Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 1 of 15 Page ID #:308

NOTE: CHANGES MADE BY THE COURT

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 LUIS NORIEGA, Case No. CV21-8154 FLA (JPRX) 5 Plaintiff,

6 v. STIPULATED PROTECTIVE

ORDER

7 EXPERIAN INFORMATION

SOLUTIONS, INC.,

8

9 Defendant.

10 NOTE: CHANGES MADE BY THE COURT

11 1. INTRODUCTION 12 1.1 PURPOSES AND LIMITATIONS 13 Discovery in this action may involve production of confidential, proprietary, 14 or private information for which special protection from public disclosure and from 15 use for any purpose other than prosecuting this litigation may be warranted. 16 Accordingly, the Parties hereby stipulate to and petition the Court to enter the 17 following Stipulated Protective Order. The Parties acknowledge that this Order 18 does not confer blanket protections on all disclosures or responses to discovery and 19 that the protection it affords from public disclosure and use extends only to the 20 limited information or items that are entitled to confidential treatment under the 21 applicable legal principles. The Parties further acknowledge, as set forth in Section 22 12.3 below, that this Order does not entitle them to file Confidential Information 23 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 24 and the standards that will be applied when a Party seeks permission from the Court 25 to file material under seal. 26

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1 1.2 GOOD CAUSE STATEMENT 2 This action involves allegations of inaccurate credit reporting relating to a 3 Citibank, N.A. (“Citibank”) account. Plaintiff alleged that there is a fraudulent 4 charge to this account but does not dispute that he is the owner of the account. 5 Plaintiff alleged that Experian Information Solutions Inc. (“Experian”), Trans 6 Union, LLC (“Trans Union”), as well as Citibank, N.A., and Home Depot U.S.A., 7 Inc. (“Home Depot”) were all inaccurately reporting negative information regarding 8 the Account on Plaintiff’s credit file. While Home Depot and Trans Union have 9 been terminated, Plaintiff continues to arbitrate these claims with Citibank and 10 litigate these claims with Experian. 11 The parties seek protection for all confidential proprietary documents, 12 testimony, transcripts and other materials in this action produced by any party or 13 non-party and the information contained therein. Some of the documents and 14 information that have been and may be sought, produced, and exhibited by Plaintiff 15 and Defendant contain sensitive personal information, such as social security 16 number, date of birth, addresses, and phone numbers. Plaintiff will further be 17 disclosing information regarding his financial and credit accounts. Plaintiff will be 18 at risk from potential identity theft if his information were to get into the wrong 19 hands. Further, in connection with the Action, Plaintiff likely will seek discovery or 20 testimony regarding certain of Defendant’s confidential and proprietary trade secrets 21 and other business information including, but not limited to, codes, computer 22 systems, software and processes used for credit reporting, and information derived 23 therefrom. Experian has previously and consistently maintained that certain of its 24 documents, whose production Plaintiff has requested in this matter, contain unique, 25 confidential codes which represent trade secrets or other proprietary information, 26 which Experian has created after considerable investment in research and 27 development, and that disclosure of those documents to the public would 28 compromise Experian’s investment. Good cause therefore exists why such personal 2 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 3 of 15 Page ID #:310

1 identifying information, as well as the above-mentioned trade secret and proprietary 2 information, should not be part of the public record of this case. 3 2. DEFINITIONS 4 2.1 Action: Luis Noriega v. Citibank, No. 2:21-cv-08154. 5 2.2 Challenging Party: a Party or Nonparty that challenges the designation 6 of information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored, or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c) and as specified above in the 10 Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 2.5 Designating Party: a Party or Nonparty that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this action. 23 2.8 House Counsel: attorneys who are employees of a Party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Nonparty: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 28 3 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 4 of 15 Page ID #:311

