Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 1 of 18 Page ID #:300

1 Rebecca H. Stephens (State Bar No. 299234) rstephens@fbm.com 2 Emily J. Tripodi (State Bar No. 334054) etripodi@fbm.com 3 Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor 4 San Francisco, California 94104 Telephone: (415) 954-4400 5 Facsimile: (415) 954-4480

6 Attorneys for AMAZON.COM, INC., AMAZON.COM SERVICES LLC, and 7 AMAZON LOGISTICS, INC.

8

9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 WESTERN DIVISION 12 MELISHA IERENEO-BLOUNT, Case No. 2:22-cv-08996 SB (KSx)

13 Plaintiff, STIPULATED PROTECTIVE

ORDER

14 vs. The Hon. Stanley Blumenfeld, Jr. 15 AMAZON.COM, INC.; AMAZON.COM SERVICES LLC; Trial Date: November 13, 2023 16 AMAZON LOGISTICS, INC., and DOES 1-10, inclusive, 17 Defendants. 18

19 20 Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based 21 on the parties’ Stipulated Protective Order (“Stipulation”) filed on February 22 14, 2023, the terms of the Stipulation to which the parties have agreed are 23 adopted as a protective order of this Court (which generally shall govern the 24 pretrial phase of this action) except to the extent, as set forth below, that those 25 terms have been modified by the Court’s amendment of paragraphs 1. A., 2.15, 26 3, 5.2(b), and 12.3 of the Stipulation, and Exhibit A to the Stipulation. 27 28 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 2 of 18 Page ID #:301

1 AGREED TERMS OF THE PROTECTIVE ORDER AS ADOPTED AND

MODIFIED BY THE COURT1

2

3

4 1. A. PURPOSES AND LIMITATIONS 5 Disclosure and discovery activity in this action are likely to involve 6 production of confidential, proprietary, or private information for which special 7 protection from public disclosure and from use for any purpose other than 8 prosecuting this litigation may be warranted. Accordingly, Defendant Amazon.com, 9 Inc., Amazon.com Services LLC, and Amazon Logistics, Inc. (“Amazon” or 10 “Defendants”) and Plaintiff Melisha Iereneo-Blount (“Plaintiff”) (collectively, “the 11 Parties”), by and through their counsel of record, hereby stipulate to and petition the 12 court to enter the following Stipulated Protective Order. The parties acknowledge 13 that this Order does not confer blanket protections on all disclosures or responses to 14 discovery and that the protection it affords from public disclosure and use extends 15 only to the limited information or items that are entitled to confidential treatment 16 under the applicable legal principles. The parties further acknowledge, as set forth 17 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 18 file confidential information under seal; Civil Local Rule 79-5.2.2(c) sets forth the 19 procedures that must be followed and the standards that will be applied when a party 20 seeks permission from the court to file material under seal. 21 B. GOOD CAUSE STATEMENT 22 This action is likely to involve confidential employment and medical 23 information, confidential information regarding third parties, and other valuable 24 information for which special protection from public disclosure and from use for 25 any purpose other than prosecution of this action is warranted. Such confidential 26 27 1 The Court’s additions to the agreed terms of the Stipulation are generally indicated in bold 28 typeface, and the Court’s deletions are indicated by lines through the text being deleted. 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 2 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 3 of 18 Page ID #:302

1 and proprietary materials and information consist of, among other things, 2 confidential business or financial information, information regarding confidential 3 business practices, employment records, medical information, individuals’ financial 4 information, sensitive information regarding third parties, or other confidential 5 information otherwise generally unavailable to the public, or which may be 6 privileged or otherwise protected from disclosure under state or federal statutes, 7 court rules, case decisions, or common law. Accordingly, to expedite the flow of 8 information, to facilitate the prompt resolution of disputes over confidentiality of 9 discovery materials, to adequately protect information the parties are entitled to keep 10 confidential, to ensure that the parties are permitted reasonable necessary uses of 11 such material in preparation for and in the conduct of trial, to address their handling 12 at the end of the litigation, and serve the ends of justice, a protective order for such 13 information is justified in this matter. It is the intent of the parties that information 14 will not be designated as confidential for tactical reasons and that nothing be so 15 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 17 record of this case. 18 2. DEFINITIONS 19 2.1 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.2 “CONFIDENTIAL” Information or Items: information (regardless of 22 how it is generated, stored or maintained) or tangible things that qualify for 23 protection under Federal Rule of Civil Procedure 26(c). 24 2.3 Counsel (without qualifier): Outside Counsel of Record and House 25 Counsel (as well as their support staff). 26 2.4 Designating Party: a Party or Non-Party that designates information or 27 items that it produces in disclosures or in responses to discovery as 28 “CONFIDENTIAL.” 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 3 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 4 of 18 Page ID #:303

