1 DEBORAH S. TROPP, ESQ. (SBN 162613)

NICOLE L. HAZLETT, ESQ. (SBN 310052)

2 McNEIL TROPP & BRAUN LLP 2 Park Plaza, Suite 620 3 Irvine, California 92614 Ph: (949) 259-2890; 4 Fax: (949) 259-2891 dtropp@mtbattorneys.com 5 nhazlett@mtbattorneys.com

6 Attorneys for Defendant COSTCO WHOLESALE CORPORATION, a Washington 7 Corporation

8 9

UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA 1 11 2

CHARLOTTE KIRIHARA, CASE NO. 2:19-CV-00611- FMO-RAO

13 14 Plaintiff, STIPULATED PROTECTIVE ORDER1

15 vs. 16

COSTCO WHOLESALE

17 CORPORATION, a Washington 18 Corporation; and DOES 1-50, Inclusive,

19 Defendants. 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 disclosure 24 and from use for any purpose other than prosecuting this litigation may be warranted. 25

26 1 This Stipulated Protective Order is substantially based on the model protective order 27 provided under Magistrate Judge Rozella A. Oliver’s Procedures. 28 ______________________________________________________________________________ 1 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 2 Stipulated Protective Order. The parties acknowledge that this Order does not confer 3 blanket protections on all disclosures or responses to discovery and that the protection it 4 affords from public disclosure and use extends only to the limited information or items 5 that are entitled to confidential treatment under the applicable legal principles. 6 B. GOOD CAUSE STATEMENT 7 This action is likely to involve trade secrets, confidential, and/or proprietary 8 information for which special protection from public disclosure and from use for any 9 purpose other than prosecution of this action is warranted. This Confidential Information 10 may be contained, among other things, in documents produced, answers to 11 interrogatories, deposition testimony, and/or any other oral or written responses to 12 discovery conducted in this matter; as well as, revealed a party or third-party. 13 Such confidential and proprietary materials and information consist of, but is not 14 limited to, confidential business information; confidential business policies, practices 15 and procedures; information regarding confidential business practices, or other 16 confidential research, development, or commercial information (including information 17 implicating privacy rights of third parties), information otherwise generally unavailable 18 to the public, or which may be privileged or otherwise protected from disclosure under 19 state or federal statutes, court rules, case decisions, or common law. 20 Accordingly, to expedite the flow of information, to facilitate the prompt 21 resolution of disputes over confidentiality of discovery materials, to adequately protect 22 information the parties are entitled to keep confidential, to ensure that the parties are 23 permitted reasonable necessary uses of such material in preparation for and in the 24 conduct of trial, to address their handling at the end of the litigation, and serve the ends 25 of justice, a protective order for such information is justified in this matter. It is the 26 intent of the parties that information will not be designated as confidential for tactical 27 reasons and that nothing be so designated without a good faith belief that it has been 28 maintained in a confidential, non-public manner, and there is good cause why it should ______________________________________________________________________________ 2 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 not be part of the public record of this case. 2 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 3 The parties further acknowledge, as set forth in Section 12.3, below, that this 4 Stipulated Protective Order does not entitle them to file confidential information under 5 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 6 standards that will be applied when a party seeks permission from the court to file 7 material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive motions, good 10 cause must be shown to support a filing under seal. See Kamakana v. City and County of 11 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 12 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 13 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), 14 and a specific showing of good cause or compelling reasons with proper evidentiary 15 support and legal justification, must be made with respect to Protected Material that a 16 party seeks to file under seal. The parties’ mere designation of Disclosure or Discovery 17 Material as CONFIDENTIAL does not— without the submission of competent evidence 18 by declaration, establishing that the material sought to be filed under seal qualifies as 19 confidential, privileged, or otherwise protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 compelling reasons, not only good cause, for the sealing must be shown, and the relief 22 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 23 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of 24 information, document, or thing sought to be filed or introduced under seal in connection 25 with a dispositive motion or trial, the party seeking protection must articulate compelling 26 reasons, supported by specific facts and legal justification, for the requested sealing 27 order. Again, competent evidence supporting the application to file documents under seal 28 must be provided by declaration. ______________________________________________________________________________ 3 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. If 3 documents can be redacted, then a redacted version for public viewing, omitting 4 only the confidential, privileged, or otherwise protectable portions of the document, 5 shall be filed. Any application that seeks to file documents under seal in their 6 entirety should include an explanation of why redaction is not feasible. 7 8 2. DEFINITIONS 9 2.1 Action: Kirihara v. Costco, Case No.. 2:19-CV-00611- FMO-RAO 10 2.2 Challenging Party: a Party or Non-Party that challenges the 11 designation of information or items under this Order. 12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 13 how it is generated, stored or maintained) or tangible things that qualify for protection 14 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 15 Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 26 expert witness or as a consultant in this Action. 27 28 ______________________________________________________________________________ 4 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 7 this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm that has 9 appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 22 a Producing Party. 23 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 extracted from Protected Material; (2) all copies, excerpts, summaries, or 28 ______________________________________________________________________________ 5 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 This Order shall govern all Protected Material revealed in the above- 4 referenced lawsuit, whether the Protected Material is contained in documents 5 produced, answers to interrogatories, deposition testimony, and/or any other oral 6 or written responses to discovery conducted in this matter, whether it is revealed 7 by Designating Party or any other party or third-party. 