Case 4|22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Pagel1of16 Page ID #:255 7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 8 WESTERN DIVISION 10 Civil Action No. 2:22-cv-01037-MCS-MRW WILLIAM JONES, 11 Plaintiff, 12 STIPULATED PROTECTIVE y ORDER 13 , 14 || TRANSUNION RENTAL SCREENING L] Check if submitted without material SOLUTIONS, INC. and REALPAGE, INC. modifications to MRW form 15 || (a/k/a LEASINGDESK SCREENING), 16 17 Defendants. 18 19 | 1. INTRODUCTION 20 1.1 PURPOSES AND LIMITATIONS 71 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public disclosure ?3 |! and from use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the parties hereby stipulate to and petition the Court to enter the 25 following Stipulated Protective Order. The parties acknowledge that this Order does 76 |! not confer blanket protections on all disclosures or responses to discovery and that *7 |! the protection it affords from public disclosure and use extends only to the limited 28

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1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 3 that this Stipulated Protective Order does not entitle them to file confidential 4 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 5 followed and the standards that will be applied when a party seeks permission from 6 the court to file material under seal. 7 1.2 GOOD CAUSE STATEMENT 8 [The parties must provide a statement establishing good cause for the entry of 9 this pretrial protective order. C.f. Oliner v. Kontrabecki,

, 1026 10 (9th Cir. 2014). The parties’ statement must be specific to the facts and issues of 11 this case, including the nature of the action, the type of anticipated discovery, 12 and the potential resulting harm should relevant materials be disclosed publicly. 13 The parties are advised not to rely on boilerplate assertions regarding good 14 cause] 15 Trans Union Rental Screening Solutions, Inc. (“TURSS”) generated multiple 16 consumer reports regarding Plaintiff in response to Plaintiff’s rental applications. 17 Plaintiff alleges that TURSS reported inaccurate and materially misleading 18 information in these consumer reports. The parties acknowledge that the information 19 produced in discovery, regardless of its designation under this Order may contain 20 personal and health information subject to the protections of the Health Insurance 21 Portability and Accountability Act of 1996, the applicable requirements of the 22 Standards for Privacy of Individually Identifiable Health Information and its 23 implementing regulations issued by the U.S. Department of Health and Human 24 Services (45 C.F.R. Parts 160-164; HIPAA Privacy Regulations), and California Civil 25 Code §§ 56 et seq. and 1798.82 et seq., which protect the confidentiality of 26 individually-identifiable personal and health information. Discovery may also involve 27 trade secrets, valuable research, development, financial and/or proprietary 28 2 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 3 of 16 Page ID #:257

1 information for which special protection from public disclosure and from use for any 2 purpose other than the litigation of this Action is warranted. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately 5 protect information the parties are entitled or required to keep confidential, to ensure 6 that the parties are permitted reasonable necessary uses of such material in preparation 7 for and in the conduct of trial, to address their handling at the end of the litigation, 8 and to serve the ends of justice, a protective order for such information is justified in 9 this matter. It is the intent of the parties that information will not be designated as 10 confidential for tactical reasons and that nothing be so designated without a good- 11 faith belief that it has been maintained in a confidential, non-public manner, and there 12 is good cause why it should not be a part of the public record in this Action.2. 13 DEFINITIONS 14 2.1 Action: This pending federal lawsuit, William Jones v. Trans Union 15 Rental Screening Solutions, Inc. et al., Case No. 2:22-cv-01037-MCS-MRW. [this 16 pending federal law suit]. [*Option: consolidated or related actions.] 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 Cause Statement, including but not limited to: 23 (a) Research and development information; 24 (b) Confidential and proprietary policies and procedures; 25 (b) Information prohibited from disclosure by statute; 26 (c) Medical information concerning any individual; 27 (d) Personal identifying information; 28 3 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 4 of 16 Page ID #:258

