Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 1 of 16 Page ID #:268

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 T.S.B. & CO., DENISE RENE ) Case No.: 8:21-cv-01556-JLS (JDEx) 11

SULLIVAN, ELIZABETH HALE, )

12 AND JESSICA MUNDO, ) 13 ) STIPULATED PROTECTIVE Plaintiffs, ) ORDER 14 ) 15 vs. ) ) 16

ARTISAN HOME LLC, ARTISSIMO )

17 DESIGNS LLC, TARGET STORES, ) 18 INC., AND HOBBY LOBBY STORES, )

INC., )

19 ) 20 Defendants. ) ) 21

22 Pursuant to the parties’ Stipulation, and for good cause shown, the 23 Court finds and orders as follows. 24 1. PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary or private information for which special protection from public 27 disclosure and from use for any purpose other than pursuing this litigation 28 PAGE NO 1 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 2 of 16 Page ID #:269

1 may be warranted. Accordingly, the parties hereby stipulate to and petition 2 the Court to enter the following Stipulated Protective Order. The parties 3 acknowledge that this Order does not confer blanket protections on all 4 disclosures or responses to discovery and that the protection it affords from 5 public disclosure and use extends only to the limited information or items 6 that are entitled to confidential treatment under the applicable legal 7 principles. 8 2. GOOD CAUSE STATEMENT 9 This action is likely to involve customer lists, pricing information, 10 market research, and other development, commercial, financial, technical 11 and/or proprietary information for which special protection from public 12 disclosure and from use for any purpose other than prosecution of this 13 14 action is warranted. Such confidential and proprietary materials and 15 information consist of, among other things, confidential business or 16 financial information, information regarding confidential business practices, 17 or other confidential research, development, or commercial information 18 (including information implicating privacy rights of third parties), 19 information otherwise generally unavailable to the public, or which may be 20 privileged or otherwise protected from disclosure under state or federal 21 statutes, court rules, case decisions, or common law. In particular, 22 discovery is likely to involve information concerning Defendants’ sales 23 and/or purchasing patterns and history, which will reveal customer 24 relationships and pricing kept secret for competitive reasons. Accordingly, 25 to expedite the flow of information, to facilitate the prompt resolution of 26 disputes over confidentiality of discovery materials, to adequately protect 27 information the parties are entitled to keep confidential, to ensure that the 28 PAGE NO 2 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 3 of 16 Page ID #:270

1 parties are permitted reasonable necessary uses of such material in 2 preparation for and in the conduct of trial, to address their handling at the 3 end of the litigation, and serve the ends of justice, a protective order for 4 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 6 that nothing be so designated without a good faith belief that it has been 7 maintained in a confidential, non-public manner, and there is good cause 8 why it should not be part of the public record of this case. 9 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 10

PROCEDURE

11 The parties further acknowledge, as set forth in Section 14.3, below, 12 that this Stipulated Protective Order does not entitle them to file 13 14 confidential information under seal; Local Civil Rule 79-5 sets forth the 15 procedures that must be followed and the standards that will be applied 16 when a party seeks permission from the court to file material under seal. 17 There is a strong presumption that the public has a right of access to judicial 18 proceedings and records in civil cases. In connection with non-dispositive 19 motions, good cause must be shown to support a filing under seal. See 20 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 21 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 22 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. 23 Wis. 1999) (even stipulated protective orders require good cause showing), 24 and a specific showing of good cause or compelling reasons with proper 25 evidentiary support and legal justification, must be made with respect to 26 Protected Material that a party seeks to file under seal. The parties’ mere 27 designation of Disclosure or Discovery Material as CONFIDENTIAL does 28 PAGE NO 3 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 4 of 16 Page ID #:271

