1 5 Note Changes Made By The Court

3 A 5 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 GERARD GUEZ, an individual, Case No. 2:19-cv-08307-GW-JPR 11 Plaintiff, 12 VS. STIPULATION FOR ENTRY OF PROTECTIVE ORDER 13 RONNY KOBO, an individual; RONNY KOBO, INC., a New York 14 corporation: TORN BY RONNY KOBO, INC., a New York 15 corporation: and 6 DOES 1 through 10, inclusive, 17 Defendants 18 19 Plaintiff Gerard Guez (‘Plaintiff’) and defendant Ronny Kobo (“Kobo” or 20 “Defendant’) stipulate and hereby request the Court enter the Stipulated Protective 21 Order attached hereto Exhibit “‘A.” 22 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 25 DATED: August 24, 2020 BOWSE LAW GROUP, A.P.C. 26 By: /s/ Michael A. Bowse MICHAEL A. BOWSE 28 Attorneys for Plaintiff GERARD GUEZ

1 2 DATED: August 24, 2020 BUCHALTER 3 A Professional Corporation 4 By: /s/ Matthew L. Seror 5 MATTHEW L. SEROR AARON M. LEVINE 6 Attorneys for Defendant 7 RONNY KOBO 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 EXHIBIT A 16 17 18 19 20 21 22 23 24 25 26 27 1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 GERARD GUEZ, an individual, Case No. 2:19-cv-08307-GW-JPR 11 Plaintiff, 12 vs. STIPULATED PROTECTIVE ORDER 13 RONNY KOBO, an individual; RONNY KOBO, INC., a New York 14 corporation; TORN BY RONNY KOBO, INC., a New York 15 corporation; and DOES 1 through 10, inclusive, 16 17 Defendants 18 19 1. INTRODUCTION 20 1.1 PURPOSES AND LIMITATIONS 21 Discovery in this action may involve production of confidential, proprietary, 22 or private information for which special protection from public disclosure and from 23 use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the Parties hereby stipulate to and petition the Court to enter the 25 following Stipulated Protective Order. The Parties acknowledge that this Order 26 does not confer blanket protections on all disclosures or responses to discovery and 27 that the protection it affords from public disclosure and use extends only to the 1 limited information or items that are entitled to confidential treatment under the 2 applicable legal principles. The Parties further acknowledge, as set forth in Section 3 12.3 below, that this Order does not entitle them to file Confidential Information 4 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 5 and the standards that will be applied when a Party seeks permission from the Court 6 to file material under seal. 7 1.2 GOOD CAUSE STATEMENT 8 In or about May 2014, Plaintiff loaned Defendant Torn by Ronny Kobo, Inc. 9 $400,000 for use in connection with the operation of its apparel business. The loan 10 was evidenced by a promissory note. On or about June 13, 2014, Plaintiff made a 11 second loan to Defendant Torn by Ronny Kobo, Inc. in the amount of $500,000. 12 The second loan was also evidenced by a written promissory note. In this action, 13 Plaintiff seeks the recovery of the $197,113 allegedly remaining due to Plaintiff on 14 his loans. 15 Plaintiff also alleges that the defendants are alter-egos of each other, and 16 specifically, that Ronny Kobo (the individual) is the alter-ego of Defendants Torn 17 by Ronny Kobo, Inc. and of Ronny Kobo, Inc. Ronny Kobo denies that she is the 18 alter ego of either Torn by Ronny Kobo, Inc. or Ronny Kobo, Inc. 19 Plaintiff has propounded discovery requests to Ronny Kobo, and may 20 propound further discovery in the future. Other parties may propound discovery in 21 the future. Given the issues presented in this case, it is anticipated that the 22 information and documents sought in discovery by the parties will include: the 23 financial condition of the parties; financial documents, including balance sheets, 24 profit and loss statements, financial statements, ledgers, and related documents; 25 corporate documents of the defendants; documents evidencing defendants’ 26 borrowing activities; documents identifying shareholders, officers and directors of 27 the defendants; shareholder agreements; documents evidencing the manufacturer 1 || categories of information and documents might also be the subject of discovery 2 || requests in this case. 3 The documents referenced above, and the information contained therein, may 4 || be confidential and contain confidential and private information. This information 5 || may not be generally known to the public. The public disclosure of these 6 || documents could harm the defendants, their shareholders, officers and/or directors 7 || by making public the financial condition the defendants and their respective 8 || shareholders, officers, directors, or employees. In addition, the information sought 9 || is likely also to include Defendants’ customers, vendors, and other proprietary 10 || information with is also not generally known to the public. 11 |] 2. DEFINITIONS 12 2.1. Action: The above captioned action. 13 2.2 Challenging Party: a Party or Nonparty that challenges the designation 14 || of information or items under this Order. 15 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 16 || how it is generated, stored, or maintained) or tangible things that qualify for 17 || protection under Federal Rule of Civil Procedure 26(c) and as specified above in the 18 || Good Cause Statement. 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 20 || their support staff). 21 2.5 Designating Party: a Party or Nonparty that designates information or 22 || items that it produces in disclosures or in responses to discovery as 23 || “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless 25 || of the medium or manner in which it is generated, stored, or maintained (including, 26 || among other things, testimony, transcripts, and tangible things), that are produced or 27 || generated in disclosures or responses to discovery in this matter. 28

