[email protected] 2 CEARTAS LEGAL LLP 3 2262 Carmel Valley Road, Suite F Del Mar, California 92014 4 Tel: (858) 356-9759 NOTE: CHANGES MADE BY THE COURT Fax: (619) 374-7389 5 Attorneys for Defendant THE LATINO COALITION, INC. 6

7 John E. Lattin (SBN 167876) 8 OSTERGAR LATTIN JULANDER LLP 9110 Irvine Center Drive 9 Irvine, CA 92618 Telephone: (949) 357-2544 10 Facsimile: (949) 305-4591 E-mail: [email protected] 11 Attorney for Plaintiff HECTOR BARRETO 12

13 UNITED STATES DISTRICT COURT

14 CENTRAL DISTRICT OF CALIFORNIA

15 HECTOR BARRETO, Case No.: 2:24-cv-5227 MRA (JPRx)

16 Plaintiff, AMENDED STIPULATED PROTECTIVE ORDER 17 v. District Judge: 18 THE LATINO COALITION, INC.; and Hon. Monica Ramirez Almadani DOES 1-10, inclusive, Magistrate Judge: 19 Hon. Jean P. Rosenbluth Defendants. 20 Complaint: May 17, 2024 21 Removal: June 21, 2024 Answer: June 20, 2024 22 Trial Date: TBD

