| || MICHAEL J. JAURIGUE (SB# 208123)

LIANA M. KHACHATOURIAN (SB# 337126)

2 michael@jlglawyers.com 3, || liana@jlglawyers.com

JAURIGUE LAW GROUP

4 || 300 W. Glenoaks Blvd. Suite 300 Glendale, California 91202 5 || Telephone: 818-630-7280 6 Facsimile: 888-879-1697 7 || Attorneys for Plaintiff

MIGUEL MARIN

8

ELIZABETH A. BROWN (SB# 235429)

9 | JENNIFER SVANFELDT (SB# 233248)

CHRISTINA C.K. SEMMER (SB# 270909)

10] lisabrown@gbgllp.com 11 || jensvanfeldt@gbgllp.com christinasemmer@gbegllp.com 12 | GBG LLP B 633 West 5" Street, Suite 1500 Los Angeles, CA 90071 14 || Telephone: (213) 358-2810 Facsimile: (213) 995-6382 15 Attorneys for Defendant 16 | AT&T MOBILITY SERVICES LLC 17 13 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 5, | MIGUEL MARIN, Case No. 2:23-cv-03747-MWE-MAA Plaintiff, 22 FPROPOSED} STIPULATED 74 VS. PROTECTIVE ORDER 74 || AT&T MOBILITY SERVICES LLC and} Judge: Hon. Michael W. Fitzgerald Does | through 50, inclusive, Dept.: 5A, First Street Courthouse 25 Defendants. 26 27 28 Case No. 2:23-cv-03747-MWF-MAA [PROPOSED] STIPULATED