1 (e) Income tax returns (including attached schedules and forms, W-2 Forms 2 and 1099 Forms). [Note: any request for a two-tiered, attorney-eyes-only 3 protective order that designates certain material as “Highly Confidential” will 4 require a separate and detailed showing of need.] 5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 6 support staff). 7 2.5 Designating Party: a Party or Non-Party that designates information or 8 items that it produces in disclosures or in responses to discovery as 9 “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless 11 of the medium or manner in which it is generated, stored, or maintained (including, 12 among other things, testimony, transcripts, and tangible things), that are produced or 13 generated in disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter 15 pertinent to the litigation who has been retained by a Party or its counsel to serve as 16 an expert witness or as a consultant in this Action. 17 2.8 House Counsel: attorneys who are employees of a party to this Action. 18 House Counsel does not include Outside Counsel of Record or any other outside 19 counsel. 20 2.9 Non-Party: any natural person, partnership, corporation, association, or 21 other legal entity not named as a Party to this action. 22 2.10 Outside Counsel of Record: attorneys who are not employees of a party 23 to this Action but are retained to represent or advise a party to this Action and have 24 appeared in this Action on behalf of that party or are affiliated with a law firm which 25 has appeared on behalf of that party, and includes support staff. 26 2.11 Party: any party to this Action, including all of its officers, directors, 27 employees, consultants, retained experts, and Outside Counsel of Record (and their 28 support staffs). 4 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 5 of 16 Page ID #:259

1 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.13 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) 6 and their employees and subcontractors. 7 2.14 Protected Material: any Disclosure or Discovery Material that is 8 designated as “CONFIDENTIAL.” 9 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 10 from a Producing Party. 11 12 3. SCOPE 13 The protections conferred by this Stipulation and Order cover not only 14 Protected Material (as defined above), but also (1) any information copied or extracted 15 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 16 Protected Material; and (3) any testimony, conversations, or presentations by Parties 17 or their Counsel that might reveal Protected Material. 18 Any use of Protected Material at trial will be governed by the orders of the trial 19 judge. This Order does not govern the use of Protected Material at trial. 20 21 4. DURATION 22 23 24 Even after final disposition of this litigation, the confidentiality obligations 25 imposed by this Order will remain in effect until a Designating Party agrees otherwise 26 in writing or a court order otherwise directs. Final disposition will be deemed to be 27 the later of (1) dismissal of all claims and defenses in this Action, with or without 28 prejudice; and (2) final judgment herein after the completion and exhaustion of all 5 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 6 of 16 Page ID #:260

1 appeals, rehearings, remands, trials, or reviews of this Action, including the time 2 limits for filing any motions or applications for extension of time pursuant to 3 applicable law. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under this 8 Order must take care to limit any such designation to specific material that qualifies 9 under the appropriate standards. The Designating Party must designate for protection 10 only those parts of material, documents, items, or oral or written communications that 11 qualify so that other portions of the material, documents, items, or communications 12 for which protection is not warranted are not swept unjustifiably within the ambit of 13 this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating Party 18 to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 25 under this Order must be clearly so designated before the material is disclosed or 26 produced. 27 Designation in conformity with this Order requires: 28 6 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 7 of 16 Page ID #:261

1 (a) for information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 3 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion or portions of the material on a page qualifies for protection, the Producing 6 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 7 markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and before 11 the designation, all of the material made available for inspection will be deemed 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or 14 portions thereof, qualify for protection under this Order. Then, before producing the 15 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 16 to each page that contains Protected Material. If only a portion or portions of the 17 material on a page qualifies for protection, the Producing Party also must clearly 18 identify the protected portion(s) (e.g., by making appropriate markings in the 19 margins). 20 (b) for testimony given in depositions that the Designating Party identify the 21 Disclosure or Discovery Material and all protected testimony on the record, either 22 before the close of the deposition or within 21 days following receipt of the deposition 23 transcript.. 24 (c) for information produced in some form other than documentary and for any 25 other tangible items, that the Producing Party affix in a prominent place on the exterior 26 of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 28 7 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 8 of 16 Page ID #:262

1 protection, the Producing Party, to the extent practicable, will identify the protected 2 portion(s). 3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 failure to designate qualified information or items does not, standing alone, waive the 5 Designating Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must make reasonable 7 efforts to assure that the material is treated in accordance with the provisions of this 8 Order. 9 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 12 designation of confidentiality at any time that is consistent with the Court’s 13 Scheduling Order. 14 6.2 Meet and Confer. The Challenging Party will initiate the dispute 15 resolution process under Local Rule 37.1 et seq. 16 6.3 The burden of persuasion in any such challenge proceeding will be on 17 the Designating Party. Frivolous challenges, and those made for an improper purpose 18 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 19 expose the Challenging Party to sanctions. Unless the Designating Party has waived 20 or withdrawn the confidentiality designation, all parties will continue to afford the 21 material in question the level of protection to which it is entitled under the Producing 22 Party’s designation until the Court rules on the challenge. 23 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending, or attempting to settle this Action. Such 28 Protected Material may be disclosed only to the categories of persons and under the 8 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 9 of 16 Page ID #:263

