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1 SEYFARTH SHAW LLP Candace Bertoldi (SBN 254725) 2 cbertoldi@seyfarth.com 601 South Figueroa Street, Suite 3300 3 Los Angeles, California 90017-5793 Telephone: (213) 270-9600 4 Facsimile: (213) 270-9601 5 SEYFARTH SHAW LLP Elizabeth J. MacGregor (SBN 267326) 6 emacgregor@seyfarth.com Robin E. Devaux (SBN 233444) 7 rdevaux@seyfarth.com 560 Mission Street, 31st Floor 8 San Francisco, California 94105 Telephone: (415) 397-2823 9 Facsimile: (415) 397-8549 10 Attorneys for Defendant

OWENS-BROCKWAY GLASS CONTAINER

11 INC.

12 MATERN LAW GROUP, P.C. Matthew J. Matern (SBN 159798) 13 mmatern@maternlawgroup.com Scott A. Brooks (SBN 160115) 14 sbrooks@maternlawgroup.com 1230 Rosecrans Avenue, Suite 200 15 Manhattan Beach, Caliornia 90266 Telephone: (310) 531-1900 16 Facsimile: (310) 531-1901

17 Attorneys for Plaintiff 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 21 LUCIO LEMUS, individually, and on Case No. 2:21-CV-00146-FLA-AFM behalf of others similarly situated;, 22 STIPULATED PROTECTIVE Plaintiff, ORDER 23 v. 24

OWENS-BROCKWAY GLASS

25 CONTAINER, INC., a Delaware corporation; and DOES 1 through 50, 26 inclusive, 27 Defendants. 28

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1 IT IS HEREBY STIPULATED by and between Plaintiff Lucio Lemus Jr. 2 (“Plaintiff”) and Defendant Owens-Brockway Glass Container Inc. (“Defendant”) 3 (collectively, “the parties”), by and through their respective counsel of record, that the 4 following Protective Order be entered in order to facilitate the exchange of information 5 and documents which may be subject to confidentiality limitations on disclosure. 6 Certificate of Conference: Pursuant to Judge MacKinnon’s Order dated October 7, 7 2022 (Dkt. 37) and Federal Rule of Civil Procedure 26(c)(1), the Parties certify that they 8 have conferred in good faith in crafting this Stipulated Protective Order so that it is 9 narrowly tailored to the issues present in this action. Pursuant to Federal Rule of Civil 10 Procedure 26(c)(1)G), the parties also certify and they agree that information protected 11 by third-party privacy rights and trade secret of other confidential research, development, 12 financial or commercial documents and information be reveal only in the specific ways 13 detailed in this Protective Order. 14 1. A. PURPOSES AND LIMITATIONS1 15 Discovery in this action is likely to involve production of confidential, proprietary 16 or private information for which special protection from public disclosure and from use 17 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 18 parties stipulate to and petition the Court to enter the following Stipulated Protective 19 Order. The parties acknowledge that this Order does not confer blanket protections on all 20 disclosures or responses to discovery and that the protection it affords from public 21 disclosure and use extends only to the limited information or items that are entitled to 22 confidential treatment under the applicable legal principles. 23 24 25 1 This Stipulated Protective Order is based substantially on the model protective 26 order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. A 27 “redline” or “compare” version showing changes between the model protective order and 28 this Order have been submitted electronically to the Judge MacKinnon’s Chambers according to the Judge’s online procedures. 2

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1 B. GOOD CAUSE STATEMENT 2 In this action, Plaintiff seeks to recover penalties pursuant to the California Private 3 Attorneys General Act (“PAGA”) on behalf of allegedly aggrieved non-exempt 4 employees who worked for Defendant in California between November 13, 2019, and the 5 present. Plaintiff also asserts individual claims for various violations under the Labor 6 Code against Defendant originally brought by his deceased father and former named 7 plaintiff Lucio Lemus Sr. 8 Plaintiff has propounded written discovery on Defendant, seeking confidential 9 information pertaining to the absent aggrieved employees’ wages, contact information, 10 and employment records. 11 Moreover, Plaintiff has sought or will seek valuable commercial, financial, 12 technical and/or proprietary information for which special protection from public 13 disclosure and from use for any purpose other than prosecution of this action is 14 warranted. Such confidential and proprietary materials and information consist of, among 15 other things, confidential business or financial information, information regarding 16 confidential business practices, or other confidential research, development, or 17 commercial information, information otherwise generally unavailable to the public, or 18 which may be privileged or otherwise protected from disclosure under state or federal 19 statutes, court rules, case decisions, or common law. 20 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 21 of disputes over confidentiality of discovery materials, to adequately protect information 22 the Parties are entitled to keep confidential, to ensure that the Parties are permitted 23 reasonable necessary uses of such material in preparation for and in the conduct of trial, 24 to address their handling at the end of the litigation, and serve the ends of justice, a 25 protective order for such information is justified in this matter. 26 This action is likely to involve trade secrets, customer and pricing lists and other 27 valuable research, development, commercial, financial, technical and/or proprietary 28 information for which special protection from public disclosure and from use for any 3