1 not— without the submission of competent evidence by declaration, 2 establishing that the material sought to be filed under seal qualifies as 3 confidential, privileged, or otherwise protectable—constitute good cause. 4 Further, if a party requests sealing related to a dispositive motion or 5 trial, then compelling reasons, not only good cause, for the sealing must be 6 shown, and the relief sought shall be narrowly tailored to serve the specific 7 interest to be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 8 677-79 (9th Cir. 2010). For each item or type of information, document, or 9 thing sought to be filed or introduced under seal, the party seeking 10 protection must articulate compelling reasons, supported by specific facts 11 and legal justification, for the requested sealing order. Again, competent 12 evidence supporting the application to file documents under seal must be 13 14 provided by declaration. 15 Any document that is not confidential, privileged, or otherwise 16 protectable in its entirety will not be filed under seal if the confidential 17 portions can be redacted. If documents can be redacted, then a redacted 18 version for public viewing, omitting only the confidential, privileged, or 19 otherwise protectable portions of the document, shall be filed. Any 20 application that seeks to file documents under seal in their entirety should 21 include an explanation of why redaction is not feasible. 22 4. DEFINITIONS 23 4.1 Action: this pending federal lawsuit. 24 4.2 Challenging Party: a Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 4.3 “CONFIDENTIAL” Information or Items: information 27 (regardless of how it is generated, stored or maintained) or tangible things 28 PAGE NO 4 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 5 of 16 Page ID #:272

1 that qualify for protection under Federal Rule of Civil Procedure 26(c), and 2 as specified above in the Good Cause Statement. 3 4.4 Counsel: Outside Counsel of Record and House Counsel (as 4 well as their support staff). 5 4.5 Designating Party: a Party or Non-Party that designates 6 information or items that it produces in disclosures or in responses to 7 discovery as “CONFIDENTIAL.” 8 4.6 Disclosure or Discovery Material: all items or information, 9 regardless of the medium or manner in which it is generated, stored, or 10 maintained (including, among other things, testimony, transcripts, and 11 tangible things), that are produced or generated in disclosures or responses 12 to discovery. 13 14 4.7 Expert: a person with specialized knowledge or experience in a 15 matter pertinent to the litigation who has been retained by a Party or its 16 counsel to serve as an expert witness or as a consultant in this Action. 17 4.8 House Counsel: attorneys who are employees of a party to this 18 Action. House Counsel does not include Outside Counsel of Record or any 19 other outside counsel. 20 4.9 Non-Party: any natural person, partnership, corporation, 21 association or other legal entity not named as a Party to this action. 22 4.10 Outside Counsel of Record: attorneys who are not employees 23 of a party to this Action but are retained to represent a party to this Action 24 and have appeared in this Action on behalf of that party or are affiliated 25 with a law firm that has appeared on behalf of that party, and includes 26 support staff. 27 / / / 28 PAGE NO 5 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 6 of 16 Page ID #:273

1 4.11 Party: any party to this Action, including all of its officers, 2 directors, employees, consultants, retained experts, and Outside Counsel of 3 Record (and their support staffs). 4 4.12 Producing Party: a Party or Non-Party that produces 5 Disclosure or Discovery Material in this Action. 6 4.13 Professional Vendors: persons or entities that provide litigation 7 support services (e.g., photocopying, videotaping, translating, preparing 8 exhibits or demonstrations, and organizing, storing, or retrieving data in 9 any form or medium) and their employees and subcontractors. 10 4.14 Protected Material: any Disclosure or Discovery Material that 11 is designated as “CONFIDENTIAL.” 12 4.15 Receiving Party: a Party that receives Disclosure or Discovery 13 14 Material from a Producing Party. 15 5. SCOPE 16 The protections conferred by this Stipulation and Order cover not 17 only Protected Material (as defined above), but also (1) any information 18 copied or extracted from Protected Material; (2) all copies, excerpts, 19 summaries, or compilations of Protected Material; and (3) any testimony, 20 conversations, or presentations by Parties or their Counsel that might reveal 21 Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders 23 of the trial judge and other applicable authorities. This Order does not 24 govern the use of Protected Material at trial. 25 6. DURATION 26 Once a case proceeds to trial, information that was designated as 27 CONFIDENTIAL or maintained pursuant to this protective order used or 28 PAGE NO 6 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 7 of 16 Page ID #:274

