1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 MONSERRAT LOPEZ, an individual, on Case No. 2:21-cv-00447 MCS (PVCx) behalf of herself, and on behalf of all persons 11 similarly situated, STIPULATED PROTECTIVE ORDER 12 Plaintiffs, 13 v. Complaint Filed: December 4, 2020 14 ADIDAS AMERICA, INC., an Oregon 15 corporation; and DOES 1 through 50, Inclusive, 16 Defendants. 17 18 19 20 21 22 23 24 25 26 27 28 Sm

1 PURPOSES AND LIMITATIONS OF STIPULATION AND PROTECTIVE Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. ° Accordingly, the parties hereby stipulate to and petition the Court to enter the following 6 Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection 8 it affords from public disclosure and use extends only to the limited information or items 9 that are entitled to confidential treatment under the applicable legal principles. The 10 parties further acknowledge, as set forth in Section XIII, below, that this Stipulated i Protective Order does not entitle them to file confidential information under seal; Civil 12 Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.

15 | Il. GOOD CAUSE STATEMENT 16 This action is likely to involve the disclosure of material protected under the 17 || constitutional, statutory, or common law right to privacy or protected as confidential 18 || business, financial, proprietary, or private personnel, policy and payroll information. 19 || Such confidential and proprietary materials and information consist of, among other 20 || things, confidential information regarding current and/ or former employees, 91 || confidential business or financial information, information regarding confidential 22 || business practices, or other confidential commercial information (including information 33 || implicating privacy rights of third parties), information otherwise generally unavailable 24 || to the public, or which may be privileged or otherwise protected from disclosure under 25 || state or federal statutes, court rules, case decisions, or common law. Accordingly, to 26 || expedite the flow of information, to facilitate the prompt resolution of disputes over 97 || confidentiality of discovery materials, to adequately protect information the parties are 2g || entitled to keep confidential, to ensure that the parties are permitted reasonable

1 || necessary uses of such material in preparation for and in the conduct of trial, to address 2 || their handling at the end of the litigation, and serve the ends of justice, a protective order 3 || for such information is justified in this matter. It is the intent of the parties that 4 || information will not be designated as confidential for tactical reasons and that nothing 5 || beso designated without a good faith belief that it has been maintained in a confidential, 6 || non-public manner, and there is good cause why it should not be part of the public 7 || record of this case. 8 | III. DEFINITIONS 9 A. Action: Action refers to the above referenced matter titled Monserrat 10 Lopez v. Adidas America, Inc., Case No. 2:21-cv-00447-MCS (PVCx). 11 B. Challenging Party: a Party or Non-Party that challenges the designation of 12 information or items under this Order. 13 C. “CONFIDENTIAL” Information or Items: information that has not been 14 made public or is not otherwise available or accessible in the public 15 domain and that concerns or relates to the confidential or proprietary 16 information of: (1) Defendant adidas America, Inc. (“Defendant”); (2) 17 Plaintiff Monserrat Lopez (‘Plaintiff’); or (3) any third parties, the 18 disclosure of which information is likely to have the effect of causing harm 19 to the competitive position of Defendant or to the organization or person 20 from whom the information was obtained, or to the parties’ privacy. 21 Confidential Information also includes private information pertaining to 22 Defendant’s or a third party’s employees, for which Defendant or a third 23 party has a duty to maintain the confidentiality of such information. 24 Information designated Confidential may be used only in connection with 25 this proceeding, and not for any other purpose. Such information may not 26 be disclosed to anyone except as provided in this Order. 27 D. Counsel: “Counsel” means: 28 1) Littler Mendelson, a professional corporation, and its respective

1 support staff and other employees who are not employed by a Party 2 and to whom it is necessary to disclose Confidential Information for 3 the purpose of this action; 4 2) JCL Law Firm, and their respective support staff and other 5 employees who are not employed by a Party and to whom it is 6 necessary to disclose Confidential Information for the purpose of 7 this action; 8 3) Zakay Law Group, and their respective support staff and other 9 employees who are not employed by a Party and to whom it is 10 necessary to disclose Confidential Information for the purpose of 11 this action; 12 E. Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 F. Disclosure or Discovery Material: all items or information, regardless of 16 the medium or manner in which it is generated, stored, or maintained 17 (including, among other things, testimony, transcripts, and tangible 18 things), that are produced or generated in disclosures or responses to 19 discovery in this matter. 20 G. Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel 22 to serve as an expert witness or as a consultant in this Action. 23 H. House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other 25 outside counsel. 26 I. Non-Party: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 28 J. Outside Counsel of Record: attorneys who are not employees of a party to Pe

