1 || GREENBERG TRAURIG, LLP Rick L. Shackelford (SBN 151262) 2 || Hannah B. Shanks-Parkin (SBN 305753) 3 || 1840 Century Park East, Suite 1900 Los Angeles, CA 90067-2121 4 || Tel: 310-586-7700; Fax:310-586-7800 5 Email: [email protected] [email protected] 6 7 Attorneys for Defendant Walmart Inc. g || ADDITIONAL COUNSEL ON FOLLOWING PAGE 9 10 11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 14 |} CHANDLER MCFALL and KAILEY | Case No. 2:20-cv-07752-FLA (MRWx) 15 MCDONALD, individually and on STIPULATED PROTECTIVE behalf of others similarly situated; ORDER 16 Plaintiffs, Complaint filed August 25, 2020 17 First Amended Complaint filed Vs October 22, 2020 18 Assigned to the Hon. Michael R. Wilner; 19 || PERRIGO COMPANY, and Comfroom 550 □□□□ WALMART INC., 20 L] Check if submitted without material Defendants modifications to MRW form 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER

1 || Daniel J. Herling (SBN 103711) [email protected] 2 || MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO, P.C. 3 || 44 Montgomery Street, 36" Floor San Francisco, California 94104 4 || Telephone: 415-432-6000 ; Facsimile: 415-432-6001

6 Nicole V. Ozeran (SBN 302321) [email protected] 7 || Adam B. Korn (SBN 331133) [email protected] 8 || MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO, P.C. 2029 Century Park East, Suite 3100 9 Il Los Angeles, CA 90067 19 || Pelephone: 310-586-3200 Facsimile: 310-586-3202 11 Melissa S. Weiner (pro hac vice) 12 || [email protected] 3 Joseph C. Bourne (SBN 308196) [email protected] 14 || PEARSON SIMON & WARSHAW LLP 800 LaSalle Avenue, Suite 2150 15 |} Minneapolis, MN 55402 16 Telephone: 612-398-0600; Fax: 612-398-0610

17 || Gillian L. Wade (SBN 22914) [email protected] 18 || Sara D. Avila (SBN 263213) [email protected] 19 || Marc A. Castenada (SBN 299001) 0 [email protected],m MILSTEIN JACKSON FAIRCHILD & WADE LLP 91 || 10990 Wilshire Boulevard, Suite 800 Los Angeles, CA 90024 22 || Telephone: 310-396-9600; Fax: 310-396-9635 23 || Hank Bates (SBN 167688) 74 || [email protected] David Slade (pro hac vice) 25 || [email protected] CARNEY BATES & PULLIAM PLLC 26 |)

" Street 07 Little Rock, Arkansas 72201 Telephone: 501-312-8500; Fax: 501-312-8505 28 STIPULATED PROTECTIVE ORDER

1 Scott Edlesberg (SBN 330990) 2 [email protected] 3 || EDELSBERG LAW, P.A.

" Avenue, Suite 417 4 || Aventura, FL 33180 ; Telephone: 305-975-3320

6 Rachel Dapeer (pro hac vice pending) [email protected] 7 || DAPEER LAW, P.A.

" Avenue, Suite 417 8 || Aventura, FL 33180 9 Telephone: 305-610-5523

10 Andrew Shamis (pro hac vice pending) [email protected] 11 || SHAMIS & GENTILE, P.A.

" Avenue, Suite 1205 12 || Miami, FL 33132 3 Telephone: 305-479-2299 14 || Attorneys for PLAINTIFFS 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER

1 |} 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 || proprietary, or private information for which special protection from public 5 || disclosure and from use for any purpose other than prosecuting this litigation may 6 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 || enter the following Stipulated Protective Order. The parties acknowledge that this 8 || Order does not confer blanket protections on all disclosures or responses to 9 || discovery and that the protection it affords from public disclosure and use extends 10 || only to the limited information or items that are entitled to confidential treatment 11 || under the applicable legal principles. The parties further acknowledge, as set forth 12 |} in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 13 || file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 || procedures that must be followed and the standards that will be applied when a 15 || party seeks permission from the court to file material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 This consumer fraud case is likely to involve pricing lists, detailed sales data, 18 || trade secrets, and other valuable research, development, commercial, financial, 19 || technical and/or proprietary information relating to the products at issue in this 20 || litigation, for which special protection from public disclosure and from use for any 21 || purposes other than the prosecution of this action is warranted. Such confidential 22 || and proprietary materials and information consist of, among other things, 23 || confidential business or financial information, information regarding confidential 24 || business practices or other confidential personnel information that implicates the 25 || privacy rights of third parties, information otherwise generally unavailable to the 26 || public or which may be privileged or otherwise protected from disclosure under 27 || state or federal statutes, court rules, case decisions, or common law. Accordingly, 28 STIPULATED PROTECTIVE ORDER

