1 GREENBERG TRAURIG, LLP 2 Karin L. Bohmholdt (SBN 234929) [email protected] 3 Blakeley S. Oranburg (SBN 309732) 4 [email protected] 1840 Century Park East, Suite 1900 5 Los Angeles, California 90067 6 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 7 8 Attorneys for Defendant JPMorgan Chase Bank, N.A. 9 THE PORTNOY LAW FIRM 10 Lesley F. Portnoy (SBN 304851) 11 Nathaniel M. Goldstein (SBN 293855) [email protected] 12 1800 Century Park East, Suite 600 13 Los Angeles, California 90067 Telephone: (310) 692-8883 14

15 Attorneys for Plaintiff 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 WESTERN DIVISION 19 YAFFA BASSON, an individual, CASE NO. 2:21-cv-01647-GW-PLA 20 Hon. George H. Wu 21 Plaintiff, [Magistrate Judge Paul L. Abrams]

22 v. [PROPOSED] STIPULATED 23 PROTECTIVE ORDER JPMORGAN CHASE BANK, N.A., a national 24 banking association; RUTH SALMAN, an 25 individual; DIANE DINA DETOLVE, an individual; and DOES 1-10, inclusive, 26 State Case Filed: December 28, 2020 Action Removed: February 22, 2021 27 Defendants. 28 1 1. GENERAL 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special protection 4 from public disclosure and from use for any purpose other than prosecuting this litigation 5 may 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 Order 7 does not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable legal 10 principles. The parties further acknowledge, as set forth in Section 12.3, below, that this 11 Stipulated Protective Order does not entitle them to file confidential information under 12 seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the 13 standards that will be applied when a party seeks permission from the court to file material 14 under seal. 15 1.2 Good Cause Statement. This action is likely to involve personal financial 16 information, valuable research, development, commercial, financial, technical and/or 17 proprietary information for which special protection from public disclosure and from use 18 for any purpose other than prosecution of this action is warranted. Such confidential and 19 proprietary materials and information consist of, among other things, confidential business 20 or financial information, private personal information, information regarding confidential 21 business practices, or other confidential research, development, or commercial 22 information (including information implicating privacy rights of third parties), 23 information otherwise generally unavailable to the public, or which may be privileged or 24 otherwise protected from disclosure under state or federal statutes, court rules, case 25 decisions, or common law. Accordingly, to expedite the flow of information, to facilitate 26 the prompt resolution of disputes over confidentiality of discovery materials, to 27 adequately protect information the parties are entitled to keep confidential, to ensure that 28 the parties are permitted reasonable necessary uses of such material in preparation for and 1 in the 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 is justified in this matter. It is the 3 intent of the parties that information will not be designated as confidential for tactical 4 reasons and that nothing be so designated without a good faith belief that it has been 5 maintained in a confidential, non-public manner, and there is good cause why it should 6 not be part of the public record of this case. 7 2. DEFINITIONS 8 2.1 Action: Yaffa Basson V. JPMorgan Chase Bank, N.A., Ruth Salman, Diane 9 Dina Detolve, Case No. 2:21-cv-01647 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 11 information or items under this Order. 12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 13 generated, stored or maintained) or tangible things that qualify for protection under 14 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 15 Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 17 support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or items 19 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of the 21 medium or manner in which it is generated, stored, or maintained (including, among other 22 things, testimony, transcripts, and tangible things), that are produced or generated in 23 disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent 25 to the litigation who has been retained by a Party or its counsel to serve as an expert 26 witness or as a consultant in this Action. 27 2.8 House Counsel: attorneys who are employees of a party to this Action. House 28 Counsel does not include Outside Counsel of Record or any other outside counsel. 1 2.9 Non-Party: any natural person, partnership, corporation, association, or other 2 legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 4 Action but are retained to represent or advise a party to this Action and have appeared in 5 this Action on behalf of that party or are affiliated with a law firm that has appeared on 6 behalf of that party, including support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 11 Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 15 their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 17 “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 19 Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only Protected 22 Material (as defined above), but also (1) any information copied or extracted from 23 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 24 Material; and (3) any testimony, conversations, or presentations by Parties or their 25 Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the trial 27 judge. This Order does not govern the use of Protected Material at trial. 28 1 4. DURATION 2 Once a case proceeds to trial, all of the court-filed information to be introduced that 3 was previously designated as confidential or maintained pursuant to this protective order 4 becomes public and will be presumptively available to all members of the public, 5 including the press, unless compelling reasons supported by specific factual findings to 6 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 7 City and Cty. of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good 8 cause” showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the terms 10 of this protective order do not extend beyond the commencement of the trial. 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 13 Party or Non-Party that designates information or items for protection under this Order 14 must take care to limit any such designation to specific material that qualifies under the 15 appropriate standards. The Designating Party must designate for protection only those 16 parts of material, documents, items, or oral or written communications that qualify so that 17 other portions of the material, documents, items, or communications for which protection 18 is not warranted are not swept unjustifiably within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that 20 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 21 to unnecessarily encumber the case development process or to impose unnecessary 22 expenses and burdens on other parties) may expose the Designating Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items that it 24 designated for protection do not qualify for protection, that Designating Party must 25 promptly notify all other Parties that it is withdrawing the inapplicable designation. 