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1 MORGAN, LEWIS & BOCKIUS LLP Barbara J. Miller, Bar No. 167223 2 Matthew M. Arnold, Bar No. 341862 600 Anton Boulevard, Suite 1800 3 Costa Mesa, CA 92626-7653 Tel: +1.714.830.0600 4 Fax: +1.714.830.0700 barbara.miller@morganlewis.com 5 sarah.allen@morganlewis.com 6 Attorneys for Defendants BOSTON SCIENTIFIC CORPORATION and 7 BOSTON SCIENTIFIC

NEUROMODULATION CORPORATION,

8 9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11 12 CYNTHIA ROMANO, an individual, Case No. 2:21-cv-09863-GW(ASx) 13 Plaintiff, 14 vs. PROTECTIVE ORDER 15

BOSTON SCIENTIFIC

16 CORPORATION, a Delaware corporation; BOSTON SCIENTIFIC 17 NEUROMODULATION CORPORATION, a Delaware 18 corporation; and DOES 1 through 20, Complaint Filed: Oct. 28, 2021 inclusive, 19 Defendants. 20 21 22 23 24 25 26 27 28

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1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. The parties further acknowledge, as set forth 11 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 12 file confidential information under seal; Civil Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a 14 party seeks permission from the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 Plaintiff worked as a Director of National Accounts for Defendant Boston 17 Scientific Neuromodulation Corporation and, based on the nature of her position 18 and duties, Plaintiff had access to and worked with documents and information that 19 are trade secrets and other valuable technical and/or proprietary information of 20 Defendants. This action is likely to involve trade secrets, customer and pricing lists 21 and other valuable research, development, commercial, financial, technical and/or 22 proprietary information for which special protection from public disclosure and 23 from use for any purpose other than prosecution of this action is warranted. Such 24 confidential and proprietary materials and information consist of, among other 25 things, confidential business or financial information, information regarding 26 confidential business practices, or other confidential research, development, or 27 commercial information (including information implicating privacy rights of third 28 parties), information otherwise generally unavailable to the public, or which may be

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1 privileged or otherwise protected from disclosure under state or federal statutes, 2 court rules, case decisions, or common law. Accordingly, to expedite the flow of 3 information, to facilitate the prompt resolution of disputes over confidentiality of 4 discovery materials, to adequately protect information the parties are entitled to 5 keep confidential, to ensure that the parties are permitted reasonable necessary uses 6 of such material in preparation for and in the conduct of trial, to address their 7 handling at the end of the litigation, and serve the ends of justice, a protective order 8 for such information is justified in this matter. It is the intent of the parties that 9 information will not be designated as confidential for tactical reasons and that 10 nothing be so designated without a good faith belief that it has been maintained in a 11 confidential, non-public manner, and there is good cause why it should not be part 12 of the public record of this case. 13 2. DEFINITIONS 14 2.1 Action: Cynthia Romano v. Boston Scientific Corporation, et al., United 15 States District Court, Central District of California, Case No. 2:21-cv-09863 GW 16 (ASx). 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 24 support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 2.6 Disclosure or Discovery Material: all items or information, regardless of

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1 the medium or manner in which it is generated, stored, or maintained (including, 2 among other things, testimony, transcripts, and tangible things), that are produced 3 or generated in disclosures or responses to discovery in this matter. 4 2.7 Expert: a person with specialized knowledge or experience in a matter 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as 6 an expert witness or as a consultant in this Action. 7 2.8 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 2.9 Non-Party: any natural person, partnership, corporation, association, or 11 other legal entity not named as a Party to this action. 12 2.10 Outside Counsel of Record: attorneys who are not employees of a party 13 to this Action but are retained to represent or advise a party to this Action and have 14 appeared in this Action on behalf of that party or are affiliated with a law firm 15 which has appeared on behalf of that party, and includes support staff. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation support 22 services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 28 from a Producing Party.

