Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 1 of 16 Page ID #:403

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 KOHAR KESIAN, an individual, Case No. 2:21-cv-01787-ODW-RAO

12 Plaintiff, [Otis D. Wright, II, Department 5D]

13 v. STIPULATED PROTECTIVE 14 TARGET CORPORATION, and DOES ORDER 1 through 100, Inclusive, 15 Defendants. 16

17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may 21 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 22 enter the following Stipulated Protective Order. The parties acknowledge that this 23 Order does not confer blanket protections on all disclosures or responses to 24 discovery and that the protection it affords from public disclosure and use extends 25 only to the limited information or items that are entitled to confidential treatment 26 under the applicable legal principles. 27 / / / 28 / / /

STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 2 of 16 Page ID #:404

1 B. GOOD CAUSE STATEMENT 2 Good cause exists for this stipulated protective order because TARGET 3 CORPORATION'S policies and procedures documents contain proprietary 4 information of TARGET CORPORATION and TARGET CORPORATION only 5 authorizes production of these proprietary documents subject to a protective order. 6 TARGET CORPORATION would suffer harm if its proprietary policies and 7 procedures documents and surveillance video were disseminated. The following is 8 the list of documents that Target would like protected under this protective order: 9 - Team Member Handbook (Hourly); 10 - Team Member Handbook (Executive); 11 - Safety Training - New Team Member Orientation DVD; 12 - Spill Clean-Up Procedures; 13 - Basic Safeness - Guest Incidents; 14 - Basic Safeness Sales Floor Guide (Employee); 15 - Basic Safeness Sales Floor Guide (Trainer); 16 - Target surveillance video pertaining to plaintiff's incident 17 This action is likely to involve trade secrets, customer and pricing lists and 18 other valuable research, development, commercial, financial, technical and/or 19 proprietary information for which special protection from public disclosure and 20 from use for any purpose other than prosecution of this action is warranted. Such 21 confidential and proprietary materials and information consist of, among other 22 things, confidential business or financial information, information regarding 23 confidential business practices, or other confidential research, development, or 24 commercial information (including information implicating privacy rights of third 25 parties), information otherwise generally unavailable to the public, or which may be 26 privileged or otherwise protected from disclosure under state or federal statutes, 27 court rules, case decisions, or common law. Accordingly, to expedite the flow of 28 information, to facilitate the prompt resolution of disputes over confidentiality of 2 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 3 of 16 Page ID #:405

1 discovery materials, to adequately protect information the parties are entitled to keep 2 confidential, to ensure that the parties are permitted reasonable necessary uses of 3 such material in preparation for and in the conduct of trial, to address their handling 4 at the end of the litigation, and serve the ends of justice, a protective order for such 5 information is justified in this matter. It is the intent of the parties that information 6 will not be designated as confidential for tactical reasons and that nothing be so 7 designated without a good faith belief that it has been maintained in a confidential, 8 non-public manner, and there is good cause why it should not be part of the public 9 record of this case. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 11 SEAL 12 The parties further acknowledge, as set forth in Section 12.3, below, that this 13 Stipulated Protective Order does not entitle them to file confidential information 14 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 15 and the standards that will be applied when a party seeks permission from the court 16 to file material under seal. 17 There is a strong presumption that the public has a right of access to judicial 18 proceedings and records in civil cases. In connection with non-dispositive motions, 19 good cause must be shown to support a filing under seal. See Kamakana v. City and 20 County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 21 Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 22 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 23 require good cause showing), and a specific showing of good cause or compelling 24 reasons with proper evidentiary support and legal justification, must be made with 25 respect to Protected Material that a party seeks to file under seal. The parties’ mere 26 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 27 without the submission of competent evidence by declaration, establishing that the 28 material sought to be filed under seal qualifies as confidential, privileged, or 3 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 4 of 16 Page ID #:406

1 otherwise protectable—constitute good cause. 2 Further, if a party requests sealing related to a dispositive motion or trial, then 3 compelling reasons, not only good cause, for the sealing must be shown, and the 4 relief sought shall be narrowly tailored to serve the specific interest to be protected. 5 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 6 each item or type of information, document, or thing sought to be filed or introduced 7 under seal in connection with a dispositive motion or trial, the party seeking 8 protection must articulate compelling reasons, supported by specific facts and legal 9 justification, for the requested sealing order. Again, competent evidence supporting 10 the application to file documents under seal must be provided by declaration. 11 Any document that is not confidential, privileged, or otherwise protectable in 12 its entirety will not be filed under seal if the confidential portions can be redacted. 13 If documents can be redacted, then a redacted version for public viewing, omitting 14 only the confidential, privileged, or otherwise protectable portions of the document 15 shall be filed. Any application that seeks to file documents under seal in their 16 entirety should include an explanation of why redaction is not feasible. 17 2. DEFINITIONS 18 2.1 Action: this pending federal lawsuit is Case No. CV 21-01787- 19 ODW(RAOx). 20 2.2 Challenging Party: a Party or Non-Party that challenges the 21 designation of information or items under this Order. 22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 23 how it is generated, stored or maintained) or tangible things that qualify for 24 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 25 the Good Cause Statement. 26 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 27 their support staff). 28 / / / 4 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 5 of 16 Page ID #:407

1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things) that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association or 15 other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent or advise a party to this Action and 18 have appeared in this Action on behalf of that party or are affiliated with a law firm 19 that has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 and their employees and subcontractors. 5 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 6 of 16 Page ID #:408

1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery 4 Material from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 Protected Material (as defined above), but also (1) any information copied or 8 extracted from Protected Material; (2) all copies, excerpts, summaries, or 9 compilations of Protected Material; and (3) any testimony, conversations, or 10 presentations by Parties or their Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial shall be governed by the orders of the 12 trial judge. This Order does not govern the use of Protected Material at trial. 13 4. DURATION 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 16 as an exhibit at trial becomes public and will be presumptively available to all 17 members of the public, including the press, unless compelling reasons supported by 18 specific factual findings to proceed otherwise are made to the trial judge in advance 19 of the trial. See Kamakana,

(distinguishing “good cause” 20 showing for sealing documents produced in discovery from “compelling reasons” 21 standard when merits-related documents are part of court record). Accordingly, the 22 terms of this protective order do not extend beyond the commencement of the trial. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection 26 under this Order must take care to limit any such designation to specific material 27 that qualifies under the appropriate standards. The Designating Party must 28 designate for protection only those parts of material, documents, items or oral or 6 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 7 of 16 Page ID #:409

1 written communications that qualify so that other portions of the material, 2 documents, items or communications for which protection is not warranted are not 3 swept unjustifiably within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to impose 7 unnecessary expenses and burdens on other parties) may expose the Designating 8 Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 under this Order must be clearly so designated before the material is disclosed or 16 produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix at a minimum, the legend 21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 22 contains protected material. If only a portion of the material on a page qualifies for 23 protection, the Producing Party also must clearly identify the protected portion(s) 24 (e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and 28 before the designation, all of the material made available for inspection shall be 7 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 8 of 16 Page ID #:410

1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must determine which 3 documents, or portions thereof, qualify for protection under this Order. Then, 4 before producing the specified documents, the Producing Party must affix the 5 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 6 portion of the material on a page qualifies for protection, the Producing Party also 7 must clearly identify the protected portion(s) (e.g., by making appropriate markings 8 in the margins). 9 (b) for testimony given in depositions that the Designating Party identifies 10 the Disclosure or Discovery Material on the record, before the close of the 11 deposition all protected testimony. 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, shall 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 material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 28 / / / 8 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 9 of 16 Page ID #:411

1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. 3 6.3 The burden of persuasion in any such challenge proceeding shall be on 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules on the 10 challenge. 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under the 16 conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 13 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 (a) The Receiving Party’s Outside Counsel of Record in this Action, as 27 well as employees of said Outside Counsel of Record to whom it is reasonably 28 necessary to disclose the information for this Action; 9 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 10 of 16 Page ID #:412

1 (b) The officers, directors, and employees (including House Counsel) of 2 the Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) The court and its personnel; 7 (e) Court reporters and their staff; 8 (f) Professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) The author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) During their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 16 will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 deposition testimony or exhibits to depositions that reveal Protected Material may 20 be separately bound by the court reporter and may not be disclosed to anyone except 21 as permitted under this Stipulated Protective Order; and 22 (i) Any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 PRODUCED IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL,” that Party must: 10 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 11 of 16 Page ID #:413

1 (a) Promptly notify in writing the Designating Party. Such notification 2 shall include a copy of the subpoena or court order; 3 (b) Promptly notify in writing the party who caused the subpoena or order 4 to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall include 6 a copy of this Stipulated Protective Order; and 7 (c) Cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action 16 to disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a 20 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 21 produced by Non-Parties in connection with this litigation is protected by the 22 remedies and relief provided by this Order. Nothing in these provisions should be 23 construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 / / / 11 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 12 of 16 Page ID #:414

1 (1) Promptly notify in writing the Requesting Party and the Non-Party that 2 some or all of the information requested is subject to a confidentiality agreement 3 with a Non-Party; 4 (2) Promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (3) Make the information requested available for inspection by the Non- 8 Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court within 10 14 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the discovery 12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and 16 expense of seeking protection in this court of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 18 MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 24 persons to whom unauthorized disclosures were made of all the terms of this Order, 25 and (d) request such person or persons to execute the “Acknowledgment and 26 Agreement to Be Bound” that is attached hereto as Exhibit A. 27 / / / 28 / / / 12 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 13 of 16 Page ID #:415

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 2 OTHERWISE PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 7 procedure may be established in an e-discovery order that provides for production 8 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 9 (e), insofar as the parties reach an agreement on the effect of disclosure of a 10 communication or information covered by the attorney-client privilege or work 11 product protection, the parties may incorporate their agreement in the stipulated 12 protective order submitted to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Local Civil Rule 79-5. Protected Material 23 may only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 / / / 28 / / / 13 STIPULATED PROTECTIVE ORDER Case 2:21-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 14 of 16 Page ID #:416

1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // 14 STIPULATED PROTECTIVE ORDER Case 2:41-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 15o0f16 Page ID #:417

1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7||DATED: January 12, 2022 KJT LA GROUP, LLP 9 _

10 By: Vache Thgmassian +} 11 Caspar S. Jivalagian □ 12 Attorneys for Plaintiff KOHAR KESIAN 3 = 13 Orsi DATED: January 12, 2022 MANNING & KASS Z ei 14 ELLROD, RAMIREZ, TRESTER LLP Bc) 15 =o 1 Lins 17 By: 06 (WAN) Eugene J. Egan 18 Linwood Warren, Jr 19 Attorneys for Defendant TARGET CORPORATION 20 71 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 | DATED: January 19, 2022 24 . 25 Rayedin, Oj. □□□ 26 HON. ROZELLA A. OLIVER United States Magistrate Judge 27 28 15 STIPULATED PROTECTIVE ORDER

Case 2:41-cv-01787-ODW-RAO Document 21 Filed 01/19/22 Page 16o0f16 Page ID #:418

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, Caspar S. Jivalagian, of KJLaw Group declare under penalty of perjury that 4 || I have read in its entirety and understand the Stipulated Protective Order that was 5 || issued by the United States District Court for the Central District of California on 6 || [propose date: January 12, 2022 in the case of 2:21-cv-01787-ODW-RAO | agree 7 ||to comply with and to be bound by all the terms of this Stipulated Protective Order 8 || and I understand and acknowledge that failure to so comply could expose me to 9 || sanctions and punishment in the nature of contempt. I solemnly promise that I will 10 || not disclose in any manner any information or item that is subject to this Stipulated a 11 || Protective Order to any person or entity except in strict compliance with the

> 12 || provisions of this Order. FI 13 I further agree to submit to the jurisdiction of the United States District Court Z 14 || for the Central District of California for enforcing the terms of this Stipulated fc | Protective Order, even if such enforcement proceedings occur after termination of 16 || this action. I hereby appoint Ingrid Calderon of KJLaw Group located at 230 N. ! 17]|Maryland Avenue, Suite 306 Glendale California Telephone 818 873 0181 as my 18 || California agent for service of process in connection with this action or any 19 || proceedings related to enforcement of this Stipulated Protective Order. 20 Executed on this 12" day of January, 2022, at Glendale, California. 21 22 \( □□

54 Caspar S. Jivaslagian 25 26 27 28 16 STIPULATED PROTECTIVE ORDER