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24 25 26 27 28 2 claims against Defendant The Latino Coalition (“Defendant”) (collectively, the 3 “Parties”). 4 Plaintiff’s Statement of Good Cause: 5 The litigation of this action may require Plaintiff, Defendant, and/or 6 third parties to disclose personal, sensitive, confidential, and/or privileged 7 medical and psychological information and records concerning Plaintiff 8 and/or third parties referenced therein (“Confidential Materials”). Plaintiff, 9 Defendant and any referenced third parties have legitimate confidentiality, 10 privilege, and/or privacy expectations in such Confidential Materials, which 11 should be protected from public disclosure. If such Confidential Materials 12 are disclosed or disseminated in an unprotected manner, it may cause 13 substantial harm to Plaintiff, Defendant and any referenced third parties. 14 Defendant’s Statement of Good Cause: 15 Plaintiff and Defendant may produce certain documents in this case 16 that contain confidential financial and third party information. Such 17 information may implicate privileges and/or the privacy interests of the Party 18 or individual and are properly protected through a Fed. R. Civ. P. 26(c) 19 Protective Order. 20 To protect Confidential Materials from unauthorized disclosure 21 outside of this action, the Parties stipulate to the following Protective Order: 22 I. DEFINITIONS 23 1. “Action” means the case entitled Barreto v. The Latino 24 Coalition, currently pending in the Central District of California, Case No. 25 2:24-cv-5227 MRA (JPRx). 26 2. “Materials” are those items and information produced or 27 disclosed by a Party or Party witness in the course of discovery (e.g., initial 28 disclosures, written discovery, requests for production, depositions, 2 and includes, but is not limited to, all items or information, regardless of the 3 medium in which it is contained or the manner in which it is generated, 4 stored, or maintained (including among other things, all materials defined in 5 Fed. R. Evid. Rule 1001, testimony transcripts, recordings and videos, 6 written records or summaries, and tangible things) that are produced, 7 disclosed or generated in Fed. R. Civ. 26 disclosures, written discovery, 8 requests for production, depositions, subpoenas, medical/psychological 9 examination, expert reports/testimony, and other discovery methods in this 10 Action that is, in good faith, deemed to be “Confidential” within the 11 conditions of this Protective Order by the Party to which such Materials 12 belong, to which any such Party has possession, custody or control, or as to 13 which any Party asserts any right or interest. 14 3. “Counsel” will mean outside counsel of record and other 15 attorneys, paralegals, secretaries, and other support staff employed by the 16 law firms for the Parties in this action. 17 4. “Designating Party” means the Party designating Materials as 18 “Confidential.” 19 5. “Disclosing Party” means the Party disclosing to another Party, 20 or to any entity or individual not a party to this Action, Materials designated 21 as “Confidential” by any Party to this Action. 22 6. “Receiving Party” means the Party receiving the Materials 23 designated as “Confidential,” including experts retained by a Party and any 24 other person to whom a Party discloses “Confidential” Material. 25 7. “Submitting Party” means the Party submitting for filing the 26 Materials designated as “Confidential” with the Court. 27 II. GENERAL RULES 28 1. Designation of Materials as “Confidential.” The Parties may 2 been made public and the disclosure of which would violate a Party or non- 3 party’s right of privacy recognized by the United States and/or California 4 Constitution, and/or is protected by a statutory privilege. Notwithstanding 5 the foregoing, “Confidential” Materials shall not include information or 6 documents produced or disclosed that are or become, without violating this 7 Protective Order and apart from production or disclosure in connection with 8 this Action, a matter of public record or publicly available by law or 9 otherwise. 10 2. Good Faith Basis for Designation. The designation by any 11 Designating Party of any Materials as “Confidential” shall constitute a 12 representation such Materials have been reviewed by Counsel for the 13 Designating Party, and there is a good faith basis both in law and fact for 14 such designation. The Designating Party must take care to limit any such 15 designation to specific material that qualifies as “Confidential.” Where a 16 material (e.g., document, writing, photograph, audio or video recording, 17 electronic data or content, transcript, or record) contains information that is 18 “Confidential” and other information that is non-confidential, the 19 Designating Party to the extent practicable shall only designate the specific 20 content that is “Confidential” information. Indiscriminate or routinized 21 designations are prohibited. Upon a showing of good cause, the Court may 22 impose sanctions on a Designating Party for designations that are clearly 23 unjustified or that have been made for an improper purpose (e.g, to 24 unnecessarily encumber the case development process or to impose 25 unnecessary expenses and burdens on other parties). 26 3. Method for Designating Materials as “Confidential.” The 27 designation of Materials as “Confidential” shall be made as follows: 28 a) Documents. Documents or other tangible Materials shall, 2 stamping or labeling the same with the legend “Confidential” on each page 3 containing any such Materials and identifying by highlight or other 4 transparent overlay the specific content or text on the page that is 5 “Confidential”. If the entire content or text on a page is “Confidential,” no 6 highlight or transparent overlay is necessary. 7 b) Electronic data, objects, photographs, video, or other 8 intangible or non-written Material. Any Material that is not a document, 9 including electronic data, objects, film, photographs, videos, intangible or 10 non-written Material, for which it is infeasible or impractical to affix a 11 stamp, label, highlight or overlay identifying the Material, or portions 12 thereof, as “Confidential,” may be designated as “Confidential” by any 13 practical written or electronic means that clearly places the Receiving Party 14 on notice that the Material is designated “Confidential.” 15 c) Deposition Testimony. Deposition Testimony shall be 16 designated “Confidential”: (a) at the taking of the deposition by a statement 17 on the record by Counsel at the time of such disclosure; or (b) by written 18 notice sent to Counsel of record for all Parties thereof within fourteen (14) 19 days after receipt of the deposition transcript, identifying the portions of the 20 transcript to be designated “Confidential.” In both of the foregoing instances, 21 Counsel for the Designating Party shall direct the legend “Confidential” be 22 affixed to the portions of the original and all copies of the transcript 23 containing any such Materials. The Parties shall not permit deposition 24 transcripts to be distributed to persons beyond those specified in Paragraph 25 II.5 below until the relevant period for the designation has expired. The 26 Designating Party will have the right to exclude from attendance at the 27 deposition, during such time as the “Confidential” information is to be 28 disclosed, any person other than the deponent, Counsel (including their staff 2 be privy to the “Confidential” information. 3 d) Materials Subject to Inspection. In the event the Designating 4 Party elects to produce Materials for inspection, no marking need be made 5 by the Designating Party in advance of the initial inspection. For purposes of 6 the initial inspection, all Materials produced will be considered as 7 “Confidential” and must be treated as such pursuant to the terms of this 8 Order. Thereafter, upon selection of specified Materials for copying or 9 reproduction by the inspecting party, the Designating Party must, within a 10 reasonable time prior to producing those Materials to the inspecting party, 11 mark the copies of those Materials that contain “Confidential” information 12 with the appropriate marking. 