1 MKaOreRnG YA. NC,h LoE, BWaIrS N &o. B2O74C8K10IU S LLP 2 Julianne G. Park, Bar No. 312791 300 South Grand Avenue 3 Twenty-Second Floor Los Angeles, CA 90071-3132 4 Tel: +1.213.612.2500 Fax: +1.213.612.2501 5 [email protected] [email protected] 6 MORGAN, LEWIS & BOCKIUS LLP 7 Kevin J. Bohm, Bar No. 329569 Anthony E. Birong, Bar No. 356613 8 600 Anton Boulevard, Suite 1800 Costa Mesa, CA 92626-7653 9 Tel: +1.714.830.0600 Fax: +1.714.830.0700 10 [email protected] [email protected] 11 12 Attorneys for Defendant LOCKHEED MARTIN CORPORATION 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 17 CHRISTIAN SKY WATERS, an Case No.: 2:24-CV-08247-JFW-MAA individual, 18 Plaintiff, 19 STIPULATED PROTECTIVE ORDER vs. 20 LOCKHEED MARTIN 21 CORPORATION, a Maryland Corporation; TERESA SULLIVAN, an 22 individual; COURTNEY BUDGE, an individual; and DOES 1 through 100, 23 inclusive, 24 Defendants. 25

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27 28 1 1. PURPOSES AND LIMITATION 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 or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. The parties further acknowledge, as 11 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a 14 party seeks permission from the Court to file material under seal. 15 16 2. GOOD CAUSE STATEMENT 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 1 discovery materials, to adequately protect information the parties are entitled to 2 keep confidential, to ensure that the parties are permitted reasonable necessary uses 3 of such material in preparation for and in the conduct of trial, to address their 4 handling at the end of the litigation, and to serve the ends of justice, a protective 5 order for such information is justified in this matter. It is the intent of the parties 6 that information will not be designated as confidential for tactical reasons and that 7 nothing be so designated without a good faith belief that it has been maintained in a 8 confidential, non-public manner, and there is good cause why it should not be part 9 of the public record of this case. 10 11 3. DEFINITIONS 12 3.1. Action: Christian Sky Waters v. Lockheed Martin Corporation 13 (Case No.: 2:24-CV-08247-JFW-MAA). 14 3.2. Challenging Party: A Party or Nonparty that challenges the designation 15 of information or items under this Stipulated Protective Order. 16 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 17 how it is generated, stored or maintained) or tangible things that 18 qualify for protection under Federal Rule of Civil Procedure 26(c), and 19 as specified above in the Good Cause Statement. 20 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as 21 their support staff). 22 3.5. Designating Party: A Party or Nonparty that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 3.6. Disclosure or Discovery Material: All items or information, regardless 26 of the medium or manner in which it is generated, stored, or 27 maintained (including, among other things, testimony, transcripts, and 28 tangible things), that is produced or generated in disclosures or 1 responses to discovery in this matter. 2 3.7. Expert: A person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its 4 counsel to serve as an expert witness or as a consultant in this Action. 5 3.8. In-House Counsel: Attorneys who are employees of a party to this 6 Action. In-House Counsel does not include Outside Counsel of Record 7 or any other outside counsel. 8 3.9. Nonparty: Any natural person, partnership, corporation, association, or 9 other legal entity not named as a Party to this action. 10 3.10. Outside Counsel of Record: Attorneys who are not employees of a 11 party to this Action but are retained to represent or advise a party to 12 this Action and have appeared in this Action on behalf of that party or 13 are affiliated with a law firm which has appeared on behalf of that 14 party, and includes support staff. 15 3.11 Party: Any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, In-House Counsel, and 17 Outside Counsel of Record (and their support staffs). 18 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 19 Discovery Material in this Action. 20 3.13. Professional Vendors: Persons or entities that provide litigation 21 support services (e.g., photocopying, videotaping, translating, 22 preparing exhibits or demonstrations, and organizing, storing, or 23 retrieving data in any form or medium) and their employees and 24 subcontractors. 25 3.14. Protected Material: Any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 3.15. Receiving Party: A Party that receives Disclosure or Discovery 28 Material from a Producing Party. 1 4. SCOPE 2 The protections conferred by this Stipulated Protective Order cover not only 3 Protected Material, but also (1) any information copied or extracted from Protected 4 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 5 and (3) any testimony, conversations, or presentations by Parties or their Counsel 6 that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Stipulated Protective Order does not govern the use of Protected 9 Material at trial. 10 11 5. DURATION 12 Once a case proceeds to trial, all of the information that was designated as 13 confidential or maintained pursuant to this Stipulated Protective Order becomes 14 public and presumptively will be available to all members of the public, including 15 the press, unless compelling reasons supported by specific factual findings to 16 proceed otherwise are made to the trial judge in advance of the trial. See 17 Kamakana v. City and County of Honolulu,

