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8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 MICHAEL GRIZZLE, an individual, ) Case No. 8:22-cv-01184-DOC-JDE

) 12 Plaintiff, )

13 v. ) STIPULATED PROTECTIVE ORDER ) 14 THE BOEING COMPANY, a ) 15 Delaware corporation; and DOES 1 ) through 150, inclusive, ) 16 ) Defendants. 17 ______________________________ 18 ______________________________ Based on the parties’ stipulation, the Court finds and orders as follows. 19 1. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, proprietary 21 or private information for which special protection from public disclosure and from use 22 for any purpose other than pursuing this litigation may be warranted. Accordingly, the 23 parties hereby stipulate to and petition the Court to enter the following Stipulated 24 Protective Order. The parties acknowledge that this Order does not confer blanket 25 protections on all disclosures or responses to discovery and that the protection it affords 26 from public disclosure and use extends only to the limited information or items that are 27 28 entitled to confidential treatment under the applicable legal principles. 1 Case 8:22-cv-01184

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1 2. GOOD CAUSE STATEMENT 2 This action is likely to involve employee personal contact information, confidential 3 company policies and procedures, trade secrets, confidential research, development, 4 commercial information relating to Boeing’s business, confidential information related to 5 defense contracts, customer information, information which was disclosed in confidence 6 by a third party, and other proprietary information for which special protection from 7 public disclosure and from use for any purpose other than prosecution of this action is 8 warranted. Such confidential and proprietary materials and information consist of, 9 among other things, confidential personnel, business or financial information, 10 information regarding confidential business practices, or other confidential research, 11 development, or commercial information (including information implicating privacy 12 rights of third parties), information otherwise generally unavailable to the public, or 13 which may be privileged or otherwise protected from disclosure under state or federal 14 statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow 15 of information, to facilitate the prompt resolution of disputes over confidentiality of 16 discovery materials, to adequately protect information the parties are entitled to keep 17 confidential, to ensure that the parties are permitted reasonable necessary uses of such 18 material in preparation for and in the conduct of trial, to address their handling at the end 19 of the litigation, and serve the ends of justice, a protective order for such information is 20 justified in this matter. It is the intent of the parties that information will not be 21 designated as confidential for tactical reasons and that nothing be so designated without a 22 good faith belief that it has been maintained in a confidential, non-public manner, and 23 there is good cause why it should not be part of the public record of this case. 24 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 25 PROCEDURE 26 The parties further acknowledge, as set forth in Section 14.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information under 28 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 2 Case 8:22-cv-01184

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1 standards that will be applied when a party seeks permission from the court to file 2 material under seal. There is a strong presumption that the public has a right of access to 3 judicial proceedings and records in civil cases. In connection with non-dispositive 4 motions, good cause must be shown to support a filing under seal. See Kamakana v. City 5 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 6 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 7 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 8 cause showing), and a specific showing of good cause or compelling reasons with proper 9 evidentiary support and legal justification, must be made with respect to Protected 10 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure 11 or Discovery Material as CONFIDENTIAL does not— without the submission of 12 competent evidence by declaration, establishing that the material sought to be filed under 13 seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the relief 16 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 17 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type 18 of information, document, or thing sought to be filed or introduced under seal, the party 19 seeking protection must articulate compelling reasons, supported by specific facts and 20 legal justification, for the requested sealing order. Again, competent evidence supporting 21 the application to file documents under seal must be provided by declaration. 22 Any document that is not confidential, privileged, or otherwise protectable in its 23 entirety will not be filed under seal if the confidential portions can be redacted. If 24 documents can be redacted, then a redacted version for public viewing, omitting only the 25 confidential, privileged, or otherwise protectable portions of the document, shall be filed. 26 Any application that seeks to file documents under seal in their entirety should include an 27 explanation of why redaction is not feasible. 28 / / / 3 Case 8:22-cv-01184

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1 4. DEFINITIONS 2 4.1 Action: this pending federal lawsuit. 3 4.2 Challenging Party: a Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 6 is generated, stored or maintained) or tangible things that qualify for protection under 7 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 8 Statement. 9 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 11 4.5 Designating Party: a Party or Non-Party that designates information or items 12 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 13 4.6 Disclosure or Discovery Material: all items or information, regardless of the 14 medium or manner in which it is generated, stored, or maintained (including, among 15 other things, testimony, transcripts, and tangible things), that are produced or generated in 16 disclosures or responses to discovery. 17 4.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 19 expert witness or as a consultant in this Action. 20 4.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other outside counsel. 22 4.9 Non-Party: any natural person, partnership, corporation, association or other 23 legal entity not named as a Party to this action. 24 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 25 this Action but are retained to represent a party to this Action and have appeared in this 26 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf 27 of that party, and includes support staff. 28 / / / 4 Case 8:22-cv-01184