1 this Action but are retained to represent or advise a party to this Action and 2 have appeared in this Action on behalf of that party or are affiliated with a 3 law firm that has appeared on behalf of that party, including support staff. 4 K. Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record 6 (and their support staffs). 7 L. Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 M. Professional Vendors: persons or entities that provide litigation support 10 services (e.g., photocopying, videotaping, translating, preparing exhibits 11 or demonstrations, and organizing, storing, or retrieving data in any form 12 or medium) and their employees and subcontractors. 13 N. Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 O. Receiving Party: a Party that receives Disclosure or Discovery Material 16 from a Producing Party. 17 || IV. SCOPE 18 The protections conferred by this Stipulation and Order cover not only Protected 19 || Material (as defined above), but also (1) any information copied or extracted from 20 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 21 || Material; and (3) any testimony, conversations, or presentations by Parties or their 22 || Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the trial 24 || judge. This Order does not govern the use of Protected Material at trial. 25 || V. DURATION 26 Once a case proceeds to trial, all of the court-filed information to be introduced 27 || that was previously designated as confidential or maintained pursuant to this protective 28 || order becomes public and will be presumptively available to all members of the public,

1 || including the press, unless compelling reasons supported by specific factual findings to 2 || proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 3 || City and County of Honolulu,

(9th Cir. 2006) (distinguishing 4 || “good cause” showing for sealing documents produced in discovery from “compelling 5 || reasons” standard when merits-related documents are part of court record). 6 || Accordingly, the terms of this protective order do not extend beyond the 7 || commencement of the trial. 8 || VI. DESIGNATING PROTECTED MATERIAL 9 A. Exercise of Restraint and Care in Designating Material for Protection. 10 || Each Party or Non-Party that designates information or items for protection under this 11 |) Order must take care to limit any such designation to specific material that qualifies 12 || under the appropriate standards. The Designating Party must designate for protection 13 || only those parts of material, documents, items, or oral or written communications that 14 || qualify so that other portions of the material, documents, items, or communications for 15 || which protection 1s not warranted are not swept unjustifiably within the ambit of this 16 || Order. 17 Mass, indiscriminate, or routinized designations are prohibited. Designations that 18 || are shown to be clearly unjustified or that have been made for an improper purpose 19 || (e.g., to unnecessarily encumber the case development process or to impose 20 |) unnecessary expenses and burdens on other parties) may expose the Designating Party 21 || to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 || designated for protection do not qualify for protection, that Designating Party must 24 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 B. Manner and Timing of Designations. Except as otherwise provided in this 26 || Order or as otherwise stipulated or ordered, Disclosure or Discovery Material that 27 || qualifies for protection under this Order must be clearly so designated before the 28 || material is disclosed or produced. Pe

1 Designation in conformity with this Order requires: 2 1. for information in documentary form (e.g., paper or electronic 3 || documents, but excluding transcripts of depositions or other pretrial or trial 4 || proceedings), that the Producing Party affix, at a minimum, the legend 5 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 6 || contains protected material. If only a portion or portions of the material on a page 7 || qualifies for protection, the Producing Party also must clearly identify the protected 8 || portion(s) (e.g., by making appropriate markings in the margins). 9 A Party or Non-Party that makes original documents available for 10 || inspection need not designate them for protection until after the inspecting Party has 11 |) indicated which documents it would like copied and produced. During the inspection 12 || and before the designation, all of the material made available for inspection shall be 13 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it 14 || wants copied and produced, the Producing Party must determine which documents, or 15 || portions thereof, qualify for protection under this Order. Then, before producing the 16 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 17 || each page that contains Protected Material. If only a portion or portions of the material 18 || on a page qualifies for protection, the Producing Party also must clearly identify the 19 || protected portion(s) (e.g., by making appropriate markings in the margins). 20 2. for testimony given in depositions that the Designating Party 21 || identify the Disclosure or Discovery Material on the record, before the close of the 22 || deposition. 23 3, for information produced in some form other than documentary and 24 || for any other tangible items, that the Producing Party affix in a prominent place on the 25 || exterior of the container or containers in which the information is stored the legend 26 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 || protection, the Producing Party, to the extent practicable, shall identify the protected 28 || portion(s).

