1 || John P. Kristensen (SBN 224132) Jesenia A. Martinez (SBN 316969) Jacob J. Ventura (SBN 315491) 3 || KRISTENSEN LLP A 12540 Beatrice Street, Suite 200 Los Angeles, California 90066 5 Telephone: 310-507-7924 6 || Fax: 310-507-7906 [email protected] 7 || [email protected] g || [email protected] 9 | Attorneys for Plaintiffs 10 THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA — EASTERN DIVISION |2 12 |< 13 KATRINA HARRIS, an individual, ) Case No.: 5:19-cv-02184-JGB-SP ) COLLECTIVE ACTION + 14 Plaintiff, ) = 15 VS. ) STIPULATED PROTECTIVE | © ) ORDER > 16 || 68-444 PEREZ, INC. dba ) SHOWGIRLS, a California ) | corporation; ABDUL WAHAB ) — 18 | SHAWKAT, an individual; DOE ) 1g | MANAGERS 1-3; and DOES 4-_) 100, inclusive, ) 20 ) Defendants. ) ) 22 ) ) 23 ) 24 ) ) 25 ) 26 ) ) 27

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1 Discovery in this action is likely to involve production of confidential, 2 || proprietary, or private information for which special protection from public 3 || disclosure and from use for any purpose other than prosecuting this litigation 4 || may be warranted. Accordingly, the parties hereby stipulate to and petition the 5 || Court to enter the following Stipulated Protective Order. The parties 6 || acknowledge that this Order does not confer blanket protections on all 7 || disclosures or responses to discovery and that the protection it affords from 8 || public disclosure and use extends only to the limited information or items that 9 || are entitled to confidential treatment under the applicable legal principles. The a 10 || parties further acknowledge that this Stipulated Protective Order does not 11. || entitle them to file confidential information under seal; Civil Local Rule 79-5 2 12 || sets forth the procedures that must be followed and the standards that will be 13 || applied when a party seeks permission from the court to file material under 14 || seal. 15 B. GOOD CAUSE STATEMENT > 16 This action is likely to involve private information of third parties, = 17 || including exotic dancers and employees of Defendant adult entertainment 18 || establishment. The parties acknowledge that highly sensitive and personal “19 | details about Plaintiffs will be exchanged in this action because: (1) there is a 20 || significant social stigma associated with nude and semi-nude dancing that 21 || exotic dancers, also known as “strippers” perform; (2) there are risks inherent 22 || in working as an exotic dancer including risk of injury by current or former 23 || customers of Defendants if an exotic dancer’s name or address is disclosed; (3) 24 || dancers will likely want to protect their rights to privacy, which are reasonable 25 || and justified. 26 This dispute will also likely involve as confidential financial records of 27 || Defendants and their employees. Such confidential and proprietary materials 28 || and information consist of, among other things, the identities, addresses, phone

1 || numbers, email addresses, of exotic dancers, confidential business or financial 2 || information including wage and hour information protected from public 3 || disclosure under California’s right to privacy, information regarding 4 || confidential business practices otherwise generally unavailable to the public 5 || and competitors of Defendant, or which may be privileged or otherwise 6 || protected from disclosure under state or federal statutes, court rules, case 7 || decisions, or common law. 8 Accordingly, to expedite the flow of information, to facilitate the prompt 9 || resolution of disputes over confidentiality of discovery materials, to adequately a 10 || protect information the parties are entitled to keep confidential, to ensure that 11 || the parties are permitted reasonable necessary uses of such material in 2 12 || preparation for and in the conduct of trial, to address their handling at the end 13 || of the litigation, and serve the ends of justice, a protective order for such 14 || information is justified in this matter. It is the intent of the parties that 15 || information will not be designated as confidential for tactical reasons and that > 16 || nothing be so designated without a good faith belief that it has been maintained = 17 || inaconfidential, non-public manner, and there is good cause why it should not 18 || be part of the public record of this case. “19 DEFINITIONS 0 Action: Harris, et al. vs. 68-444 Perez, Inc. dba Showgirls, a California 1 Corporation, et al. (CASE NO. 5:19-cv-02184-JGB-SP).