PROTECTIVE ORDER

1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this 7 Stipulated Protective Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. The parties further acknowledge, as 11 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a party 14 seeks permission from the Court to file material under seal. 15 2. GOOD CAUSE STATEMENT 16 This action is likely to involve the exchange of records and information 17 referencing or otherwise reflecting certain business practices, internal procedures, 18 sensitive internal investigations, customer and employee information, and other 19 valuable research, development, commercial, financial, technical and/or proprietary 20 information for which special protection from public disclosure and from use for any 21 purpose other than prosecution of this action is warranted. Such confidential and 22 proprietary materials and information consist of, among other things, confidential 23 business or financial information, information regarding confidential business 24 practices, or other confidential research, development, or commercial information 25 (including information implicating privacy rights of third parties), information 26 otherwise generally unavailable to the public, or which may be privileged or 27 otherwise protected from disclosure under state or federal statutes, court rules, case 28 decisions, or common law. Accordingly, to expedite the flow of information, to 1 facilitate the prompt resolution of disputes over confidentiality of discovery 2 materials, to adequately protect information the parties are entitled to keep 3 confidential, to ensure that the parties are permitted reasonable necessary uses of such 4 material in preparation for and in the conduct of trial, to address their handling at the 5 end of the litigation, and to serve the ends of justice, a protective order for such 6 information is justified in this matter. It is the intent of the parties that information 7 will not be designated as confidential for tactical reasons and that nothing be so 8 designated without a good faith belief that it has been maintained in a confidential, 9 non-public manner, and there is good cause why it should not be part of the public 10 record of this case. 11 3. DEFINITIONS 12 3.1. Action: Miguel Marin v. AT&T Mobility Services LLC and Does 1 13 through 50, inclusive (C.D. Cal. Case No. 2:23-cv-03747-MWF- 14 MAA). 15 3.2. Challenging Party: A Party or Nonparty that challenges the designation 16 of information or items under this Stipulated Protective Order. 17 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 18 how it is generated, stored or maintained) or tangible things that 19 qualify for protection under Federal Rule of Civil Procedure 26(c), and 20 as specified above in the Good Cause Statement. 21 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as 22 their support staff). 23 3.5. Designating Party: A Party or Nonparty that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 3.6. Disclosure or Discovery Material: All items or information, regardless 27 of the medium or manner in which it is generated, stored, or 28 maintained (including, among other things, testimony, transcripts, and 1 tangible things), that is produced or generated in disclosures or 2 responses to discovery in this matter. 3 3.7. Expert: A person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its 5 counsel to serve as an expert witness or as a consultant in this Action. 6 3.8. In-House Counsel: Attorneys who are employees of a party to this 7 Action. In-House Counsel does not include Outside Counsel of Record 8 or any other outside counsel. 9 3.9. Nonparty: Any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 3.10. Outside Counsel of Record: Attorneys who are not employees of a 12 party to this Action but are retained to represent or advise a party to 13 this Action and have appeared in this Action on behalf of that party or 14 are affiliated with a law firm which has appeared on behalf of that 15 party, and includes support staff. 16 3.11. Party: Any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, In-House Counsel, and 18 Outside Counsel of Record (and their support staffs). 19 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 20 Discovery Material in this Action. 21 3.13. Professional Vendors: Persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, 23 preparing exhibits or demonstrations, and organizing, storing, or 24 retrieving data in any form or medium) and their employees and 25 subcontractors. 26 3.14. Protected Material: Any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 3.15. Receiving Party: A Party that receives Disclosure or Discovery 1 Material from a Producing Party. 2 4. SCOPE 3 The protections conferred by this Stipulated Protective Order cover not only 4 Protected Material, but also (1) any information copied or extracted from Protected 5 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 6 and (3) any testimony, conversations, or presentations by Parties or their Counsel that 7 might reveal Protected Material. 8 Any use of Protected Material at trial shall be governed by the orders of the 9 trial judge. This Stipulated Protective Order does not govern the use of Protected 10 Material at trial. 11 5. DURATION 12 Once a case proceeds to trial, all of the information that was designated as 13 confidential or maintained pursuant to this Stipulated Protective Order becomes 14 public and presumptively will be available to all members of the public, including 15 the press, unless compelling reasons supported by specific factual findings to proceed 16 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City 17 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 18 “good cause” showing for sealing documents produced in discovery from 19 “compelling reasons” standard when merits-related documents are part of court 20 record). Accordingly, the terms of this Stipulated Protective Order do not extend 21 beyond the commencement of the trial. 22 6. DESIGNATING PROTECTED MATERIAL 23 6.1. Exercise of Restraint and Care in Designating Material for Protection. 24 Each Party or Nonparty that designates information or items for 25 protection under this Stipulated Protective Order must take care to limit 26 any such designation to specific material that qualifies under the 27 appropriate standards. The Designating Party must designate for 28 1 protection only those parts of material, documents, items, or oral or 2 written communications that qualify so that other portions of the 3 material, documents, items, or communications for which protection is 4 not warranted are not swept unjustifiably within the ambit of this 5 Stipulated Protective Order. 6 Mass, indiscriminate, or routinized designations are prohibited. 7 Designations that are shown to be clearly unjustified or that have been 8 made for an improper purpose (e.g., to unnecessarily encumber the case 9 development process or to impose unnecessary expenses and burdens 10 on other parties) may expose the Designating Party to sanctions. 11 6.2. Manner and Timing of Designations. 12 Except as otherwise provided in this Stipulated Protective Order 13 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 14 Disclosure or Discovery Material that qualifies for protection under this 15 Stipulated Protective Order must be clearly so designated before the 16 material is disclosed or produced. 