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1 purpose other than prosecution of this action is warranted. Such confidential and 2 proprietary materials and information consist of, among other things, confidential 3 business or financial information, information regarding confidential business practices, 4 or other confidential research, development, or commercial information (including 5 information implicating privacy rights of third parties), information otherwise generally 6 unavailable to the public, or which may be privileged or otherwise protected from 7 disclosure under state or federal statutes, court rules, case decisions, or common law. 8 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 9 disputes over confidentiality of discovery materials, to adequately protect information the 10 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 11 necessary uses of such material in preparation for and in the conduct of trial, to address 12 their handling at the end of the litigation, and serve the ends of justice, a protective order 13 for such information is justified in this matter. It is the intent of the parties that 14 information will not be designated as confidential for tactical reasons and that nothing be 15 so designated without a good faith belief that it has been maintained in a confidential, 16 non-public manner, and there is good cause why it should not be part of the public record 17 of this case. 18 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 19 The parties further acknowledge, as set forth in Section 12.3, below, that this 20 Stipulated Protective Order does not entitle them to file confidential information under 21 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 22 standards that will be applied when a party seeks permission from the court to file 23 material under seal. 24 There is a strong presumption that the public has a right of access to judicial 25 proceedings and records in civil cases. In connection with non-dispositive motions, good 26 cause must be shown to support a filing under seal. See Kamakana v. City and County of 27 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 28 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 4

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1 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and 2 a specific showing of good cause or compelling reasons with proper evidentiary support 3 and legal justification, must be made with respect to Protected Material that a party seeks 4 to file under seal. The parties’ mere designation of Disclosure or Discovery Material as 5 CONFIDENTIAL does not— without the submission of competent evidence by 6 declaration, establishing that the material sought to be filed under seal qualifies as 7 confidential, privileged, or otherwise protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the relief 10 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 11 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type 12 of information, document, or thing sought to be filed or introduced under seal in 13 connection with a dispositive motion or trial, the party seeking protection must articulate 14 compelling reasons, supported by specific facts and legal justification, for the requested 15 sealing order. Again, competent evidence supporting the application to file documents 16 under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in its 18 entirety will not be filed under seal if the confidential portions can be redacted. If 19 documents can be redacted, then a redacted version for public viewing, omitting only the 20 confidential, privileged, or otherwise protectable portions of the document, shall be filed. 21 Any application that seeks to file documents under seal in their entirety should include an 22 explanation of why redaction is not feasible. 23 2. DEFINITIONS 24 2.1. Action: this pending federal lawsuit. 25 2.2. Challenging Party: a Party or Non-Party that challenges the designation of 26 information or items under this Order. 27 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how it 28 is generated, stored or maintained) or tangible things that qualify for protection under 5

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1 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 2 Statement. 3 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 4 support staff). 5 2.5. Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 7 2.6. Disclosure or Discovery Material: all items or information, regardless of the 8 medium or manner in which it is generated, stored, or maintained (including, among 9 other things, testimony, transcripts, and tangible things), that are produced or generated in 10 disclosures or responses to discovery in this matter. 11 2.7. Expert: a person with specialized knowledge or experience in a matter 12 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 13 expert witness or as a consultant in this Action. 14 2.8. House Counsel: attorneys who are employees of a party to this Action. 15 House Counsel does not include Outside Counsel of Record or any other outside counsel. 16 2.9. Non-Party: any natural person, partnership, corporation, association or other 17 legal entity not named as a Party to this action. 18 2.10. Outside Counsel of Record: attorneys who are not employees of a party to 19 this Action but are retained to represent or advise a party to this Action and have 20 appeared in this Action on behalf of that party or are affiliated with a law firm that has 21 appeared on behalf of that party, and includes support staff. 22 2.11. Party: any party to this Action, including all of its officers, directors, 23 employees, consultants, retained experts, and Outside Counsel of Record (and their 24 support staffs). 25 2.12. Producing Party: a Party or Non-Party that produces Disclosure or 26 Discovery Material in this Action. 27 2.13. Professional Vendors: persons or entities that provide litigation support 28 services (e.g., photocopying, videotaping, translating, preparing exhibits or 6