22 Challenging Party: a Party or Non-Party that challenges the designation 23 || of information or items under this Order. 24 “CONFIDENTIAL” Information or Items: information (regardless of 25 || how it is generated, stored or maintained) or tangible things that qualify for 26 || protection under Federal Rule of Civil Procedure 26(c), and as specified above 27 || in the Good Cause Statement. 28 Counsel: Outside Counsel of Record and House Counsel (as well as

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

1 || demonstrations, and organizing, storing, or retrieving data in any form or 2 || medium) and their employees and subcontractors. 3 Protected Material: any Disclosure or Discovery Material that is 4 || designated as “CONFIDENTIAL.” 5 Receiving Party: a Party that receives Disclosure or Discovery Material 6 || from a Producing Party. 7 SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 || Protected Material (as defined above), but also (1) any information copied or a te, 10 extracted from Protected Material; (2) all copies, excerpts, summaries, or 11 || compilations of Protected Material; and (3) any testimony, conversations, or 2 12 || presentations by Parties or their Counsel that might reveal Protected Material. |= 13 Any use of Protected Material at trial shall be governed by the orders of 14 || the trial judge. This Order does not govern the use of Protected Material at 15 || trial, 16 DURATION = 17 Once a case proceeds to trial, all of the information that was designated 18 || as confidential or maintained pursuant to this protective order and offered into “19 || evidence or referenced therein becomes public and will be presumptively 20 || available to all members of the public, including the press, unless compelling 21 || reasons supported by specific factual findings to proceed otherwise are made to 22 || the trial judge in advance of the trial, including the identities of Defendants’ 23 || exotic dancers and other employees and Defendants’ financial information. See 24 || Kamakana v. City and County of Honolulu,

(9th Cir. 25 || 2006) (distinguishing “good cause” showing for sealing documents produced 26 || in discovery from “compelling reasons” standard when merits-related 27 || documents are part of court record). Accordingly, the terms of this protective 28 || order do not extend beyond the commencement of the trial to the extent noted.

1 Even after final disposition of this litigation, the confidentiality 2 || obligations imposed by this Order shall remain in effect until a Designating 3 || Party agrees otherwise in writing or a court order otherwise directs. Final 4 || disposition shall be deemed to be the later of (1) dismissal of all claims and 5 || defenses in this Action, with or without prejudice; and (2) final judgment 6 || herein after the completion and exhaustion of all appeals, rehearings, remands, 7 || trials, or reviews of this Action, including the time limits for filing any motions 8 || or applications for extension of time pursuant to applicable law. 9 DESIGNATING PROTECTED MATERIAL a te, 10 Exercise of Restraint and Care in Designating Material for 11 || Protection. Each Party or Non-Party that designates information or items for 2 12 || protection under this Order must take care to limit any such designation to 13 || specific material that qualifies under the appropriate standards. The 14 || Designating Party must designate for protection only those parts of material, 15 || documents, items, or oral or written communications that qualify so that other > 16 || portions of the material, documents, items, or communications for which = 17 || protection is not warranted are not swept unjustifiably within the ambit of this 18 | Order. “19 Mass, indiscriminate, or routinized designations are prohibited. 20 || Designations that are shown to be clearly unjustified or that have been made 21 || for an improper purpose (e.g., to unnecessarily encumber the case development 22 || process or to impose unnecessary expenses and burdens on other parties) may 23 || expose the Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items 25 || that it designated for protection do not qualify for protection, that Designating 26 || Party must promptly notify all other Parties that it is withdrawing the 27 || inapplicable designation. 28 ///

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

1 For information produced in some form other than documentary and for 2 || any other tangible items, that the Producing Party affix in a prominent place on 3 || the exterior of the container or containers in which the information is stored the 4 || legend “CONFIDENTIAL.” If only a portion or portions of the information 5 || warrants protection, the Producing Party, to the extent practicable, shall 6 || identify the protected portion(s). 7 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 || failure to designate qualified information or items does not, standing alone, 9 || waive the Designating Party’s right to secure protection under this Order for a to 10 || such material. Upon timely correction of a designation, the Receiving Party 11 || must make reasonable efforts to assure that the material is treated in 2 12 || accordance with the provisions of this Order. 13 CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 Timing of Challenges. Any Party or Non-Party may challenge a 15 || designation of confidentiality at any time that is consistent with the Court’s > 16 || Scheduling Order. = 17 Meet and Confer. The Challenging Party shall initiate the dispute 18 || resolution process under Local Rule 37.1 et seq. “19 The burden of persuasion in any such challenge proceeding shall be on 20 || the Designating Party. Frivolous challenges, and those made for an improper 21 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 || parties) may expose the Challenging Party to sanctions. Unless the Designating 23 || Party has waived or withdrawn the confidentiality designation, all parties shall 24 || continue to afford the material in question the level of protection to which it is 25 || entitled under the Producing Party’s designation until the Court rules on the 26 || challenge. 27 | /// 28 | ///

