1||SAWYER & LABAR LLP IVO LABAR, State Bar No. 203492 labar@sawyerlabar.com ADRIAN SAWYER State Bar No. 203712 3 5 pwyer@ sawyerlabar, com ission Street, 22"° Floor || San Francisco, California 94105 NOTE: CHANGES MADE BY THE COURT Telephone: 415.262.3820 5 Attorneys for Defendants 6 MENASHA PACKAGING COMPANY, LLC and MENASHA CORPORATION 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 10 11 |} LEONARD ENRIQUEZ, on behalf of Case No. 2:19-cv-8104-DSF (JPRx) himself and all others similarly situated, 12 STIPULATED PROTECTIVE Plaintiffs, ORDER 1 Vv. 14

MENASHA PACKAGING

COMPANY, LLC, a Wisconsin limited lability company. MENASHA CORPORATION, a Wisconsin 8 corporation; and DOES | through 100, 17 || inclusive, 18 Defendants. 19 20 21 22 23 24 25 26 27 28

1 1. A. 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 5 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 || enter the following Stipulated Protective Order. The parties acknowledge that this 7 || Order does not confer blanket protections on all disclosures or responses to 8 || discovery and that the protection it affords from public disclosure and use extends 9 || only to the limited information or items that are entitled to confidential treatment 10 |) under the applicable legal principles. The parties further acknowledge, as set forth in 11 ||Section 12.3, below, that this Stipulated Protective Order does not entitle them to 12 || file confidential information under seal; Civil Local Rule 79-5 sets forth the 3. 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.

B. GOOD CAUSE STATEMENT

ge 16 As a putative employment class action, this action is likely to involve 17 || confidential information regarding personnel and their compensation and 18 || confidential business information regarding operations at defendants’ facilities in 19 || California. Special protection of this information from public disclosure and from 20 || use for any purpose other than prosecution of this action is warranted, both to 21 || protect individuals’ rights to privacy and to protect Defendants’ interest in the 22 || confidentiality of certain aspects of their business operations, including but not 23 || limited to staffing, output, operations and logistics, and strategy employed at their 24 || facilities, which information would be of interest to Defendant’s competitors. 25 || Accordingly, to expedite the flow of information, to facilitate the prompt resolution 26 || of disputes over confidentiality of discovery materials, to adequately protect 27 || information the parties are entitled to keep confidential, to ensure that the parties are 28 || permitted reasonable necessary uses of such material in preparation for and in the

1 || conduct of trial, to address their handling at the end of the litigation, and serve the 2 || ends of justice, a protective order for such information 1s justified in this matter. It is 3 || the intent of the parties that information will not be designated as confidential for 4 || tactical reasons and that nothing be so designated without a good faith belief that it 5 || has been maintained in a confidential, non-public manner, and there is good cause 6 || why it should not be part of the public record of this case. 7|/2. DEFINITIONS 8 2.1 Action: this pending federal law suit. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 || of information or items under this Order. 11 2.3. CONFIDENTIAL” Information or Items: information (regardless of 12 || how it is generated, stored or maintained) or tangible things that qualify for 3 as 13 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 || the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 || items that 1t produces in disclosures or in responses to discovery as 19 || “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless 21 || of the medium or manner in which it is generated, stored, or maintained (including, 22 ||among other things, testimony, transcripts, and tangible things), that are produced or 23 || generated in disclosures or responses to discovery in this matter. 24 2.7. Expert: a person with specialized knowledge or experience in a matter 25 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 || an expert witness or as a consultant in this Action. 27 28

l 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 || House Counsel does not include Outside Counsel of Record or any other outside 3 || counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 || other legal entity not named as a Party to this action. 6 2.10 Qutside Counsel of Record: attorneys who are not employees ofa 7 || party to this Action but are retained to represent or advise a party to this Action and 8 || have appeared in this Action on behalf of that party or are affiliated with a law firm 9 || which has appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 ||employees, consultants, retained experts, and Outside Counsel of Record (and their 12 || support staffs). 3. 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 || Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support ge 16 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 || and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 || designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 || from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 || Protected Material (as defined above), but also(1) any information copied or 26 || Extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 || compilations of Protected Material; and (3) any testimony, conversations, or 28 || presentations by Parties or their Counsel that might reveal Protected Material.

l Any use of Protected Material at trial shall be governed by the orders of the 2 || trial judge. This Order does not govern the use of Protected Material at trial. 31/4. DURATION 4 Even after final disposition of this litigation, the confidentiality obligations 5 ||imposed by this Order shall remain in effect until a Designating Party agrees 6 || otherwise in writing or a court order otherwise directs. Final disposition shall be 7 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 8 || or without prejudice; and (2) final judgment herein after the completion and 9 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 10 || including the time limits for filing any motions or applications for extension of time 11 || pursuant to applicable law. 12]|5. DESIGNATING PROTECTED MATERIAL 3 1 5.1 Each Party or Nonparty that designates information or items for 14 || protection under this Order must take care to limit any such designation to specific 15 || material that qualifies under the appropriate standards. The Designating Party must ge 16 || designate for protection only those parts of material, documents, items, or oral or 17 || written communications that qualify so that other portions of the material, 18 || documents, items, or communications for which protection is not warranted are not 19 ||swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations 21 || that are shown to be clearly unjustified or that have been made for an improper 22 || purpose (for example, to unnecessarily encumber the case-development process or 23 || to impose unnecessary expenses and burdens on other parties) may expose the 24 || Designating Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items it 26 || designated for protection do not qualify for that level of protection, that Designating 27 || Party must promptly notify all other Parties that it is withdrawing the inapplicable 28 || designation.