(9th Cir. 2006) 18 (distinguishing “good cause” showing for sealing documents produced in discovery 19 from “compelling reasons” standard when merits-related documents are part of 20 court record). Accordingly, the terms of this Stipulated Protective Order do not 21 extend beyond the commencement of the trial. 22 23 6. DESIGNATING PROTECTED MATERIAL 24 6.1 Exercise of Restraint and Care in Desginating Material for Protection. 25 Each Party or Nonparty that designates information or items for 26 protection under this Stipulated Protective Order must take care to limit 27 any such designation to specific material that qualifies under the 28 appropriate standards. The Designating Party must designate for 1 protection only those parts of material, documents, items, or oral or 2 written communications that qualify so that other portions of the 3 material, documents, items, or communications for which protection is 4 not warranted are not swept unjustifiably within the ambit of this 5 Stipulated Protective Order. 6 Mass, indiscriminate, or routinized designations are prohibited. 7 Designations that are shown to be clearly unjustified or that have been 8 made for an improper purpose (e.g., to unnecessarily encumber the 9 case development process or to impose unnecessary expenses and 10 burdens on other parties) may expose the Designating Party to 11 sanctions. 12 6.2 Manner and Timing of Designations. 13 Except as otherwise provided in this Stipulated Protective Order 14 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 15 Disclosure or Discovery Material that qualifies for protection under this 16 Stipulated Protective Order must be clearly so designated before the 17 material is disclosed or produced. 18 Designation in conformity with this Stipulated Protective Order 19 requires the following: 20 (a) For information in documentary form (e.g., paper or electronic 21 documents, but excluding transcripts of depositions or other 22 pretrial or trial proceedings), that the Producing Party affix at a 23 minimum, the legend “CONFIDENTIAL” to each page that 24 contains protected material. If only a portion or portions of the 25 material on a page qualifies for protection, the Producing Party 26 also must clearly identify the protected portion(s) (e.g., by 27 making appropriate markings in the margins). 28 A Party or Nonparty that makes original documents 1 available for inspection need not designate them for protection 2 until after the inspecting Party has indicated which documents it 3 would like copied and produced. During the inspection and 4 before the designation, all of the material made available for 5 inspection shall be deemed “CONFIDENTIAL.” After the 6 inspecting Party has identified the documents it wants copied 7 and produced, the Producing Party must determine which 8 documents, or portions thereof, qualify for protection under this 9 Stipulated Protective Order. Then, before producing the 10 specified documents, the Producing Party must affix the legend 11 “CONFIDENTIAL” to each page that contains Protected 12 Material. If only a portion or portions of the material on a page 13 qualifies for protection, the Producing Party also must clearly 14 identify the protected portion(s) (e.g., by making appropriate 15 markings in the margins). 16 (b) For testimony given in depositions, that the Designating Party 17 identify the Disclosure or Discovery Material on the record, 18 before the close of the deposition, all protected testimony. 19 (c) For information produced in nondocumentary form, and for any 20 other tangible items, that the Producing Party affix in a 21 prominent place on the exterior of the container or containers in 22 which the information is stored the legend “CONFIDENTIAL.” 23 If only a portion or portions of the information warrants 24 protection, the Producing Party, to the extent practicable, shall 25 identify the protected portion(s). 26 6.3 Inadvertent Failure to Designate. 27 If timely corrected, an inadvertent failure to designate qualified 28 information or items does not, standing alone, waive the Designating 1 Party’s right to secure protection under this Stipulated Protective Order 2 for such material. Upon timely correction of a designation, the 3 Receiving Party must make reasonable efforts to assure that the 4 material is treated in accordance with the provisions of this Stipulated 5 Protective Order. 6 7 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 7.1 Timing of Challenges. 9 Any Party or Nonparty may challenge a designation of 10 confidentiality at any time that is consistent with the Court’s Scheduling 11 Order. 12 7.2 Meet and Confer. 13 The Challenging Party shall initiate the dispute process, which 14 shall comply with Local Rule 37.1 et seq., and with Section 4 of Judge 15 Audero’s Procedures (“Mandatory Telephonic Conference for 16 Discovery Disputes”).1 17 7.3 Burden of Persuasion. 18 The burden of persuasion in any such challenge proceeding shall 19 be on the Designating Party. Frivolous challenges, and those made for 20 an improper purpose (e.g., to harass or impose unnecessary expenses 21 and burdens on other parties) may expose the Challenging Party to 22 sanctions. Unless the Designating Party has waived or withdrawn the 23 confidentiality designation, all parties shall continue to afford the 24 material in question the level of protection to which it is entitled under 25 the Producing Party’s designation until the Court rules on the 26 challenge. 27 1 Judge Audero’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-maria-audero. 1 8. ACCESS TO AND USE OF PROTECTED MATERIALS 2 8.1. Basic Principles. 