the documents it wants copied and produced, the Producing 6 Party must determine which documents, or portions thereof, qualify for 7 protection under this Stipulated Protective Order. Then, before 8 producing the specified documents, the Producing Party must affix the 9 “Confidential” or “Confidential-Attorneys’ Eyes Only” legend to each 10 page that contains Protected Material. If only a portion or portions of 11 the material on a page qualifies for protection, the Producing Party also 12 must clearly identify the protected portion(s) (e.g., by making 13 appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party 15 identify the Disclosure or Discovery Material on the record, before the 16 close of the deposition all protected testimony. 17 (c) for information produced in some form other than 18 documentary and for any other tangible items, that the Producing Party 19 affix in a prominent place on the exterior of the container or containers 20 in which the information is stored the “Confidential” or “Confidential- 21 22 Attorneys’ Eyes Only” legend. If only a portion or portions of the 23 information warrants protection, the Producing Party, to the extent 24 practicable, shall identify the protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an 26 inadvertent failure to designate qualified information or items does not, 27 standing alone, waive the Designating Party’s right to secure protection 1 under this Order for such material. Upon timely correction of a 2 designation, the Receiving Party must make reasonable efforts to assure 3 that the material is treated in accordance with the provisions of this 4 Stipulated Protective Order. 5 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may 8 challenge a designation of confidentiality at any time that is consistent 9 with the court’s Scheduling Order. 10 6.2 Meet and Confer. The Challenging Party shall initiate the 11 dispute resolution process under Local Rule 37.1 et seq. and with 12 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 13 Discovery Motion Conference.”2 14 6.3 The burden of persuasion in any such challenge proceeding 15 shall be on the Designating Party. Frivolous challenges, and those 16 made for an improper purpose (e.g., to harass or impose unnecessary 17 expenses and burdens on other parties) may expose the Challenging 18 19 Party to sanctions. Unless the Designating Party has waived or 20 withdrawn the confidentiality designation, all parties shall continue to 21 afford the material in question the level of protection to which it is 22 entitled under the Producing Party’s designation until the court rules on 23 the challenge. 24 // 25 // 26

