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8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 BERESFORD TREVOR WALL, Case No. 8:24-cv-01680-JWH-KESx 13 Plaintiff, 14 vs. 15 EXPERIAN INFORMATION STIPULATED PROTECTIVE SOLUTIONS, INC., DISCOVER ORDER 16 BANK and DOES 1-25, inclusive, 17 Defendant.

18 19 1. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary, or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may be 23 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 24 the following Stipulated Protective Order. The parties acknowledge that this Order 25 does not confer blanket protections on all disclosures or responses to discovery and 26 that the protection it affords from public disclosure and use extends only to the 27 limited information or items that are entitled to confidential treatment under the 28 applicable legal principles. The parties further acknowledge, as set forth in Section 1 12.3, below, that this Stipulated Protective Order does not entitle them to file 2 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 3 that must be followed and the standards that will be applied when a party seeks 4 permission from the court to file material under seal. 5 6 A. GOOD CAUSE STATEMENT 7 8 This action is likely to involve trade secrets, customer and pricing lists and 9 other valuable research, development, commercial, financial, technical and/or 10 proprietary information for which special protection from public disclosure and from 11 use for any purpose other than prosecution of this action is warranted. Such 12 confidential and proprietary materials and information consist of, among other 13 things, confidential business or financial information, information regarding 14 confidential business practices, or other confidential research, development, or 15 commercial information (including information implicating privacy rights of third 16 parties), information otherwise generally unavailable to the public, or which may be 17 privileged or otherwise protected from disclosure under state or federal statutes, court 18 rules, case decisions, or common law. Accordingly, to expedite the flow of 19 information, to facilitate the prompt resolution of disputes over confidentiality of 20 discovery materials, to adequately protect information the parties are entitled to keep 21 confidential, to ensure that the parties are permitted reasonable necessary uses of such 22 material in preparation for and in the conduct of trial, to address their handling at the 23 end of the litigation, and serve the ends of justice, a protective order for such 24 information is justified in this matter. It is the intent of the parties that information 25 will not be designated as confidential for tactical reasons and that nothing be so 26 designated without a good faith belief that it has been maintained in a confidential, 27 non-public manner, and there is good cause why it should not be part of the public 28 record of this case. 1 2. DEFINITIONS 2 2.1 Action: Wall v. Discover Bank, Inc., No. 8:24-CV-01680-JWH-KESx. 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation 4 of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 6 how it is generated, stored or maintained) or tangible things that qualify for protection 7 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 8 Cause Statement. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 10 their support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless 15 of the medium or manner in which it is generated, stored, or maintained (including, 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8 House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9 Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 2.10 Outside Counsel of Record: attorneys who are not employees of a party 27 to this Action but are retained to represent or advise a party to this Action and have 28 1 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 has appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 Once a case proceeds to trial, all of the information that was designated as 28 confidential or maintained pursuant to this protective order becomes public and will 1 be presumptively available to all members of the public, including the press, unless 2 compelling reasons supported by specific factual findings to proceed otherwise are 3 made to the trial judge in advance of the trial. See Kamakana v. City and County of 4 Honolulu,