1 || to expedite the flow of information, to facilitate the prompt resolution of disputes 2 || over confidentiality of discovery materials, to adequately protect information the 3 || parties are entitled to keep confidential, to ensure that the parties are permitted 4 || reasonably necessary uses of such material in preparation for and in the conduct of 5 || trial, to address their handling at the end of the litigation, and to serve the ends of 6 || justice, a protective order for such information is justified in this matter. It is the 7 || intent of the parties that information will not be designated as confidential for 8 || tactical reasons and that no document will be so designated without a good-faith 9 || belief that it has been maintained in a confidential manner and there is good cause 10 || why it should not be part of the public record of this case. 11 12 |} 2. DEFINITIONS 13 2.1 Action: this pending federal law suit. Chandler McFall et al. v. Perrigo 14 || Company and Walmart Inc., United State District Court Case No.: 2:20-cv-07752- 15 |} FLA (MRWsx). 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 || of information or items under this Order. 18 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 19 || how it is generated, stored or maintained) or tangible things that qualify for 20 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 21 || the Good Cause Statement. 22 2.4 “ATTORNEYS’ EYES ONLY” Information or Items: especially 23 || sensitive “CONFIDENTIAL” information or documents that is designated as 24 || “Attorneys’ Eyes Only” by a Producing Party based on a good faith belief that the 25 || information or documents are either (1) protected by the attorney-client, attorney 26 || work product immunity, or other applicable privilege related to any underlying 27 || claims asserted in the case but have nonetheless been produced voluntarily, (11) 28 STIPULATED PROTECTIVE ORDER

1 || contain trade secrets or other commercially sensitive information, (111) contain 2 || highly sensitive financial information whose public disclosure would create a 3 || clearly defined and very serious injury, or (iv) contain confidential, proprietary, or 4 || commercially or personally sensitive information that, if disclosed to the other 5 || party or to a non-party would create a substantial risk of serious harm to the 6 || Producing Party that could not be avoided by less restrictive means and that, if not 7 || disclosed to the other party (but rather only to its counsel) would not prejudice that 8 || party’s ability to prosecute or defend against the claims alleged in this action. 9 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 10 || their support staff). 11 2.6 Designating Party: a Party or Non-Party that designates information or 12 || items that it produces in disclosures or in responses to discovery as 13 || “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 14 2.7 Disclosure or Discovery Material: all items or information, regardless 15 || of the medium or manner in which it is generated, stored, or maintained (including, 16 || among other things, testimony, transcripts, and tangible things), that are produced 17 || or generated in disclosures or responses to discovery in this matter. 18 2.8 Expert: a person with specialized knowledge or experience in a matter 19 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 || an expert witness or as a consultant in this Action. 21 2.9 House Counsel: attorneys who are employees of a party to this Action. 22 || House Counsel does not include Outside Counsel of Record or any other outside 23 || counsel. 24 2.10 Non-Party: any natural person, partnership, corporation, association, or 25 || other legal entity not named as a Party to this action. 26 2.11 Outside Counsel of Record: attorneys who are not employees of a party 27 || to this Action but are retained to represent or advise a party to this Action and have 28 STIPULATED PROTECTIVE ORDER APTIVE RRRRANOQ 4

1 || appeared in this Action on behalf of that party or are affiliated with a law firm 2 || which has appeared on behalf of that party, and includes support staff. 3 2.12 Party: any party to this Action, including all of its officers, directors, 4 || employees, consultants, retained experts, and Outside Counsel of Record (and their 5 || support staffs). 6 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 7 || Discovery Material in this Action. 8 2.14 Professional Vendors: persons or entities that provide litigation support 9 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 |} and their employees and subcontractors. 12 2.15 Protected Material: any Disclosure or Discovery Material that is 13 || designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 14 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 15 || from a Producing Party. 16 17 |} 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 || Protected Material (as defined above), but also (1) any information copied or 20 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 || compilations of Protected Material; and (3) any testimony, conversations, or 22 || presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial will be governed by the orders of the 24 || trial judge. This Order does not govern the use of Protected Material at trial. 25 26 || 4. DURATION 27 28 STIPULATED PROTECTIVE ORDER