3 A Receiving Party may use Protected Material that is disclosed 4 or produced by another Party or by a Nonparty in connection with this 5 Action only for prosecuting, defending, or attempting to settle this 6 Action. Such Protected Material may be disclosed only to the 7 categories of persons and under the conditions described in this 8 Stipulated Protective Order. When the Action reaches a final 9 disposition, a Receiving Party must comply with the provisions of 10 Section 14 below. 11 Protected Material must be stored and maintained by a 12 Receiving Party at a location and in a secure manner that ensures that 13 access is limited to the persons authorized under this Stipulated 14 Protective Order. 15 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 16 Unless otherwise ordered by the Court or permitted in writing 17 by the Designating Party, a Receiving Party may disclose any 18 information or item designated “CONFIDENTIAL” only to: 19 (a) The Receiving Party’s Outside Counsel of Record, as well as 20 employees of said Outside Counsel of Record to whom it is 21 reasonably necessary to disclose the information for this Action; 22 (b) The officers, directors, and employees (including In-House 23 Counsel) of the Receiving Party to whom disclosure is 24 reasonably necessary for this Action; 25 (c) Experts of the Receiving Party to whom disclosure is reasonably 26 necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 (d) The Court and its personnel; 1 (e) Court reporters and their staff; 2 (f) Professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably 4 necessary or this Action and who have signed the 5 “Acknowledgment and Agreement to be Bound” (Exhibit A); 6 (g) The author or recipient of a document containing the 7 information or a custodian or other person who otherwise 8 possessed or knew the information; 9 (h) During their depositions, witnesses, and attorneys for witnesses, 10 in the Action to whom disclosure is reasonably necessary 11 provided: (i) the deposing party requests that the witness sign 12 the “Acknowledgment and Agreement to Be Bound” (Exhibit 13 A); and (ii) the witness will not be permitted to keep any 14 confidential information unless they sign the “Acknowledgment 15 and Agreement to Be Bound,” unless otherwise agreed by the 16 Designating Party or ordered by the Court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal 18 Protected Material may be separately bound by the court 19 reporter and may not be disclosed to anyone except as permitted 20 under this Stipulated Protective Order; and 21 (i) Any mediator or settlement officer, and their supporting 22 personnel, mutually agreed upon by any of the parties engaged 23 in settlement discussions. 24 25 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 26 PRODUCED IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 28 that compels disclosure of any information or items designated in this Action as 1 “CONFIDENTIAL,” that Party must: 2 (a) Promptly notify in writing the Designating Party. Such notification 3 shall include a copy of the subpoena or court order; 4 (b) Promptly notify in writing the party who caused the subpoena or order 5 to issue in the other litigation that some or all of the material covered 6 by the subpoena or order is subject to this Stipulated Protective Order. 7 Such notification shall include a copy of this Stipulated Protective 8 Order; and 9 (c) Cooperate with respect to all reasonable procedures sought to be 10 pursued by the Designating Party whose Protected Material may be 11 affected. 12 If the Designating Party timely seeks a protective order, the Party served with 13 the subpoena or court order shall not produce any information designated in this 14 action as “CONFIDENTIAL” before a determination by the Court from which the 15 subpoena or order issued, unless the Party has obtained the Designating Party’s 16 permission. The Designating Party shall bear the burden and expense of seeking 17 protection in that court of its confidential material and nothing in these provisions 18 should be construed as authorizing or encouraging a Receiving Party in this Action 19 to disobey a lawful directive from another court. 20 21 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 PRODUCED IN THIS LITIGATION 23 10.1. Application. 24 The terms of this Stipulated Protective Order are applicable to 25 information produced by a Nonparty in this Action and designated as 26 “CONFIDENTIAL.” Such information produced by Nonparties in 27 connection with this litigation is protected by the remedies and relief 28 provided by this Stipulated Protective Order. Nothing in these 1 provisions should be construed as prohibiting a Nonparty from seeking 2 additional protections. 3 10.2. Notification. 4 In the event that a Party is required, by a valid discovery 5 request, to produce a Nonparty’s confidential information in its 6 possession, and the Party is subject to an agreement with the Nonparty 7 not to produce the Nonparty’s confidential information, then the Party 8 shall: 9 (a) Promptly notify in writing the Requesting Party and the 10 Nonparty that some or all of the information requested is subject 11 to a confidentiality agreement with a Nonparty; 12 (b) Promptly provide the Nonparty with a copy of the Stipulated 13 Protective Order in this Action, the relevant discovery 14 request(s), and a reasonably specific description of the 15 information requested; and 16 (c) Make the information requested available for inspection by the 17 Nonparty, if requested. 18 10.3. Conditions of Production. 