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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

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11 AARON KOGAN, CASE NO. 2:21-cv-05932-RGK-PD

12 Plaintiff, ORDER APPROVING STIPULATED PROTECTIVE ORDER 13 vs.

14 TARGET CORPORATION and DOES 1 TO 10, inclusive, Case Filed: July 22, 2021 15 State Court Action Filed: May 25, 2021 Defendants. Trial Date: June 21, 2022 16

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18 19 On November 15, 2021, the parties jointly submitted a STIPULATED 20 PROTECTIVE ORDER. Having reviewed this STIPULATED PROTECTIVE 21 ORDER, and good causing having been shown, the Court hereby approves the 22 STIPULATED PROTECTIVE ORDER, the full text of which is set forth below.

23 1. A. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public 26 disclosure and from use for any purpose other than prosecuting this litigation may 27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 Order does not confer blanket protections on all disclosures or responses to 3 discovery and that the protection it affords from public disclosure and use extends 4 only to the limited information or items that are entitled to confidential treatment 5 under the applicable legal principles. 6 7 B. GOOD CAUSE STATEMENT 8 This action is likely to involve trade secrets, protected health information and 9 other valuable research, development, commercial, financial, technical and/or 10 proprietary information for which special protection from public disclosure and from 11 use for any purpose other than prosecution of this action is warranted. Such 12 confidential and proprietary materials and information consist of, among other 13 things, Defendant Target Corporation’s confidential business information regarding 14 confidential business practices, or other confidential research, development, or 15 commercial information (including information implicating privacy rights of third 16 parties), Plaintiff’s protected health information such as medical records, billing and 17 imaging, and other information otherwise generally unavailable to the public, or 18 which may be privileged or otherwise protected from disclosure under state or 19 federal statutes, court rules, case decisions, or common law. Accordingly, to expedite 20 the flow of information, to facilitate the prompt resolution of disputes over 21 confidentiality of discovery materials, to adequately protect information the parties 22 are entitled to keep confidential, to ensure that the parties are permitted reasonable 23 necessary uses of such material in preparation for and in the conduct of trial, to 24 address their handling at the end of the litigation, and serve the ends of justice, a 25 protective order for such information is justified in this matter. It is the intent of the 26 parties that information will not be designated as confidential for tactical reasons 27 and that nothing be so designated without a good faith belief that it has been 1 maintained in a confidential, non-public manner, and there is good cause why it 2 should not be part of the public record of this case. 3 4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 5 The parties further acknowledge, as set forth in Section 12.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information 7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 8 the standards that will be applied when a party seeks permission from the court to 9 file material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 14 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 15 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 16 good cause showing), and a specific showing of good cause or compelling reasons 17 with proper evidentiary support and legal justification, must be made with respect to 18 Protected Material that a party seeks to file under seal. The parties’ mere designation 19 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 20 submission of competent evidence by declaration, establishing that the material 21 sought to be filed under seal qualifies as confidential, privileged, or otherwise 22 protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the 25 relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 27 item or type of information, document, or thing sought to be filed or introduced under 1 seal in connection with a dispositive motion or trial, the party seeking protection 2 must articulate compelling reasons, supported by specific facts and legal 3 justification, for the requested sealing order. Again, competent evidence supporting 4 the application to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. If 7 documents can be redacted, then a redacted version for public viewing, omitting only 8 the confidential, privileged, or otherwise protectable portions of the document, shall 9 be filed. Any application that seeks to file documents under seal in their entirety 10 should include an explanation of why redaction is not feasible. 11 12 2. DEFINITIONS 13 2.1 Action: this pending federal law suit. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 19 Good Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 21 their support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless 26 of the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced or 1 generated in disclosures or responses to discovery in this matter. 2 2.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 an expert witness or as a consultant in this Action. 5 2.8 House Counsel: attorneys who are employees of a party to this Action. 6 House Counsel does not include Outside Counsel of Record or any other outside 7 counsel. 8 2.9 Non-Party: any natural person, partnership, corporation, association, or 9 other legal entity not named as a Party to this action. 10 2.10 Outside Counsel of Record: attorneys who are not employees of a party 11 to this Action but are retained to represent or advise a party to this Action and have 12 appeared in this Action on behalf of that party or are affiliated with a law firm which 13 has appeared on behalf of that party, and includes support staff. 14 2.11 Party: any party to this Action, including all of its officers, directors, 15 employees, consultants, retained experts, and Outside Counsel of Record (and their 16 support staffs). 17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 18 Discovery Material in this Action. 19 2.13 Professional Vendors: persons or entities that provide litigation 20 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 21 demonstrations, and organizing, storing, or retrieving data in any form or medium) 22 and their employees and subcontractors. 23 2.14 Protected Material: any Disclosure or Discovery Material that is 24 designated as “CONFIDENTIAL.” 25 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 26 from a Producing Party. 27 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Order does not govern the use of Protected Material at trial. 9 10 4. DURATION 11 FINAL DISPOSITION of the action is defined as the conclusion of any 12 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 13 has run. Except as set forth below, the terms of this protective order apply through 14 FINAL DISPOSITION of the action. The parties may stipulate that they will be 15 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 16 but will have to file a separate action for enforcement of the agreement once all 17 proceedings in this case are complete. 18 Once a case proceeds to trial, information that was designated as 19 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 20 as an exhibit at trial becomes public and will be presumptively available to all 21 members of the public, including the press, unless compelling reasons supported by 22 specific factual findings to proceed otherwise are made to the trial judge in advance 23 of the trial. See Kamakana,

(distinguishing “good cause” 24 showing for sealing documents produced in discovery from “compelling reasons” 25 standard when merits-related documents are part of court record). Accordingly, for 26 such materials, the terms of this protective order do not extend beyond the 27 commencement of the trial. 1 2 5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for Protection. 4 Each Party or Non-Party that designates information or items for protection under 5 this Order must take care to limit any such designation to specific material that 6 qualifies under the appropriate standards. The Designating Party must designate for 7 protection only those parts of material, documents, items, or oral or written 8 communications that qualify so that other portions of the material, documents, items, 9 or communications for which protection is not warranted are not swept unjustifiably 10 within the ambit of this Order. 11 Mass, indiscriminate, or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper 13 purpose (e.g., to unnecessarily encumber the case development process or to impose 14 unnecessary expenses and burdens on other parties) may expose the Designating 15 Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 22 under this Order must be clearly so designated before the material is disclosed or 23 produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 proceedings), that the Producing Party affix at a minimum, the legend 1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 2 contains protected material. If only a portion or portions of the material on a page 3 qualifies for protection, the Producing Party also must clearly identify the protected 4 portion(s) (e.g., by making appropriate markings in the margins). 5 A Party or Non-Party that makes original documents available for inspection 6 need not designate them for protection until after the inspecting Party has indicated 7 which documents it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for inspection shall be 9 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 10 documents it wants copied and produced, the Producing Party must determine which 11 documents, or portions thereof, qualify for protection under this Order. Then, before 12 producing the specified documents, the Producing Party must affix the 13 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 14 portion or portions of the material on a page qualifies for protection, the Producing 15 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 16 markings in the margins). 17 (b) for testimony given in depositions that the Designating Party 18 identify the Disclosure or Discovery Material on the record, before the close of the 19 deposition all protected testimony. 20 (c) for information produced in some form other than documentary 21 and for any other tangible items, that the Producing Party affix in a prominent place 22 on the exterior of the container or containers in which the information is stored the 23 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 24 protection, the Producing Party, to the extent practicable, shall identify the protected 25 portion(s). 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 failure to designate qualified information or items does not, standing alone, waive 1 the Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make reasonable 3 efforts to assure that the material is treated in accordance with the provisions of this 4 Order. 5 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 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 9 Scheduling Order. 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 11 resolution process under Local Rule 37.1 et seq. 12 6.3 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 15 expose the Challenging Party to sanctions. Unless the Designating Party has waived 16 or withdrawn the confidentiality designation, all parties shall continue to afford the 17 material in question the level of protection to which it is entitled under the Producing 18 Party’s designation until the Court rules on the challenge. 19 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 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 23 Action only for prosecuting, defending, or attempting to settle this Action. Such 24 Protected Material may be disclosed only to the categories of persons and under the 25 conditions described in this Order. When the Action has been terminated, a 26 Receiving Party must comply with the provisions of section 13 below (FINAL 27 DISPOSITION). 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 9 as employees of said Outside Counsel of Record to whom it is reasonably necessary 10 to disclose the information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 26 not be permitted to keep any confidential information unless they sign the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 1 agreed by the Designating Party or ordered by the court. Pages of transcribed 2 deposition testimony or exhibits to depositions that reveal Protected Material may 3 be separately bound by the court reporter and may not be disclosed to anyone except 4 as permitted under this Stipulated Protective Order; and 5 (i) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 that compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification shall 14 include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or order 16 to issue in the other litigation that some or all of the material covered by the subpoena 17 or order is subject to this Protective Order. Such notification shall include a copy of 18 this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served 22 with the subpoena or court order shall not produce any information designated in this 23 action as “CONFIDENTIAL” before a determination by the court from which the 24 subpoena or order issued, unless the Party has obtained the Designating Party’s 25 permission. The Designating Party shall bear the burden and expense of seeking 26 protection in that court of its confidential material and nothing in these provisions 27 should be construed as authorizing or encouraging a Receiving Party in this Action 1 to disobey a lawful directive from another court. 2 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT 4 TO BE PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a 6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the 21 Non-Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 23 14 days of receiving the notice and accompanying information, the Receiving Party 24 may produce the Non-Party’s confidential information responsive to the discovery 25 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 26 not produce any information in its possession or control that is subject to the 27 confidentiality agreement with the Non-Party before a determination by the court. 1 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 2 of seeking protection in this court of its Protected Material. 3 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 10 persons to whom unauthorized disclosures were made of all the terms of this Order, 11 and (d) request such person or persons to execute the “Acknowledgment and 12 Agreement to Be Bound” that is attached hereto as Exhibit A. 13 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 22 parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted 25 to the court. 26 27 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material at issue. If a Party's request to file Protected Material 13 under seal is denied by the court, then the Receiving Party may file the information 14 in the public record unless otherwise instructed by the court. 15 16 13. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 4, within 60 18 days of a written request by the Designating Party, each Receiving Party must return 19 all Protected Material to the Producing Party or destroy such material. As used in 20 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 21 summaries, and any other format reproducing or capturing any of the Protected 22 Material. Whether the Protected Material is returned or destroyed, the Receiving 23 Party must submit a written certification to the Producing Party (and, if not the same 24 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 25 (by category, where appropriate) all the Protected Material that was returned or 26 destroyed and (2)affirms that the Receiving Party has not retained any copies, 27 abstracts, compilations, summaries or any other format reproducing or capturing any 1 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 2 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 || reports, attorney work product, and consultant and expert work product, even if such 5 ||materials contain Protected Material. Any such archival copies that contain or 6 || constitute Protected Material remain subject to this Protective Order as set forth in 7 || Section 4 (DURATION). 8 9||14. Any violation of this Order may be punished by any and all appropriate 10 ||measures including, without limitation, contempt proceedings and/or monetary 11 || sanctions. 12 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 14 DATED: November 15, 2021 LAW OFFICES OF DROCIAK & YEAGER 15 /s/ Kenneth C. Yeager 16 Kenneth C. Yeager, Esq. 7 Attorneys for Plaintiff AARON KOGAN 18 DATED: November 15, 2021 19 QUINTAIROS, PRIETO, WOOD & BOYER. 0 /s/ David G. Halm David G. Halm, Esq. 21 Attorneys for Defendant TARGET CORPORATION 23 ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 || DATED: November 16, 2021 25 os 26 Paltues □□□ hoe 27 Patricia Donahue 38 United States Magistrate Judge 1&5

Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer attests that all signatories listed, and 1 on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 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 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 perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Aaron Kogan v. Target Corporation, United States District 9 Court, Central District of California, Western Division, Case No. 2:21-cv-05932- 10 RGK-PD. I agree to comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so comply could 12 expose me to sanctions and punishment in the nature of contempt. I solemnly 13 promise that I will not disclose in any manner any information or item that is subject 14 to this Stipulated Protective Order to any person or entity except in strict 15 compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint ________________________ [print or 20 type full name] of _________ [print or type full address and telephone number] as 21 my California agent for service of process in connection with this action or any 22 proceedings related to enforcement of this Stipulated Protective Order. 23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25 Printed name: ____________________________________ 26 Signature: ________________________________ 27 1 PROOF OF SERVICE 2 Aaron Kogan v. Target Corporation 3 Los Angeles County Superior Court Case No.: 21STCV19623 4 Client/Matter: 161475 5 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 6 At the time of service, I was over 18 years of age and not a party to the action. 7||My business address is 500 N. Brand Boulevard, Suite 1650, Glendale, California g || 91203. 9 On November 16, 2021, I served the following document described as 10 || [PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER on the following persons at the following address: 11 12 SEE ATTACHED SERVICE LIST 13 (BY CM/ECF) | hereby certify that on this date, I electronically filed the oregoing with the Clerk of the Court using the CM/ECF system which will 14 send notification of such filing to the e-mail addresses denoted on the Electronic Mail notice list, and I hereby certify that I have mailed the 15 foregoing document Or paper via the United States Postal Service to the non- CM/ECF participants (if any) indicated on the Manual Notice list. 16 I declare under penalty of perjury under the laws of the United States of 17 America that the foregoing is true and correct. 18 Executed on November 16, 2021, at Glendale, California. 19 \ Vaoty * 20 LISETH GONZALEZ 21 22 23 24 25 26 27 28 12

SERVICE LIST 1

2 Aaron Kogan v. Target Corporation 3 Los Angeles County Superior Court Case No.: 21STCV19623 Client/Matter: 161475 4 5 Kenneth C. Yeager, Esq. Attorney for Plaintiff LAW OFFICES OF DROCIAK & 6 YEAGER 7 7627 S. Western Ave. Los Angeles, CA 90047 8 Tel: 323-971-3981 9 Fax: 323-753-4910 Email: [email protected] 10

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