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1 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 2 their employees and subcontractors. 3 2.14. Protected Material: any Disclosure or Discovery Material that is designated 4 as “CONFIDENTIAL.” 5 2.15. Receiving Party: a Party that receives Disclosure or Discovery Material 6 from a Producing Party. 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only Protected 9 Material (as defined above), but also (1) any information copied or extracted from 10 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 11 Material; and (3) any testimony, conversations, or presentations by Parties or their 12 Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the trial 14 judge. This Order does not govern the use of Protected Material at trial. 15 4. DURATION 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 18 an exhibit at trial becomes public and will be presumptively available to all members of 19 the public, including the press, unless compelling reasons supported by specific factual 20 findings to proceed otherwise are made to the trial judge in advance of the trial. See 21 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 22 documents produced in discovery from “compelling reasons” standard when merits- 23 related documents are part of court record). Accordingly, the terms of this protective 24 order do not extend beyond the commencement of the trial. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1. Exercise of Restraint and Care in Designating Material for Protection. Each 27 Party or Non-Party that designates information or items for protection under this Order 28 must take care to limit any such designation to specific material that qualifies under the 7

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

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1 copied and produced, the Producing Party must determine which documents, or portions 2 thereof, qualify for protection under this Order. Then, before producing the specified 3 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 4 that contains Protected Material. If only a portion of the material on a page qualifies for 5 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 6 by making appropriate markings in the margins). 7 (b) for testimony given in depositions that the Designating Party 8 identifies the Disclosure or Discovery Material on the record, before the close of the 9 deposition all protected testimony. 10 (c) for information produced in some form other than documentary and 11 for any other tangible items, that the Producing Party affix in a prominent place on the 12 exterior of the container or containers in which the information is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 14 the Producing Party, to the extent practicable, shall identify the protected portion(s). 15 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 16 to designate qualified information or items does not, standing alone, waive the 17 Designating Party’s right to secure protection under this Order for such material. Upon 18 timely correction of a designation, the Receiving Party must make reasonable efforts to 19 assure that the material is treated in accordance with the provisions of this Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 22 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 23 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution 24 process under Local Rule 37-1 et seq. 25 6.3. Joint Stipulation. Any challenge submitted to the Court shall be via a joint 26 stipulation pursuant to Local Rule 37-2. 27 6.4. The burden of persuasion in any such challenge proceeding shall be on the 28 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 9

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

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

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

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

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

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1 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 2 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 3 deposition and trial exhibits, expert reports, attorney work product, and consultant and 4 expert work product, even if such materials contain Protected Material. Any such archival 5 copies that contain or constitute Protected Material remain subject to this Protective 6 Order as set forth in Section 4 (DURATION). 7 14. VIOLATION 8 Any violation of this Order may be punished by appropriate measures including, 9 without limitation, contempt proceedings and/or monetary sanctions. 10

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

11

12

13 DATED: October 12, 2022 Respectfully submitted,

14 SEYFARTH SHAW LLP 15 16 By: /s/ Candace Bertoldi Candace Bertoldi 17 Elizabeth J. MacGregor Robin Devaux 18 Attorneys for Defendant

OWENS-BROCKWAY GLASS

19 CONTAINER INC.

20 DATED: October 12, 2022 Respectfully submitted, 21

MATERN LAW GROUP, P.C.

22 23 By: /s/ Scott A. Brooks 24 Matthew J. Matern Scott A Brooks 25 Attorneys for Plaintiff

LUCIO LEMUS

26 27

28 15

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1 SIGNATURE ATTESTATION 2 Pursuant to Local Rule 5-4.3.4(a)(2), the filer attests that all other signatories listed, and 3 ||on whose behalf the filing is submitted, concur in the filing’s content and have authorized 4 filing. 5 6 7 ORDER 8 ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 9 10 11 |IDATED: 10/11/2022 12 13 (Wy 14 15 |]Umted States Mugistrats Judge 16 17 18 19 20 21 22 23 24 25 26 27 28 16 vein STIPULATED PROTECTIVE ORDER

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________ [print or type full name], of ___________________ 4 [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California on 7 [date] in the case of ___________________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint ___________________ [print or type full name] of 18 ___________________ [print or type full address and telephone number] as my 19 California agent for service of process in connection with this action or any proceedings 20 related to enforcement of this Stipulated Protective Order. 21 Date: 22 23 City and State where sworn and signed: 24 Printed name: 25 26 Signature: 27 28 17

STIPULATED PROTECTIVE ORDER

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