1 introduced as an exhibit at trial becomes public and will be presumptively 2 available to all members of the public, including the press, unless 3 compelling reasons supported by specific factual findings to proceed 4 otherwise are made to the trial judge in advance of the trial. See Kamakana, 5 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 6 documents produced in discovery from “compelling reasons” standard 7 when merits-related documents are part of court record). Accordingly, the 8 terms of this protective order do not extend beyond the commencement of 9 the trial. 10 7. DESIGNATING PROTECTED MATERIAL 11 7.1 Exercise of Restraint and Care in Designating Material for 12 Protection. Each Party or Non-Party that designates 13 14 information or items for protection under this Order must take care to limit 15 any such designation to specific material that qualifies under the 16 appropriate standards. The Designating Party must designate for protection 17 only those parts of material, documents, items or oral or written 18 communications that qualify so that other portions of the material, 19 documents, items or communications for which protection is not warranted 20 are not swept unjustifiably within the ambit of this Order. 21 Mass, indiscriminate or routinized designations are prohibited. 22 Designations that are shown to be clearly unjustified or that have been 23 made for an improper purpose (e.g., to unnecessarily encumber the case 24 development process or to impose unnecessary expenses and burdens on 25 other parties) may expose the Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or 27 items that it designated for protection do not qualify for protection, that 28 PAGE NO 7 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 8 of 16 Page ID #:275

1 Designating Party must promptly notify all other Parties that it is 2 withdrawing the inapplicable designation. 3 7.2 Manner and Timing of Designations. Except as otherwise 4 provided in this Order, or as otherwise stipulated or ordered, Disclosure of 5 Discovery Material that qualifies for protection under this Order must be 6 clearly so designated before the material is disclosed or produced. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or 9 electronic documents, but excluding transcripts of depositions or other 10 pretrial or trial proceedings), that the Producing Party affix at a minimum, 11 the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), 12 to each page that contains protected material. If only a portion of the 13 14 material on a page qualifies for protection, the Producing Party also must 15 clearly identify the protected portion(s) (e.g., by making appropriate 16 markings in the margins). 17 A Party or Non-Party that makes original documents available for 18 inspection need not designate them for protection until after the inspecting 19 Party has indicated which documents it would like copied and produced. 20 During the inspection and before the designation, all of the material made 21 available for inspection shall be deemed “CONFIDENTIAL.” After the 22 inspecting Party has identified the documents it wants copied and 23 produced, the Producing Party must determine which documents, or 24 portions thereof, qualify for protection under this Order. Then, before 25 producing the specified documents, the Producing Party must affix the 26 “CONFIDENTIAL legend” to each page that contains Protected Material. 27 If only a portion of the material on a page qualifies for protection, the 28 PAGE NO 8 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 9 of 16 Page ID #:276

1 Producing Party also must clearly identify the protected portion(s) (e.g., by 2 making appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating 4 Party identifies the Disclosure or Discovery Material on the record, before 5 the close of the deposition all protected testimony. 6 (c) for information produced in some form other than 7 documentary and for any other tangible items, that the Producing Party 8 affix in a prominent place on the exterior of the container or containers in 9 which the information is stored the legend “CONFIDENTIAL.” If only a 10 portion or portions of the information warrants protection, the Producing 11 Party, to the extent practicable, shall identify the protected portion(s). 12 7.3 Inadvertent Failures to Designate. If timely corrected, an 13 14 inadvertent failure to designate qualified information or items does not, 15 standing alone, waive the Designating Party’s right to secure protection 16 under this Order for such material. Upon timely correction of a designation, 17 the Receiving Party must make reasonable efforts to assure that the material 18 is treated in accordance with the provisions of this Order. 19 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 8.1. 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 8.2 Meet and Confer. The Challenging Party shall initiate the 24 dispute resolution process under Local Rule 37-1 et seq. 25 8.3 Joint Stipulation. Any challenge submitted to the Court shall be 26 via a joint stipulation pursuant to Local Rule 37-2. 27 / / / 28 PAGE NO 9 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 10 of 16 Page ID #:277