1 Even after final disposition of this litigation, the confidentiality obligations 2 || imposed by this Order will remain in effect until a Designating Party agrees 3 || otherwise in writing or a court order otherwise directs. Final disposition will be 4 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, 5 || with or without prejudice; and (2) final judgment herein after the completion and 6 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 7 || including the time limits for filing any motions or applications for extension of time 8 || pursuant to applicable law. 9 10 |} 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for Protection. 12 || Each Party or Non-Party that designates information or items for protection under 13 || this Order must take care to limit any such designation to specific material that 14 || qualifies under the appropriate standards. The Designating Party must designate 15 || for protection only those parts of material, documents, items, or oral or written 16 |} communications that qualify so that other portions of the material, documents, 17 || items, or communications for which protection is not warranted are not swept 18 || unjustifiably within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations 20 || that are shown to be clearly unjustified or that have been made for an improper 21 || purpose (e.g., to unnecessarily encumber the case development process or to 22 || impose unnecessary expenses and burdens on other parties) may expose the 23 || Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 || designated for protection do not qualify for protection, that Designating Party must 26 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 27 28 STIPULATED PROTECTIVE ORDER

1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 || under this Order must be clearly so designated before the material is disclosed or 5 || produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 || documents, but excluding transcripts of depositions or other pretrial or trial 9 || proceedings), that the Producing Party affix at a minimum, the legend 10 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 11 |} contains protected material. If only a portion or portions of the material on a page 12 || qualifies for protection, the Producing Party also must clearly identify the protected 13 |} portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 |} need not designate them for protection until after the inspecting Party has indicated 16 || which documents it would like copied and produced. During the inspection and 17 || before the designation, all of the material made available for inspection will be 18 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 19 || documents it wants copied and produced, the Producing Party must determine 20 || which documents, or portions thereof, qualify for protection under this Order. Then, 21 || before producing the specified documents, the Producing Party must affix the 22 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 23 || portion or portions of the material on a page qualifies for protection, the Producing 24 || Party also must clearly identify the protected portion(s) (e.g., by making 25 || appropriate markings in the margins). 26 (b) for testimony given in depositions or other oral testimony to be recorded 27 || in a written transcript, the Designating Party may designate information as 28 STIPULATED PROTECTIVE ORDER

1 || “Confidential” or “Attorneys’ Eyes Only” by making a statement on the record to 2 || that effect during the deposition or proceeding at issue. The court reporter shall 3 || separately bind the designated portion of the deposition transcript and all 4 || designated exhibits. The separately bound deposition material shall be marked in 5 || accordance with its designation, as “CONFIDENTIAL, SUBJECT TO 6 || PROTECTIVE ORDER” or “ATTORNEYS’ EYES ONLY, SUBJECT TO 7 || PROTECTIVE ORDER.” Alternatively, the Designating Party may, within a 8 || reasonable time after the deposition transcript is delivered to the Designating Party, 9 || provide to all counsel written notice identifying the specific portion (by page and 10 || line numbers) that the Designating Party seeks to protect, and all parties to the 11 || litigation will mark the pages with the appropriate legends.. 12 (c) for information produced in some form other than documentary and for 13 || any other tangible items, that the Producing Party affix in a prominent place on the 14 || exterior of the container or containers in which the information is stored the legend 15 |} “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 || protection, the Producing Party, to the extent practicable, will identify the protected 17 || portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 || failure to designate qualified information or items does not, standing alone, waive 20 || the Designating Party’s right to secure protection under this Order for such 21 || material. Upon timely correction of a designation, the Receiving Party must make 22 || reasonable efforts to assure that the material is treated in accordance with the 23 || provisions of this Order. 24 25 26 27 28 STIPULATED PROTECTIVE ORDER

1 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 || designation of confidentiality at any time that is consistent with the Court’s 4 || Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party will initiate the dispute 6 || resolution process (and, if necessary, file a discovery motion) under Local Rule 7 || 37.1 et seq. 8 6.3 The burden of persuasion in any such challenge proceeding will be on 9 || the Designating Party. Frivolous challenges, and those made for an improper 10 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 || parties) may expose the Challenging Party to sanctions. Unless the Designating 12 || Party has waived or withdrawn the confidentiality designation, all parties will 13 || continue to afford the material in question the level of protection to which it is 14 || entitled under the Producing Party’s designation until the Court rules on the 15 || challenge. 16 17 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 || disclosed or produced by another Party or by a Non-Party in connection with this 20 || Action only for prosecuting, defending, or attempting to settle this Action. Such 21 || Protected Material may be disclosed only to the categories of persons and under the 22 |} conditions described in this Order. When the Action has been terminated, a 23 || Receiving Party must comply with the provisions of section 13 below (FINAL 24 || DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 || location and in a secure manner that ensures that access is limited to the persons 27 || authorized under this Order. 28 STIPULATED PROTECTIVE ORDER