1 C. Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 || failure to designate qualified information or items does not, standing alone, waive the 3 || Designating Party’s right to secure protection under this Order for such material. Upon 4 || timely correction of a designation, the Receiving Party must make reasonable efforts to 5 || assure that the material is treated in accordance with the provisions of this Order. 6 || VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 A. Timing of Challenges. Any Party or Non-Party may challenge a 8 || designation of confidentiality at any time that is consistent with the Court’s Scheduling 9 || Order. 10 B. Meet _and Confer. The Challenging Party shall initiate the dispute 11 || resolution process under Local Rule 37.1, et seg. Any discovery motion must strictly 12 || comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 13 C. Burden. The burden of persuasion in any such challenge proceeding shall 14 || be on the Designating Party. Frivolous challenges, and those made for an improper 15 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 16 || may expose the Challenging Party to sanctions. Unless the Designating Party has 17 || waived or withdrawn the confidentiality designation, all parties shall continue to afford 18 || the material in question the level of protection to which it is entitled under the Producing 19 || Party’s designation until the Court rules on the challenge. 20 || ACCESS TO AND USE OF PROTECTED MATERIAL 21 A. — Basic Principles. A Receiving Party may use Protected Material that is 22 || disclosed or produced by another Party or by a Non-Party in connection with this Action 23 || only for prosecuting, defending, or attempting to settle this Action. Such Protected 24 || Material may be disclosed only to the categories of persons and under the conditions 25 || described in this Order. When the Action has been terminated, a Receiving Party must 26 || comply with the provisions of section XV below (FINAL DISPOSITION). 27 Protected Material must be stored and maintained by a Receiving Party at a 28 || location and in a secure manner that ensures that access is limited to the persons

1 || authorized under this Order. 2 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 3 || ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 4 || may disclose any information or item designated “CONFIDENTIAL” only to: 5 1. the Receiving Party’s Outside Counsel of Record in this Action, as 6 || well as employees of said Outside Counsel of Record to whom it is reasonably 7 || necessary to disclose the information for this Action; 8 2. the officers, directors, and employees (including House Counsel) of 9 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 3, 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 4, the Court and its personnel; 14 5. court reporters and their staff; 15 6. professional jury or trial consultants, mock jurors, and Professional 16 || Vendors to whom disclosure is reasonably necessary for this Action and who have 17 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 7. the author or recipient of a document containing the information or 19 |) a custodian or other person who otherwise possessed or knew the information; 20 8. during their depositions, witnesses, and attorneys for witnesses, in 21 || the 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 will 23 || not be permitted to keep any confidential information unless they sign the 24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 25 || by the Designating Party or ordered by the Court. Pages of transcribed deposition 26 || testimony or exhibits to depositions that reveal Protected Material may be separately 27 || bound by the court reporter and may not be disclosed to anyone except as permitted 28 || under this Stipulated Protective Order; and

1 9. any mediator or settlement officer, and their supporting personnel, 2 || mutually agreed upon by any of the parties engaged in settlement discussions. 3 C. Protected Material Subpoenaed Or Ordered Produced In Other Litigation 4 If a Party is served with a subpoena or a court order issued in other litigation that 5 | compels disclosure of any information or items designated in this Action as 6 || “CONFIDENTIAL,” that Party must: 7 1. promptly notify in writing the Designating Party. Such notification 8 || shall include a copy of the subpoena or court order; 9 2. promptly notify in writing the party who caused the subpoena or 10 || order to issue in the other litigation that some or all of the material covered by the 11 || subpoena or order is subject to this Protective Order. Such notification shall include a 12 || copy of this Stipulated Protective Order; and 13 3, cooperate with respect to all reasonable procedures sought to be 14 || pursued by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with the 16 || subpoena or court order shall not produce any information designated in this action as 17 | “CONFIDENTIAL” before a determination by the court from which the subpoena or 18 || order issued, unless the Party has obtained the Designating Party’s permission. The 19 || Designating Party shall bear the burden and expense of seeking protection in that court 20 || of its confidential material and nothing in these provisions should be construed as 21 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 22 || from another court. 23 | IX. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 24 IN THIS LITIGATION 25 A. The terms of this Order are applicable to information produced by a Non- 26 || Party in this Action and designated as “CONFIDENTIAL.” Such information produced 27 || by Non-Parties in connection with this litigation is protected by the remedies and relief 28 || provided by this Order. Nothing in these provisions should be construed as prohibiting