(9th Cir. 2006) (distinguishing “good cause” 5 showing for sealing documents produced in discovery from “compelling reasons” 6 standard when merits-related documents are part of court record). Accordingly, the 7 terms of this protective order do not extend beyond the commencement of the trial. 8 Even after final disposition of this litigation, the confidentiality obligations 9 imposed by this Order shall remain in effect until a Designating Party agrees 10 otherwise in writing or a court order otherwise directs. Final disposition shall be 11 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 12 or without prejudice; and (2) final judgment herein after the completion and 13 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 14 including the time limits for filing any motions or applications for extension of time 15 pursuant to applicable law. 16 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection under 20 this Order must take care to limit any such designation to specific material that 21 qualifies under the appropriate standards. The Designating Party must designate for 22 protection only those parts of material, documents, items, or oral or written 23 communications that qualify so that other portions of the material, documents, items, 24 or communications for which protection is not warranted are not swept unjustifiably 25 within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations 27 that are shown to be clearly unjustified or that have been made for an improper 28 purpose (e.g., to unnecessarily encumber the case development process or to impose 1 unnecessary expenses and burdens on other parties) may expose the Designating 2 Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion or portions of the material on a page 17 qualifies for protection, the Producing Party also must clearly identify the protected 18 portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 24 it wants copied and produced, the Producing Party must determine which documents, 25 or portions thereof, qualify for protection under this Order. Then, before producing 26 the specified documents, the Producing Party must affix the “CONFIDENTIAL 27 legend” to each page that contains Protected Material. If only a portion or portions 28 of the material on a page qualifies for protection, the Producing Party also must 1 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 2 margins). 3 (b) for testimony given in depositions that the Designating Party 4 identify the Disclosure or Discovery Material on the record, before the close of the 5 deposition all protected testimony. Transcripts will be treated, in their entirety, as if 6 designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS 7 EYES ONLY” until the expiration of thirty (30) days from the date on which the 8 transcripts were received from the stenographer. 9 (c) for information produced in some form other than documentary 10 and for any other tangible items, that the Producing Party affix in a prominent place 11 on the exterior of the container or containers in which the information is stored the 12 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, shall identify the protected 14 portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 resolution process under Local Rule 37.1 et seq. 28 1 6.3 The burden of persuasion in any such challenge proceeding shall be on 2 the Designating Party. Frivolous challenges, and those made for an improper purpose 3 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 expose the Challenging Party to sanctions. Unless the Designating Party has waived 5 or withdrawn the confidentiality designation, all parties shall continue to afford the 6 material in question the level of protection to which it is entitled under the Producing 7 Party’s designation until the Court rules on the challenge. 8 9 7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1 Basic Principles. A Receiving Party may use Protected Material that is 11 disclosed or produced by another Party or by a Non-Party in connection with this 12 Action only for prosecuting, defending, or attempting to settle this Action. Such 13 Protected Material may be disclosed only to the categories of persons and under the 14 conditions described in this Order. When the Action has been terminated, a Receiving 15 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, 24 as well as employees of said Outside Counsel of Record to whom it is reasonably 25 necessary to disclose the information for this Action; 26 (b) the officers, directors, and employees (including House Counsel) 27 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 28 1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and 7 Professional Vendors to whom disclosure is reasonably necessary for this Action and 8 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information 10 or a custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses ,and attorneys for witnesses, 12 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 13 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 14 will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may be 18 separately bound by the court reporter and may not be disclosed to anyone except as 19 permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting 21 personnel, mutually agreed upon by any of the parties engaged in settlement 22 discussions. 23 \\ 24 25 26 27 28 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 or 9 order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order shall not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 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 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced 26 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 27 information produced by Non-Parties in connection with this litigation is protected 28 by the remedies and relief provided by this Order. Nothing in these provisions should 1 be construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, 3 to produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the 7 Non-Party that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the 10 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 11 reasonably specific description of the information requested; and 12 (3) make the information requested available for inspection by 13 the Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court 15 within 14 days of receiving the notice and accompanying information, the Receiving 16 Party may produce the Non-Party’s confidential information responsive to the 17 discovery request. If the Non-Party timely seeks a protective order, the Receiving 18 Party shall not produce any information in its possession or control that is subject to 19 the confidentiality agreement with the Non-Party before a determination by the court. 20 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 21 of seeking protection in this court of its Protected Material. 22 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 28 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 1 persons to whom unauthorized disclosures were made of all the terms of this Order, 2 and (d) request such person or persons to execute the “Acknowledgment and 3 Agreement to Be Bound” that is attached hereto as Exhibit A. 4 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without prior 12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 parties reach an agreement on the effect of disclosure of a communication or 14 information covered by the attorney-client privilege or work product protection, the 15 parties may incorporate their agreement in the stipulated protective order submitted 16 to the court. 17 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this Protective Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 28 only be filed under seal pursuant to a court order authorizing the sealing of the 1 specific Protected Material at issue. If a Party’s request to file Protected Material 2 under seal is denied by the court, then the Receiving Party may file the information 3 in the public record unless otherwise instructed by the court. 4 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 60 7 days of a written request by the Designating Party, each Receiving Party must return 8 all Protected Material to the Producing Party or destroy such material. As used in this 9 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 summaries, and any other format reproducing or capturing any of the Protected 11 Material. Whether the Protected Material is returned or destroyed, the Receiving 12 Party must submit a written certification to the Producing Party (and, if not the same 13 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 14 (by category, where appropriate) all the Protected Material that was returned or 15 destroyed and (2)affirms that the Receiving Party has not retained any copies, 16 abstracts, compilations, summaries or any other format reproducing or capturing any 17 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 18 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 20 reports, attorney work product, and consultant and expert work product, even if such 21 materials contain Protected Material. Any such archival copies that contain or 22 constitute Protected Material remain subject to this Protective Order as set forth in 23 Section 4 (DURATION). 24 \\ 25 \\ 26 \\ 27 \\ 28 1 || 14. Any violation of this Order may be punished by any and all appropriate 2 || measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 4 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || DATED: February 5, 2025 8 9 || BAF. Jay Rahimi F. Jay Rahimi, Esq. 10 11 12 || DATED: February 5, 2025 13 14 || 2/Arjun P. Rao Arjun P. Rao 15 16 17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 || DATED: February 7, 2025 | Tous E. Seatts 21 || Honorable Karen E. Scott United States Magistrate Judge 23 24 25 26 27 28 14 STIPULATED PROTECTIVE ORDER

1 EXHIB IT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full 5 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 8 of [insert formal name of the case and the 9 number and initials assigned to it by the court]. I agree to comply with and to be 10 bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint [print or type 19 full name] of [print 20 or type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 26 Printed name: 27 28 Signature: