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1 Eugene J. Egan (State Bar No. 130108) eje@manningllp.com 2 James A. Harris (State Bar No. 312309) jah@manningllp.com 3 MANNING & KASS

ELLROD, RAMIREZ, TRESTER LLP

4 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 5 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 6 7 Attorneys for COSTCO WHOLESALE CORPORATION 8 Haleh Shekarchian, (State Bar No. 158449) 9 hs@halehshekarchian.com

THE LAW OFFICE OF HALEH SHEKARCHIAN, APC.

10 9440 Santa Monica Blvd., Suite 707 11 Beverly Hills, California 90210 Telephone: (310) 271-23121 12 Attorneys for ADRINA BAGHUMAN 13

14

UNITED STATES DISTRICT COURT

15

CENTRAL DISTRICT OF CALIFORNIA

16

17 18 ADRINA BAGHUMYAN. an Case No. 2:21-cv-09881-AB (JEMx) individual,, [Assigned to the Hon. Andre Birotte, 19 Jr., Courtroom 7B] Plaintiff,

20 v. 21 STIPULATED PROTECTIVE

COSTCO WHOLESALE ORDER

22 CORPORATION dba COSTCO, and DOES 1 to 50, Inclusive, 23 Action filed: 08/03/21 Defendants. Trial date: 01/31/23 24

25 26 A. PURPOSES AND LIMITATIONS 27 Discovery in this action is likely to involve production of confidential, 28 proprietary, or private information for which special protection from public

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1 disclosure and from use for any purpose other than prosecuting this litigation may 2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 3 enter the following Stipulated Protective Order. The parties acknowledge that this 4 Order does not confer blanket protections on all disclosures or responses to 5 discovery and that the protection it affords from public disclosure and use extends 6 only to the limited information or items that are entitled to confidential treatment 7 under the applicable legal principles. The parties further acknowledge, as set forth 8 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective 9 Order does not entitle them to a file confidential information under seal; Civil Local 10 Rule 79-5 sets forth the procedures that must be followed and the standards that will 11 be applied when a party seeks permission from the court to file material under seal. 12 13 B. GOOD CAUSE STATEMENT 14 15 Good cause exists for this stipulated protective order because Costco's 16 policies and procedures documents contain proprietary information of Costco and 17 Costco only authorizes production of these proprietary documents subject to a 18 protective order. Costco would suffer harm if its proprietary policies and 19 procedures documents and surveillance video were disseminated. Such confidential 20 and proprietary materials and information consist of, among other things, 21 confidential business or financial information, information regarding confidential 22 business practices, or other confidential research, development, or commercial 23 information (including information implicating privacy rights of third parties), 24 information otherwise generally unavailable to the public, or which may be 25 privileged or otherwise protected from disclosure under state or federal statutes, 26 court rules, case decisions, or common law. Accordingly, to expedite the flow of 27 information, to facilitate the prompt resolution of disputes over confidentiality of 28 discovery materials, to adequately protect information the parties are entitled to 2

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1 keep confidential, to ensure that the parties are permitted reasonable necessary uses 2 of such material in preparation for and in the conduct of trial, to address their 3 handling at the end of the litigation, and serve the ends of justice, a protective order 4 for such information is justified in this matter. It is the intent of the parties that 5 information will not be designated as confidential for tactical reasons and that 6 nothing be so designated without a good faith belief that it has been maintained in a 7 confidential, non-public manner, and there is good cause why it should not be part 8 of the public record of this case. 9 Good cause also exists for this stipulated protective order because 10 Adrina Baghumyan has a privacy interest in her personal medical and financial 11 information, however stored, whether in documents, disk, x-rays, etc. Adrina 12 Baghumyan would be harmed if such personal information were to be made public. 13 The rest of the text of this GOOD CAUSE STATEMENT shall be applied and 14 modified to apply to the personal privacy information, medical and financial, of 15 Adrina Baghumyan. 16 17 1. DEFINITIONS 18 1.1 Action: Adrina Baghumyan, an Individual v. Costco Wholesale 19 Corporation dba Costco; and Does 1 to 50, Inclusive; Case No. 2:21-cv-09581 AB 20 (JEMx). 21 1.2 Challenging Party: a Party or Non-Party that challenges the 22 designation of information or items under this Order. 23 1.3 “CONFIDENTIAL” Information or Items: information (regardless of 24 how it is generated, stored, or maintained) or tangible things that qualify for 25 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 26 the Good Cause Statement. 27 1.4 Counsel: Outside Counsel of Record and House Counsel (as well as 28 their support staff). 3

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1 1.5 Designating Party: a Party or Non-Party that designates information 2 or items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 1.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced 7 or generated in disclosures or responses to discovery in this matter. 8 1.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. 11 1.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 1.9 Non-Party: any natural person, partnership, corporation, association, 15 or other legal entity not named as a Party to this action. 16 1.10 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent or advise a party to this Action and 18 have appeared in this Action on behalf of that party or are affiliated or assisting with 19 a law firm which has appeared on behalf of that party, including support staff. 20 1.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 1.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 1.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 and their employees and subcontractors. 4

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1 1.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 1.15 Receiving Party: a Party that receives Disclosure or Discovery 4 Material from a Producing Party. 5 6 2. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 3. DURATION 15 FINAL DISPOSITION of the action is defined as the conclusion of any 16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 17 has run. Except as set forth below, the terms of this protective order apply through 18 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 20 but will have to file a separate action for enforcement of the agreement once all 21 proceedings in this case are complete. 22 23 Once a case proceeds to trial, information that was designated as 24 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 25 as an exhibit at trial becomes public and will be presumptively available to all 26 members of the public, including the press, unless compelling reasons supported by 27 specific factual findings to proceed otherwise are made to the trial judge in advance 28 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 5

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1 showing for sealing documents produced in discovery from “compelling reasons” 2 standard when merits-related documents are part of court record). Accordingly, for 3 such materials, the terms of this protective order do not extend beyond the 4 commencement of the trial. 5 6 4. DESIGNATING PROTECTED MATERIAL 7 4.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, documents, 13 items, or communications for which protection is not warranted are not swept 14 unjustifiably within the ambit of this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 4.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 28 Designation in conformity with this Order requires: 6

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1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for 9 inspection need not designate them for protection until after the inspecting Party has 10 indicated which documents it would like copied and produced. During the 11 inspection and before the designation, all of the material made available for 12 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 13 identified the documents it wants copied and produced, the Producing Party must 14 determine which documents, or portions thereof, qualify for protection under this 15 Order. Then, before producing the specified documents, the Producing Party must 16 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 17 If only a portion or portions of the material on a page qualifies for protection, the 18 Producing Party also must clearly identify the protected portion(s) (e.g., by making 19 appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identify 21 the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. 23 (c) for information produced in some form other than documentary and 24 for any other tangible items, that the Producing Party affix in a prominent place on 25 the exterior of the container or containers in which the information is stored the 26 legend “CONFIDENTIAL.” If only a portion or portions of the information 27 warrants protection, the Producing Party, to the extent practicable, shall identify the 28 protected portion(s). 7

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1 4.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 8 5. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 5.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 5.2 Meet and Confer. The Challenging Party Shall initiate the dispute 13 resolution process under Civil Local Rule 37-1 et seq. 14 5.3 The burden of persuasion in any such challenge proceeding shall be 15 on the Designating Party. Frivolous challenges, and those made for an improper 16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 17 parties), may expose the Challenging Party to sanctions. Unless the Designating 18 Party has waived or withdrawn the confidentiality designation, all parties shall 19 continue to afford the material in question the level of protection to which it 20 is entitled under the Producing Party’s designation until the Court rules on the 21 challenge. 22 23 6. ACCESS TO AND USE OF PROTECTED MATERIAL 24 6.1 Basic Principles. A Receiving Party may use Protected Material that 25 is disclosed or produced by another Party or by a Non-Party in connection with 26 this Action only for prosecuting, defending, or attempting to settle this Action. 27 Such Protected Material may be disclosed only to the categories of persons and 28 under the conditions described in this Order. When the Action has been 8

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1 terminated, a Receiving Party must comply with the provisions of Section 13 below 2 (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at 4 a location and in a secure manner that ensures that access is limited to the 5 persons authorized under this Order. 6 6.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the Court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 11 well as employees of said Outside Counsel of Record to whom it is reasonably 12 necessary to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of 14 the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the Court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in 26 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 27 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 28 they will not be permitted to keep any confidential information unless they sign the 9

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1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the Court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may 4 be separately bound by the court reporter and may not be disclosed to anyone except 5 as permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 9 7. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 10 IN OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation 12 that compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification 15 shall include a copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or order 17 to issue in the other litigation that some or all of the material covered by the 18 subpoena or order is subject to this Protective Order. Such notification shall include 19 a copy of this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be 21 pursued by the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with 23 the subpoena or court order shall not produce any information designated in this 24 action as “CONFIDENTIAL” before a determination by the court from which the 25 subpoena or order issued, unless the Party has obtained the Designating Party’s 26 permission. The Designating Party shall bear the burden and expense of seeking 27 protection in that court of its confidential material, and nothing in these provisions 28 should be construed as authorizing or encouraging a Receiving Party in this Action 10

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1 to disobey a lawful directive from another court. 2 3 8. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a 6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this Court within 23 14 days of receiving the notice and accompanying information, the Receiving Party 24 may produce the Non-Party’s confidential information responsive to the discovery 25 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 26 not produce any information in its possession or control that is subject to the 27 confidentiality agreement with the Non-Party before a determination by the Court. 28 Absent a court order to the contrary, the Non-Party shall bear the burden and 11

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1 expense of seeking protection in this Court of its Protected Material. 2 3 9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 9 or persons to whom unauthorized disclosures were made of all the terms of this 10 Order, and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 13 10. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other protection, 17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 19 procedure may be established in an e-discovery order that provides for production 20 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 21 (e), insofar as the parties reach an agreement on the effect of disclosure of a 22 communication or information covered by the attorney-client privilege or work 23 product protection, the parties may incorporate their agreement in the stipulated 24 protective order submitted to the Court. 25 26 11. MISCELLANEOUS 27 11.1 Right to Relief. Nothing in this Order abridges the right of any person 28 to seek its modification by the Court in the future. 12

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1 11.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective Order. 6 11.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Civil Local Rule 79-5. Protected Material 8 may only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party’s request to file Protected Material 10 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. 12 13 12. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in Section 4 15 (DURATION), within 60 days of a written request by the Designating Party, each 16 Receiving Party must return all Protected Material to the Producing Party or destroy 17 such material. As used in this subdivision, “all Protected Material” includes all 18 copies, abstracts, compilations, summaries, and any other format reproducing or 19 capturing any of the Protected Material. Whether the Protected Material is returned 20 or destroyed, the Receiving Party must submit a written certification to the 21 Producing Party (and, if not the same person or entity, to the Designating Party) by 22 the 60 day deadline that (1) identifies (by category, where appropriate) all the 23 Protected Material that was returned or destroyed; and (2) affirms that the Receiving 24 Party has not retained any copies, abstracts, compilations, summaries, or any other 25 format reproducing or capturing any of the Protected Material. Notwithstanding this 26 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 27 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 28 deposition and trial exhibits, expert reports, attorney work product, and consultant 13

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1 | and expert work product, even if such materials contain Protected Material. Any 2] such archival copies that contain or constitute Protected Material remain subject to 3 | this Protective Order as set forth in Section 4 (DURATION). S| 13. Any violation of this Order may be punished by any and all appropriate 6 measures including, without limitation, contempt proceedings and/or 7 monetary sanctions. 8} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10} DATED: 6/24/22 11 12 /s/ Haleh Shekarchian 13 | Attorneys for Plaintiff. 14 15 | DATED: 6/24/22 6 yO 17 \ 18 | Attorneys for Defendant. 19 20 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22) DATED: 6/27/22 23 Ph E WeBerial_ 25 norable John E. McDermott 6 nited States Magistrate Judge

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 13.1 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 Adrina Baghumyan, an Individual v. Costco Wholesale 8 Corporation dba Costco; and Does 1 to 50, Inclusive; Case No. 2:21-cv-09581 AB 9 (JEMx). I agree to comply with and to be bound by all the terms of this Stipulated 10 Protective Order, and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly 12 promise that I will not disclose in any manner any information or item that is subject 13 to this Stipulated Protective Order to any person or entity except in strict compliance 14 with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 15

STIPULATED PROTECTIVE ORDER