1 || a Non-Party from seeking additional protections. 2 B. In the event that a Party is required, by a valid discovery request, to 3 || produce a Non-Party’s confidential information in its possession, and the Party is 4 || subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 5 || information, then the Party shall: 6 1. promptly notify in writing the Requesting Party and the Non-Party 7 || that some or all of the information requested is subject to a confidentiality agreement 8 || with a Non-Party; 9 2. promptly provide the Non-Party with a copy of the Stipulated 10 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 11 || specific description of the information requested; and 12 3. make the information requested available for inspection by the Non- 13 || Party, if requested. 14 C. If the Non-Party fails to seek a protective order from this Court within 14 15 || days of receiving the notice and accompanying information, the Receiving Party may 16 || produce the Non-Party’s confidential information responsive to the discovery request. 17 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 18 || any information in its possession or control that is subject to the confidentiality 19 || agreement with the Non-Party before a determination by the Court. Absent a court order 20 || to the contrary, the Non-Party shall bear the burden and expense of seeking protection 21 || in this Court of its Protected Material. 22 X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 || Protected Material to any person or in any circumstance not authorized under this 25 || Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing 26 || the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 27 || all unauthorized copies of the Protected Material, (3) inform the person or persons to 28 || whom unauthorized disclosures were made of all the terms of this Order, and (4) request

1 || such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 2 || that is attached hereto as Exhibit A. 3 | XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 || inadvertently produced material is subject to a claim of privilege or other protection, 7 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 || may be established in an e-discovery order that provides for production without prior 10 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 || parties reach an agreement on the effect of disclosure of a communication or 12 || information covered by the attorney-client privilege or work product protection, the 13 || parties may incorporate their agreement in the stipulated protective order submitted to 14 || the Court. 15 || XII. FEDERAL RULE OF EVIDENCE 502(D) AND (E) CLAWBACK 16 AGREEMENT 17 Pursuant to Federal Rules of Evidence 502(d) and (e), the Parties agree to and the 18 || Court orders protection of privileged and otherwise protected Documents against claims 19 || of waiver (including as against third parties and in other federal and state proceedings) 20 || as follows: 21 A. — The disclosure or production of documents by a Producing Party subject 22 || to a legally recognized claim of privilege, including without limitation the attorney- 23 || client privilege and the work-product doctrine, to a Receiving Party, shall in no way 24 || constitute the voluntary disclosure of such document. 25 B. — The inadvertent disclosure or production of any document in this action 26 || shall not result in the waiver of any privilege, evidentiary protection or other protection 27 || associated with such document as to the Receiving Party or any third parties, and shall 28 || not result in any waiver, including subject matter waiver, of any kind. CA 11

If, during the course of this litigation, a party determines that any document 2 || produced by another party is or may reasonably be subject to a legally recognizable 3 || privilege or evidentiary protection (“Protected Document’): 4 1. the Receiving Party shall: (a) refrain from reading the Protected 5 || Document any more closely than is necessary to ascertain that it is privileged or 6 || otherwise protected from disclosure; (b) immediately notify the Producing Party in 7 || writing that it has discovered Documents believed to be privileged or protected; (c) 8 || specifically identify the Protected Documents by Bates number range or hash value, 9 || and, (d) within 10 days of discovery by the Receiving Party, return, sequester, or destroy 10 || all copies of such Protected Documents, along with any notes, abstracts or compilations 11 || of the content thereof. To the extent that a Protected Document has been loaded into a 12 |) litigation review database under the control of the Receiving Party, the Receiving Party 13 || shall have all electronic copies of the Protected Document extracted from the database. 14 || Where such Protected Documents cannot be destroyed or separated, they shall not be 15 || reviewed, disclosed, or otherwise used by the Receiving Party. Notwithstanding, the 16 || Receiving Party is under no obligation to search or review the Producing Party’s 17 || Documents to identify potentially privileged or work product Protected Documents. 18 2. If the Producing Party intends to assert a claim of privilege or other 19 || protection over Documents identified by the Receiving Party as Protected Documents, 20 || the Producing Party will, within 10 days of receiving the Receiving Party’s written 21 |) notification described above, inform the Receiving Party of such intention in writing 22 || and shall provide the Receiving Party with a log for such Protected Documents that is 23 || consistent with the requirements of the Federal Rules of Civil Procedure, setting forth 24 || the basis for the claim of privilege or other protection. In the event that any portion of 25 || a Protected Document does not contain privileged or protected information, the 26 || Producing Party shall also provide to the Receiving Party a redacted copy of the 27 || document that omits the information that the Producing Party believes is subject to a 28 || claim of privilege or other protection.

If, during the course of this litigation, a party determines it has produced a 2 || Protected Document: 3 1. the Producing Party may notify the Receiving Party of such 4 || inadvertent production in writing, and demand the return of such documents. Such 5 || notice shall be in writing, however, it may be delivered orally on the record at a 6 || deposition, promptly followed up in writing. The Producing Party’s written notice will 7 || identify the Protected Document inadvertently produced by bates number range or hash 8 || value, the privilege or protection claimed, and the basis for the assertion of the privilege 9 || and shall provide the Receiving Party with a log for such Protected Documents that 1s 10 || consistent with the requirements of the Federal Rules of Civil Procedure, setting forth 11 || the basis for the claim of privilege or other protection. In the event that any portion of 12 || the Protected Document does not contain privileged or protected information, the 13 || Producing Party shall also provide to the Receiving Party a redacted copy of the 14 || Document that omits the information that the Producing Party believes is subject to a 15 || claim of privilege or other protection. 16 2. The Receiving Party must, within 10 days of receiving the 17 || Producing Party’s written notification described above, return, sequester, or destroy the 18 || Protected Document and any copies, along with any notes, abstracts or compilations of 19 || the content thereof. To the extent that a Protected Document has been loaded into a 20 || litigation review database under the control of the Receiving Party, the Receiving Party 21 || shall have all electronic copies of the Protected Document extracted from the database. 22 E. — To the extent that the information contained in a Protected Document has 23 || already been used in or described in other documents generated or maintained by the 24 || Receiving Party prior to the date of receipt of written notice by the Producing Party as 25 || set forth in paragraphs XII (C)(2) and XI (D)(1), then the Receiving Party shall 26 || sequester such documents until the claim has been resolved. If the Receiving Party 27 || disclosed the Protected Document before being notified of its inadvertent production, it 28 || must take reasonable steps to retrieve it.

1 F, The Receiving Party’s return, sequestering or destruction of Protected 2 || Documents as provided herein will not act as a waiver of the Requesting Party’s right 3 || to move for the production of the returned, sequestered or destroyed documents on the 4 || grounds that the documents are not, in fact, subject to a viable claim of privilege or 5 || protection. However, the Receiving Party is prohibited and estopped from arguing that: 6 1. the disclosure or production of the Protected Documents acts as a 7 || waiver of an applicable privilege or evidentiary protection; 8 2. the disclosure of the Protected Documents was not inadvertent; 9 3. the Producing Party did not take reasonable steps to prevent the 10 || disclosure of the Protected Documents; or 11 4. the Producing Party failed to take reasonable or timely steps to 12 || rectify the error pursuant to Federal Rule of Civil Procedure 26(b)(5)(B), or otherwise. 13 G. Either party may submit Protected Documents to the Court under seal for 14 || a determination of the claim of privilege or other protection. The Producing Party shall 15 || preserve the Protected Documents until such claim is resolved. The Receiving Party 16 || may not use the Protected Documents for any purpose absent this Court’s order. 17 H. Upon a determination by the Court that the Protected Documents are 18 || protected by the applicable privilege or evidentiary protection, and if the Protected 19 || Documents have been sequestered rather than returned or destroyed by the Receiving 20 || Party, the Protected Documents shall be returned or destroyed within 10 days of the 21 |) Court’s order. The Court may also order the identification by the Receiving Party of 22 || Protected Documents by search terms or other means. 23 I. Nothing contained herein is intended to, or shall serve to limit a party’s 24 || right to conduct a review of documents, data (including electronically stored 25 || information) and other information, including without limitation, metadata, for 26 || relevance, responsiveness and/or the segregation of privileged and/or protected 27 || information before such information 1s produced to another party. 28 J. By operation of the Parties’ agreement and Court Order, the Parties are