8 Any use of Protected Material at trial shall be governed by the orders of the trial judge. 9 This Order does not govern the use of Protected Material at trial. 10 11 4, DURATION 12 Once a case proceeds to trial, information that was designated as 13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 14 an exhibit at trial becomes public and will be presumptively available to all members of 15 the public, including the press, unless compelling reasons supported by specific factual 16 findings to proceed otherwise are made to the trial judge in advance of the trial if it is a 17 merit-related document. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good 18 cause” showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record). Accordingly, the 20 parties agree to take reasonable steps to maintain the confidentiality of any Protected 21 Information at trial of this matter in such a manner and until such time as the Court may 22 direct and/or as the parties may otherwise agree. 23 The receiving party shall provide Designating Party with appropriate notice so that 24 Designating Party may have the opportunity to lodge appropriate objections or seek the 25 Court’s direction to prevent disclosure of the Protected Material and/or move for 26 appropriate confidential treatment of the information at trial. 27 The terms of this Order shall remain fully active until released by written consent 28 of Designating Party. The Court shall retain jurisdiction over the parties, this Protective ______________________________________________________________________________ 6 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 Order, and recipients of confidential documents, materials, and/or information for the 2 sole purpose of enforcing this Order and adjudicating claims of breaches thereof and 3 administering damages and other remedies related thereto. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 7 Party or Non-Party that designates information or items for protection under this Order 8 must take care to limit any such designation to specific material that qualifies under the 9 appropriate standards. The Designating Party must designate for protection only those 10 parts of material, documents, items or oral or written communications that qualify so 11 that other portions of the material, documents, items or communications for which 12 protection is not warranted are not swept unjustifiably within the ambit of this Order. 13 Mass, indiscriminate or routinized designations are prohibited. Designations that 14 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 15 to unnecessarily encumber the case development process or to impose unnecessary 16 expenses and burdens on other parties) may expose the Designating Party to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it 18 designated for protection do not qualify for protection, that Designating Party must 19 promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in 21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 under this Order must be clearly so designated before the material is disclosed or 24 produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (e.g., paper or electronic documents, 27 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 28 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter ______________________________________________________________________________ 7 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 2 portion of the material on a page qualifies for protection, the Producing Party also must 3 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 4 margins). 5 A Party or Non-Party that makes original documents available for inspection 6 need not designate them for protection until after the inspecting Party has indicated 7 which documents it would like copied and produced. During the inspection and before 8 the designation, all of the material made available for inspection shall be deemed 9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 10 copied and produced, the Producing Party must determine which documents, or 11 portions thereof, qualify for protection under this Order. Then, before producing the 12 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 13 each page that contains Protected Material. If only a portion of the material on a page 14 qualifies for protection, the Producing Party also state clearly identify the protected 15 portion(s) (e.g., by making appropriate markings in the margins). 16 (b) for testimony given in depositions that the Designating Party identifies the 17 Disclosure or Discovery Material on the record, before the close of the deposition all 18 protected testimony. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 23 the Producing Party, to the extent practicable, shall identify the protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 25 designate qualified information or items does not, standing alone, waive the Designating 26 Party’s right to secure protection under this Order for such material. Upon timely 27 correction of a designation, the Receiving Party must make reasonable efforts to assure 28 that the material is treated in accordance with the provisions of this Order. ______________________________________________________________________________ 8 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 2 6. Challenging Confidentiality Designations CHALLENGING CONFIDENTIALITY 3 DESIGNATINS. 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on the 10 Challenging Party. Frivolous challenges, and those made for an improper purpose (e.g., 11 to harass or impose unnecessary expenses and burdens on other parties) may expose the 12 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 13 the confidentiality designation, all parties shall continue to afford the material in 14 question the level of protection to which it is entitled under the Producing Party’s 15 designation until the Court rules on the challenge. 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a Receiving 23 Party must comply with the provisions of section 13 below. 