l 5.2. Except as otherwise provided in this Order, Disclosure or Discovery 2 || Material that qualifies for protection under this Order must be clearly so designated 3 || before the material is disclosed or produced. 4 Designation in conformity with this Order requires the following: 5 (a) for information in documentary form (for example, paper or electronic 6 || documents but excluding transcripts of depositions or other pretrial or trial 7 || proceedings), the Producing Party must affix at a minimum the legend 8 || “CONFIDENTIAL” to each page that contains Protected Material. If only a portion 9 || or portions of the material on a page qualify for protection, the Producing Party 10 || must clearly identify the protected portion(s) (for example, by making appropriate 11 || markings in the margins). 12 A Party or Nonparty that makes original documents available for inspection 3. 13]/need not designate them for protection until after the inspecting Party has indicated 14 || which documents it would like copied and produced. During the inspection and 15 || before the designation, all material made available for inspection must be treated as 16 “CONFIDENTIAL.” After the inspecting Party has identified the documents it 17 || wants copied and produced, the Producing Party must determine which documents, 18 || or portions thereof, qualify for protection under this Order. Then, before producing 19 || the specified documents, the Producing Party must affix the “CONFIDENTIAL” 20 || legend to each page that contains Protected Material. If only a portion or portions of 21 material on a page qualify for protection, the Producing Party also must clearly 22 ||identify the protected portion(s) (for example, by making appropriate markings in 23 || the margins). 24 (b) for testimony given in depositions, the Designating Party must identify 25 || the Disclosure or Discovery Material that is protected on the record, before the close 26 || of the deposition. 27 (c) for information produced in some form other than documentary and for 28 || any other tangible items, the Producing Party must affix in a prominent place on the

1 || exterior of the container or containers in which the information is stored the legend 2 || “CONFIDENTIAL.” If only a portion or portions of the information warrant 3 || protection, the Producing Party, to the extent practicable, must identify the protected 4 || portion(s). 5 5.3 If timely corrected, an inadvertent failure to designate qualified 6 || information or items does not, standing alone, waive the Designating Party’s right to 7 || secure protection under this Order for that material. On timely correction of a 8 || designation, the Receiving Party must make reasonable efforts to assure that the 9 || material 1s treated in accordance with the provisions of this Order. 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Any Party or Nonparty may challenge a designation of confidentiality 12 || at any time consistent with the Court’s scheduling order. 3. 6.2 The Challenging Party must initiate the dispute-resolution process (and, 14 ||if necessary, file a discovery motion) under Local Rule 37. 15 6.3. The burden of persuasion in any such proceeding is on the Designating 16 || Party. Frivolous challenges, and those made for an improper purpose (for example, 17 || to harass or impose unnecessary expenses and burdens on other parties), may expose 18 || the Challenging Party to sanctions. Unless the Designating Party has waived or 19 || withdrawn the confidentiality designation, all parties must continue to afford the 20 || material in question the level of protection to which it is entitled under the 21 || Producing Party’s designation until the Court rules on the challenge. 22||7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1. A Receiving Party may use Protected Material that is disclosed or 24 || produced by another Party or by a Nonparty in connection with this Action only for 25 || prosecuting, defending, or attempting to settle this Action, including presenting 26 || evidence for class certification purposes. Such Protected Material may be disclosed 27 || only to the categories of people and under the conditions described in this Order. 28

l When the Action has been terminated, a Receiving Party must comply with 2 ||the provisions of Section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 || location and in a manner sufficiently secure to ensure that access is limited to the 5 || people authorized under this Order. 6 7.2. Unless otherwise ordered by the Court or permitted in writing by the 7 || Designating Party, a Receiving Party may disclose any information or item 8 || designated “CONFIDENTIAL” only to the following people: 9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 10 |] as employees of that Outside Counsel of Record to whom it is reasonably necessary 11 || to disclose the information for this Action; 12 (b) the officers, directors, and employees (including House Counsel) of the 3. 13]/Receiving Party to whom disclosure is reasonably necessary for this Action; 14 (c) Experts or consultants (as defined in this Order) of the Receiving Party to 15 || whom disclosure is reasonably necessary for this Action and who have signed the 16 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (d) the Court and its personnel; 18 (e) court reporters and their staff; 19 (f) professional jury or trial consultants, mock jurors, and Professional 20 || Vendors to whom disclosure is reasonably necessary for this Action and who have 21 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (g) the author or recipient of a document containing the information or a 23 || custodian or other person who otherwise possessed or knew the information; 24 (h) during their depositions, witnesses and attorneys for witnesses to whom 25 || disclosure is reasonably necessary, provided that the deposing party requests that the 26 || witness sign the form attached as Exhibit A hereto and the witnesses will not be 27 || permitted to keep any confidential information unless they sign the form, unless 28 || otherwise agreed by the Designating Party or ordered by the Court. Pages of

