CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 11 ooff 1166 PPaaggee IIDD ##::335784

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION 11 CUAUHTEMOC CEBALLOS, CASE NO. 2:22-cv-07596-JSL-PD 12 Plaintiff, Assigned to Hon. Josephine L. Staton Magistrate Judge Patricia Donahue 13 v. STIPULATED PROTECTIVE 14 ANHEUSER-BUSCH, LLC, a Missouri ORDER Limited Liability Company; and DOES 15 1 through 50, inclusive, Complaint Filed: Sept. 16, 2022 16 Defendants. Final Pretrial Conference: Jan. 26, 2024 17 Trial Date: Not set 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 22 ooff 1166 PPaaggee IIDD ##::335795

1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Stipulated Protective Order does not confer blanket protections on all disclosures 8 or responses to discovery and that the protection it affords from public disclosure 9 and use extends only to the limited information or items that are entitled to 10 confidential treatment under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, personal, commercial, financial, 13 technical and/or proprietary information for which special protection from public 14 disclosure and from use for any purpose other than prosecution of this action is 15 warranted. Such confidential and proprietary materials and information consist of, 16 among other things, confidential business or financial information, information 17 regarding confidential business practices, or other confidential research, 18 development, or commercial information (including information implicating 19 privacy rights of third parties), information otherwise generally unavailable to the 20 public, or which may be privileged or otherwise protected from disclosure under 21 state or federal statutes, court rules, case decisions, or common law. Accordingly, 22 to expedite the flow of information, to facilitate the prompt resolution of disputes 23 over confidentiality of discovery materials, to adequately protect information the 24 parties are entitled to keep confidential, to ensure that the parties are permitted 25 reasonable necessary uses of such material in preparation for and in the conduct of 26 trial, to address their handling at the end of the litigation, and to serve the ends of 27 justice, a protective order for such information is justified in this matter. It is the 28 intent of the parties that information will not be designated as confidential for 2 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 33 ooff 1166 PPaaggee IIDD ##::336706

1 tactical reasons and that nothing will be so designated without a good faith belief 2 that it has been maintained in a confidential, non-public manner, and there is good 3 cause why it should not be part of the public record of this case. 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 8 and the standards that will be applied when a party seeks permission from the Court 9 to 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 16 require good cause showing), and a specific showing of good cause or compelling 17 reasons with proper evidentiary support and legal justification, must be made with 18 respect to Protected Material that a party seeks to file under seal. The parties’ mere 19 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 20 without the submission of competent evidence by declaration, establishing that the 21 material sought to be filed under seal qualifies as confidential, privileged, or 22 otherwise protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, 24 then compelling reasons, not only good cause, for the sealing must be shown, and 25 the relief sought shall be narrowly tailored to serve the specific interest to be 26 protected. See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 27 2010). For each item or type of information, document, or thing sought to be filed 28 or introduced under seal in connection with a dispositive motion or trial, the party 3 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 44 ooff 1166 PPaaggee IIDD ##::336717

1 seeking protection must articulate compelling reasons, supported by specific facts 2 and legal justification, for the requested sealing order. Again, competent evidence 3 supporting the application to file documents under seal must be provided by 4 declaration. 5 Any document that is not confidential, privileged, or otherwise protectable 6 in its entirety will not be filed under seal if the confidential portions can be redacted. 7 If documents can be redacted, then a redacted version for public viewing, omitting 8 only the confidential, privileged, or otherwise protectable portions of the document, 9 shall be filed. Any application that seeks to file documents under seal in their 10 entirety should include an explanation of why redaction is not feasible. 11 2. DEFINITIONS 12 2.1 Action: The above-captioned lawsuit. 13 2.2 Challenging Party: A Party or Nonparty that challenges the 14 designation of information or items under this Stipulated Protective Order. 15 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 18 the Good Cause Statement. 19 2.4 Counsel: Outside Counsel of Record and In-House Counsel (as well 20 as their support staff). 21 2.5 Designating Party: A Party or Nonparty that designates information or 22 items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: All items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that is produced or 27 generated in disclosures or responses to discovery in this matter. 28 4 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 55 ooff 1166 PPaaggee IIDD ##::336728