17 Designation in conformity with this Stipulated Protective Order 18 requires the following: 19 (a) For information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other 21 pretrial or trial proceedings), that the Producing Party affix at a 22 minimum, the legend “CONFIDENTIAL” to each page that 23 contains protected material. If only a portion or portions of the 24 material on a page qualifies for protection, the Producing Party 25 also must clearly identify the protected portion(s) (e.g., by 26 making appropriate markings in the margins). 27 A Party or Nonparty that makes original documents 28 available for inspection need not designate them for protection 1 until after the inspecting Party has indicated which documents it 2 would like copied and produced. During the inspection and 3 before the designation, all of the material made available for 4 inspection shall be deemed “CONFIDENTIAL.” After the 5 inspecting Party has identified the documents it wants copied and 6 produced, the Producing Party must determine which documents, 7 or portions thereof, qualify for protection under this Stipulated 8 Protective Order. Then, before producing the specified 9 documents, the Producing Party must affix the legend 10 “CONFIDENTIAL” to each page that contains Protected 11 Material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly 13 identify the protected portion(s) (e.g., by making appropriate 14 markings in the margins). 15 (b) For testimony given in depositions, that the Designating Party 16 identify the Disclosure or Discovery Material on the record, 17 before the close of the deposition, all protected testimony. 18 (c) For information produced in nondocumentary form, and for any 19 other tangible items, that the Producing Party affix in a prominent 20 place on the exterior of the container or containers in which the 21 information is stored the legend “CONFIDENTIAL.” If only a 22 portion or portions of the information warrants protection, the 23 Producing Party, to the extent practicable, shall identify the 24 protected portion(s). 25 6.3. Inadvertent Failure to Designate. 26 If timely corrected, an inadvertent failure to designate qualified 27 information or items does not, standing alone, waive the Designating 28 Party’s right to secure protection under this Stipulated Protective Order 1 for such material. Upon timely correction of a designation, the 2 Receiving Party must make reasonable efforts to assure that the material 3 is treated in accordance with the provisions of this Stipulated Protective 4 Order. 5 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 7.1. Timing of Challenges. 7 Any Party or Nonparty may challenge a designation of confidentiality 8 at any time that is consistent with the Court’s Scheduling Order. 9 7.2. Meet and Confer. 10 The Challenging Party shall initiate the dispute resolution process, 11 which shall comply with Local Rule 37.1 et seq., and with Section 4 of Judge 12 Audero’s Procedures (“Mandatory Telephonic Conference for Discovery 13 Disputes”).1 14 7.3. Burden of Persuasion. 15 The burden of persuasion in any such challenge proceeding shall be on 16 the Designating Party. Frivolous challenges, and those made for an improper 17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 18 parties) may expose the Challenging Party to sanctions. Unless the 19 Designating Party has waived or withdrawn the confidentiality designation, all 20 parties shall continue to afford the material in question the level of protection 21 to which it is entitled under the Producing Party’s designation until the Court 22 rules on the challenge. 23 8. ACCESS TO AND USE OF PROTECTED MATERIALS 24 8.1. Basic Principles. 25 A Receiving Party may use Protected Material that is disclosed or 26 produced by another Party or by a Nonparty in connection with this Action 27 1 Judge Audero’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-maria-audero. 1 only for prosecuting, defending, or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and 3 under the conditions described in this Stipulated Protective Order. When the 4 Action reaches a final disposition, a Receiving Party must comply with the 5 provisions of Section 14 below. 6 Protected Material must be stored and maintained by a Receiving Party 7 at a location and in a secure manner that ensures that access is limited to the 8 persons authorized under this Stipulated Protective Order. 9 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 10 Unless otherwise ordered by the Court or permitted in writing by the 11 Designating Party, a Receiving Party may disclose any information or item 12 designated “CONFIDENTIAL” only to: 13 (a) The Receiving Party’s Outside Counsel of Record, as well as 14 employees of said Outside Counsel of Record to whom it is 15 reasonably necessary to disclose the information for this Action; 16 (b) The officers, directors, and employees (including In-House 17 Counsel) of the Receiving Party to whom disclosure is 18 reasonably necessary for this Action; 19 (c) Experts of the Receiving Party to whom disclosure is reasonably 20 necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (d) The Court and its personnel; 23 (e) Court reporters and their staff; 24 (f) Professional jury or trial consultants, mock jurors, and 25 Professional Vendors to whom disclosure is reasonably 26 necessary or this Action and who have signed the 27 “Acknowledgment and Agreement to be Bound” (Exhibit A); 28 (g) The author or recipient of a document containing the 1 information or a custodian or other person who otherwise 2 possessed or knew the information; 3 (h) During their depositions, witnesses, and attorneys for witnesses, 4 in the Action to whom disclosure is reasonably necessary 5 provided: (i) the deposing party requests that the witness sign 6 the “Acknowledgment and Agreement to Be Bound” (Exhibit 7 A); and (ii) the witness will not be permitted to keep any 8 confidential information unless they sign the “Acknowledgment 9 and Agreement to Be Bound,” unless otherwise agreed by the 10 Designating Party or ordered by the Court. Pages of transcribed 11 deposition testimony or exhibits to depositions that reveal 12 Protected Material may be separately bound by the court 13 reporter and may not be disclosed to anyone except as permitted 14 under this Stipulated Protective Order; and 15 (i) Any mediator or settlement officer, and their supporting 16 personnel, mutually agreed upon by any of the parties engaged 17 in settlement discussions. 18 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other litigation 20 that 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 26 by the subpoena or order is subject to this Stipulated Protective Order. 27 Such notification shall include a copy of this Stipulated Protective 28 1 Order; and 2 (c) Cooperate with respect to all reasonable procedures sought to be 3 pursued by the Designating Party whose Protected Material may be 4 affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order shall not produce any information designated in this 7 action as “CONFIDENTIAL” before a determination by the Court from which the 8 subpoena or order issued, unless the Party has obtained the Designating Party’s 9 permission. The Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these provisions 11 should be construed as authorizing or encouraging a Receiving Party in this Action 12 to disobey a lawful directive from another court. 13 10. 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE

PRODUCED IN THIS LITIGATION

14 10.1. Application. 15 The terms of this Stipulated Protective Order are applicable to 16 information produced by a Nonparty in this Action and designated as 17 “CONFIDENTIAL.” Such information produced by Nonparties in connection 18 with this litigation is protected by the remedies and relief provided by this 19 Stipulated Protective Order. Nothing in these provisions should be construed 20 as prohibiting a Nonparty from seeking additional protections. 21 10.2. Notification. 22 In the event that a Party is required, by a valid discovery request, to 23 produce a Nonparty’s confidential information in its possession, and the Party 24 is subject to an agreement with the Nonparty not to produce the Nonparty’s 25 confidential information, then the Party shall: 26 (a) Promptly notify in writing the Requesting Party and the 27 Nonparty that some or all of the information requested is subject 28 1 to a confidentiality agreement with a Nonparty; 2 (b) Promptly provide the Nonparty with a copy of the Stipulated 3 Protective Order in this Action, the relevant discovery 4 request(s), and a reasonably specific description of the 5 information requested; and 6 (c) Make the information requested available for inspection by the 7 Nonparty, if requested. 8 10.3. Conditions of Production. 9 If the Nonparty fails to seek a protective order from this Court within 10 fourteen (14) days after receiving the notice and accompanying information, 11 the Receiving Party may produce the Nonparty’s confidential information 12 responsive to the discovery request. If the Nonparty timely seeks a protective 13 order, the Receiving Party shall not produce any information in its possession 14 or control that is subject to the confidentiality agreement with the Nonparty 15 before a determination by the Court. Absent a court order to the contrary, the 16 Nonparty shall bear the burden and expense of seeking protection in this Court 17 of its Protected Material. 18 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 22 writing the Designating Party of the unauthorized disclosures, (2) use its best efforts 23 to retrieve all unauthorized copies of the Protected Material, (3) inform the person or 24 persons to whom unauthorized disclosures were made of all the terms of this 25 Stipulated Protective Order, and (4) request such person or persons to execute the 26 “Acknowledgment and Agreement to be Bound” (Exhibit A). 27 28 1 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