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 Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 || mutually agreed on by any of the Parties engaged in settlement discussions or 6 || appointed by the Court. 7 7.3. Notwithstanding any other provisions herein, the parties recognize that 8 || the contact information and employment records for some or all putative class 9 || members may be produced at some point during the pendency of this litigation 10 || pursuant to the procedure adopted in Belaire-West Landscape, Inc. v. Superior 11 || Court, 149 Cal. App. 4th 554 (2007). None of the contact information or 12 |}employment records of putative class members shall be used for any purpose outside 3. , 13]/of this Litigation, and will not be disseminated to any third party under any 14 || circumstances outside of this Litigation. 15 |/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED ge 16 || IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 || that compels disclosure of any information or items designated in this Action as 19 || “CONFIDENTIAL,” that Party must 20 (a) promptly notify in writing the Designating Party. Such notification must 21 || include a copy of the subpoena or court order unless prohibited by law; 22 (b) promptly notify in writing the party who caused the subpoena or order to 23 issue in the other litigation that some or all of the material covered by the subpoena 24 || or order is subject to this Protective Order. Such notification must include a copy of 25 || this Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued 27 || by the Designating Party whose Protected Material may be affected. 28 If the Designating Party timely seeks a protective order, the Party served with

1 || the subpoena or court order should not produce any information designated in this 2 || action as “CONFIDENTIAL” before a determination on the protective-order request 3 || by the relevant court unless the Party has obtained the Designating Party’s 4|| permission. The Designating Party bears the burden and expense of seeking 5 || protection of its Confidential Material, and nothing in these provisions should be 6 || construed as authorizing or encouraging a Receiving Party in this Action to disobey 7 \|a lawful directive from another court. 8119. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9 || PRODUCED IN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced by a Non- 11 || Party in this Action and designated as “CONFIDENTIAL.” Such information 12 || produced by Non-Parties in connection with this litigation is protected by the 3. , 13]/remedies and relief provided by this Order. Nothing in these provisions should be 14 || construed as prohibiting a Non-Party from seeking additional protections. 15 (b) In the event that a Party is required, by a valid discovery request, to 16 || produce a Non-Party’s confidential information in its possession, and the Party is 17 || subject to an agreement with the Non-Party not to produce the Non-Party’s 18 || confidential information, then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the Non-Party 20 || that some or all of the information requested is subject to a confidentiality 21 ||agreement with a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the Stipulated 23 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 24 || specific description of the information requested; and 25 (3) make the information requested available for inspection by the Non- 26 || Party, if requested. 27 (c) If the Non-Party fails to seek a protective order from this court within 21 28 || days of receiving the notice and accompanying information, the Receiving Party nh

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

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

1 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 2 ||reports, attorney work product, and consultant and expert work product, even if such 3 || materials contain Protected Material. Any such archival copies that contain or 4 || constitute Protected Material remain subject to this Protective Order as set forth in 5 || Section 4 (DURATION). 6||14. Any violation of this Order may be punished by any and all appropriate 7 || measures including, without limitation, contempt proceedings and/or monetary 8 || sanctions. 9 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 DATED: August 25, 2020 SAWYER & LABAR LLP

1B by. y: /s/ Adrian Sawyer Adrian Sawyer Bed: 16 Attorneys for Defendants

MENASHA PACKAGING COMPANY,

17 LLC and MENASHA CORPORATION DATED: August 25, 2020 THE NOURMAND LAW FIRM, APC 19 20 21 By: /s/ James A. De Sario Michael Nourmand, Esq. James A. De Sario, Esq. 23 Attorneys for Plaintiff

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25 761! Dated: August 27, 2020 fe hrenhlade~ 27 Hon. Jean P. Rosenbluth 28 United States Magistrate Judge 19

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of [print or type full address], 5 || declare under penalty of perjury that I have read in its entirety and understand the 6 |! Stipulated Protective Order (“Protective Order”) that was issued by the United 7 \| States District Court for the Central District of California on [date] in 8 || the case of Enriquez v. Menasha Packaging Company, LLC, et al., Case No. 2:19- 9 || cv-8104-DSF (JPRx). I agree to comply with and to be bound by all the terms of 10 || this Protective Order and I understand and acknowledge that failure to so comply 11 || could expose me to sanctions and punishment in the nature of contempt. I solemnly 12 || promise that I will not disclose in any manner any information or item that is subject 3 13 || to this Protective Order to any person or entity except in strict compliance with the : 14 |! provisions of this Order. 15 I further agree to submit to the jurisdiction of United States District Court for the Central District of California for the purpose of enforcing the terms of this 17 || Protective Order, even if such enforcement proceedings occur after termination of 18 || this action. 19 20 Date: 21 22 City and State where sworn and signed: 23 24 Printed name: 25 26 Signature: 27 28 14