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 28 otherwise ordered by the court or permitted in writing by the Designating Party, a ______________________________________________________________________________ 9 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 2 only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 (c) Experts (as defined in this Order) of the Receiving Party to whom 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A) 11 (d) the court and its personnel; 12 (e) court reporters and their staff; 13 (f) professional jury or trial consultants, mock jurors, and Professional 14 Vendors to whom disclosure is reasonably necessary for this Action and who have 15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, witnesses, and attorneys for witnesses, in the 19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 20 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 21 not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 23 agreed by the Designating Party or ordered by the court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material may 25 be separately bound by the court reporter and may not be disclosed to anyone except 26 as permitted under this Stipulated Protective Order; and 27 (i) any mediator or settlement officer, and their supporting personnel, 28 mutually agreed upon by any of the parties engaged in settlement discussions. ______________________________________________________________________________ 10 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 shall include a copy of the subpoena or court order; promptly notify in writing the 8 party who caused the subpoena or order to issue in the other litigation that some or 9 all of the material covered by the subpoena or order is subject to this Protective 10 Order. Such notification shall include a copy of this Stipulated Protective Order; and 11 (c) cooperate with respect to all reasonable procedures sought to be 12 pursued by the Designating Party whose Protected Material may be affected. 13 If the Designating Party timely seeks a protective order, the Party served with the 14 subpoena or court order shall not produce any information designated in this action as 15 “CONFIDENTIAL” before a determination by the court from which the subpoena or 16 order issued, unless the Party has obtained the Designating Party’s permission. The 17 Designating Party shall bear the burden and expense of seeking protection in that court 18 of its confidential material and nothing in these provisions should be construed as 19 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 20 from another court. 21 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 26 by Non-Parties in connection with this litigation is protected by the remedies and relief 27 provided by this Order. Nothing in these provisions should be construed as prohibiting 28 a Non-Party from seeking additional protections. ______________________________________________________________________________ 11 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party that 6 some or all of the information requested is subject to a confidentiality agreement with a 7 Non-Party; promptly provide the Non-Party with a copy of the Stipulated Protective 8 Order in this Action, the relevant discovery request(s), and a reasonably specific 9 description of the information requested; and 10 (3) make the information requested available for inspection by the 11 Non-Party, if requested. 12 (c) If the Non-Party fails to seek a protective order from this court within 14 13 days of receiving the notice and accompanying information, the Receiving Party may 14 produce the Non-Party’s confidential information responsive to the discovery request. 15 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 16 any information in its possession or control that is subject to the confidentiality 17 agreement with the Non-Party before a determination by the court. Absent a court order 18 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 19 in this court of its Protected Material. 20 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 26 all unauthorized copies of the Protected Material, (c) inform the person or persons to 27 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 28 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” ______________________________________________________________________________ 12 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 that is attached hereto as Exhibit A. 2 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 produced material is subject to a claim of privilege or other protection, the obligations of 7 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 This provision is not intended to modify whatever procedure may be established in an e- 9 discovery order that provides for production without prior privilege review. Pursuant to 10 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 11 effect of disclosure of a communication or information covered by the attorney-client 12 privilege or work product protection, the parties may incorporate their agreement in the 13 stipulated protective order submitted to the court. 14 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. No party who has received Confidential Information 17 shall seek to vacate or otherwise modify this Protective Order at any time. This 18 Protective Order shall not be abrogated, modified, amended, or enlarged except by 19 stipulation and agreement of the parties or by the Court with notices given to each of the 20 parties. 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 ground 25 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 Protected 27 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 28 under seal pursuant to a court order authorizing the sealing of the specific Protected ______________________________________________________________________________ 13 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 Material at issue. If a Party’s request to file Protected Material under seal is denied by 2 the court, then the Receiving Party may file the information in the public record unless 3 otherwise instructed by the court. 4 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 30 7 days of a written request by the Designating Party, each Receiving Party must return 8 all Protected Material to the Producing Party or destroy such material. As used in this 9 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 summaries, and any other format reproducing or capturing any of the Protected 11 Material. Whether the Protected Material is returned or destroyed, the Receiving 12 Party must submit a written certification to the Producing Party (and, if not the same 13 person or entity, to the Designating Party) by the 30 day deadline that (1) identifies 14 (by category, where appropriate) all the Protected Material that was returned or 15 destroyed and (2) affirms that the Receiving Party has not retained any copies, 16 abstracts, compilations, summaries or any other format reproducing or capturing 17 any of the Protected Material. Notwithstanding this provision, Counsel are entitled 18 to retain an archival copy of all pleadings, motion papers, trial, deposition, and 19 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 20 expert reports, attorney work product, and consultant and expert work product, even 21 if such materials contain Protected Material. Any such archival copies that contain 22 or constitute Protected Material remain subject to this Protective Order as set forth 23 in Section 4. 24 /// 25 /// 26 /// 27 /// 28 ______________________________________________________________________________ 14 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 2 ||14. VIOLATION 3 Any violation of this Order may be punished by appropriate measures 4 |/including, without limitation, contempt proceedings and/or monetary sanctions. 6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 || Dated: August 8, 2019 McNEIL TROPP & BRAUN LLP 10 By:__/s/ Nicole L. Hazlett Deborah S. Tropp, Esq. 11 Nicole L. Hazlet, Esq. 2 Attorneys for Defendant,

COSTCO WHOLESALE CORPORATION

13 14 || Dated: August 8, 2019 REED & GARCIA LAW, P.C. 15 16 By:__/s/Mummer Reed Muammer Reed, Esq. 17 Attorneys for Plaintiff,

CHARLOTTE KIRIHARA

18 19 99 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 || Dated: August 9, 2019 Rapelis, a. C2 2 _ HON. ROZELLA A. OLIVER United States Magistrate Judge 23 24 25 26 27 28 15 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER

1

2

SIGNATURE CERTIFICATION

3 Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies 4 and Procedures Manual, I hereby certify that the content of this document is acceptable to 5 Muammer Reed, counsel for the Plaintiff, and that I have obtained authorization from Mr. 6 Reed to affix his electronic signature to this document. 7

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ______________________________________________________________________________ 16 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER 1 CERTIFICATE OF SERVICE 2 IT IS HEREBY CERTIFIED THAT: 3 I, the undersigned, am a citizen of the United States and am at least eighteen years 4 of age. My business address is 2 Park Plaza, Suite 620, Irvine, California 92614. 5 I am not a party to the above-entitled action. I have caused service of the 6 STIPULATED PROTECTIVE ORDER by electronically filing the foregoing with the 7 Clerk of the District Court using its ECF System, which electronically provides notice, on 8 the following: 9 Muammar Reed, Esq.

REED & GARCIA LAW, P.C.

10 5777 W. Century Blvd., Suite 775 11 Los Angeles, CA 90045 reed@reedgarcialaw.com 12 Attorneys for Plaintiff 13

14 I declare under penalty of perjury that the foregoing is true and correct. 15 Executed on August 8, 2019 at Irvine, California. 16 /s/ Nicole L. Hazlett Nicole L. Hazlett 17

18 19 20 21 22 23 24 25 26 27 28 ______________________________________________________________________________ 17 Case No. 2:19-CV-00611-FMO-RAO STIPULATED 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], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California on 7 _____________in the case of Charlotte Kirihara v. Costco Wholesale Corporation, et. al, 8 CASE NO. 2:19-CV-00611- FMO-RAO. I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge that failure 10 to so comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint [print or type full name] of [print or type full address and telephone 18 number] as my California agent for service of process in connection with this action or 19 any proceedings related to enforcement of this Stipulated Protective Order. 20 21 Date: 22 City and State where sworn and signed: 23 Printed name: 24 Signature: 25 26 27 28 ______________________________________________________________________________ 18 Case No. 2:19-CV-00611-FMO-RAO STIPULATED PROTECTIVE ORDER