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1 4.11 Party: any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 4 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 5 Discovery Material in this Action. 6 4.13 Professional Vendors: persons or entities that provide litigation support 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 9 their employees and subcontractors. 10 4.14 Protected Material: any Disclosure or Discovery Material that is designated 11 as “CONFIDENTIAL.” 12 4.15 Receiving Party: a Party that receives Disclosure or Discovery 13 Material from a Producing Party. 14 5. SCOPE 15 The protections conferred by this Stipulation and Order cover not only Protected 16 Material (as defined above), but also (1) any information copied or extracted from 17 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 18 Material; and (3) any testimony, conversations, or presentations by Parties or their 19 Counsel that might reveal Protected Material. 20 Any use of Protected Material at trial shall be governed by the orders of the trial 21 judge and other applicable authorities. This Order does not govern the use of Protected 22 Material at trial. 23 6. DURATION 24 Once a case proceeds to trial, information that was designated as 25 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 26 an exhibit at trial becomes public and will be presumptively available to all members of 27 the public, including the press, unless compelling reasons supported by specific factual 28 findings to proceed otherwise are made to the trial judge in advance of the trial. See 5 Case 8:22-cv-01184

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1 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 2 documents produced in discovery from “compelling reasons” standard when merits- 3 related documents are part of court record). Accordingly, the terms of this protective 4 order do not extend beyond the commencement of the trial. 5 7. DESIGNATING PROTECTED MATERIAL 6 7.1 Exercise of Restraint and Care in Designating Material for 7 Protection. Each Party or Non-Party that designates information or items for 8 protection under this Order must take care to limit any such designation to specific 9 material that qualifies under the appropriate standards. The Designating Party must 10 designate for protection only those parts of material, documents, items or oral or written 11 communications that qualify so that other portions of the material, documents, items or 12 communications for which protection is not warranted are not swept unjustifiably within 13 the ambit of this Order. 14 Mass, indiscriminate or routinized designations are prohibited. Designations that 15 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 16 to unnecessarily encumber the case development process or to impose unnecessary 17 expenses and burdens on other parties) may expose the Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 7.2 Manner and Timing of Designations. Except as otherwise provided in this 22 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 23 qualifies for protection under this Order must be clearly so designated before the material 24 is disclosed or produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (e.g., paper or electronic 27 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 28 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 6 Case 8:22-cv-01184

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1 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 2 portion of the material on a page qualifies for protection, the Producing Party also must 3 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 4 margins). 5 A Party or Non-Party that makes original documents available for inspection need 6 not designate them for protection until after the inspecting Party has indicated which 7 documents it would like copied and produced. During the inspection and before the 8 designation, all of the material made available for inspection shall be deemed 9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 10 copied and produced, the Producing Party must determine which documents, or portions 11 thereof, qualify for protection under this Order. Then, before producing the specified 12 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 13 that contains Protected Material. If only a portion of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 15 by making appropriate markings in the margins). 16 (b) for testimony given in depositions that the Designating Party identifies 17 the Disclosure or Discovery Material on the record, before the close of the deposition all 18 protected testimony. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 23 the Producing Party, to the extent practicable, shall identify the protected portion(s). 24 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 25 to designate qualified information or items does not, standing alone, waive the 26 Designating Party’s right to secure protection under this Order for such material. Upon 27 timely correction of a designation, the Receiving Party must make reasonable efforts to 28 assure that the material is treated in accordance with the provisions of this Order. 7 Case 8:22-cv-01184

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1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 3 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 4 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 5 process under Local Rule 37-1 et seq. 6 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 7 stipulation pursuant to Local Rule 37-2. 8 8.4 The burden of persuasion in any such challenge proceeding shall be on the 9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 10 harass or impose unnecessary expenses and burdens on other parties) may expose the 11 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 12 the confidentiality designation, all parties shall continue to afford the material in question 13 the level of protection to which it is entitled under the Producing Party’s designation until 14 the Court rules on the challenge. 15 9. ACCESS TO AND USE OF PROTECTED MATERIAL 16 9.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this Action 18 only for prosecuting, defending or attempting to settle this Action. Such Protected 19 Material may be disclosed only to the categories of persons and under the conditions 20 described in this Order. When the Action has been terminated, a Receiving Party must 21 comply with the provisions of section 15 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 26 otherwise ordered by the court or permitted in writing by the Designating Party, a 27 Receiving Party may disclose any information or item designated 28 “CONFIDENTIAL” only to: 8 Case 8:22-cv-01184

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1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the 5 Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 13 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not 19 be permitted to keep any confidential information unless they sign the “Acknowledgment 20 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 21 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 22 depositions that reveal Protected Material may be separately bound by the court reporter 23 and may not be disclosed to anyone except as permitted under this Stipulated Protective 24 Order; and 25 (i) any mediators or settlement officers and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 / / / 28 / / / 9 Case 8:22-cv-01184