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 || otherwise ordered by the court or permitted in writing by the Designating Party, a 3 || Receiving Party may disclose any information or item designated 4 || “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 6 || as employees of said Outside Counsel of Record to whom it is reasonably necessary 7 || to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 || Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 || disclosure is reasonably necessary for this Action and who have signed the 12 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 || Vendors to whom disclosure 1s reasonably necessary for this Action and who have 17 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or a 19 || custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses, and attorneys for witnesses, in the 21 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they 23 || will not be permitted to keep any confidential information unless they sign the 24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 || agreed by the Designating Party or ordered by the court. Pages of transcribed 26 || deposition testimony or exhibits to depositions that reveal Protected Material may 27 28 STIPULATED PROTECTIVE ORDER

1 || be separately bound by the court reporter and may not be disclosed to anyone 2 || except as permitted under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, 4 || mutually agreed upon by any of the parties engaged in settlement discussions. 5 7.3 Disclosure of “ATTORNEYS’ EYES ONLY” Information or Items. 6 || Unless otherwise ordered by the Court or permitted in writing by the Designating 7 \| Party, a Receiving Party may disclose any information or item designated 8 || “ATTORNEYS’ EYES ONLY” only to the following individuals and/or under the 9 || following conditions: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 || as employees or contractors of said Outside Counsel of Record to whom it is 12 || reasonably necessary to disclose the information for this litigation; 13 (b) experts or consultants retained by the Receiving Party (including their 14 || employees, associates and support staff) to whom disclosure is reasonably 15 || necessary for this Action, and who have signed the “Acknowledgement and 16 |} Agreement to Be Bound” (Exhibit A); 17 (c) the author or recipient of a document containing the information; 18 (d) an Expert (as defined in this Order) of the Producing Party may be shown 19 |} or examined on any information, document or thing designated “ATTORNEYS 20 |} EYES ONLY” during his or her deposition; 21 (e) the Court and its personnel as well as court reporters and the staff of court 22 || reporting services; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 || Vendors to whom disclosure is reasonably necessary for this Litigation, and who 25 || have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (g) any mediator or settlement officer, and their supporting personnel, 27 || mutually agreed upon by Parties engaged in settlement discussions; and 28 10 STIPULATED PROTECTIVE ORDER

1 (h) such other persons as the Parties may agree in writing and who have 2 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 || INOTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 || that compels disclosure of any information or items designated in this Action as 8 || “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification will 10 || include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order to 12 || issue in the other litigation that some or all of the material covered by the subpoena 13 || or order is subject to this Protective Order. Such notification will include a copy of 14 || this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be pursued 16 || by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served 18 || with the subpoena or court order will not produce any information designated in 19 || this action as “CONFIDENTIAL” before a determination by the court from which 20 || the subpoena or order issued, unless the Party has obtained the Designating Party’s 21 || permission. The Designating Party will bear the burden and expense of seeking 22 || protection in that court of its confidential material and nothing in these provisions 23 || should be construed as authorizing or encouraging a Receiving Party in this Action 24 || to disobey a lawful directive from another court. 25 26 || 9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 || PRODUCED IN THIS LITIGATION 28 11 STIPULATED PROTECTIVE ORDER

1 (a) The terms of this Order are applicable to information produced by a Non- 2 || Party in this Action and designated as “CONFIDENTIAL.” Such information 3 || produced by Non-Parties in connection with this litigation is protected by the 4 || remedies and relief provided by this Order. Nothing tn these provisions should be 5 || construed as prohibiting a Non-Party from seeking additional protections. 6 (b) In the event that a Party is required, by a valid discovery request, to 7 || produce a Non-Party’s confidential information in its possession, and the Party is 8 || subject to an agreement with the Non-Party not to produce the Non-Party’s 9 || confidential information, then the Party will: 10 (1) promptly notify in writing the Requesting Party and the Non-Party 11 || that some or all of the information requested is subject to a confidentiality 12 || agreement with a Non-Party; 13 (2) promptly provide the Non-Party with a copy of the Stipulated 14 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 15 || specific description of the information requested; and 16 (3) make the information requested available for inspection by the 17 || Non-Party, if requested. If the Non-Party fails to seek a protective order from this 18 || court within 14 days of receiving the notice and accompanying information, the 19 || Receiving Party may produce the Non-Party’s confidential information responsive 20 || to the discovery request. If the Non-Party timely seeks a protective order, the 21 || Receiving Party will not produce any information in its possession or control that is 22 || subject to the confidentiality agreement with the Non-Party before a determination 23 || by the court. Absent a court order to the contrary, the Non-Party will bear the 24 || burden and expense of seeking protection in this court of its Protected Material. 25 26 27 28 12 STIPULATED PROTECTIVE ORDER