1 || specifically afforded the protections of Federal Rules of Evidence 502 (d) and (e). 2] XII. MISCELLANEOUS 3 A. — Right to Further Relief. Nothing in this Order abridges the right of any 4 || person to seek its modification by the Court in the future. 5 B. Right to Assert Other Objections. By stipulating to the entry of this 6 || Protective Order, no Party waives any right it otherwise would have to object to 7 || disclosing or producing any information or item on any ground not addressed in this 8 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 9 || ground to use in evidence of any of the material covered by this Protective Order. 10 C. Filing Protected Material. A Party that seeks to file under seal any 11 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 12 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 13 || Protected Material at issue; good cause must be shown in the request to file under seal. 14 || Ifa Party’s request to file Protected Material under seal is denied by the Court, then the 15 || Receiving Party may file the information in the public record unless otherwise 16 || instructed by the Court. 17 || XIV. INFORMATION SECURITY 18 A. □ Any person in possession of another party's CONFIDENTIAL information 19 | shall maintain a written information security program that includes reasonable 20 || administrative, technical, and physical safeguards designed to protect the security and 21 || confidentiality of such CONFIDENTIAL information, protect against any reasonably 22 || anticipated threats or hazards to the security of such CONFIDENTIAL information, and 23 || protect against unauthorized access to or use of such CONFIDENTIAL information. 24 || To the extent a person or party does not have an information security program they may 25 || comply with this provision by having the CONFIDENTIAL information managed by 26 || and/or stored with eDiscovery vendors or claims administrators that maintain such an 27 || information security program. 28 B. □ Ifthe Receiving Party discovers a breach of security, including any actual 15

1 || or suspected unauthorized access, relating to another party's CONFIDENTIAL 2 || information, the Receiving Party shall: 3 1. promptly provide written notice to Designating Party of such 4 || breach; 5 2. investigate and take reasonable efforts to remediate the effects of the 6 || breach, and provide Designating Party with assurances reasonably satisfactory to 7 || Designating Party that such breach shall not recur; and 8 3. provide sufficient information about the breach that the Designating 9 || Party can reasonably ascertain the size and scope of the breach. If required by any 10 || judicial or governmental request, requirement or order to disclose such information, the 11 || Receiving Party shall take all reasonable steps to give the Designating Party sufficient 12 || prior notice in order to contest such request, requirement or order through legal means. 13 || The Receiving Party agrees to cooperate with the Designating Party or law enforcement 14 || in investigating any such security incident. In any event, the Receiving Party shall 15 | promptly take all necessary and appropriate corrective action to terminate the 16 || unauthorized access. 17 || XV. FINAL DISPOSITION 18 After the final disposition of this Action, within 60 days of a written request by 19 || the Designating Party, each Receiving Party must return all Protected Material to the 20 || Producing Party or destroy such material. As used in this subdivision, “all Protected 21 || Material” includes all copies, abstracts, compilations, summaries, and any other format 22 || reproducing or capturing any of the Protected Material. Whether the Protected Material 23 || is returned or destroyed, the Receiving Party must submit a written certification to the 24 || Producing Party (and, if not the same person or entity, to the Designating Party) by the 25 || 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 26 || Material that was returned or destroyed and (2) affirms that the Receiving Party has not 27 || retained any copies, abstracts, compilations, summaries or any other format reproducing 28 || or capturing any of the Protected Material. Notwithstanding this provision, counsel are

1 || entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 2 || hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 3 || expert reports, attorney work product, and consultant and expert work product, even if 4 || such materials contain Protected Material. Any such archival copies that contain or 5 || constitute Protected Material remain subject to this Protective Order as set forth in 6 || Section V (DURATION). 7 Any violation of this Order may be punished by any and all appropriate measures 8 || including, without limitation, contempt proceedings and/or monetary sanctions. 9 10 | FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS SO 11 | ORDERED. 12 | DATED: April 23, 2021 14 . ful i= 16 HON.PEDROV.CASTILLO UNITED STATES MAGISTRATE JUDGE

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Exhibit A 2 UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA 4 || MONSERRAT LOPEZ, an individual, on Case No.: 2:21-cv-00447 MCS (PVCx) behalf of herself, and on behalf of all persons 5 || similarly situated; 6 AGREEMENT TO BE BOUND BY Plaintiff, PROTECTIVE ORDER 7 vs. 8 ADIDAS AMERICA, INC., an Oregon 9 corporation; and DOES | through 50, Inclusive, 10 11 Defendants. 12 The undersigned hereby acknowledges that he/she having read the Stipulated 13 || Protective Order entered in the above-captioned action and attached hereto, understands the terms 14 thereof, and agrees to be bound by its terms, ensuring that any employees and/or clerical assistants 15 will also abide thereby. The undersigned submits to the jurisdiction of this Court in matters relating to the Protective Order and understands that the terms obligate him/her to use documents designated 16 “CONFIDENTIAL” in accordance with the Protective Order solely for the purposes of the above- 17 captioned action, and not to disclose any such documents or information derived directly therefrom to 18 || any other person, firm or concern. 19 The undersigned acknowledges that violation of the Protective Order may result in 99 || penalties for contempt of court. Entered into on this day of , 20 .

22 73 Signature: 24 Print Name: 25 Address: 26 27 28 Sm 18