27 2 Judge Christensen’s Procedures are available at 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected 3 Material that is disclosed or produced by another Party or by a Non- 4 Party in connection with this Action only for prosecuting, defending, or 5 attempting to settle this Action. Such Protected Material may be 6 disclosed only to the categories of persons and under the conditions 7 described in this Order. When the Action reaches a Final Disposition, a 8 Receiving Party must comply with the provisions of section 13 below. 9 Protected Material must be stored and maintained by a Receiving 10 Party at a location and in a secure manner that ensures that access is 11 limited to the persons authorized under this Stipulated Protective 12 Order. 13 7.2 Disclosure of “Confidential” Information or Items. Unless 14 otherwise ordered by the court or permitted in writing by the 15 Designating Party, a Receiving Party may disclose any information or 16 item designated “Confidential” only: 17 18 (a) to the Receiving Party’s Outside Counsel of Record in this 19 Action, as well as employees of said Outside Counsel of Record to whom 20 it is reasonably necessary to disclose the information for this Action; 21 (b) to the officers, directors, and employees (including House 22 Counsel) of the Receiving Party to whom disclosure is reasonably 23 necessary for this Action; 24 (c) to Experts (as defined in this Order) of the Receiving Party to 25 whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) to the court and its personnel; 1 (e) to court reporters and their staff; 2 (f) to professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably necessary for 4 this Action and who have signed the “Acknowledgment and Agreement 5 to Be Bound” (Exhibit A); 6 (g) to the author or recipient of a document containing the 7 information or a custodian or other person who otherwise possessed or 8 knew the information; 9 (h) during their depositions, to witnesses, and attorneys for 10 witnesses, in the Action to whom disclosure is reasonably necessary, 11 provided: (1) the deposing party requests that the witness sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 13 witness will not be permitted to keep any confidential information 14 unless they sign the “Acknowledgment and Agreement to Be Bound” 15 (Exhibit A), unless otherwise agreed by the Designating Party or 16 ordered by the court. Pages of transcribed deposition testimony or 17 exhibits to depositions that reveal Protected Material may be separately 18 bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and 20 (i) to any mediator or settlement officer, and their supporting 21 22 personnel, mutually agreed upon by any of the parties engaged in 23 settlement discussions. 24 7.3 Disclosure of “Confidential-Attorneys’ Eyes Only” 25 Information or Items: Unless otherwise ordered by the Court or 26 permitted in writing by the Designating Party, a Receiving Party may 27 only disclose any information or item designated “Confidential- 1 (a) the Receiving Party’s Outside Counsel of Record in this 2 Action, as well as employees of said Outside Counsel of Record to whom 3 it is reasonably necessary to disclose the information for this Action; 4 (b) the Receiving Party’s House Counsel; 5 (c) Experts (as defined in this Order) of the Receiving Party to 6 whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the Court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and 11 Professional Vendors to whom disclosure is reasonably necessary for 12 this Action and who have signed the “Acknowledgment and Agreement 13 to Be Bound” (Ex. A); 14 (g) the author or recipient of a document containing the 15 information or a custodian or other person who otherwise possessed or 16 knew the information; 17 (h) any mediator or settlement officer who may be utilized in 18 connection with this Action, and their supporting personnel, mutually 19 agreed upon by any of the parties engaged in settlement discussions; 20 and 21 22 (i) any other person that the Designating Party agrees to in 23 writing. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 PRODUCED IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in 27 other litigation that compels disclosure of any information or items 1 designated in this Action as “Confidential” or “Confidential-Attorneys’ 2 Eyes Only,” that Party must: 3 (a) promptly notify in writing the Designating Party. Such 4 notification shall include a copy of the subpoena or court order; 5 (b) promptly notify in writing the party who caused the 6 subpoena or order to issue in the other litigation that some or all of the 7 material covered by the subpoena or order is subject to this Protective 8 Order. Such notification shall include a copy of this Stipulated 9 Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to 11 be pursued by the Designating Party whose Protected Material may be 12 affected. 13 If the Designating Party timely seeks a protective order, the 14 Party served with the subpoena or court order shall not produce any 15 information designated in this action as “Confidential” or “Confidential- 16 Attorneys’ Eyes Only” before a determination by the court from which 17 18 the subpoena or order issued, unless the Party has obtained the 19 Designating Party’s permission. The Designating Party shall bear the 20 burden and expense of seeking protection in that court of its confidential 21 material and nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a 23 lawful directive from another court. 24 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 9.1 Application. The terms of this Stipulated Protective Order 1 are applicable to information produced by a Non-Party in this Action and 2 designated as “Confidential” or “Confidential-Attorneys’ Eyes Only.” 3 Such information produced by Non-Parties in connection with this 4 litigation is protected by the remedies and relief provided by this Order. 5 Nothing in these provisions should be construed as prohibiting a Non- 6 Party from seeking additional protections. 7 9.2 Notification. In the event that a Party is required, by a valid 8 discovery request, to produce a Non-Party’s confidential information in 9 its possession, and the Party is subject to an agreement with the Non- 10 Party not to produce the Non-Party’s confidential information, then the 11 Party shall: 12 (a) promptly notify in writing the Requesting Party and the 13 Non-Party that some or all of the information requested is subject to a 14 confidentiality agreement with a Non-Party; 15 (b) make the information requested available for inspection by 16 the Non-Party, if requested. 17 9.3 Conditions of Production. If the Non-Party fails to seek a 18 protective order from this court within 14 days of receiving the notice 19 and accompanying information, the Receiving Party may produce the 20 Non-Party’s confidential information responsive to the discovery request. 21 22 If the Non-Party timely seeks a protective order, the Receiving Party 23 shall not produce any information in its possession or control that is 24 subject to the confidentiality agreement with the Non-Party before a 25 determination by the court. Absent a court order to the contrary, the 26 Non-Party shall bear the burden and expense of seeking protection in 27 this court of its Protected Material. 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 2 MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it 4 has disclosed Protected Material to any person or in any circumstance 5 not authorized under this Stipulated Protective Order, the Receiving 6 Party must immediately (a) notify in writing the Designating Party of 7 the unauthorized disclosures, (b) use its best efforts to retrieve all 8 unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of 10 this Order, and (d) request such person or persons to execute the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 12