1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this action. 4 2.8 House Counsel: attorneys who are employees of a Party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Nonparty: any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a 10 Party to this Action but are retained to represent or advise a Party and have appeared 11 in this Action on behalf of that Party or are affiliated with a law firm that has 12 appeared on behalf of that Party, including support staff. 13 2.11 Party: any Party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Nonparty that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation 19 support services (for example, photocopying, videotaping, translating, preparing 20 exhibits or demonstrations, and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 27 3. SCOPE 1 The protections conferred by this Stipulation and Order cover not only 2 Protected Material (as defined above) but also any information copied or extracted 3 from Protected Material; all copies, excerpts, summaries, or compilations of 4 Protected Material; and any testimony, conversations, or presentations by Parties or 5 their Counsel that might reveal Protected Material. 6 Any use of Protected Material at trial will be governed by the orders of the 7 trial judge. This Order does not govern the use of Protected Material at trial. 8 4. DURATION 9 Once a case proceeds to trial, all the information that was designated as 10 confidential or maintained under this Order becomes public and will be 11 presumptively available to all members of the public, including the press, unless the 12 trial judge finds compelling reasons to proceed otherwise. See Kamakana v. City & 13 Cnty. of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good 14 cause” showing for sealing documents produced in discovery from “compelling 15 reasons” needed for merits-related documents). Accordingly, the terms of this 16 Order do not extend beyond the beginning of trial. 17 Even after final disposition of this litigation, the confidentiality obligations 18 imposed by this Order will remain in effect until a Designating Party agrees 19 otherwise in writing or a court order otherwise directs. Final disposition is the later 20 of (1) dismissal of all claims and defenses in this Action, with or without prejudice, 21 or (2) final judgment after the completion and exhaustion of all appeals, rehearings, 22 remands, trials, or reviews of this Action, including the time limits for filing any 23 motions or applications for extension of time under applicable law. 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Each Party or Nonparty that designates information or items for 26 protection under this Order must take care to limit any such designation to specific 27 material that qualifies under the appropriate standards. The Designating Party must 1 written communications that qualify so that other portions of the material, 2 documents, items, or communications for which protection is not warranted are not 3 swept unjustifiably within the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (for example, to unnecessarily encumber the case-development process or 7 to impose unnecessary expenses and burdens on other parties) may expose the 8 Designating Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items it 10 designated for protection do not qualify for that level of protection, that Designating 11 Party must promptly notify all other Parties that it is withdrawing the inapplicable 12 designation. 13 5.2 Except as otherwise provided in this Order, Disclosure or Discovery 14 Material that qualifies for protection under this Order must be clearly so designated 15 before the material is disclosed or produced. 16 Designation in conformity with this Order requires the following: 17 (a) for information in documentary form (for example, paper or electronic 18 documents but excluding transcripts of depositions or other pretrial or trial 19 proceedings), the Producing Party must affix at a minimum the legend 20 “CONFIDENTIAL” to each page that contains Protected Material. If only a portion 21 or portions of the material on a page qualify for protection, the Producing Party 22 must clearly identify the protected portion(s) (for example, by making appropriate 23 markings in the margins). 