13 4. Inadvertent Failure to Identify Documents as 14 “Confidential.” Any Party who inadvertently fails to identify Materials as 15 “Confidential” shall have ten business (10) days from the date of discovery 16 of the oversight to correct such failure. Such failure shall be corrected by 17 providing written notice of the error and substituted copies of the 18 inadvertently produced Materials. Upon timely correction of a designation, 19 the Receiving Party must make reasonable efforts to assure the Material is 20 treated in accordance with the provisions of this Protective Order. 21 5. Disclosure of “Confidential” Materials. The Materials 22 designated as “Confidential” pursuant to Paragraph II.1 of this Protective 23 Order shall not be disclosed to any other person or entity without a Court 24 Order, except to: 25 a) Parties. The Parties and directors or employees of the 26 Parties assisting Counsel for the purposes of this Action; 27 b) Counsel. Counsel to the Parties in this Action (outside 28 counsel, of counsel, and in-house counsel), members of their firms, associate 2 temporary employees, and service vendors of such Counsel (including 3 outside copying services and outside litigation support services such as 4 translations services or graphics, design, or document handling 5 services/consultants retained in connection with this Action for purposes of 6 preparing demonstrative or other exhibits for deposition, trial, or other court 7 proceedings); 8 c) Deposition or Trial Witnesses. A potential deposition or 9 trial witness or other percipient witness to Plaintiff’s allegations and/or 10 Defendant’s defenses who reasonably appears to the Disclosing Party to 11 have information concerning or involving the “Confidential” Materials. 12 d) Experts and Consultants. Outside experts and 13 consultants engaged by Counsel or by a Party to assist in this Action, who 14 shall use such Materials solely for purposes of this Action, provided each 15 such outside expert or consultant signs an Acknowledgment in the form 16 attached hereto as Exhibit “A” prior to receiving any “Confidential” 17 Materials. An executed Exhibit “A” shall not be discoverable by the 18 opposing Party except upon Court Order for good cause shown; 19 e) The Court. The Court and its staff and administrative 20 personnel, the jury, Court reporters, videographers, and stenographers 21 employed to take depositions, and any essential personnel retained by the 22 Court; 23 f) Mediators. Professionals engaged as a mediator, 24 arbitrator, or other neutral, and settlement judges; 25 g) Authors/Recipients. Any authors or recipients of the 26 “Confidential” Materials, or anyone who Counsel for the Party believes, in 27 good faith, had access to the “Confidential” Materials before the designation 28 as “Confidential”; and 2 stipulation of the Parties. 3 6. Filing Under Seal. Before any Materials produced in discovery, 4 answers to interrogatories, responses to requests for admissions, deposition 5 transcripts, or other documents which are designated as “Confidential” are 6 filed with the Court for any purpose, the Submitting Party seeking to file 7 such Material must seek permission of the Court to file the Material under 8 seal in full compliance with Local Rule 79-5. No document may be filed 9 under seal, i.e., closed to inspection by the public except pursuant to a Court 10 order that authorizes the sealing of the particular document, or portions of it. 11 A sealing order may issue only upon a showing that the information is 12 privileged or protectable under the law. The request must be narrowly 13 tailored to seek sealing only of the “Confidential” or otherwise privileged 14 Material. Unless otherwise directed by the Court, the Submitting Party must 15 file a ‘public’ version of any document it seeks to file under seal. In the 16 public version, the Submitting Party may redact only that information that is 17 deemed “Confidential.” The Submitting Party should file the redacted 18 document(s) simultaneously with a joint motion or ex parte application 19 requesting that the “Confidential” portions of the document(s) be filed under 20 seal and setting forth good cause for the request. 21 7. Challenges to “Confidential” Designation. At any time after 22 the designation of Material as “Confidential” and consistent with the Court’s 23 scheduling order, Counsel for the Receiving Party may challenge the 24 “Confidential” designation of any such Material (or portion of such Material) 25 by providing to Counsel for the Designating Party a written notice of such 26 challenge identifying the documents, transcripts, or other Materials or items 27 of information challenged and setting forth the reasons for such challenge. In 28 the event Counsel for the Designating Party does not agree to withdraw its 2 (60) days from receipt of the notice in which to seek a further protective 3 order from the Court with respect to the Materials at issue in full compliance 4 with Local Rule 37. The burden shall be on the Designating Party to justify 5 the designation of the Materials as “Confidential.” All challenged Materials 6 for which a protective order is not sought within this sixty (60)-day period 7 shall thereafter not be accorded “Confidential” treatment under the terms of 8 this Protective Order, unless and until otherwise ordered by the Court. This 9 sixty (60)-day period may be reduced or extended by Court Order or by 10 written stipulation of Counsel. The “Confidential” status of the Materials at 11 issue shall be maintained until final ruling by the Court on any application 12 for protective order. Notwithstanding the foregoing, nothing herein shall be 13 construed to modify or waive the Parties’ rights or obligations under the 14 Court’s Civil Chambers Rules, or any other applicable Court Orders 15 regarding the matters described herein. 16 8. Duration of Protective Order/Return of “Confidential” 17 Material. Upon conclusion of the Action (whether by settlement, final order 18 of dismissal, judgment, or otherwise, including the exhaustion of all 19 permissible appeals), all persons and entities having received “Confidential” 20 Materials that are not otherwise available to the public shall destroy such 21 Materials within sixty (60) days after conclusion of the Action, including any 22 copies, excerpts, and summaries of that Material, and must purge all such 23 Material from all machine-readable media on which it resides. If, prior to 24 the conclusion of the Action, or prior to the destruction of “Confidential” 25 Material after the Action, the Designating Party requests the return of 26 “Confidential” Material disclosed by the Designating Party, the Receiving 27 Party shall return the “Confidential” Material to the Designating Party within 28 sixty (60) days after the conclusion of the Action. Notwithstanding the 2 papers, deposition and trial transcripts, deposition and trial exhibits, and 3 attorney work-product (regardless of whether such Materials contain or 4 reference Materials designated as “Confidential” by any Party or non-party), 5 provided such Counsel, and employees and agents of such Counsel, shall not 6 disclose any non-public information contained or referenced in such 7 Materials to any person except pursuant to this Protective Order, other Court 8 Order or agreement with the Designating Party. All Materials, if any, 9 returned to the Parties or their Counsel by the Court likewise shall be 10 disposed of in accordance with this Paragraph. 11 Notwithstanding the above, “Confidential” Materials once admitted 12 into evidence at trial, will be presumptively available to all members of the 13 public, unless compelling reasons supported by specific factual findings to 14 proceed otherwise are made to the trial judge in advance of the trial. 15 Kamakana v. City and County of Honolulu,

