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1 Tanja L. Darrow, Bar No. 175502 tdarrow@littler.com 2 Melissa Velez, Bar No. 316714 mvelez@littler.com 3 LITTLER MENDELSON, P.C. 633 West 5th Street 4 63rd Floor Los Angeles, California 90071 5 Telephone: 213.443.4300 Fax No.: 213.443.4299 6 Attorneys for Defendant 7 AMERICAN AIRLINES, INC.

8 Avi Burkwitz. Esq., Bar No.: 217225 aburkwitz@pDbllp.com 9 Sherry M. Gregorio, Esq., Bar No.: 263856 10 sgregorio@pbbllp.com Irene Yousefi, Esq., Bar No.: 328432 11 iyousefi@pbbllp.com 12 PETERSON, BRADFORD, BURKWITZ,

GREGORIO, BURKWITZ & SU, LLP

13 100 North First Street, Suite 300 14 Burbank, California 91502 818.562.5800 15

16 Attorneys for Plaintiff,

RENEE MAXWELL

17

18

UNITED STATES DISTRICT COURT

19

CENTRAL DISTRICT OF CALIFORNIA

20 21 RENEE MAXWELL, an individual, Case No. 2:22−cv−01803−FLA−(KSx) 22 Plaintiff, [Assigned: Hon. Fernando L. Aenlle- Rocha, Courtroom: 6B] 23 v. 24 STIPULATED PROTECTIVE AMERICAN AIRLINES, INC.; and DOES 1-50, inclusive, ORDER 25 Defendants. 26 FAC Filed: February 15, 2022 Complaint Filed: February 4, 2022 27 28

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Case 2:22-cv-01803-FLA-KS Document 26 Filed 03/03/23 Page 2 of 16 Page ID #:197

1 I. PURPOSES AND LIMITATIONS OF STIPULATION AND

PROTECTIVE ORDER

2 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public disclosure 5 and from use for any purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 7 Stipulated Protective Order. The parties acknowledge that this Order does not confer 8 blanket protections on all disclosures or responses to discovery and that the protection 9 it affords from public disclosure and use extends only to the limited information or items 10 that are entitled to confidential treatment under the applicable legal principles. The 11 parties further acknowledge, as set forth in Section XIII.C., below, that this Stipulated 12 Protective Order does not entitle them to file confidential information under seal; Civil 13 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 14 will be applied when a party seeks permission from the court to file material under seal. 15 II. GOOD CAUSE STATEMENT 16 This action is likely to involve the disclosure of material protected under the 17 constitutional, statutory, or common law right to privacy or protected as confidential 18 business, financial, proprietary, or private personnel, policy and payroll information. 19 Such confidential and proprietary materials and information consist of, among other 20 things, confidential information regarding current and/ or former employees, 21 confidential business or financial information, information regarding confidential 22 business practices, or other confidential commercial information (including information 23 implicating privacy rights of third parties), information otherwise generally unavailable 24 to the public, or which may be privileged or otherwise protected from disclosure under 25 state or federal statutes, court rules, case decisions, or common law. Accordingly, to 26 expedite the flow of information, to facilitate the prompt resolution of disputes over 27 confidentiality of discovery materials, to adequately protect information the parties are 28 entitled to keep confidential, to ensure that the parties are permitted reasonable

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1 necessary uses of such material in preparation for and in the conduct of trial, to address 2 their handling at the end of the litigation, and serve the ends of justice, a protective order 3 for such information is justified in this matter. It is the intent of the parties that 4 information will not be designated as confidential for tactical reasons and that nothing 5 be so designated without a good faith belief that it has been maintained in a confidential, 6 non-public manner, and there is good cause why it should not be part of the public 7 record of this case. 8 III. DEFINITIONS 9 A. Action: Action refers to the above referenced matter titled Renee Maxwell 10 v. American Airlines, Inc., Case No. 2:22-cv-01 803-FLA-KS. 11 B. Challenging Party: a Party or Non-Party that challenges the designation of 12 information or items under this Order. 13 C. “CONFIDENTIAL” Information or Items: information that has not been 14 made public or is not otherwise available or accessible in the public 15 domain and that concerns or relates to the confidential or proprietary 16 information of: (1) Defendant American Airlines, Inc. (“Defendant”); (2) 17 Plaintiff Renee Maxwell (“Plaintiff”); or (3) any third parties, the 18 disclosure of which information is likely to have the effect of causing harm 19 to the competitive position of Defendants or to the organization or person 20 from whom the information was obtained, or to the parties’ privacy. 21 Confidential Information also includes private information pertaining to 22 Defendants’ or a third party’s employees, for which Defendants or a third 23 party has a duty to maintain the confidentiality of such information. 24 Information designated Confidential may be used only in connection with 25 this proceeding, and not for any other purpose. Such information may not 26 be disclosed to anyone except as provided in this Order. 27 28