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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 8 trial 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 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. 21 Each Party or Non-Party that designates information or items for protection under 22 this Order must take care to limit any such designation to specific material that 23 qualifies under the appropriate standards. The Designating Party must designate for 24 protection only those parts of material, documents, items, or oral or written 25 communications that qualify so that other portions of the material, documents, 26 items, or communications for which protection is not warranted are not swept 27 unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized 28 designations are prohibited. Designations that are shown to be clearly unjustified or

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1 that have been made for an improper purpose (e.g., to unnecessarily encumber 2 the case development process or to impose unnecessary expenses and burdens on 3 other parties) may expose the Designating Party to sanctions. If it comes to a 4 Designating Party’s attention that information or items that it designated for 5 protection do not qualify for protection, that Designating Party must promptly 6 notify all other Parties that it is withdrawing the inapplicable designation. 7 5.2 Manner and Timing of Designations. Except as otherwise provided in this 8 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 10 under this Order must be clearly so designated before the material is disclosed or 11 produced. 12 Designation in conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic documents, 14 but excluding transcripts of depositions or other pretrial or trial proceedings), that 15 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 16 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 17 material. If only a portion or portions of the material on a page qualifies for 18 protection, the Producing Party also must clearly identify the protected portion(s) 19 (e.g., by making appropriate markings in the margins). 20 A Party or Non-Party that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and 23 before the designation, all of the material made available for inspection shall be 24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 25 documents it wants copied and produced, the Producing Party must determine 26 which documents, or portions thereof, qualify for protection under this Order. Then, 27 before producing the specified documents, the Producing Party must affix the 28 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

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1 portion or portions of the material on a page qualifies for protection, the 2 Producing Party also must clearly identify the protected portion(s) (e.g., by making 3 appropriate markings in the margins). 4 (b) for testimony given in depositions that the Designating Party identify the 5 Disclosure or Discovery Material on the record, before the close of the deposition 6 all protected testimony. 7 (c) for information produced in some form other than documentary and for 8 any other tangible items, that the Producing Party affix in a prominent place on the 9 exterior of the container or containers in which the information is stored the legend 10 “CONFIDENTIAL.” If only a portion or portions of the information warrants 11 protection, the Producing Party, to the extent practicable, shall identify the 12 protected portion(s). 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 14 failure to designate qualified information or items does not, standing alone, waive 15 the Designating Party’s right to secure protection under this Order for such 16 material. Upon timely correction of a designation, the Receiving Party must make 17 reasonable efforts to assure that the material is treated in accordance with the 18 provisions of this Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the informal 24 dispute resolution process set forth in the Court's Procedures and Schedules. see 25 http://www.cacd.uscourts.gov/honorable-alka-sagar 26 6.3 The burden of persuasion in any such challenge proceeding shall be on 27 the Designating Party. Frivolous challenges, and those made for an improper 28 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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1 parties) may expose the Challenging Party to sanctions. Unless the Designating 2 Party has waived or withdrawn the confidentiality designation, all parties shall 3 continue to afford the material in question the level of protection to which it is 4 entitled under the Producing Party’s designation until the Court rules on the 5 challenge. 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this 9 Action only for prosecuting, defending, or attempting to settle this Action. Such 10 Protected Material may be disclosed only to the categories of persons and under the 11 conditions described in this Order. When the Action has been terminated, a 12 Receiving Party must comply with the provisions of section 13 below (FINAL 13 DISPOSITION). Protected Material must be stored and maintained by a Receiving 14 Party at a location and in a secure manner that ensures that access is limited to the 15 persons authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 21 as employees of said Outside Counsel of Record to whom it is reasonably necessary 22 to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) of the 24 Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 (d) the court and its personnel;

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1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 (g) the author or recipient of a document containing the information or a 6 custodian or other person who otherwise possessed or knew the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 9 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 10 will not be permitted to keep any confidential information unless they sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 12 agreed by the Designating Party or ordered by the court. Pages of transcribed 13 deposition testimony or exhibits to depositions that reveal Protected Material may 14 be separately bound by the court reporter and may not be disclosed to anyone 15 except as permitted under this Stipulated Protective Order; and 16 (i) any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions. 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 19 PRODUCED IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena 27 or order is subject to this Protective Order. Such notification shall include a copy of 28 this Stipulated Protective Order; and

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1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be affected. If the 3 Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action 5 as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action 10 to disobey a lawful directive from another court. 11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a Non- 14 Party in this Action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to 19 produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the Non-Party that 23 some or all of the information requested is subject to a confidentiality agreement 24 with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 26 Order in this Action, the relevant discovery request(s), and a reasonably specific 27 description of the information requested; and 28 (3) make the information requested available for inspection by the Non-