1 2.7 Expert: A person with specialized knowledge or experience in a 2 matter pertinent to the litigation who has been retained by a Party or its counsel to 3 serve as an expert witness or as a consultant in this Action. 4 2.8 In-House Counsel: Attorneys who are employees of a party to this 5 Action. In-House Counsel does not include Outside Counsel of Record or any 6 other outside counsel. 7 2.9 Nonparty: Any natural person, partnership, corporation, association, 8 or other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: Attorneys who are not employees of a 10 party to this Action but are retained to represent or advise a party to this Action 11 and have appeared in this Action on behalf of that party or are affiliated with a law 12 firm which has appeared on behalf of that party, and includes support staff. 13 2.11 Party: Any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, In-House Counsel, and Outside Counsel 15 of Record (and their support staffs). 16 2.12 Producing Party: A Party or Nonparty that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: Persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: Any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: A Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulated Protective Order cover not only 28 Protected Material, but also (1) any information copied or extracted from Protected 5 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 66 ooff 1166 PPaaggee IIDD ##::336739

1 Material; (2) all copies, excerpts, summaries, or compilations of Protected 2 Material; and (3) any testimony, conversations, or presentations by Parties or their 3 Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Stipulated Protective Order does not govern the use of Protected 6 Material at trial. 7 4. DURATION 8 Once a case proceeds to trial, all of the information that was designated as 9 confidential or maintained pursuant to this Stipulated Protective Order becomes 10 public and presumptively will be available to all members of the public, including 11 the press, unless compelling reasons supported by specific factual findings to 12 proceed otherwise are made to the trial judge in advance of the trial. See 13 Kamakana v. City and County of Honolulu,

(9th Cir. 14 2006) (distinguishing “good cause” showing for sealing documents produced in 15 discovery from “compelling reasons” standard when merits-related documents are 16 part of court record). Accordingly, the terms of this Stipulated Protective Order do 17 not extend beyond the commencement of the trial. 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Nonparty that designates information or items for protection 21 under this Stipulated Protective Order must take care to limit any such designation 22 to specific material that qualifies under the appropriate standards. The Designating 23 Party must designate for protection only those parts of material, documents, items, 24 or oral or written communications that qualify so that other portions of the 25 material, documents, items, or communications for which protection is not 26 warranted are not swept unjustifiably within the ambit of this Stipulated Protective 27 Order. 28 6 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 77 ooff 1166 PPaaggee IIDD ##::336840

1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to 4 impose unnecessary expenses and burdens on other parties) may expose the 5 Designating Party to sanctions. 6 5.2 Manner and Timing of Designations. 7 Except as otherwise provided in this Stipulated Protective Order (see, e.g., 8 Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure or Discovery 9 Material that qualifies for protection under this Stipulated Protective Order must be 10 clearly so designated before the material is disclosed or produced. 11 Designation in conformity with this Stipulated Protective Order requires the 12 following: 13 (a) For information in documentary form (e.g., paper or electronic 14 documents, but excluding transcripts of depositions or other pretrial or trial 15 proceedings), that the Producing Party affix at a minimum, the legend 16 “CONFIDENTIAL” to each page that contains protected material. If only a portion 17 or portions of the material on a page qualifies for protection, the Producing Party 18 also must clearly identify the protected portion(s) (e.g., by making appropriate 19 markings in the margins). 20 A Party or Nonparty that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and 23 before the designation, all of the material made available for inspection shall be 24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 25 documents it wants copied and produced, the Producing Party must determine 26 which documents, or portions thereof, qualify for protection under this Stipulated 27 Protective Order. Then, before producing the specified documents, the Producing 28 Party must affix the legend “CONFIDENTIAL” to each page that contains 7 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 88 ooff 1166 PPaaggee IIDD ##::336851

1 Protected Material. If only a portion or portions of the material on a page qualifies 2 for protection, the Producing Party also must clearly identify the protected 3 portion(s) (e.g., by making appropriate markings in the margins). 4 (b) For testimony given in depositions, that the Designating Party 5 identify the Disclosure or Discovery Material on the record, before the close of the 6 deposition, all protected testimony. 7 (c) For information produced in nondocumentary form, and for any 8 other tangible items, that the Producing Party affix in a prominent place on the 9 exterior of the container or containers in which the information is stored the legend 10 “CONFIDENTIAL.” If only a portion or portions of the information warrants 11 protection, the Producing Party, to the extent practicable, shall identify the 12 protected portion(s). 13 5.3 Inadvertent Failure to Designate. 14 If timely corrected, an inadvertent failure to designate qualified information 15 or items does not, standing alone, waive the Designating Party’s right to secure 16 protection under this Stipulated Protective Order for such material. Upon timely 17 correction of a designation, the Receiving Party must make reasonable efforts to 18 assure that the material is treated in accordance with the provisions of this 19 Stipulated Protective Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. 22 Any Party or Nonparty may challenge a designation of confidentiality at any 23 time that is consistent with the Court’s Scheduling Order. 24 6.2 Meet and Confer. 25 The Challenging Party shall initiate the dispute resolution process, which 26 shall comply with Local Rule 37.1, et seq. 27 28 8 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 99 ooff 1166 PPaaggee IIDD ##::336862