1 2.10 Outside Counsel of Record: attorneys who are not employees of a 2 Party to this Action but are retained to represent or advise a Party and have appeared 3 in this Action on behalf of that Party or are affiliated with a law firm that has 4 appeared on behalf of that Party, including support staff. 5 2.11 Party: any Party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 2.12 Producing Party: a Party or Nonparty that produces Disclosure or 9 Discovery Material in this Action. 10 2.13 Professional Vendors: persons or entities that provide litigation 11 support services (for example, photocopying, videotaping, translating, preparing 12 exhibits or demonstrations, and organizing, storing, or retrieving data in any form or 13 medium) and their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL.” 16 2.15 Receiving Party: a Party that receives Disclosure or Discovery 17 Material from a Producing Party. 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 20 Protected Material (as defined above) but also any information copied or extracted 21 from Protected Material; all copies, excerpts, summaries, or compilations of 22 Protected Material; and any testimony, conversations, or presentations by Parties or 23 their Counsel that might reveal Protected Material. 24 Any use of Protected Material at trial will be governed by the orders of the 25 trial judge. This Order does not govern the use of Protected Material at trial. 26 4. DURATION 27 Once a case proceeds to trial, all the information that was designated as 28 confidential or maintained under this Order becomes public and will be 4 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 5 of 15 Page ID #:312

1 presumptively available to all members of the public, including the press, unless the 2 trial judge finds compelling reasons to proceed otherwise. See Kamakana v. City & 3 Cnty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good 4 cause” showing for sealing documents produced in discovery from “compelling 5 reasons” needed for merits-related documents). Accordingly, the terms of this 6 Order do not extend beyond the beginning of trial. 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Order will remain in effect until a Designating Party agrees 9 otherwise in writing or a court order otherwise directs. Final disposition is the later 10 of (1) dismissal of all claims and defenses in this Action, with or without prejudice, 11 or (2) final judgment after the completion and exhaustion of all appeals, rehearings, 12 remands, trials, or reviews of this Action, including the time limits for filing any 13 motions or applications for extension of time under applicable law. 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Each Party or Nonparty that designates information or items for 16 protection under this Order must take care to limit any such designation to specific 17 material that qualifies under the appropriate standards. The Designating Party must 18 designate for protection only those parts of material, documents, items, or oral or 19 written communications that qualify so that other portions of the material, 20 documents, items, or communications for which protection is not warranted are not 21 swept unjustifiably within the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations 23 that are shown to be clearly unjustified or that have been made for an improper 24 purpose (for example, to unnecessarily encumber the case-development process or 25 to impose unnecessary expenses and burdens on other parties) may expose the 26 Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items it 28 designated for protection do not qualify for that level of protection, that Designating 5 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 6 of 15 Page ID #:313

1 Party must promptly notify all other Parties that it is withdrawing the inapplicable 2 designation. 3 5.2 Except as otherwise provided in this Order, Disclosure or Discovery 4 Material that qualifies for protection under this Order must be clearly so designated 5 before the material is disclosed or produced. 6 Designation in conformity with this Order requires the following: 7 (a) for information in documentary form (for example, paper or electronic 8 documents but excluding transcripts of depositions or other pretrial or trial 9 proceedings), the Producing Party must affix at a minimum the legend 10 “CONFIDENTIAL” to each page that contains Protected Material. If only a portion 11 or portions of the material on a page qualify for protection, the Producing Party 12 must clearly identify the protected portion(s) (for example, by making appropriate 13 markings in the margins). 14 A Party or Nonparty that makes original documents available for 15 inspection need not designate them for protection until after the inspecting Party has 16 indicated which documents it would like copied and produced. During the 17 inspection and before the designation, all material made available for inspection 18 must be treated as “CONFIDENTIAL.” After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must determine which 20 documents, or portions thereof, qualify for protection under this Order. Then, 21 before producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualify for protection, the Producing 24 Party also must clearly identify the protected portion(s) (for example, by making 25 appropriate markings in the margins). 26 (b) for testimony given in depositions, the Designating Party must identify 27 the Disclosure or Discovery Material that is protected on the record, before the close 28 of the deposition. 6 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 7 of 15 Page ID #:314