26 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 27 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 28 1 Disclosure or Discovery Material that qualifies for protection under this Order must be 2 clearly so designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, but 5 excluding transcripts of depositions or other pretrial or trial proceedings), that the 6 Producing Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter 7 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 8 portion or portions of the material on a page qualifies for protection, the Producing Party 9 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 10 in the margins). 11 A Party or Non-Party that makes original documents available for inspection need 12 not designate them for protection until after the inspecting Party has indicated which 13 documents it would like copied and produced. During the inspection and before the 14 designation, all of the material made available for inspection shall be deemed 15 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 16 copied and produced, the Producing Party must determine which documents, or portions 17 thereof, qualify for protection under this Order. Then, before producing the specified 18 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 19 that contains Protected Material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify the protected 21 portion(s) (e.g., by making appropriate markings in the margins). 22 (b) for testimony given in depositions that the Designating Party identify the 23 Disclosure or Discovery Material on the record, before the close of the deposition. 24 (c) for information produced in some form other than documentary and for any 25 other tangible items, that the Producing Party affix in a prominent place on the exterior of 26 the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 28 the Producing Party, to the extent practicable, shall identify the protected portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 2 designate qualified information or items does not, standing alone, waive the Designating 3 Party’s right to secure protection under this Order for such material. Upon timely 4 correction of a designation, the Receiving Party must make reasonable efforts to assure 5 that the material is treated in accordance with the provisions of this Order. 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 8 confidentiality at any time that is consistent with the Court’s Scheduling Order. 9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 10 process under Local Rule 37-1, et seq. Any discovery motion must strictly comply with 11 the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 12 6.3 Burden. The burden of persuasion in any such challenge proceeding shall be on 13 the Designating Party. Frivolous challenges, and those made for an improper purpose 14 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose 15 the Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 16 the confidentiality designation, all parties shall continue to afford the material in question 17 the level of protection to which it is entitled under the Producing Party’s designation until 18 the Court rules on the challenge. 19 7. ACCESS TO AND USE OF PROTECTED MATERIAL 20 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed 21 or produced by another Party or by a Non-Party in connection with this Action only for 22 prosecuting, defending, or attempting to settle this Action. Such Protected Material may 23 be disclosed only to the categories of persons and under the conditions described in this 24 Order. When the Action has been terminated, a Receiving Party must comply with the 25 provisions of section 13 below (FINAL DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a location 27 and in a secure manner that ensures that access is limited to the persons authorized under 28 this Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 3 may disclose any information or item designated “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 5 employees of said Outside Counsel of Record to whom it is reasonably necessary to 6 disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of the 8 Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 10 reasonably necessary for this Action and who have signed the “Acknowledgment and 11 Agreement to Be Bound” (Exhibit A); 12 (d) the Court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 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 (g) the author or recipient of a document containing the information or a custodian 18 or other person who otherwise possessed or knew the information; 19 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to 20 whom disclosure is reasonably necessary provided: (1) the deposing party requests that 21 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 22 to keep any confidential information unless they sign the “Acknowledgment and 23 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 24 or ordered by the Court. Pages of transcribed deposition testimony or exhibits to 25 depositions that reveal Protected Material may be separately bound by the court reporter 26 and may not be disclosed to anyone except as permitted under this Stipulated Protective 27 Order; and 28 1 (i) any mediator or settlement officer, and their supporting personnel, mutually 2 agreed upon by any of the parties engaged in settlement discussions. 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 4 OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation that 6 compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification shall include 9 a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to issue 11 in the other litigation that some or all of the material covered by the subpoena or order is 12 subject to this Protective Order. Such notification shall include a copy of this Stipulated 13 Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 15 Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with the 17 subpoena or court order shall not produce any information designated in this action as 18 “CONFIDENTIAL” before a determination by the court from which the subpoena or 19 order issued, unless the Party has obtained the Designating Party’s permission. The 20 Designating Party shall bear the burden and expense of seeking protection in that court of 21 its confidential material and nothing in these provisions should be construed as 22 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 23 from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a Non-Party 27 in this Action and designated as “CONFIDENTIAL.” Such information produced by Non- 28 Parties in connection with this litigation is protected by the remedies and relief provided 1 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party 2 from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce a 4 Non-Party’s confidential information in its possession, and the Party is subject to an 5 agreement with the Non-Party not to produce the Non-Party’s confidential information, 6 then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party that some 8 or all of the information requested is subject to a confidentiality agreement with a Non- 9 Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 11 Order in this Action, the relevant discovery request(s), and a reasonably specific 12 description of the information requested; and 13 (3) make the information requested available for inspection by the Non-Party, if 14 requested. 