1 6.3 Burden of Persuasion. 2 The burden of persuasion in any such challenge proceeding shall be on the 3 Designating Party. Frivolous challenges, and those made for an improper purpose 4 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 5 expose the Challenging Party to sanctions. Unless the Designating Party has 6 waived or withdrawn the confidentiality designation, all parties shall continue to 7 afford the material in question the level of protection to which it is entitled under 8 the Producing Party’s designation until the Court rules on the challenge. 9 7. ACCESS TO AND USE OF PROTECTED MATERIALS 10 7.1 Basic Principles. 11 A Receiving Party may use Protected Material that is disclosed or produced 12 by another Party or by a Nonparty in connection with this Action only for 13 prosecuting, defending, or attempting to settle this Action. Such Protected Material 14 may be disclosed only to the categories of persons and under the conditions 15 described in this Stipulated Protective Order. When the Action reaches a final 16 disposition, a Receiving Party must comply with the provisions of Section 14 17 below. 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Stipulated Protective Order. 21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 22 Unless otherwise ordered by the Court or permitted in writing by the 23 Designating Party, a Receiving Party may disclose any information or item 24 designated “CONFIDENTIAL” only to: 25 (a) The Receiving Party’s Outside Counsel of Record, as well as 26 employees of said Outside Counsel of Record to whom it is reasonably necessary 27 to disclose the information for this Action; 28 9 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1100 ooff 1166 PPaaggee IIDD ##::336873

1 (b) The officers, directors, and employees (including In-House 2 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 3 this Action; 4 (c) Experts of the Receiving Party to whom disclosure is 5 reasonably necessary for this Action and who have signed the “Acknowledgment 6 and Agreement to Be Bound” (Exhibit A); 7 (d) The Court and its personnel; 8 (e) Court reporters and their staff; 9 (f) Professional jury or trial consultants, mock jurors, and 10 Professional Vendors to whom disclosure is reasonably necessary or this Action 11 and who have signed the “Acknowledgment and Agreement to be Bound” 12 (Exhibit A); 13 (g) The author or recipient of a document containing the 14 information or a custodian or other person who otherwise possessed or knew the 15 information; 16 (h) During their depositions, witnesses, and attorneys for witnesses, 17 in the Action to whom disclosure is reasonably necessary provided: (i) the 18 deposing party requests that the witness sign the “Acknowledgment and 19 Agreement to Be Bound” (Exhibit A); and (ii) the witness will not be permitted to 20 keep any confidential information unless they sign the “Acknowledgment and 21 Agreement to Be Bound,” unless otherwise agreed by the Designating Party or 22 ordered by the Court. Pages of transcribed deposition testimony or exhibits to 23 depositions that reveal Protected Material may be separately bound by the court 24 reporter and may not be disclosed to anyone except as permitted under this 25 Stipulated Protective Order; and 26 (i) Any mediator or settlement officer, and their supporting 27 personnel, mutually agreed upon by any of the parties engaged in settlement 28 discussions. 10 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1111 ooff 1166 PPaaggee IIDD ##::336884

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) Promptly notify in writing the Designating Party. Such 7 notification shall include a copy of the subpoena or court order; 8 (b) Promptly notify in writing the party who caused the subpoena 9 or order to issue in the other litigation that some or all of the material covered by 10 the subpoena or order is subject to this Stipulated Protective Order. Such 11 notification shall include a copy of this Stipulated Protective Order; and 12 (c) Cooperate with respect to all reasonable procedures sought to 13 be pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 with the subpoena or court order shall not produce any information designated in 16 this action as “CONFIDENTIAL” before a determination by the Court from which 17 the subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a 25 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the 27 remedies and relief provided by this Order. Nothing in these provisions should be 28 construed as prohibiting a Non-Party from seeking additional protections. 11 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1122 ooff 1166 PPaaggee IIDD ##::336895

1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non- 6 Party that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this Court within 14 14 days of receiving the notice and accompanying information, the Receiving Party 15 may produce the Non-Party’s confidential information responsive to the discovery 16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 17 not produce any information in its possession or control that is subject to the 18 confidentiality agreement with the Non-Party before a determination by the Court. 19 Absent a court order to the contrary, the Non-Party shall bear the burden and 20 expense of seeking protection in this Court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 25 writing the Designating Party of the unauthorized disclosures, (2) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (3) inform the person 27 or persons to whom unauthorized disclosures were made of all the terms of this 28 12 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1133 ooff 1166 PPaaggee IIDD ##::337806