1 (c) for information produced in some form other than documentary and for 2 any other tangible items, the Producing Party must affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrant 5 protection, the Producing Party, to the extent practicable, must identify the protected 6 portion(s). 7 5.3 If timely corrected, an inadvertent failure to designate qualified 8 information or items does not, standing alone, waive the Designating Party’s right to 9 secure protection under this Order for that material. On timely correction of a 10 designation, the Receiving Party must make reasonable efforts to assure that the 11 material is treated in accordance with the provisions of this Order. 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 6.1 Any Party or Nonparty may challenge a designation of confidentiality 13 at any time consistent with the Court’s scheduling order. 14 6.2 The Challenging Party must initiate the dispute-resolution process (and, 15 if necessary, file a discovery motion) under Local Rule 37. 16 6.3 The burden of persuasion in any such proceeding is on the Designating 17 Party. Frivolous challenges, and those made for an improper purpose (for example, 18 to harass or impose unnecessary expenses and burdens on other parties), may expose 19 the Challenging Party to sanctions. Unless the Designating Party has waived or 20 withdrawn the confidentiality designation, all parties must continue to afford the 21 material in question the level of protection to which it is entitled under the 22 Producing Party’s designation until the Court rules on the challenge. 23 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 A Receiving Party may use Protected Material that is disclosed or 25 produced by another Party or by a Nonparty in connection with this Action only for 26 prosecuting, defending, or attempting to settle this Action. Such Protected Material 27 may be disclosed only to the categories of people and under the conditions described 28 7 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 8 of 15 Page ID #:315

1 in this Order. When the Action has been terminated, a Receiving Party must comply 2 with the provisions of Section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a manner sufficiently secure to ensure that access is limited to the 5 people authorized under this Order. 6 All documents, transcripts, or other materials subject to this Order, and all 7 information derived therefrom (including, but not limited to, all testimony given in a 8 deposition, declaration or otherwise, that refers, reflects or otherwise discusses any 9 information designated “Confidential” hereunder), shall not be used, directly or 10 indirectly, by any person for any business, commercial or competitive purposes or 11 for any purpose whatsoever other than solely for the preparation for and trial of this 12 action in accordance with the provisions of this Order. 13 7.2 Unless otherwise ordered by the Court or permitted in writing by the 14 Designating Party, a Receiving Party may disclose any information or item 15 designated “CONFIDENTIAL” only to the following people: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 well as employees of that Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the Court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 9 of 15 Page ID #:316

1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses and attorneys for witnesses to 4 whom disclosure is reasonably necessary, provided that the deposing party requests 5 that the witness sign the form attached as Exhibit A hereto and the witnesses will 6 not be permitted to keep any confidential information unless they sign the form, 7 unless otherwise agreed by the Designating Party or ordered by the Court. Pages of 8 transcribed deposition testimony or exhibits to depositions that reveal Protected 9 Material may be separately bound by the court reporter and may not be disclosed to 10 anyone except as permitted under this Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, 12 mutually agreed on by any of the Parties engaged in settlement discussions or 13 appointed by the Court. 14 7. 3 Except as to judicial officers, documents produced pursuant to this 15 Order shall not be made available to any person designated in Paragraph 7.2 unless 16 he or she shall have first read this Order, agreed to be bound by its terms, and signed 17 the attached “Declaration of Compliance” (Exhibit A). 18 7.4 All persons receiving any or all documents produced pursuant to this 19 Order shall be advised of their confidential nature. Except as to judicial officers, 20 all persons to whom confidential information and/or documents are disclosed are 21 hereby enjoined from disclosing the same to any person except as provided herein, 22 and are further enjoined from using same except in the preparation for and trial of 23 the above-captioned action between the named parties thereto. Absent further court 24 order, no person receiving or reviewing such confidential documents, information or 25 transcript shall disseminate or disclose them to any person other than those 26 described above in Paragraph 7.2 and for the purposes specified, and in no event 27 shall such person make any other use of such document or transcript. 28 7.5 This Order has been agreed to by the parties to facilitate discovery and 9 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 10 of 15 Page ID #:317

1 the production of relevant evidence in this action. Neither the entry of this Order, 2 nor the designation of any information, document, or the like as “Confidential,” nor 3 the failure to make such designation, shall constitute evidence with respect to any 4 issue in this action. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 6 IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must 10 (a) promptly notify in writing the Designating Party. Such notification 11 must include a copy of the subpoena or court order unless prohibited by law; 12 (b) promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification must include 15 a copy of this Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 the subpoena or court order should not produce any information designated in this 20 action as “CONFIDENTIAL” before a determination on the protective-order request 21 by the relevant court unless the Party has obtained the Designating Party’s 22 permission. The Designating Party bears the burden and expense of seeking 23 protection of its Confidential Material, and nothing in these provisions should be 24 construed as authorizing or encouraging a Receiving Party in this Action to disobey 25 a lawful directive from another court. 26 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 10 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 11 of 15 Page ID #:318