1 8.4 The burden of persuasion in any such challenge proceeding 2 shall be on the Designating Party. Frivolous challenges, and those made for 3 an improper purpose (e.g., to harass or impose unnecessary expenses and 4 burdens on other parties) may expose the Challenging Party to sanctions. 5 Unless the Designating Party has waived or withdrawn the confidentiality 6 designation, all parties shall continue to afford the material in question the 7 level of protection to which it is entitled under the Producing Party’s 8 designation until the Court rules on the challenge. 9 9. ACCESS TO AND USE OF PROTECTED MATERIAL 10 9.1 Basic Principles. A Receiving Party may use Protected 11 Material that is disclosed or produced by another Party or by a Non-Party 12 in connection with this Action only for prosecuting, defending or 13 14 attempting to settle this Action. Such Protected Material may be disclosed 15 only to the categories of persons and under the conditions described in this 16 Order. When the Action has been terminated, a Receiving Party must 17 comply with the provisions of section 15 below (FINAL DISPOSITION). 18 Protected Material must be stored and maintained by a Receiving 19 Party at a location and in a secure manner that ensures that access is limited 20 to the persons authorized under this Order. 21 9.2 Disclosure of “CONFIDENTIAL” Information or Items. 22 Unless otherwise ordered by the court or permitted in writing by the 23 Designating Party, a Receiving Party may disclose any information or item 24 designated “CONFIDENTIAL” only to: 25 (a) the Receiving Party’s Outside Counsel of Record in this 26 Action, as well as employees of said Outside Counsel of Record to whom it 27 is reasonably necessary to disclose the information for this Action; 28 PAGE NO 10 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 11 of 16 Page ID #:278

1 (b) the officers, directors, and employees (including House 2 Counsel) of the Receiving Party to whom disclosure is reasonably necessary 3 for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to 5 whom disclosure is reasonably necessary for this Action and who have 6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) 7 (d) the court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and 10 Professional Vendors to whom disclosure is reasonably necessary for this 11 Action and who have signed the “Acknowledgment and Agreement to Be 12 Bound” (Exhibit A); 13 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) during their depositions, witnesses, and attorneys for 18 witnesses, in the Action to whom disclosure is reasonably necessary 19 provided: (1) the deposing party requests that the witness sign the form 20 attached as Exhibit A hereto; and (2) they will not be permitted to keep any 21 confidential information unless they sign the “Acknowledgment and 22 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 23 Designating Party or ordered by the court. Pages of transcribed deposition 24 testimony or exhibits to depositions that reveal Protected Material may be 25 separately bound by the court reporter and may not be disclosed to anyone 26 except as permitted under this Stipulated Protective Order; and 27 / / / 28 PAGE NO 11 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 12 of 16 Page ID #:279

1 (i) any mediators or settlement officers and their supporting 2 personnel, mutually agreed upon by any of the parties engaged in settlement 3 discussions. 4 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 5 PRODUCED IN OTHER LITIGATION

6 If a Party is served with a subpoena or a court order issued in other 7 litigation that compels disclosure of any information or items designated in 8 this Action as “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such 10 notification shall include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the 12 subpoena or order to issue in the other litigation that some or all of the 13 material covered by the subpoena or order is subject to this Protective 14 Order. Such notification shall include a copy of this Stipulated Protective 15 Order; and 16 (c) cooperate with respect to all reasonable procedures sought 17 to be pursued by the Designating Party whose Protected Material may be 18 19 affected. If the Designating Party timely seeks a protective order, the Party 20 served with the subpoena or court order shall not produce any information 21 designated in this action as “CONFIDENTIAL” before a determination by 22 the court from which the subpoena or order issued, unless the Party has 23 obtained the Designating Party’s permission. The Designating Party shall 24 bear the burden and expense of seeking protection in that court of its 25 confidential material and nothing in these provisions should be construed as 26 authorizing or encouraging a Receiving Party in this Action to disobey a 27 lawful directive from another court. 28 PAGE NO 12 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 13 of 16 Page ID #:280