(9th Cir. 16 2006) (distinguishing “good cause” showing for sealing documents produced 17 in discovery from “compelling reasons” standard when merits-related 18 documents are part of a court record). Accordingly, unless otherwise 19 ordered by the trial judge, such Material admitted into evidence at trial shall 20 no longer be termed or designated as “Confidential” Material for any reason 21 under the terms of this Protective Order. 22 9. Subpoena or Demand for Production of “Confidential” 23 Materials. If any Receiving Party (or any other person) receiving Materials 24 designated as “Confidential” by this Protective Order is: (a) subpoenaed in, 25 or (b) served with a demand in another action to which he, she, or it is a 26 party, or (c) served with any other legal process by one not a Party to this 27 Action seeking Materials that were produced or designated as “Confidential” 28 by someone other than the Receiving Party, the Receiving Party shall, unless 2 within seven (7) business days of receipt of such subpoena, demand, or legal 3 process, to the Designating Party. The Receiving Party shall cooperate with 4 respect to all reasonable procedures sought to be pursued by the Designating 5 Party. If the Designating Party timely seeks a protective order, the Receiving 6 Party may not produce the requested documents unless ordered to do so by a 7 court. The Designating Party will be responsible for any and all attorneys’ 8 fees and costs incurred in seeking protection of its “Confidential” Material. 9 If the Receiving Party provides notice as required in this Paragraph and the 10 Designating Party fails to timely seek a protective order, disclosure of 11 “Confidential” Materials by the Receiving Party shall not constitute a 12 violation of this Protective Order. The Designating Party shall be solely 13 responsible for timely asserting any objection and seeking a protective order 14 to the requested production. Nothing herein shall be construed as requiring 15 the Receiving Party or anyone else covered by this Protective Order to 16 challenge or appeal any order requiring production of “Confidential” 17 Materials covered by this Protective Order, or to disobey any legal process or 18 court order that may subject such person to any penalties for non- 19 compliance, or to seek any relief from the Court. 20 10. Use of “Confidential” Material is Limited to This Action. No 21 Materials designated “Confidential” may be used by any Party for any reason 22 other than the prosecution or defense of claims in, or the settlement of, the 23 Action. 24 11. Reservation of Rights. Nothing within this Protective Order 25 will prejudice the right of any Party to object to the production of any 26 Materials on the grounds the Materials are protected by any privileges or 27 privacy protections recognized by applicable law, including, but not limited 28 to, the attorney-client privilege, the attorney work product doctrine, the 2 addition, nothing contained in this Protective Order or any designation of 3 “Confidential” Material hereunder, or any failure to make such designation, 4 shall be used or characterized by any Party as an admission by a Party. 5 Nothing in this Protective Order shall be deemed an admission that any 6 particular information designated as “Confidential” is entitled to protection 7 under this Protective Order or any other law. The Parties specifically reserve 8 the right to challenge the designation of any Material as “Confidential.” This 9 Protective Order does not prejudice in any way the rights of any Party to 10 object to the relevancy, authenticity, or admissibility into evidence of any 11 Material subject to this Protective Order, or otherwise constitute or operate 12 as an admission by any Party that any Material is or is not relevant, 13 authentic, or admissible into evidence at any deposition, at trial, or in a 14 hearing. 15 12. Enforcement of Protective Order. Any Party seeking 16 enforcement of this Protective Order against any other Party may petition the 17 Court by properly noticed motion, pursuant to this Court’s rules, including a 18 concise statement of the specific relief sought. 19 13. Continuing Jurisdiction. The Court shall retain jurisdiction for 20 a period of one (1) year after the conclusion of this Action to enforce the 21 terms of the Protective Order. 22 14. Modification of Protective Order by the Parties. This 23 Protective Order may be modified by agreement of the Parties, subject to 24 approval by the Court. 25 15. Modification of Protective Order by the Court. The Court 26 may modify the terms and conditions of the Order for good cause, or in the 27 interest of justice, or on its own order at any time during these proceedings. 28 16. The foregoing is without prejudice to the right of any Party: (a) 1 ||to apply to the Court for a further protective order relating to any 2 ||‘““Confidential” Material subject to this Order; (b) to apply to the Court for an 3 |jorder permitting disclosure of “Confidential” and protected Material, if 4 || necessary. 5 |} IT IS SO STIPULATED. 7 || Dated: December 4, 2024 CEARTAS LEGAL 9 By: /s/ Greg A. Klawitter GREG A. KLAWITTER 10 Attorneys for Defendant THE LATINO COALITION, INC. 12 13 Dated: December 4, 2024 OSTERGAR LATTIN JULANDER LLP 14 By: /s/ John E. Lattin 15 JOHN E. LATTIN 16 Attorney for Plaintiff HECTOR BARRETO 17 18 19 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED 20 hrowhlatt- Dated: December 4, 2024