1 (a) The terms of this Order are applicable to information produced by a 2 Nonparty in this Action and designated as “CONFIDENTIAL.” Such information is 3 protected by the remedies and relief provided by this Order. Nothing in these 4 provisions should be construed as prohibiting a Nonparty from seeking additional 5 protections. 6 (b) In the event that a Party is required by a valid discovery request to 7 produce a Nonparty’s Confidential Information in its possession and the Party is 8 subject to an agreement with the Nonparty not to produce the Nonparty’s 9 Confidential Information, then the Party must 10 (1) promptly notify in writing the Requesting Party and the Nonparty 11 that some or all of the information requested is subject to a confidentiality 12 agreement with a Nonparty; 13 (2) promptly provide the Nonparty with a copy of this Order, the 14 relevant discovery request(s), and a reasonably specific description of the 15 information requested; and 16 (3) make the information requested available for inspection by the 17 Nonparty, if requested. 18 (c) If the Nonparty fails to seek a protective order within 21 days of 19 receiving the notice and accompanying information, the Receiving Party may 20 produce the Nonparty’s Confidential Information responsive to the discovery 21 request. If the Nonparty timely seeks a protective order, the Receiving Party must 22 not produce any information in its possession or control that is subject to the 23 confidentiality agreement with the Nonparty before a ruling on the protective-order 24 request. Absent a court order to the contrary, the Nonparty must bear the burden 25 and expense of seeking protection of its Protected Material. 26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this 11 Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 12 of 15 Page ID #:319

1 Order, the Receiving Party must immediately notify the Designating Party in writing 2 of the unauthorized disclosures, use its best efforts to retrieve all unauthorized 3 copies of the Protected Material, inform the person or people to whom unauthorized 4 disclosures were made of the terms of this Order, and ask that person or people to 5 execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto 6 as Exhibit A. 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7

PROTECTED MATERIAL

8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). 12 12. MISCELLANEOUS 13 12.1 Nothing in this Order abridges the right of any person to seek its 14 modification by the Court. 15 12.2 By stipulating to the entry of this Order, no Party waives any right it 16 otherwise would have to object to disclosing or producing any information or item 17 on any ground not addressed in this Order. Similarly, no Party waives any right to 18 object on any ground to use in evidence of any of the material covered by this 19 Order. 20 12.3 A Party that seeks to file under seal any Protected Material must 21 comply with Civil Local Rule 79-5. Protected Material may be filed under seal only 22 pursuant to a court order authorizing the sealing of the specific Protected Material at 23 issue. If a Party's request to file Protected Material under seal is denied, then the 24 Receiving Party may file the information in the public record unless otherwise 25 instructed by the Court. 26

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1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60-day deadline that identifies (by 10 category, when appropriate) all the Protected Material that was returned or 11 destroyed and affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries, or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings; motion papers; trial, deposition, and hearing 15 transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert 16 reports; attorney work product; and consultant and expert work product even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Order as set forth in Section 4 19 (DURATION). 20 14. SANCTIONS 21 Any willful violation of this Order may be punished by civil or criminal 22 contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or 23 other appropriate action at the discretion of the Court. 24 25 26 27 28 13 Case #:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 14o0f15 Page ID #:321

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 DATED: July 29, 2022 /s/ Matthew M. Loker Matthew M. Loker (SBN 279939) 4 Counsel for Plaintif: ; LUIS NORIEGA

6 || DATED: July 29, 2022 /s/ Stephanie Dilworth Stephanie Dilworth (SBN 342109) 7 Counsel for Defendant

EXPERIAN INFORMATION

8 SOLUTIONS, INC. 10 || DATED: August 4, 2022 fe huehletl~ 11

D JEAN P. ROSENBLUTH

U.S. MAGISTRATE JUDGE

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14

Case 2:21-cv-08154-FLA-JPR Document 65 Filed 08/04/22 Page 15 of 15 Page ID #:322

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the U.S. District Court 7 for the Central District of California on [date] in the case of Luis Noriega v. 8 Citibank, No. 2:21-cv-08154. I agree to comply with and to be bound by all terms of 9 this Stipulated Protective Order, and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment, including contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is 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 U.S. 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 __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 15