1 Stipulated Protective Order, and (4) request such person or persons to execute the 2 “Acknowledgment and Agreement to be Bound” (Exhibit A). 3 11. 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 7 protection, the obligations of the Receiving Parties are those set forth in Federal 8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 9 whatever procedure may be established in an e-discovery order that provides for 10 production without prior privilege review. Pursuant to Federal Rule of Evidence 11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 12 of a communication or information covered by the attorney-client privilege or 13 work product protection, the parties may incorporate their agreement in the 14 Stipulated Protective Order submitted to the Court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. 17 Nothing in this Stipulated Protective Order abridges the right of any person 18 to seek its modification by the Court in the future. 19 12.2 Right to Assert Other Objections. 20 By stipulating to the entry of this Stipulated Protective Order, no Party 21 waives any right it otherwise would have to object to disclosing or producing any 22 information or item on any ground not addressed in this Stipulated Protective 23 Order. Similarly, no Party waives any right to object on any ground to the use in 24 evidence of any of the material covered by this Stipulated Protective Order. 25 12.3 Filing Protected Material. 26 A Party that seeks to file under seal any Protected Material must comply 27 with Local Rule 79-5. Protected Material may only be filed under seal pursuant to 28 a court order authorizing the sealing of the specific Protected Material at issue. If a 13 STIPULATED PROTECTIVE ORDER CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1144 ooff 1166 PPaaggee IIDD ##::337817

1 Party's request to file Protected Material under seal is denied by the Court, then the 2 Receiving Party may file the information in the public record unless otherwise 3 instructed by the Court. 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, within sixty (60) days of a written 6 request by the Designating Party, each Receiving Party must return all Protected 7 Material to the Producing Party or destroy such material. As used in this subdivision, 8 “all Protected Material” includes all copies, abstracts, compilations, summaries, and 9 any other format reproducing or capturing any of the Protected Material. Whether 10 the Protected Material is returned or destroyed, the Receiving Party must submit a 11 written certification to the Producing Party (and, if not the same person or entity, to 12 the Designating Party) by the 60-day deadline that (1) identifies (by category, where 13 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 14 that the Receiving Party has not retained any copies, abstracts, compilations, 15 summaries or any other format reproducing or capturing any of the Protected 16 Material. Notwithstanding this provision, Counsel is entitled to retain an archival 17 copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal 18 memoranda; correspondence; deposition and trial exhibits; expert reports; attorney 19 work product; and consultant and expert work product, even if such materials 20 contain Protected Material. Any such archival copies that contain or constitute 21 Protected Material remain subject to this Stipulated Protective Order as set forth in 22 Section 5. 23 14. VIOLATION 24 Any violation of this Stipulated Order may be punished by any and all 25 appropriate measures including, without limitation, contempt proceedings and/or 26 monetary sanctions. 27 28 14 STIPULATED PROTECTIVE ORDER Case 2:22-cv-07596-JLS-PD Document 20 Filed 02/22/23 Page 15o0f16 Page ID #:338

1 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 DATED: _ February 21, 2023 5 O . Dave Malia 6 O. David Natanz1 Jay S. Rothman & Associates 7 Attorneys for Plaintiff Cuauhtemoc Ceballos 9 DATED: February 22, 2023 10 a 11 □ 2 Emma Luevano Kyle DeCamp 13 Mitchell Silberberg & Knupp LLP 14 Attomeys for Defendant Anheuser-Busch, LLC 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 DATED: February 23, 2023 19 20 Liaticcra Denisa 21 Patricia Donahue 7 United States Magistrate Judge 23 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER

CCaassee 22::2222--ccvv--0077559966--JJLLSS--PPDD DDooccuummeenntt 2201 FFiilleedd 0022//2223//2233 PPaaggee 1166 ooff 1166 PPaaggee IIDD ##::337839

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _______________________________ [full name], of 4 ________________________ [address], declare under penalty of perjury that I 5 have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 _______________________ [date] in the case of Cuauhtemoc Ceballos v. 8 Anheuser-Busch, LLC, 2:22-cv-07596-JSL-PD (C.D. Cal. 2022). I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order, and I 10 understand and acknowledge that failure to so comply could expose me to 11 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 Stipulated Protective Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [full name] of _______________________________ [address and telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 24 Signature: ____________________________ 25 Printed Name: ____________________________ 26 Date: ____________________________ 27 City and State Where Sworn and Signed: ____________________________ 28 STIPULATED PROTECTIVE ORDER