1 2.5 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced or 4 generated in disclosures or responses to discovery in this matter. 5 2.6 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this action. 8 2.7 House Counsel: attorneys who are employees of a party to this action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.8 Non-Party: any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.9 Outside Counsel of Record: attorneys who are not employees of a 14 party to this action but are retained to represent or advise a party to this action and 15 have appeared in this action on behalf of that party or are affiliated with a law firm 16 which has appeared on behalf of that party. 17 2.10 Party: any party to this action, including all of its officers, directors, 18 employees, consultants, retained experts and investigators, and Outside Counsel of 19 Record (and their support staffs). 20 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this action. 22 2.12 Professional Vendors: persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 2.13 Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 2.14 Receiving Party: a Party that receives Disclosure or Discovery 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 4 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 5 of 18 Page ID #:304

1 Material from a Producing Party. 2 2.15 Action: Melisha Iereneo-Blount v. Amazon.Com Inc., et al., Case 3 No. 2:22-cv-08996-SB (KSx). 4 3. SCOPE 5 The types of information eligible for protection under this Stipulation and 6 Order include the following: Plaintiff’s medical records, Plaintiff’s personnel 7 records containing information which is private pursuant to Article 1 Section 1 of 8 the California Constitution, communications and documents related to Plaintiff’s 9 termination, and Amazon’s internal communications and documents discussing 10 Plaintiff. Courts have routinely recognized a legally cognizable privacy interest in 11 records of this nature. See e.g., Miesegaes v. Allenby, No. CV1501574CJCRAO, 12 2020 WL 2542064, at *4 (C.D. Cal. Mar. 13, 2020) (stating that “to the extent the 13 Court orders disclosure of medical information, the Court will issue an 14 adequate protective order”); Curtin v. Cty. of Orange, No. SACV16591SVWPLAX, 15 2017 WL 5593025, at *8 (C.D. Cal. Mar. 13, 2017) (ordering discovery of 16 personnel records as subject to protective order). 17 The protections conferred by this Stipulation and Order cover not only 18 Protected Material (as defined above), but also (1) any information copied or 19 extracted from Protected Material; (2) all copies, excerpts, summaries, or 20 compilations of Protected Material; and (3) any testimony, conversations, or 21 presentations by Parties or their Counsel that might reveal Protected Material. 22 However, the protections conferred by this Stipulation and Order do not cover the 23 following information: (a) any information that is in the public domain at the time of 24 disclosure to a Receiving Party or becomes part of the public domain after its 25 disclosure to a Receiving Party as a result of publication not involving a violation of 26 this Order, including becoming part of the public record through trial or otherwise; 27 and (b) any information known to the Receiving Party prior to the disclosure or 28 obtained by the Receiving Party after the disclosure from a source who obtained the 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 5 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 6 of 18 Page ID #:305

1 information lawfully and under no obligation of confidentiality to the Designating 2 Party. Any use of Protected Material at trial shall be governed by a separate 3 agreement or order the orders of the trial judge. This Order does not govern the 4 use of Protected Material at trial. 5 4. DURATION 6 Even after final disposition of this litigation, the confidentiality obligations 7 imposed by this Order shall remain in effect until a Designating Party agrees 8 otherwise in writing or a court order otherwise directs. Final disposition shall be 9 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 10 or without prejudice; and (2) final judgment herein after the completion and 11 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 12 including the time limits for filing any motions or applications for extension of time 13 pursuant to applicable law. 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection under 17 this Order must take care to limit any such designation to specific material that 18 qualifies under the appropriate standards. The Designating Party must designate for 19 protection only those parts of material, documents, items, or oral or written 20 communications that qualify—so that other portions of the material, documents, 21 items, or communications for which protection is not warranted are not swept 22 unjustifiably within the ambit of this Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper 25 purpose (e.g., to unnecessarily encumber or retard the case development process or 26 to impose unnecessary expenses and burdens on other parties) expose the 27 Designating Party to sanctions. 28 If it comes to a Designating Party’s attention that information or items that it 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 6 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 7 of 18 Page ID #:306