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1 D. Counsel: “Counsel” means: 2 1. Littler Mendelson, a professional corporation, and its respective 3 support staff and other employees who are not employed by a Party 4 and to whom it is necessary to disclose Confidential Information for 5 the purpose of this action; 6 2. Peterson, Bradford, Burkwitz, Gregorio, Burkwitz & Su, LLP, and 7 their respective support staff and other employees who are not 8 employed by a Party and to whom it is necessary to disclose 9 Confidential Information for the purpose of this action; 10 E. Designating Party: a Party or Non-Party that designates information or 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL.” 13 F. Disclosure or Discovery Material: all items or information, regardless of 14 the medium or manner in which it is generated, stored, or maintained 15 (including, among other things, testimony, transcripts, and tangible 16 things), that are produced or generated in disclosures or responses to 17 discovery in this matter. 18 G. Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel 20 to serve as an expert witness or as a consultant in this Action. 21 H. House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other 23 outside counsel. 24 I. Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 J. Outside Counsel of Record: attorneys who are not employees of a party to 27 this Action but are retained to represent or advise a party to this Action and 28

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

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1 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 2 City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 3 “good cause” showing for sealing documents produced in discovery from “compelling 4 reasons” standard when merits-related documents are part of court record). 5 Accordingly, the terms of this protective order do not extend beyond the 6 commencement of the trial. 7 VI. DESIGNATING PROTECTED MATERIAL 8 A. Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Non-Party that designates information or items for protection under this 10 Order must take care to limit any such designation to specific material that qualifies 11 under the appropriate standards. The Designating Party must designate for protection 12 only those parts of material, documents, items, or oral or written communications that 13 qualify so that other portions of the material, documents, items, or communications for 14 which protection is not warranted are not swept unjustifiably within the ambit of this 15 Order. 16 Mass, indiscriminate, or routinized designations are prohibited. Designations that 17 are shown to be clearly unjustified or that have been made for an improper purpose 18 (e.g., to unnecessarily encumber the case development process or to impose 19 unnecessary expenses and burdens on other parties) may expose the Designating Party 20 to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 designated for protection do not qualify for protection, that Designating Party must 23 promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 B. Manner and Timing of Designations. Except as otherwise provided in this 25 Order or as otherwise stipulated or ordered, Disclosure or Discovery Material that 26 qualifies for protection under this Order must be clearly so designated before the 27 material is disclosed or produced. 28

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1 Designation in conformity with this Order requires: 2 1. for information in documentary form (e.g., paper or electronic 3 documents, but excluding transcripts of depositions or other pretrial or trial 4 proceedings), that the Producing Party affix, at a minimum, the legend 5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 6 contains protected material. If only a portion or portions of the material on a page 7 qualifies for protection, the Producing Party also must clearly identify the protected 8 portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-Party 9 that makes original documents available for inspection need not designate them for 10 protection until after the inspecting Party has indicated which documents it would like 11 copied and produced. During the inspection and before the designation, all of the 12 material made available for inspection shall be deemed “CONFIDENTIAL.” After the 13 inspecting Party has identified the documents it wants copied and produced, the 14 Producing Party must determine which documents, or portions thereof, qualify for 15 protection under this Order. Then, before producing the specified documents, the 16 Producing Party must affix the “CONFIDENTIAL legend” to each page that contains 17 Protected Material. If only a portion or portions of the material on a page qualifies for 18 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 19 by making appropriate markings in the margins). 20 2. for testimony given in depositions that the Designating Party 21 identify the Disclosure or Discovery Material on the record, before the close of the 22 deposition. 23 3. for information produced in some form other than documentary and 24 for any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 protection, the Producing Party, to the extent practicable, shall identify the protected 28 portion(s).