15 (c) If the Non-Party fails to seek a protective order from this Court within 14 days 16 of receiving the notice and accompanying information, the Receiving Party may produce 17 the Non-Party’s confidential information responsive to the discovery request. If the Non- 18 Party timely seeks a protective order, the Receiving Party shall not produce any 19 information in its possession or control that is subject to the confidentiality agreement 20 with the Non-Party before a determination by the Court. Absent a court order to the 21 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 22 Court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 28 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 1 unauthorized disclosures were made of all the terms of this Order, and (d) request such 2 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 3 attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain inadvertently 7 produced material is subject to a claim of privilege or other protection, the obligations of 8 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 9 This provision is not intended to modify whatever procedure may be established in an e- 10 discovery order that provides for production without prior privilege review. Pursuant to 11 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 12 effect of disclosure of a communication or information covered by the attorney-client 13 privilege or work product protection, the parties may incorporate their agreement in the 14 stipulated protective order submitted to the Court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 17 to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 19 Order, no Party waives any right it otherwise would have to object to disclosing or 20 producing any information or item on any ground not addressed in this Stipulated 21 Protective Order. Similarly, no Party waives any right to object on any ground to use in 22 evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 24 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 25 under seal pursuant to a court order authorizing the sealing of the specific Protected 26 Material at issue; good cause must be shown in the request to file under seal. If a Party’s 27 request to file Protected Material under seal is denied by the Court, then the Receiving 28 1 Party may file the information in the public record unless otherwise instructed by the 2 Court. 3 13. FINAL DISPOSITION 4 After the final disposition of this Action, within 60 days of a written request by the 5 Designating Party, each Receiving Party must return all Protected Material to the 6 Producing Party or destroy such material. As used in this subdivision, “all Protected 7 Material” includes all copies, abstracts, compilations, summaries, and any other format 8 reproducing or capturing any of the Protected Material. Whether the Protected Material is 9 returned or destroyed, the Receiving Party must submit a written certification to the 10 Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 11 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 12 that was returned or destroyed, and (2) affirms that the Receiving Party has not retained 13 any copies, abstracts, compilations, summaries or any other format reproducing or 14 capturing any of the Protected Material. Notwithstanding this provision, counsel are 15 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 16 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 17 reports, attorney work product, and consultant and expert work product, even if such 18 materials contain Protected Material. Any such archival copies that contain or constitute 19 Protected Material remain subject to this Protective Order as set forth in Section 4 20 (DURATION). 21 14. VIOLATION OF ORDER 22 Any violation of this Order may be punished by any and all appropriate measures 23 including, without limitation, contempt proceedings and/or monetary sanctions. 24 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 25 26 27 28 1 Respectfully submitted, 2 Dated: March 19, 2021 GREENBERG TRAURIG, LLP 3 By: /s/ Karin L. Bohmholdt 4 Karin L. Bohmholdt 5 Blakeley S. Oranburg Attorneys for Defendant 6 JPMorgan Chase Bank, N.A. 7 8 Dated: March 19, 2021 THE PORTNOY LAW FIRM 9 By: /s/ Lesley F. Portnoy 10 Lesley F. Portnoy 11 Attorneys for Plaintiff

12 ECF CERTIFICATION 13 Pursuant to Local Civil Rule 5-4.3.4(a)(2)(i), I hereby attest that Lesley Portnoy, on 14 whose behalf this filing is jointly submitted, has concurred in this filing’s content and has 15 authorized me to file this document. 16 17 By: /s/ Karin L. Bohmholdt 18 Karin L. Bohmholdt 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of _____________ 5 ___________________________ [print or type full address], declare under penalty of 6 perjury that I have read in its entirety and understand the Protective Order that was issued 7 by the United States District Court for the Central District of California on ____________ 8 in the case of _____________________________________. I agree to comply with and 9 to be bound by all the terms of this Protective Order and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information or 12 item that is subject to this Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this Protective 16 Order, even if such enforcement proceedings occur after termination of this action. I 17 hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or 20 any proceedings related to enforcement of this Protective Order. 21 Date: _____________________ 22 City and State where sworn and signed: _________________________________ 23 Printed name: _______________________________ 24 Signature: __________________________________ 25 26 27 28 1 ORDER 2 Having considered the Parties’ Stipulated Protective Order, the Stipulated 3 || Protective Order is granted. 4 IT IS SO ORDERED. Arama 6|| DATED: March 22 , 2021 7 HON. PAUL L. ABRAMS UNITED STATES MAGISTRATE JUDGE

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