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1 Party, if requested. 2 (c) If the Non-Party fails to seek a protective order from this court within 14 3 days of receiving the notice and accompanying information, the Receiving Party 4 may produce the Non-Party’s confidential information responsive to the discovery 5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 6 not produce any information in its possession or control that is subject to the 7 confidentiality agreement with the Non-Party before a determination by the court. 8 Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best 15 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 16 person or persons to whom unauthorized disclosures were made of all the terms of 17 this Order, and (d) request such person or persons to execute the “Acknowledgment 18 and Agreement to Be Bound” that is attached hereto as Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other 23 protection, the obligations of the Receiving Parties are those set forth in Federal 24 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 25 whatever procedure may be established in an e-discovery order that provides for 26 production without prior privilege review. Pursuant to Federal Rule of Evidence 27 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 28 of a communication or information covered by the attorney-client privilege or work

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1 product protection, the parties may incorporate their agreement in the stipulated 2 protective order submitted to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in 9 this Stipulated Protective Order. Similarly, no Party waives any right to object on 10 any ground to use in evidence of any of the material covered by this Protective 11 Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Civil Local Rule 79-5. Protected Material 14 may only be filed under seal pursuant to a court order authorizing the sealing of the 15 specific Protected Material at issue. If a Party's request to file Protected Material 16 under seal is denied by the court, then the Receiving Party may file the information 17 in the public record unless otherwise instructed by the court. 18 13. FINAL DISPOSITION 19 After the final disposition of this Action, as defined in paragraph 4, within 60 20 days of a written request by the Designating Party, each Receiving Party must 21 return all Protected Material to the Producing Party or destroy such material. As 22 used in this subdivision, “all Protected Material” includes all copies, abstracts, 23 compilations, summaries, and any other format reproducing or capturing any of the 24 Protected Material. Whether the Protected Material is returned or destroyed, the 25 Receiving Party must submit a written certification to the Producing Party (and, if 26 not the same person or entity, to the Designating Party) by the 60 day deadline that 27 (1) identifies (by category, where appropriate) all the Protected Material that was 28 returned or destroyed and (2)affirms that the Receiving Party has not retained any

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1 copies, abstracts, compilations, summaries or any other format reproducing or 2 capturing any of the Protected Material. Notwithstanding this provision, Counsel 3 are entitled to retain an archival copy of all pleadings, motion papers, trial, 4 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 5 and trial exhibits, expert reports, attorney work product, and consultant and expert 6 work product, even if such materials contain Protected Material. Any such archival 7 copies that contain or constitute Protected Material remain subject to this Protective 8 Order as set forth in Section 4 (DURATION). 9 14. Any violation of this Order may be punished by any and all appropriate 10 measures including, without limitation, contempt proceedings and/or monetary 11 sanctions. 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 DATED ___F_e_b_r_u_ar_y_ _2_2_, _2_0_2_2_______ 14 ___/s_/ _D_a_w__n_ K__n_ep__p_er_______________ 15 KNEPPER LAW PC 16 Dawn Knepper 17 Attorneys for Plaintiff 18 19 DATED: __F_e_b_r_u_a_ry_ _2_2_, _2_0_2_2________ 20 __/_s_/ _B_a_r_b_a_ra_ _J_. _M__il_le_r______________ 21 MORGAN, LEWIS & BOCKIUS LLP 22 Barbara J. Miller 23 Attorneys for Defendant 24 25 26 27 28

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1 FILER’S ATTESTATION 2 Pursuant to Local Rule 5-4.3.4 regarding signatures, I attest that concurrence 3 || in the filing of the document has been obtained from the other signatory listed above. 5 Dated: February 22, 2022 MORGAN, LEWIS & BOCKIUS LLP By _ /s/ Barbara J. Miller 7 Barbara J. Miller 10 i FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. '? | DATED: February 23, 2022 13 /s / Sagar Honorable Alka Sagar 1S United States Magistrate Judge 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 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 7 on [date] in the case of Cynthia Romano v. Boston Scientific Corporation et al., 8 Case No. 2:21-cv-09863-GW(ASx). I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the 11 nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. I further 14 agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [print 18 or type full name] of _______________________________________ [print or 19 type full address and telephone number] as my California agent for service of 20 process in connection with this action or any proceedings related to enforcement of 21 this Stipulated Protective Order. Date: 22 ______________________________________ 23 City and State where sworn and signed: ________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27 28

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