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1 C. Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. Upon 4 timely correction of a designation, the Receiving Party must make reasonable efforts to 5 assure that the material is treated in accordance with the provisions of this Order. 6 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 A. Timing of Challenges. Any Party or Non-Party may challenge a 8 designation of confidentiality at any time that is consistent with the Court’s Scheduling 9 Order. 10 B. Meet and Confer. The Challenging Party shall initiate the dispute 11 resolution process under Local Rule 37.1, et seq. Any discovery motion must strictly 12 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 13 C. Burden. The burden of persuasion in any such challenge proceeding shall 14 be on the Designating Party. Frivolous challenges, and those made for an improper 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 16 may expose the Challenging Party to sanctions. Unless the Designating Party has 17 waived or withdrawn the confidentiality designation, all parties shall continue to afford 18 the material in question the level of protection to which it is entitled under the Producing 19 Party’s designation until the Court rules on the challenge. 20 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 21 A. Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this Action 23 only for prosecuting, defending, or attempting to settle this Action. Such Protected 24 Material may be disclosed only to the categories of persons and under the conditions 25 described in this Order. When the Action has been terminated, a Receiving Party must 26 comply with the provisions of Section XV. below (FINAL DISPOSITION). 27 28

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1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 5 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 6 may disclose any information or item designated “CONFIDENTIAL” only to: 7 1. the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably 9 necessary to disclose the information for this Action; 10 2. the officers, directors, and employees (including House Counsel) of 11 the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 3. Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound by Protective Order” (Exhibit A); 15 4. the Court and its personnel; 16 5. court reporters and their staff; 17 6. professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound by Protective Order” 20 (Exhibit A); 21 7. the author or recipient of a document containing the information or 22 a custodian or other person who otherwise possessed or knew the information; 23 8. during their depositions, witnesses, and attorneys for witnesses, in 24 the Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 26 not be permitted to keep any confidential information unless they sign the 27 “Acknowledgment and Agreement to Be Bound by Protective Order” (Exhibit A), 28 unless otherwise agreed by the Designating Party or ordered by the Court. Pages of

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1 transcribed deposition testimony or exhibits to depositions that reveal Protected 2 Material may be separately bound by the court reporter and may not be disclosed to 3 anyone except as permitted under this Stipulated Protective Order; and 4 9. any mediator or settlement officer, and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement discussions. 6 C. Protected Material Subpoenaed Or Ordered Produced In Other Litigation 7 If a Party is served with a subpoena or a court order issued in other litigation that 8 compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 1. promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 2. promptly notify in writing the party who caused the subpoena or 13 order to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification shall include a 15 copy of this Stipulated Protective Order; and 16 3. cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with the 19 subpoena or court order shall not produce any information designated in this action as 20 “CONFIDENTIAL” before a determination by the court from which the subpoena or 21 order issued, unless the Party has obtained the Designating Party’s permission. The 22 Designating Party shall bear the burden and expense of seeking protection in that court 23 of its confidential material and nothing in these provisions should be construed as 24 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 25 from another court. 26 /// 27 /// 28 ///

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1 IX. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED

IN THIS LITIGATION

2 3 A. The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 5 by Non-Parties in connection with this litigation is protected by the remedies and relief 6 provided by this Order. Nothing in these provisions should be construed as prohibiting 7 a Non-Party from seeking additional protections. 8 B. In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 1. promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 2. promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 3. make the information requested available for inspection by the Non- 19 Party, if requested. 20 C. If the Non-Party fails to seek a protective order from this Court within 21 fourteen (14) days of receiving the notice and accompanying information, the Receiving 22 Party may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not 24 produce any information in its possession or control that is subject to the confidentiality 25 agreement with the Non-Party before a determination by the Court. Absent a court order 26 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 27 in this Court of its Protected Material. 28 ///

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1 X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing 5 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (3) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (4) request 8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound 9 by Protective Order” that is attached hereto as Exhibit A. 10 XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

11 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the Court. 22 XIII. MISCELLANEOUS 23 A. Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 B. Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 //

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1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Protective Order. 3 C. Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the specific 6 Protected Material at issue; good cause must be shown in the request to file under seal. 7 If a Party’s request to file Protected Material under seal is denied by the Court, then the 8 Receiving Party may file the information in the public record unless otherwise 9 instructed by the Court. 10 XIV. INFORMATION SECURITY 11 A. Any person in possession of another party’s CONFIDENTIAL 12 information shall maintain a written information security program that includes 13 reasonable administrative, technical, and physical safeguards designed to protect the 14 security and confidentiality of such CONFIDENTIAL information, protect against any 15 reasonably anticipated threats or hazards to the security of such CONFIDENTIAL 16 information, and protect against unauthorized access to or use of such 17 CONFIDENTIAL information. 18 B. If the Receiving Party discovers a breach of security, including any actual 19 or suspected unauthorized access, relating to another party’s CONFIDENTIAL 20 information, the Receiving Party shall: 21 1. promptly provide written notice to Designating Party of such breach; 22 2. investigate and take reasonable efforts to remediate the effects of the 23 breach, and provide Designating Party with assurances reasonably satisfactory to 24 Designating Party that such breach shall not recur; and 25 3. provide sufficient information about the breach that the Designating Party 26 can reasonably ascertain the size and scope of the breach. If required by any judicial or 27 governmental request, requirement or order to disclose such information, the Receiving 28 Party shall take all reasonable steps to give the Designating Party sufficient prior notice