1 ACCESS TO AND USE OF PROTECTED MATERIAL 2 Basic Principles. A Receiving Party may use Protected Material that is 3 || disclosed or produced by another Party or by a Non-Party in connection with 4 || this Action only for prosecuting, defending, or attempting to settle this Action. 5 || Such Protected Material may be disclosed only to the categories of persons and 6 || under the conditions described in this Order. When the Action has been 7 || terminated, a Receiving Party must comply with the provisions of the section 8 || below denominated (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party a 10 || at a location and in a secure manner that ensures that access 1s limited to the 11 || persons authorized under this Order. 2 12 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 || otherwise ordered by the court or permitted in writing by the Designating 14 || Party, a Receiving Party may disclose any information or item designated 15 || “CONFIDENTIAL” only to: > 16 The Receiving Party’s Outside Counsel of Record in this Action, as well = 17 || as employees of said Outside Counsel of Record to whom it is reasonably 18 || necessary to disclose the information for this Action; “19 The officers, directors, and employees (including House Counsel) of the 20 || Receiving Party to whom disclosure is reasonably necessary for this Action; 21 Experts (as defined in this Order) of the Receiving Party to whom 22 || disclosure is reasonably necessary for this Action and who have signed the 23 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 94 The court and its personnel; 25 Court reporters and their staff; 26 professional jury or trial consultants, mock jurors, and Professional 27 || Vendors to whom disclosure is reasonably necessary for this Action and who 28 || have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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

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

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

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

1 || affirms that the Receiving Party has not retained any copies, abstracts, 2 || compilations, summaries or any other format reproducing or capturing any of 3 || the Protected Material. Notwithstanding this provision, Counsel are entitled to 4 || retain an archival copy of all pleadings, motion papers, trial, deposition, and 5 || hearing transcripts, legal memoranda, correspondence, deposition and trial 6 || exhibits, expert reports, attorney work product, and consultant and expert work 7 || product, even if such materials contain Protected Material. Any such archival 8 || copies that contain or constitute Protected Material remain subject to this || Protective Order as set forth in the section denominated (DURATION). a te, 10 Any violation of this Order may be punished by any and all appropriate 11 || measures including, without limitation, contempt proceedings and/or monetary JR |2 12 | sanctions. 13 44 | Dated: June 11, 2020 KRISTENSEN LLP

15 /s/ John P. Kristensen 16 John P. Kristensen Jesenia A. Martinez 17 Jacob J. Ventura 18 Attorneys for Plaintiff

“19 20 Dated: June 11, 2020 SHAPERO & SHAPERO 21 22 /s/ Steven J. Shapero Steven J. Shapero 23 Attorneys for Defendants 24 25 IT ISSO ORDERED. 26 | Dated: June 23, 2020 27 Honorable Sheri Pym 28 United States Magistrate Judge

1 Hon. Jesus G. Bernal 2 United States District/Magistrate Judge Sheri Pym 3 4 EXHIBIT A 5 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 6 7 I, , declare under penalty of perjury that I have read in its 8 || entirety and understand the Stipulated Protective Order that was issued by the 9 || United States District Court for the Central District of California in the case of a te, 10 Katrina Harris, et al. vs. 68-444 PEREZ, INC. dba Showgirls, a California 11 || corporation; Abdul Wahab Shawkat, an individual; DOE MANAGERS 1-3; 2 12 || and DOES 4-100, inclusive; Case No.: 5:19-cv-02184-JGB-SP. I agree to 13 || comply with and to be bound by all the terms of this Stipulated Protective 14 || Order and I understand and acknowledge that failure to so comply could 15 || expose me to sanctions and punishment in the nature of contempt. I solemnly > 16 || promise that I will not disclose in any manner any information or item that is = 17 || subject to this Stipulated Protective Order to any person or entity except in 18 || strict compliance with the provisions of this Order. “19 I further agree to submit to the jurisdiction of the United States District 20 || Court for the Central District of California for the purpose of enforcing the 21 || terms of this Stipulated Protective Order, even if such enforcement 22 || proceedings occur after termination of this action. 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 Signature: 27 28

1 LOCAL RULES-4.3.4(a)(2)() CERTIFICATION 2 The undersigned attests that all other signatories listed above on whose 3 || behalf this filing is submitted concur in the filing’s content and have authorized 4 || the filing. 5 6 7 LS/ John P. Kristensen John P. Kristensen 8 9 a 10

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