13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 14

OTHERWISE PROTECTED MATERIAL

15 16 When a Producing Party gives notice to Receiving Parties that 17 certain inadvertently produced material is subject to a claim of privilege 18 or other protection, the obligations of the Receiving Parties are those set 19 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 20 provision is not intended to modify whatever procedure may be 21 established in an e-discovery order that provides for production without 22 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 23 Rules of Evidence, insofar as the parties reach an agreement on the 24 effect of disclosure of a communication or information covered by the 25 attorney-client privilege or work product protection, the parties may 26 incorporate their agreement in the stipulated protective order 27 submitted to the court. 1 2 12. MISCELLANEOUS 3 12.1 Right to Further Relief. Nothing in this Stipulated 4 Protective Order abridges the right of any person to seek its 5 modification by the court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry 7 of this Stipulated Protective Order no Party waives any right it 8 otherwise would have to object to disclosing or producing any 9 information or item on any ground not addressed in this Stipulated 10 Protective Order. Similarly, no Party waives any right to object on any 11 ground to use in evidence of any of the material covered by this 12 Stipulated Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under 14 seal any Protected Material must comply with Local Rule 79-5. 15 Protected Material may only be filed under seal pursuant to a court 16 order authorizing the sealing of the specific Protected Material at issue. 17 If a Party's request to file Protected Material under seal is denied by the 18 19 court, then the Receiving Party may file the information in the public 20 record unless otherwise instructed by the court. 21 22 13. FINAL DISPOSITION 23 After the Final Disposition of this Action, as defined in paragraph 24 4, within 60 days of a written request by the Designating Party, each 25 Receiving Party must return all Protected Material to the Producing 26 Party or destroy such material. As used in this subdivision, “all 27 Protected Material” includes all copies, abstracts, compilations, 1 summaries, and any other format reproducing or capturing any of the 2 Protected Material. Whether the Protected Material is returned or 3 destroyed, the Receiving Party must submit a written certification to 4 the Producing Party (and, if not the same person or entity, to the 5 Designating Party) by the 60 day deadline that (1) identifies (by 6 category, where appropriate) all the Protected Material that was 7 returned or destroyed and (2) affirms that the Receiving Party has not 8 retained any copies, abstracts, compilations, summaries or any other 9 format reproducing or capturing any of the Protected Material. 10 Notwithstanding this provision, Counsel is entitled to retain an archival 11 copy of all pleadings, motion papers, trial, deposition, and hearing 12 transcripts, legal memoranda, correspondence, deposition and trial 13 exhibits, expert reports, attorney work product, and consultant and 14 expert work product, even if such materials contain Protected Material. 15 Any such archival copies that contain or constitute Protected Material 16 remain subject to this Protective Order as set forth in Section 4. 17 18 // 19 // 20 // 21 // 22 // 23 24 // 25 // 26 // 27 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 || by any and all appropriate measures including, without limitation, 4 || contempt proceedings and/or monetary sanctions. 5 6 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 g || Dated: January 7, 2026 KAZEROUNI LAW GROUP, APC ? By: /s/ Gor Antonyan, Esq. 10 Gor Antonyan, Esq. Attorneys for Plaintiff 12 || Dated: January 7, 2026 TROUTMAN PEPPER LOCKE LLP 13 By: /s/ Jacob Kozaczuk, Esq. 14 Jacob Kozaczuk, Esq. 15 Attorneys for Defendant Navy 16 Federal Credit Union

17 || Dated: January 7, 2026 TROUTMAN PEPPER LOCKE LLP 8 By: /s/ Katalina Baumann, Esq. 19 Katalina Baumann, Esq. 0 Attorneys for Defendant Early Warning Services LLC 21 || FOR GOOD CAUSE SHOWN, IT IS SO O RED. 23

STEPHANIE 8. CHRISTENSEN

26 United States Magistrate Judge 27 28

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 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 Sean Leonard v. Navy Federal Credit Union et al.; Case No. 9 2:25-cv-04799-MRA-SSC. I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I 13 14 will not disclose in any manner any information or item that is subject 15 to this Stipulated Protective Order to any person or entity except in 16 strict compliance with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States 18 District Court for the Central District of California for the purpose of 19 enforcing the terms of this Stipulated Protective Order, even if such 20 enforcement proceedings occur after termination of this action. I 21 hereby appoint ________________________ [print or type full name] 22 of _________ [print or type full address and telephone number] as 23 24 25 26 27 1 my California agent for service of process in connection with this action 2 or any proceedings related to enforcement of this Stipulated Protective 3 Order. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10

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