1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the mistaken designation. 3 5.2 Manner and Timing of Designations. Except as otherwise provided in 4 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 5 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 6 under this Order must be clearly so designated before the material is disclosed or 7 produced. 8 Designation in conformity with this Order requires: 9 (a) for information in documentary form (e.g., paper or electronic 10 documents, but excluding transcripts of depositions or other pretrial or trial 11 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each 12 page that contains protected material. If only a portion or portions of the material on 13 a page qualifies for protection, the Producing Party also must clearly identify the 14 protected portion(s) (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents or materials available for 16 inspection need not designate them for protection until after the inspecting Party has 17 indicated which material it would like copied and produced. During the inspection 18 and before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 documents it wants copied and produced, the Producing Party must determine which 21 documents, or portions thereof, qualify for protection under this Order. Then, 22 before producing the specified documents, the Producing Party must affix the 23 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 24 portion or portions of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 (b) for testimony given in depositions or in other pretrial or trial 28 proceedings, that the Designating Party identify on the record, before the close of 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 7 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 8 of 18 Page ID #:307

1 the deposition, hearing, or other proceeding, all protected testimony. that the 2 Designating Party identify the Disclosure or Discovery Material on the record, 3 before the close of the deposition all protected testimony. 4 (c) for information produced in some form other than documentary and 5 for any other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information or item is stored 7 the legend “CONFIDENTIAL.” If only a portion or portions of the information or 8 item warrant protection, the Producing Party, to the extent practicable, shall identify 9 the protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party’s right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time. Unless a prompt challenge to a 19 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 20 substantial unfairness, unnecessary economic burdens, or a significant disruption or 21 delay of the litigation, a Party does not waive its right to challenge a confidentiality 22 designation by electing not to mount a challenge promptly after the original 23 designation is disclosed. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process by providing written notice of each designation it is challenging 26 and describing the basis for each challenge. To avoid ambiguity as to whether a 27 challenge has been made, the written notice must recite that the challenge to 28 confidentiality is being made in accordance with this specific paragraph of the 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 8 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 9 of 18 Page ID #:308

1 Protective Order. The parties shall attempt to resolve each challenge in good faith 2 and must begin the process by conferring directly (in voice to voice dialogue; other 3 forms of communication are not sufficient) within 14 days of the date of service of 4 notice. In conferring, the Challenging Party must explain the basis for its belief that 5 the confidentiality designation was not proper and must give the Designating Party 6 an opportunity to review the designated material, to reconsider the circumstances, 7 and, if no change in designation is offered, to explain the basis for the chosen 8 designation. A Challenging Party may proceed to the next stage of the challenge 9 process only if it has engaged in this meet and confer process first or establishes that 10 the Designating Party is unwilling to participate in the meet and confer process in a 11 timely manner. 12 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 13 court intervention, the Designating Party shall file and serve a motion to retain 14 confidentiality as per applicable judicial standing orders and local rules within 21 15 days of the initial notice of challenge or within 14 days of the parties agreeing that 16 the meet and confer process will not resolve their dispute, whichever is earlier. 17 Each such motion must be accompanied by a competent declaration affirming that 18 the movant has complied with the meet and confer requirements imposed in the 19 preceding paragraph. Failure by the Designating Party to make such a motion 20 including the required declaration within 21 days (or 14 days, if applicable) shall 21 automatically waive the confidentiality designation for each challenged designation. 22 In addition, the Challenging Party may file a motion challenging a confidentiality 23 designation at any time if there is good cause for doing so, including a challenge to 24 the designation of a deposition transcript or any portions thereof. Any motion 25 brought pursuant to this provision must be accompanied by a competent declaration 26 affirming that the movant has complied with the meet and confer requirements 27 imposed by the preceding paragraph. 28 The burden of persuasion in any such challenge proceeding shall be on the 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 9 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 10 of 18 Page ID #:309