19 If the Nonparty fails to seek a protective order from this Court within 20 fourteen (14) days after receiving the notice and accompanying 21 information, the Receiving Party may produce the Nonparty’s 22 confidential information responsive to the discovery request. If the 23 Nonparty timely seeks a protective order, the Receiving Party shall not 24 produce any information in its possession or control that is subject to 25 the confidentiality agreement with the Nonparty before a 26 determination by the Court. Absent a court order to the contrary, the 27 Nonparty shall bear the burden and expense of seeking protection in 28 this Court of its Protected Material. 1 2 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 4 Protected Material to any person or in any circumstance not authorized under this 5 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 6 writing the Designating Party of the unauthorized disclosures, (2) use its best efforts 7 to retrieve all unauthorized copies of the Protected Material, (3) inform the person or 8 persons to whom unauthorized disclosures were made of all the terms of this 9 Stipulated Protective Order, and (4) request such person or persons to execute the 10 “Acknowledgment and Agreement to be Bound” (Exhibit A). 11 12 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other 16 protection, the obligations of the Receiving Parties are those set forth in Federal 17 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 18 whatever procedure may be established in an e-discovery order that provides for 19 production without prior privilege review. Pursuant to Federal Rule of Evidence 20 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 21 of a communication or information covered by the attorney-client privilege or work 22 product protection, the parties may incorporate their agreement in the Stipulated 23 Protective Order submitted to the Court. 24 25 13. MISCELLANEOUS 26 13.1 Right to Further Relief. 27 Nothing in this Stipulated Order abridges the right of any person 28 to seek its modification by the Court in the future. 1 13.2 Right to Assert Other Objections. 2 By stipulating to the entry of this Stipulated Protective Order, no 3 Party waives any right it otherwise would have to object to disclosing 4 or producing any information or item on any ground not addressed in 5 this Stipulated Protective Order. Similarly, no Party waives any right to 6 object on any ground to use in evidence of any of the material covered 7 by this Stipulated Protective Order. 8 13.3 Filing Protected Material. 9 A Party that seeks to file under seal any Protected Material must 10 comply with Local Rule 79-5. Protected Material may only be filed 11 under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material at issue. If a Party’s request to file Protected 13 Material under seal is denied by the Court, then the Receiving Party may 14 file the information in the public record unless otherwise instructed by 15 the Court. 16 17 14. FINAL DISPOSITION 18 After the final disposition of this Action, within sixty (60) days of a written 19 request by the Designating Party, each Receiving Party must return all Protected 20 Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if not the 25 same person or entity, to the Designating Party) by the 60-day deadline that 26 (1) identifies (by category, where appropriate) all the Protected Material that was 27 returned or destroyed and (2) affirms that the Receiving Party has not retained any 28 copies, abstracts, compilations, summaries or any other format reproducing or 1 || capturing any of the Protected Material. Notwithstanding this provision, counsel is 2 || entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 3 || and hearing transcripts; legal memoranda; correspondence; deposition and trial 4 || exhibits; expert reports; attorney work product; and consultant and expert work 5 || product, even if such materials contain Protected Material. Any such archival 6 || copies that contain or constitute Protected Material remain subject to this Protective 7 || Order as set forth in Section 5. 8 9] 15. VIOLATION 10 Any violation of this Stipulated Order may be punished by any and all 11 || appropriate measures including, without limitation, contempt proceedings and/or 12 || monetary sanctions. 13 14 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 16 || Dated: February 4, 2025 /s/ Anthony E. Birong 17 Attorney(s) for Plaintiff(s) 18 19 || Dated: February 4, 2025 _/s/ Thomas H. Schelly 20 Attorney(s) for Defendant(s) 21 22 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. ; 23 yw 24 || Dated: February 5, 2025 25 Maria A. Audero 26 United States Magistrate Judge 27 28 15 STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 __________ [address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on ____________ 7 [date] in the case of Christian Sky Waters v. Lockheed Martin Corporation, et al. 8 (Case No.: 2:24-CV-08247-JFW-MAA). I agree to comply with and to be bound by 9 all the terms of this Stipulated Protective Order, and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the nature 11 of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Stipulated 14 Protective 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 17 of this Stipulated Protective Order, even if such enforcement proceedings 18 occur after termination of this action. I hereby appoint 19 [full name] of [address and telephone number] as 20 my California agent for service of process in with this action or any proceedings 21 related to enforcement of this Stipulated Protective Order. 22 23 Signature: __________________________ 24 Printed Name: __________________________ 25 Date: __________________________ 26 City and State Where Sworn and Signed: __________________________ 27 28