24 A Party or Nonparty that makes original documents available for 25 inspection need not designate them for protection until after the inspecting Party has 26 indicated which documents it would like copied and produced. During the 27 inspection and before the designation, all material made available for inspection 1 documents it wants copied and produced, the Producing Party must determine which 2 documents, or portions thereof, qualify for protection under this Order. Then, 3 before producing the specified documents, the Producing Party must affix the 4 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 5 portion or portions of the material on a page qualify for protection, the Producing 6 Party also must clearly identify the protected portion(s) (for example, by making 7 appropriate markings in the margins). 8 (b) for testimony given in depositions, the Designating Party must identify 9 the Disclosure or Discovery Material that is protected on the record, before the close 10 of the deposition. 11 (c) for information produced in some form other than documentary and for 12 any other tangible items, the Producing Party must affix in a prominent place on the 13 exterior of the container or containers in which the information is stored the legend 14 “CONFIDENTIAL.” If only a portion or portions of the information warrant 15 protection, the Producing Party, to the extent practicable, must identify the protected 16 portion(s). 17 5.3 If timely corrected, an inadvertent failure to designate qualified 18 information or items does not, standing alone, waive the Designating Party’s right to 19 secure protection under this Order for that material. On timely correction of a 20 designation, the Receiving Party must make reasonable efforts to assure that the 21 material is treated in accordance with the provisions of this Order. 22 23 24 25 26 27 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Any Party or Nonparty may challenge a designation of confidentiality 3 at any time consistent with the Court’s scheduling order. 4 6.2 The Challenging Party must initiate the dispute-resolution process (and, 5 if necessary, file a discovery motion) under Local Rule 37. 6 6.3 The burden of persuasion in any such proceeding is on the Designating 7 Party. Frivolous challenges, and those made for an improper purpose (for example, 8 to harass or impose unnecessary expenses and burdens on other parties), may expose 9 the Challenging Party to sanctions. Unless the Designating Party has waived or 10 withdrawn the confidentiality designation, all parties must continue to afford the 11 material in question the level of protection to which it is entitled under the 12 Producing Party’s designation until the Court rules on the challenge. 13 7. ACCESS TO AND USE OF PROTECTED MATERIAL 14 7.1 A Receiving Party may use Protected Material that is disclosed or 15 produced by another Party or by a Nonparty in connection with this Action only for 16 prosecuting, defending, or attempting to settle this Action. Such Protected Material 17 may be disclosed only to the categories of people and under the conditions described 18 in this Order. When the Action has been terminated, a Receiving Party must comply 19 with the provisions of Section 13 below (FINAL DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a manner sufficiently secure to ensure that access is limited to the 22 people authorized under this Order. 23 7.2 Unless otherwise ordered by the Court or permitted in writing by the 24 Designating Party, a Receiving Party may disclose any information or item 25 designated “CONFIDENTIAL” only to the following people: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 27 well as employees of that Outside Counsel of Record to whom it is reasonably 1 (b) the officers, directors, and employees (including House Counsel) of 2 the Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the Court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses and attorneys for witnesses to 14 whom disclosure is reasonably necessary, provided that the deposing party requests 15 that the witness sign the form attached as Exhibit A hereto and the witnesses will 16 not be permitted to keep any confidential information unless they sign the form, 17 unless otherwise agreed by the Designating Party or ordered by the Court. Pages of 18 transcribed deposition testimony or exhibits to depositions that reveal Protected 19 Material may be separately bound by the court reporter and may not be disclosed to 20 anyone except as permitted under this Order; and 21 (i) any mediator or settlement officer, and their supporting personnel, 22 mutually agreed on by any of the Parties engaged in settlement discussions or 23 appointed by the Court. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 25 IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 1 (a) promptly notify in writing the Designating Party. Such notification 2 must include a copy of the subpoena or court order unless prohibited by law; 3 (b) promptly notify in writing the party who caused the subpoena or order 4 to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification must include 6 a copy of this Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order should not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination on the protective-order request 12 by the relevant court unless the Party has obtained the Designating Party’s 13 permission. The Designating Party bears the burden and expense of seeking 14 protection of its Confidential Material, and nothing in these provisions should be 15 construed as authorizing or encouraging a Receiving Party in this Action to disobey 16 a lawful directive from another court. 17 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a 20 Nonparty in this Action and designated as “CONFIDENTIAL.” Such information is 21 protected by the remedies and relief provided by this Order. Nothing in these 22 provisions should be construed as prohibiting a Nonparty from seeking additional 23 protections. 24 (b) In the event that a Party is required by a valid discovery request to 25 produce a Nonparty’s Confidential Information in its possession and the Party is 26 subject to an agreement with the Nonparty not to produce the Nonparty’s 27 Confidential Information, then the Party must 1 (1) promptly notify in writing the Requesting Party and the Nonparty 2 that some or all of the information requested is subject to a confidentiality 3 agreement with a Nonparty; 4 (2) promptly provide the Nonparty with a copy of this Order, the 5 relevant discovery request(s), and a reasonably specific description of the 6 information requested; and 7 (3) make the information requested available for inspection by the 8 Nonparty, if requested. 9 (c) If the Nonparty fails to seek a protective order within 21 days of 10 receiving the notice and accompanying information, the Receiving Party may 11 produce the Nonparty’s Confidential Information responsive to the discovery 12 request. If the Nonparty timely seeks a protective order, the Receiving Party must 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Nonparty before a ruling on the protective-order 15 request. Absent a court order to the contrary, the Nonparty must bear the burden 16 and expense of seeking protection of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Order, the Receiving Party must immediately notify the Designating Party in writing 21 of the unauthorized disclosures, use its best efforts to retrieve all unauthorized 22 copies of the Protected Material, inform the person or people to whom unauthorized 23 disclosures were made of the terms of this Order, and ask that person or people to 24 execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto 25 as Exhibit A. 26 27 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). 7 12. MISCELLANEOUS 8 12.1 Nothing in this Order abridges the right of any person to seek its 9 modification by the Court. 10 12.2 By stipulating to the entry of this Order, no Party waives any right it 11 otherwise would have to object to disclosing or producing any information or item 12 on any ground not addressed in this Order. Similarly, no Party waives any right to 13 object on any ground to use in evidence of any of the material covered by this 14 Order. 15 12.3 A Party that seeks to file under seal any Protected Material must 16 comply with Civil Local Rule 79-5. Protected Material may be filed under seal only 17 pursuant to a court order authorizing the sealing of the specific Protected Material at 18 issue. If a Party's request to file Protected Material under seal is denied, then the 19 Receiving Party may file the information in the public record unless otherwise 20 instructed by the Court. 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 days of a written request by the Designating Party, each Receiving Party must return 24 all Protected Material to the Producing Party or destroy such material. As used in 25 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected 27 Material. Whether the Protected Material is returned or destroyed, the Receiving 1 || person or entity, to the Designating Party) by the 60-day deadline that identifies (by 2 || category, when appropriate) all the Protected Material that was returned or 3 || destroyed and affirms that the Receiving Party has not retained any copies, abstracts, 4 || compilations, summaries, or any other format reproducing or capturing any of the 5 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 6 || archival copy of all pleadings; motion papers; trial, deposition, and hearing 7 || transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert 8 || reports; attorney work product; and consultant and expert work product even if such 9 || materials contain Protected Material. Any such archival copies that contain or 10 || constitute Protected Material remain subject to this Order as set forth in Section 4 11 || (DURATION). 12 14. SANCTIONS 13 Any willful violation of this Order may be punished by civil or criminal 14 || contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or 15 || other appropriate action at the discretion of the Court. 16 17 18 DATED: September 17, 2020 19 py, fe bent 20 Honorable Jean P. Rosenbluth United States Magistrate Judge 22 23 24 25 26 27 28