1 Designating Party. Frivolous challenges, and those made for an improper purpose 2 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 3 expose the Challenging Party to sanctions. Unless the Designating Party has waived 4 the confidentiality designation by failing to file a motion to retain confidentiality as 5 described above, all parties shall continue to afford the material in question the level 6 of protection to which it is entitled under the Producing Party’s designation until the 7 court rules on the challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 11 case only for prosecuting, defending, or attempting to settle this litigation. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the litigation has been terminated, a 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary 25 to disclose the information for this litigation and who have signed the 26 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 27 A; 28 (b) the officers, directors, and employees (including House Counsel) of 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 10 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 11 of 18 Page ID #:310

1 the Receiving Party to whom disclosure is reasonably necessary for this litigation 2 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 3 A); 4 (c) Experts (as defined in this Order) of the Receiving Party to whom 5 disclosure is reasonably necessary for this litigation and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel; 8 (e) court reporters and their staff, professional jury or trial consultants, 9 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary 10 for this litigation and who have signed the “Acknowledgment and Agreement to Be 11 Bound” (Exhibit A); 12 (f) during their depositions, witnesses in the action to whom disclosure is 13 reasonably necessary and who have signed the “Acknowledgment and Agreement to 14 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered 15 by the court. Pages of transcribed deposition testimony or exhibits to depositions 16 that reveal Protected Material must be separately bound by the court reporter and 17 may not be disclosed to anyone except as permitted under this Stipulated Protective 18 Order. 19 (g) the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the information. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification 27 shall include a copy of the subpoena or court order; 28 (b) promptly notify in writing the party who caused the subpoena or order 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 11 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 12 of 18 Page ID #:311

1 to issue in the other litigation that some or all of the material covered by the 2 subpoena or order is subject to this Protective Order. Such notification shall include 3 a copy of this Stipulated Protective Order; and 4 (c) cooperate with respect to all reasonable procedures sought to be 5 pursued by the Designating Party whose Protected Material may be affected. 6 If the Designating Party timely seeks a protective order, the Party served with 7 the subpoena or court order shall not produce any information designated in this 8 action as “CONFIDENTIAL” before a determination by the court from which the 9 subpoena or order issued, unless the Party has obtained the Designating Party’s 10 permission. The Designating Party shall bear the burden and expense of seeking 11 protection in that court of its confidential material – and nothing in these provisions 12 should be construed as authorizing or encouraging a Receiving Party in this action 13 to disobey a lawful directive from another court. 14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a 17 Non-Party in this action and designated as “CONFIDENTIAL.” Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party 26 that some or all of the information requested is subject to a confidentiality 27 agreement with a Non-Party; 28 (2) promptly provide the Non-Party with a copy of the Stipulated 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 12 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 13 of 18 Page ID #:312

1 Protective Order in this litigation, the relevant discovery request(s), and a 2 reasonably specific description of the information requested; and 3 (3) make the information requested available for inspection by the 4 Non-Party. 5 (c) If the Non-Party fails to object or seek a protective order from this 6 court within 14 days of receiving the notice and accompanying information, the 7 Receiving Party may produce the Non-Party’s confidential information responsive 8 to the discovery request. If the Non-Party timely seeks a protective order, the 9 Receiving Party shall not produce any information in its possession or control that is 10 subject to the confidentiality agreement with the Non-Party before a determination 11 by the court. Absent a court order to the contrary, the Non-Party shall bear the 12 burden and expense of seeking protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 19 persons to whom unauthorized disclosures were made of all the terms of this Order, 20 and (d) request such person or persons to execute the “Acknowledgment and 21 Agreement to Be Bound” that is attached hereto as Exhibit A. 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 28 procedure may be established in an e-discovery order that provides for production 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 13 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 14 of 18 Page ID #:313