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1 in order to contest such request, requirement or order through legal means. The 2 Receiving Party agrees to cooperate with the Designating Party or law enforcement in 3 investigating any such security incident. In any event, the Receiving Party shall 4 promptly take all necessary and appropriate corrective action to terminate the 5 unauthorized access. 6 XV. FINAL DISPOSITION 7 After the final disposition of this Action, within sixty (60) days of a written 8 request by the Designating Party, each Receiving Party must return all Protected 9 Material to the Producing Party or destroy such material. As used in this subdivision, 10 “all Protected Material” includes all copies, abstracts, compilations, summaries, and 11 any other format reproducing or capturing any of the Protected Material. Whether the 12 Protected Material is returned or destroyed, the Receiving Party must submit a written 13 certification to the Producing Party (and, if not the same person or entity, to the 14 Designating Party) by the sixty (60) day deadline that (1) identifies (by category, where 15 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 16 that the Receiving Party has not retained any copies, abstracts, compilations, summaries 17 or any other format reproducing or capturing any of the Protected Material. 18 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 20 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 21 consultant and expert work product, even if such materials contain Protected Material. 22 Any such archival copies that contain or constitute Protected Material remain subject to 23 this Protective Order as set forth in Section V. above (DURATION). 24 Any violation of this Order may be punished by any and all appropriate measures 25 including, without limitation, contempt proceedings and/or monetary sanctions. 26 27 28

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1 Once executed by all parties, the Stipulated Protective Order shall be by treated 2 | by the parties as an Order of Court until it is formally approved by the Court. 4 | ITISSOSTIPULATED, THROUGH COUNSEL OF RECORD. 6 Dated: February 28, 2023

7 /s/ Melissa Velez Tanja Darrow 8 Melissa Velez Littler Mendelson, P.C. 9 Attorneys for Defendant 10 11 12 Dated: February 28, 2023 /s/ Sherry M. Gregorio 13 Avi Burkwitz 14 Sherry M. Gregorio Irene Yousefi Peterson, Bradford, Burkwitz, Gregorio, 15 Burkwitz & Su, LLP 16 Attomeys for Plaintiff

17 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 | DATED: March 3, 2023 ty mn fs is iain 30 HON. KAREN L. STEVENSON

CHIEF MAGISTRATE JUDGE

21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.cl| 4862-1693-6787.1 / 086761-1323 sce ee 15 STIPULATED PROTECTIVE

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1 EXHIBIT A

2

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

3

4 RENEE MAXWELL, Case No.: No. 2:22−cv−01803−FLA−KS

5 Plaintiff,

ACKNOWLEDGMENT AND

6 v. AGREEMENT TO BE BOUND BY

PROTECTIVE ORDER

7

AMERICAN AIRLINES, INC., AND

8

DOES 1-50, INCLUSIVE

9

10 Defendant. 11 12 The undersigned hereby acknowledges that he/she having read the Stipulated Protective Order 13 entered in the above-captioned action and attached hereto, understands the terms thereof, and agrees to be bound by its terms, ensuring that any employees and/or clerical assistants will also abide thereby. 14 The undersigned submits to the jurisdiction of this Court in matters relating to the Protective Order 15 and understands that the terms obligate him/her to use documents designated “CONFIDENTIAL” in 16 accordance with the Protective Order solely for the purposes of the above-captioned action, and not to 17 disclose any such documents or information derived directly therefrom to any other person, firm or 18 concern. 19 The undersigned acknowledges that violation of the Protective Order may result in penalties for contempt of court. 20

21 Entered into on this _________ day of ______________________, 2023. 22

23 Signature: ______________________________________ 24 Print Name: ______________________________________ 25 Address: ______________________________________ 26 27 ______________________________________ 28

LITTLER MENDELSON, P.C. 4862-1693-6787.1 / 086761-1323

Lo6 s3 A3 2n W 1g6 3e3e .lrs 4edt 4s 3F5 .tlC4ho 3A oS 0r t 09r e 0e 0t 7 1 16 STIPULATED PROTECTIVE

ORDER