03 Jean P. Rosenbluth Honorable Jean P. Rosenbluth 24 25 26 27 28

-12-

2 UNITED STATES DISTRICT COURT

3 CENTRAL DISTRICT OF CALIFORNIA

4 HECTOR BARRETO, Case No.: 2:24-cv-5227 MRA (JPRx)

5 Plaintiff, STIPULATED PROTECTIVE ORDER 6 v. District Judge: 7 THE LATINO COALITION, INC.; and Hon. Monica Ramirez Almadani 8 DOES 1-10, inclusive, Magistrate Judge: Hon. Jean P. Rosenbluth 9 Defendants. Complaint: May 17, 2024 10 Removal: June 21, 2024 Answer: June 20, 2024 11 Trial Date: TBD 12 13 I, ____________________________________, declare and say that: 14 1. I am retained as ___________________________________________ 15 by ________________________________________________________________ 16 2. I have received a copy and have read the Stipulated Protective Order 17 entered in Hector Barreto v. The Latino Coalition, Inc., currently pending in the 18 Central District of California, Case No. 2:24-cv-5227 MRA (JPRx) (the “Action”). 19 3. I affirm that I will use any and all “Confidential” Materials, as defined 20 in the Stipulated Protective Order given to, or shared with, me only in a manner 21 authorized by the Stipulated Protective Order and only to assist Counsel in the 22 litigation of this Action. 23 4. I affirm that I will not disclose or discuss such “Confidential” 24 Materials in any manner with anyone other than the persons described in Paragraph 25 II.5 of the Stipulated Protective Order for “Confidential” Materials. 26 5. I acknowledge that, by signing this agreement, I am subjecting myself 27 to the jurisdiction of the United States District Court for the Central District of 28 California with respect to enforcement of the Stipulated Protective Order. 2 any manner contrary to the provisions of the Stipulated Protective Order may 3 subject me to sanctions for contempt of Court. 4 7. I understand that all Materials designated as “Confidential” in the 5 Stipulated Protective Order, including but not limited to all copies thereof or notes 6 made therefrom, shall be maintained in a secure manner and, following the 7 conclusion of this Action, shall be destroyed or returned as required by Paragraph 8 II.8 of the Stipulated Protective Order. 9 I declare under penalty of perjury under the laws of the United States of 10 America that the foregoing is true and correct. Executed on , 11 _____, at ________________, _________________.

12 Date: 13 Signature 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28