1 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO

BE PRODUCED IN THIS LITIGATION

2 (a) The terms of this Order are applicable to information 3 produced by a Non-Party in this Action and designated as 4 5 “CONFIDENTIAL.” Such information produced by Non-Parties in 6 connection with this litigation is protected by the remedies and relief 7 provided by this Order. Nothing in these provisions should be construed as 8 prohibiting a Non-Party from seeking additional protections. 9 (b) In the event that a Party is required, by a valid discovery 10 request, to produce a Non-Party’s confidential information in its possession, 11 and the Party is subject to an agreement with the Non-Party not to produce 12 the Non-Party’s confidential information, then the Party shall: 13 (1) promptly notify in writing the Requesting Party and the 14 Non-Party that some or all of the information requested is subject to a 15 confidentiality agreement with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the 17 Stipulated Protective Order in this Action, the relevant discovery request(s), 18 and a reasonably specific description of the information requested; and 19 (3) make the information requested available for inspection by 20 21 the Non-Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this 23 court within 14 days of receiving the notice and accompanying information, 24 the Receiving Party may produce the Non-Party’s confidential information 25 responsive to the discovery request. If the Non-Party timely seeks a 26 protective order, the Receiving Party shall not produce any information in 27 its possession or control that is subject to the confidentiality agreement with 28 the Non-Party before a determination by the court. Absent a court order to PAGE NO 13 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 14 of 16 Page ID #:281

1 the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this court of its Protected Material. 3 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 4 MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has 6 disclosed Protected Material to any person or in any circumstance not 7 authorized under this Stipulated Protective Order, the Receiving Party must 8 immediately (a) notify in writing the Designating Party of the unauthorized 9 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 10 Protected Material, (c) inform the person or persons to whom unauthorized 11 disclosures were made of all the terms of this Order, and (d) request such 12 person or persons to execute the “Acknowledgment an Agreement to Be 13 Bound” attached hereto as Exhibit A. 14 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 15 OTHERWISE PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other 18 protection, the obligations of the Receiving Parties are those set forth in 19 Federal Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended 20 21 to modify whatever procedure may be established in an e-discovery order 22 that provides for production without prior privilege review. Pursuant to 23 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an 24 agreement on the effect of disclosure of a communication or information 25 covered by the attorney-client privilege or work product protection, the 26 parties may incorporate their agreement in the stipulated protective order 27 submitted to the court. 28 PAGE NO 14 OF 16 CASE NO.: 8:21-cv-01556 Case 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 15 of 16 Page ID #:282

1 14. MISCELLANEOUS 2 14.1 Right to Further Relief. Nothing in this Order abridges the right 3 of any person to seek its modification by the Court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of 5 this 6 Protective Order, no Party waives any right it otherwise would have to 7 object to disclosing or producing any information or item on any ground 8 not addressed in this Stipulated Protective Order. Similarly, no Party 9 waives any right to object on any ground to use in evidence of any of the 10 material covered by this Protective Order. 11 14.3 Filing Protected Material. A Party that seeks to file under seal 12 any Protected Material must comply with Local Civil Rule 79-5. Protected 13 14 Material may only be filed under seal pursuant to a court order authorizing 15 the sealing of the specific Protected Material. If a Party’s request to file 16 Protected Material under seal is denied by the court, then the Receiving 17 Party may file the information in the public record unless otherwise 18 instructed by the court. 19 15. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 6, 21 within 60 days of a written request by the Designating Party, each 22 Receiving Party must return all Protected Material to the Producing Party 23 or destroy such material. As used in this subdivision, “all Protected 24 Material” includes all copies, abstracts, compilations, summaries, and any 25 other format reproducing or capturing any of the Protected Material. 26 Whether the Protected Material is returned or destroyed, the Receiving 27 Party must submit a written certification to the Producing Party (and, if not 28 PAGE NO 15 OF 16 CASE NO.: 8:21-cv-01556 Cage 8:21-cv-01556-JLS-JDE Document 45 Filed 06/30/22 Page 16o0f16 Page ID #:283

1 | | the same person or entity, to the Designating Party) by the 60-day deadline 2 | | that (1) identifies (by category, where appropriate) all the Protected 3 | | Material that was returned or destroyed and (2) affirms that the Receiving 4 Party has not retained any copies, abstracts, compilations, summaries or 5 any other format reproducing or capturing any of the Protected Material. 6 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work

1 product, even if such materials contain Protected Material. Any such D archival copies that contain or constitute Protected Material remain subject 13 | | © this Protective Order as set forth in Section 6 (DURATION). 14 16. VIOLATION 15 Any violation of this Order may be punished by appropriate measures 16 | | including, without limitation, contempt proceedings and/or monetary 17 | | sanctions.. 18 19 50 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21 92 | | DATED: June 30, 2022 vf 23 Lh Le: as 74 JO D. EARLY ted States Magistrate Judge 25 26 27 28

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