2 When a Producing Party gives notice to Receiving Parties that certain 3 inadvertently produced material is subject to a claim of privilege or other protection, 4 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 5 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 6 may be established in an e-discovery order that provides for production without prior 7 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 8 parties reach an agreement on the effect of disclosure of a communication or 9 information covered by the attorney-client privilege or work product protection, the 10 parties may incorporate their agreement in the Stipulated Protective Order submitted 11 to the Court. 12 13. MISCELLANEOUS 13 13.1. Right to Further Relief. 14 Nothing in this Stipulated Protective Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 13.2. Right to Assert Other Objections. 17 By stipulating to the entry of this Stipulated Protective Order, no Party 18 waives any right it otherwise would have to object to disclosing or producing 19 any information or item on any ground not addressed in this Stipulated 20 Protective Order. Similarly, no Party waives any right to object on any ground 21 to use in evidence of any of the material covered by this Stipulated Protective 22 Order. 23 13.3. Filing Protected Material. 24 A Party that seeks to file under seal any Protected Material must comply 25 with Local Rule 79-5. Protected Material may only be filed under seal pursuant 26 to a court order authorizing the sealing of the specific Protected Material at 27 issue. If a Party’s request to file Protected Material under seal is denied by the 28 1 Court, then the Receiving Party may file the information in the public record 2 unless otherwise instructed by the Court. 3 14. FINAL DISPOSITION 4 After the final disposition of this Action, within sixty (60) days of a written 5 request by the Designating Party, each Receiving Party must return all Protected 6 Material to the Producing Party or destroy such material. As used in this subdivision, 7 “all Protected Material” includes all copies, abstracts, compilations, summaries, and 8 any other format reproducing or capturing any of the Protected Material. Whether 9 the Protected Material is returned or destroyed, the Receiving Party must submit a 10 written certification to the Producing Party (and, if not the same person or entity, to 11 the Designating Party) by the 60-day deadline that (1) identifies (by category, where 12 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 13 that the Receiving Party has not retained any copies, abstracts, compilations, 14 summaries or any other format reproducing or capturing any of the Protected 15 Material. Notwithstanding this provision, Counsel is entitled to retain an archival 16 copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal 17 memoranda; correspondence; deposition and trial exhibits; expert reports; attorney 18 work product; and consultant and expert work product, even if such materials contain 19 Protected Material. Any such archival copies that contain or constitute Protected 20 Material remain subject to this Stipulated Protective Order as set forth in Section 5. 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 1 | 15. VIOLATION 2 Any violation of this Stipulated Order may be punished by any and all 3 || appropriate measures including, without limitation, contempt proceedings and/or 4 || monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 g | DATED: _ August 18, 2023 JAURIGUE LAW GROUP 9 10 By: Leena Khachatowern ll Michael J. Jaurigue Liana M. Khachatourian 12 B Attorneys for Plaintiff

MIGUEL MARIN

14 | DATED: August 18, 2023 GBG LLP 16 17 By: /s/ Christina C.K. Semmer 18 CHRISTINA C.K. SEMMER 19 Attorneys for Defendant 20 AT&T MOBILITY SERVICES LLC 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 || DATED: August 24, 2023 25 26 Liaticoea Denafii Patricia Donahue Merra-A--Aayr-ergy 27 United States Magistrate Judge 28 Case No. 2:23-cv-03747-MWF-MAA -14- [PROPOSED] STIPULATED

PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, __________________________ [full name], of 4 _____________________________ [address], declare under penalty of perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 __________________ [date] in the case of Miguel Marin v. AT&T Mobility 8 Services LLC et al., C.D. Cal. Case No. 2:23-cv-03747-MWF-MAA. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order, 10 and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Stipulated Protective Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint _______________________[full name] 19 of _______________________________________[address and telephone number] 20 as my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 Signature: _____________________________ 23 Printed Name: _____________________________ 24 Date: _____________________________ 25 City and State Where Sworn and Signed: _____________________________ 26 27 28