1 jj 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has 3 || disclosed Protected Material to any person or in any circumstance not authorized 4 || under this Stipulated Protective Order, the Receiving Party must immediately (a) 5 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its 6 || best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 7 || the person or persons to whom unauthorized disclosures were made of all the terms 8 || of this Order, and (d) request such person or persons to execute the 9 || “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 10 || A. 11 12 |} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 || PROTECTED MATERIAL 14 Pursuant to Fed. R. Evid. 502(d), the production of privileged or work-product 15 || protected documents, whether inadvertent or otherwise, 1s not a waiver of the privilege or 16 || protection from discovery in this case or in any other federal or state proceeding. For example, 17 || the mere production of privileged or work-product-protected documents in this case as part of a 18 || mass production is not itself a waiver in this case or in any other federal or state proceeding. 19 || Nothing in this paragraph shall require a party to produce documents that are protected from 20 || disclosure. This paragraph shall be interpreted to provide the greatest protection allowed by 21 || Federal Rule of Evidence 502, or otherwise permitted by law. 22 Nothing contained herein is intended to or shall serve to limit a party’s right 23 || to conduct a review of documents, ESI or information (including metadata) for 24 || relevance, responsiveness and/or segregation of privileged and/or protected 25 || information before production. 26 If the Requesting Party has reason to believe that a produced document or 27 || other information may reasonably be subject to a claim of privilege, then the 28 13 STIPULATED PROTECTIVE ORDER ARTIVE ERBRANO D4

1 || Requesting Party shall immediately sequester the document or information, cease 2 || using the document or information and cease using any work product containing 3 || the information, and shall inform the Designating Party of the beginning BATES 4 || number of the document or, if no BATES number is available, shall otherwise 5 || inform the Designating Party of the information. 6 A Designating Party must give written notice to any Requesting Party 7 || asserting a claim of privilege, work-product protection, or other ground for 8 |} reclaiming documents or information (a “clawback request’). After a clawback 9 || request is received, the Requesting Party shall immediately sequester the document 10 || Gf not already sequestered) and shall not review or use that document, or any work 11 || product containing information taken from that document, for any purpose. The 12 || Parties shall meet and confer regarding any clawback request. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the nght of any 16 || person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 || Protective Order no Party waives any right it otherwise would have to object to 19 || disclosing or producing any information or item on any ground not addressed in 20 || this Stipulated Protective Order. Similarly, no Party waives any right to object on 21 || any ground to use in evidence of any of the material covered by this Protective 22 || Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 || Protected Material must comply with Civil Local Rule 79-5. Protected Material 25 || may only be filed under seal pursuant to a court order authorizing the sealing of the 26 || specific Protected Material at issue. If a Party's request to file Protected Material 27 28 14 STIPULATED PROTECTIVE ORDER

1 || under seal is denied by the court, then the Receiving Party may file the information 2 || in the public record unless otherwise instructed by the court. 3 4 || 13. FINAL DISPOSITION 5 After the final disposition of this Action, as defined in paragraph 4, within 60 6 || days of a written request by the Designating Party, each Receiving Party must 7 \| return all Protected Material to the Producing Party or destroy such material. As 8 || used in this subdivision, “all Protected Material” includes all copies, abstracts, 9 || compilations, summaries, and any other format reproducing or capturing any of the 10 || Protected Material. Whether the Protected Material is returned or destroyed, the 11 || Receiving Party must submit a written certification to the Producing Party (and, if 12 || not the same person or entity, to the Designating Party) by the 60 day deadline that 13 || (1) identifies (by category, where appropriate) all the Protected Material that was 14 || returned or destroyed and (2) affirms that the Receiving Party has not retained any 15 || copies, abstracts, compilations, summaries or any other format reproducing or 16 || capturing any of the Protected Material. Notwithstanding this provision, Counsel 17 || are entitled to retain an archival copy of all pleadings, motion papers, trial, 18 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition 19 || and trial exhibits, expert reports, attorney work product, and consultant and expert 20 || work product, even if such materials contain Protected Material. Any such archival 21 || copies that contain or constitute Protected Material remain subject to this Protective 22 || Order as set forth in Section 4 (DURATION). 23 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER

1 |} 14. Any willful violation of this Order may be punished by civil or criminal 2 || contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 3 || authorities, or other appropriate action at the discretion of the Court. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: April 15, 2021 PEARSON SIMON & WARSHAW LLP 7 8 By: /s/ Melissa S. Weiner 9 MELISSA S. WEINER JOSEPH C. BOURNE 10 Attorneys for PLAINTIFFS 11 12 13 || Dated: April 15, 2021 MILSTEIN JACKSON FAIRCHILD & WADE LLP 14 15 By: /s/Gillian L. Wade GILLIAN L. WADE 16 SARA D. AVILA MARC A. CASTENADA 17 Attorneys for PLAINTIFFS 18 19 20 |) Dated: April 15, 2021 CARNEY BATES & PULLIAM PLLC 21 By: /s/ Hank Bates HANK BATES 23 DAVID SLADE 24 Attornevs for PLAINTIFFS 25 26 27 28 16 STIPULATED PROTECTIVE ORDER

1 |} Dated: April 15, 2021 EDELSBERG LAW, P.A. 2 By: /s/ Scott Edelsberg 3 SCOTT EDELSBERG 4 Attorneys for PLAINTIFFS 5 6 7 Dated: April 15, 2021 DAPEER LAW, P.A. 8 By: /s/ Rachel Dapeer 9 RACHEL DAPEER 10 Attorneys for PLAINTIFFS 11 12 || Dated: April 15, 2021 SHAMIS & GENTILE, P.A.. 13 By: /s/ Andrew Shamis 14 ANDREW SHAMIS 15 Attorneys for PLAINTIFFS 16 17 || Dated: = April 15, 2021 GREENBERG TRAURIG LLP 18 By: /s/ Rick L. Shackelford 19 RICK L. SHACKELFORD 20 HANNAH PARKS-SHANKIN Attorneys for WALMART INC. 22 Dated: April 15, 2021 MINTZ LEVIN COHN FERRIS 23 GLOVSKY AND POPEO, P.C. 24 5 By: /s/ Daniel J. Herling DANIEL J. HERLING 6 NICOLE V. OZERAN ADAM B. KORN 27 Attornevs for PERRIGO COMPANY 28 17 STIPULATED PROTECTIVE ORDER

ATTESTATION REGARDING SIGNATURES I, Hannah B. Shanks-Parkin, attest pursuant to L.R. 5-4.3.4(a)(2)(i) that all

4 signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. ° DATED: April 15, 2021 /s/ Hanna B. Shanks-Parkin 6 Hanna B. Shanks-Parkin 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 STIPULATED PROTECTIVE ORDER

1 ORDER FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 DATED: April 16, 2021 Mt - HON. MICHAEL R. WILNER 6 United States Magistrate Judge - 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27] a □□□□□□□□□□□□□□□□□□□□□□□□□□□□ pean STIPULATED PROTECTIVE ORDER

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 Il, [full name], of 5 || [full address], declare under penalty of perjury that I have read in its entirety and 6 || understand the Stipulated Protective Order that was issued by the United States 7 || District Court for the Central District of California on [date] in the case of 8 [insert case name and number]. | agree to comply with and to be 9 || bound by all the terms of this Stipulated Protective Order and I understand and 10 || acknowledge that failure to so comply could expose me to sanctions and 11 |} punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 |} any manner any information or item that is subject to this Stipulated Protective 13 || Order to any person or entity except in strict compliance with the provisions of this 14 || Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 || for the Central District of California for the purpose of enforcing the terms of this 17 || Stipulated Protective Order, even if such enforcement proceedings occur after 18 || termination of this action. I hereby appoint [full 19 || name] of [full address and 20 || telephone number] as my California agent for service of process in connection 21 || with this action or any proceedings related to enforcement of this Stipulated 22 || Protective Order. 23 || Date: 24 || City and State where signed: 25 26 || Printed name: 27 28 STIPULATED PROTECTIVE ORDER

Signature; ee 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 oo ATIVE Reamanaee 4 STIPULATED PROTECTIVE ORDER