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1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena or 10 order is subject to this Protective Order. Such notification shall include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. If the Designating 14 Party timely seeks a protective order, the Party served with the subpoena or court order 15 shall not produce any information designated in this action as “CONFIDENTIAL” before 16 a determination by the court from which the subpoena or order issued, unless the Party 17 has obtained the Designating Party’s permission. The Designating Party shall bear the 18 burden and expense of seeking protection in that court of its confidential material and 19 nothing in these provisions should be construed as authorizing or encouraging a 20 Receiving Party in this Action to disobey a lawful directive from another court. 21 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 22 BE PRODUCED IN THIS LITIGATION 23 (a) The terms of this Order are applicable to information produced by a Non- 24 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 25 by Non-Parties in connection with this litigation is protected by the remedies and relief 26 provided by this Order. Nothing in these provisions should be construed as prohibiting a 27 Non-Party from seeking additional protections. 28 10 Case 8:22-cv-01184

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1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is subject 3 to an agreement with the Non-Party not to produce the Non-Party’s confidential 4 information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party that 6 some or all of the information requested is subject to a confidentiality agreement with a 7 Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 9 Order in this Action, the relevant discovery request(s), and a reasonably specific 10 description of the information requested; and 11 (3) make the information requested available for inspection by the Non- 12 Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party may 15 produce the Non-Party’s confidential information responsive to the discovery request. If 16 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 17 information in its possession or control that is subject to the confidentiality agreement 18 with the Non-Party before a determination by the court. Absent a court order to the 19 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 20 court of its Protected Material. 21 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 22 MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 26 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 27 all unauthorized copies of the Protected Material, (c) inform the person or persons to 28 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 11 Case 8:22-cv-01184

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1 such person or persons to execute the “Acknowledgment an Agreement to Be Bound” 2 attached hereto as Exhibit A. 3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 4 OTHERWISE PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 produced material is subject to a claim of privilege or other protection, the obligations of 7 the Receiving Parties are those set forth in Federal Rule of Civil\ Procedure 26(b)(5)(B). 8 This provision is not intended to modify whatever procedure may be established in an e- 9 discovery order that provides for production without prior privilege review. Pursuant to 10 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 11 effect of disclosure of a communication or information covered by the attorney-client 12 privilege or work product protection, the parties may incorporate their agreement in the 13 stipulated protective order submitted to the court. 14 14. MISCELLANEOUS 15 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 14.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 21 to use in evidence of any of the material covered by this Protective Order. 22 14.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Civil Rule 79-5. Protected Material may only 24 be filed under seal pursuant to a court order authorizing the sealing of the specific 25 Protected Material. If a Party’s request to file Protected Material under seal is denied by 26 the court, then the Receiving Party may file the information in the public record unless 27 otherwise instructed by the court. 28 / / / 12 Case 8:22-cv-01184

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1 15. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 6, within 60 days 3 || of a written request by the Designating Party, each Receiving Party must return all 4 || Protected Material to the Producing Party or destroy such material. As used in this 5 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 ||Summaries, and any other format reproducing or capturing any of the Protected Material. 7 || Whether the Protected Material is returned or destroyed, the Receiving Party must submit 8 ||a written certification to the Producing Party (and, if not the same person or entity, to the 9 || Designating Party) by the 60-day deadline that (1) identifies (by category, where 10 ||appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 11 || the Receiving Party has not retained any copies, abstracts, compilations, summaries or 12 other format reproducing or capturing any of the Protected Material. Notwithstanding 13 ||this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 14 || papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 15 || deposition and trial exhibits, expert reports, attorney work product, and consultant and 16 ||expert work product, even if such materials contain Protected Material. Any such archival 17 ||copies that contain or constitute Protected Material remain subject to this Protective 18 || Order as set forth in Section 6 (DURATION). 19 16. VIOLATION 20 Any violation of this Order may be punished by appropriate measures including, 21 || without limitation, contempt proceedings and/or monetary sanctions. 22 73 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 94 || DATED: September 23, 2022 i dL 25 Lh a6 46 J D. EARLY hited States Magistrate Judge 27 28 13 Case 8:22-cv-01184

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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 that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on ___________ [date] in the case of 7 Michael Grizzle v. The Boeing Company, Case No. 8:22-cv-01184-DOC-JDE. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order and I 9 understand and acknowledge that failure to so comply could expose me to sanctions and 10 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 11 manner any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. I further 13 agree to submit to the jurisdiction of the United States District Court for the Central 14 District of California for the purpose of enforcing the terms of this Stipulated Protective 15 Order, even if such enforcement proceedings occur after termination of this action. 16

17 Date: ______________________________________ 18 City and State where sworn and signed: _________________________________ 19 20 Printed name: ______________________________ 21 Signature: _________________________________ 22 23 24 25 26 27 28 14 Case 8:22-cv-01184

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