1 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 2 (e), insofar as the parties reach an agreement on the effect of disclosure of a 3 communication or information covered by the attorney-client privilege or work 4 product protection, the parties may incorporate their agreement in the stipulated 5 protective order submitted to the court. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Protective Order no Party waives any right it otherwise would have to object to 11 disclosing or producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object on any 13 ground to use in evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. Without written permission from the 15 Designating Party or a court order secured after appropriate notice to all interested 16 persons, a Party may not file in the public record in this action any Protected 17 Material. A Party that seeks to file under seal any Protected Material must comply 18 with Civil Local Rules 140 and 141 79-5. Protected Material may only be filed 19 under seal pursuant to a court order authorizing the sealing of the specific 20 Protected Material at issue. 21 13. FINAL DISPOSITION 22 Within 60 days after the final disposition of this action, as defined in 23 paragraph 4, each Receiving Party must return all Protected Material to the 24 Producing Party or destroy such material. As used in this subdivision, “all Protected 25 Material” includes all copies, abstracts, compilations, summaries, and any other 26 format reproducing or capturing any of the Protected Material. Whether the 27 Protected Material is returned or destroyed, the Receiving Party must submit a 28 written certification to the Producing Party (and, if not the same person or entity, to 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 14 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 15 of 18 Page ID #:314

1 the Designating Party) by the 60 day deadline that (1) identifies (by category, where 2 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 3 that the Receiving Party has not retained any copies, abstracts, compilations, 4 summaries or any other format reproducing or capturing any of the Protected 5 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 6 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 7 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 8 work product, and consultant and expert work product, even if such materials 9 contain Protected Material. Any such archival copies that contain or constitute 10 Protected Material remain subject to this Protective Order as set forth in Section 4 11 (DURATION). 12 14. Any violation of this Order may be punished by any and all appropriate 13 measures including, without limitation, contempt proceedings and/or monetary 14 sanctions. 15 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 18 Dated: February 14, 2023 FARELLA BRAUN + MARTEL LLP

19

20 By: /s/ Rebecca H. Stephens Rebecca H. Stephens 21 22 Attorneys for AMAZON.COM, INC., AMAZON.COM SERVICES LLC, and 23

AMAZON LOGISTICS, INC.

24 25 / / 26 / / 27 / / 28 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 15 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2~:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 16 o0f18 Page ID #:315

1 |) Dated: February 14, 2023 KING & SIEGEL LLP 3 By: /s/ Margaret R. Wright 4 Margaret R. Wright 5 Attorneys for Plaintiff MELISHA IERENEO- 6 BLOUNT 7||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 9 | DATED: February 15, 2023 Li □□□ Biusysr 10 .8. Magistrate Judge Karen L. Stevenson 11 12 13 14 15 16 17 18 19 20 21 De 23 24 25 26 27 28 2a STIPULATED PROTECTIVE ORDER - Case No. 16 42988\15290860.1 2:22-cv-08996 SB (KSx)

Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 17 of 18 Page ID #:316

1 ATTESTATION 2 Pursuant to Local Rule 5-4.3.4, I hereby attest that all other signatories 3 listed, and on whose behalf the filing is submitted, concur in the filing’s content 4 and have authorized the filing. 5 Dated: February 14, 2023 FARELLA BRAUN + MARTEL LLP 6

7 By: /s/ Emily J. Tripodi 8 Emily J. Tripodi 9 Attorneys for AMAZON.COM, INC., 10 AMAZON.COM SERVICES LLC, and 11 AMAZON LOGISTICS, INC.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 17 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx) Case 2:22-cv-08996-SB-KS Document 23 Filed 02/15/23 Page 18 of 18 Page ID #:317

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 7 on [date] in the case of Melisha Iereneo-Blount v. Amazon.com Inc. et al., Case No. 8 2:22-cv-08996-SB (KSx). I agree to comply with and to be bound by all the terms 9 of this Stipulated Protective Order and I understand and acknowledge that failure to 10 so comply could expose me to sanctions and punishment in the nature of contempt. 11 I solemnly promise that I will not disclose in any manner any information or item 12 that is subject to this Stipulated Protective Order to any person or entity except in 13 strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Eastern 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. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature:___________________________________________________________ ___ 28 23 S5 a nF M a Fr o re anll nta g c o iB sm cra oeu ,r yn C S+ alt irM fe oea rtr n,t ie 1 al 7 9Lth 4L F 1Pl 0o 4o r STIPULATED PROTECTIVE ORDER - Case No. 18 42988\15290860.1 (415) 954-4400 2:22-cv-08996 SB (KSx)