1 conditions described in this Order. When the Action has been terminated, a Receiving 2 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 as employees of said Outside Counsel of Record to whom it is reasonably necessary 12 to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the Court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, jurors, and 21 Professional Vendors to whom disclosure is reasonably necessary for this Action and 22 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 28 not be permitted to keep any confidential information unless they sign the 9 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 10 of 16 Page ID #:264

1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may be 4 separately bound by the court reporter and may not be disclosed to anyone except as 5 permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 10 OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation 12 that compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification will 15 include a copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or order 17 to issue in the other litigation that some or all of the material covered by the subpoena 18 or order is subject to this Protective Order. Such notification will include a copy of 19 this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be pursued 21 by the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with 23 the subpoena or court order will not produce any information designated in this action 24 as “CONFIDENTIAL” before a determination by the court from which the subpoena 25 or order issued, unless the Party has obtained the Designating Party’s permission. The 26 Designating Party will bear the burden and expense of seeking protection in that court 27 of its confidential material and nothing in these provisions should be construed as 28 10 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 11 of 16 Page ID #:265

1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 3 4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 5 PRODUCED IN THIS LITIGATION 6 (a) The terms of this Order are applicable to information produced by a 7 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 8 produced by Non-Parties in connection with this litigation is protected by the 9 remedies and relief provided by this Order. Nothing in these provisions should be 10 construed as prohibiting a Non-Party from seeking additional protections. 11 (b) In the event that a Party is required, by a valid discovery request, to 12 produce a Non-Party’s confidential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party’s 14 confidential information, then the Party will: 15 (1) promptly notify in writing the Requesting Party and the Non-Party 16 that some or all of the information requested is subject to a confidentiality agreement 17 with a Non-Party; 18 (2) promptly provide the Non-Party with a copy of the Stipulated 19 Protective Order in this Action, the relevant discovery request(s), and a reasonably 20 specific description of the information requested; and 21 (3) make the information requested available for inspection by the Non- 22 Party, if requested. 23 (c) If the Non-Party fails to seek a protective order from this court within 24 14 days of receiving the notice and accompanying information, the Receiving Party 25 may produce the Non-Party’s confidential information responsive to the discovery 26 request. If the Non-Party timely seeks a protective order, the Receiving Party will not 27 produce any information in its possession or control that is subject to the 28 confidentiality agreement with the Non-Party before a determination by the court. 11 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 12 of 16 Page ID #:266

1 Absent a court order to the contrary, the Non-Party will 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 28 12 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 13 of 16 Page ID #:267

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 specific 12 Protected Material at issue. If a Party's request to file Protected Material under seal 13 is denied by the court, then the Receiving Party may file the information in the public 14 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 this 20 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 28 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 13 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 14 of 16 Page ID #:268

1 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 reports, attorney work product, and consultant and expert work product, even if such 4 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 4 (DURATION). 7 8 14. Any willful violation of this Order may be punished by any and all appropriate 9 measures, including, without limitation, contempt proceedings and/or monetary 10 sanctions. 11 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 14 DATED: September 9, 2022 /s/ Youssef H. Hammoud Attorneys for Plaintiff 15 William Jones 16 17 DATED: September 9, 2022 /s/ Kristin L. Marker Attorneys for Defendant 18 Transunion Rental Screening Solutions, Inc. 19 20 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 25 DATED: _____0_9_/0_6_/_2_0_2_2__ __________/_S_/______________________ 26 HON. MICHAEL R. WILNER United States Magistrate Judge 27 28 14 Case 2:22-cv-01037-MCS-MRW Document 41 Filed 09/06/22 Page 15 of 16 Page ID #:269

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of William 8 Jones v. Trans Union Rental Screening Solutions, Inc. et al., Case No. 2:22-cv-01037. 9 I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me 11 to sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 16