1 Eric A. Welter, Bar No. 270591 [email protected] 2 WELTER LAW FIRM, P.C. 20130 Lakeview Center Plaza, Suite 400 3 Ashburn, VA 20147 Telephone: (703) 435-8500 4 Facsimile: (703) 435-8851

5 Julie R. Trotter, Bar No. 209675 Mireya A. R. Llaurado, Bar No. 194882 6 CALL & JENSEN APC 610 Newport Center Drive, Suite 700 7 Newport Beach, CA 92660 Telephone: (949) 717–3000 8 [email protected] [email protected] 9 Attorneys for Defendant 10 7-Eleven, Inc.

11 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 12

13 DIANA BOSS, CASE NO. 1:25-cv-00074-JLT-BAM

14 Plaintiff; Assigned to: Judge Barbara A. McAuliffe

15 v. STIPULATED PROTECTIVE 16 ORDER 7-ELEVEN, INC.; and DOES 1 - 20, 17 inclusive

18 Defendants. 19 20 21 TO THE COURT AND TO ALL INTERESTED PARTIES AND THEIR 22 ATTORNEYS OF RECORD HEREIN: 23 24 Upon review of the Parties’ Stipulated Protective Order Regarding 25 Confidential Information and Documents governing confidential information and 26 documents, to facilitate discovery and the exchange of information, including 27 1 confidentiality of information which is proprietary, contains sensitive business, 2 commercial or other technical information, or personal health, financial or other 3 sensitive information, the uncontrolled release of which would cause competitive or 4 5 personal harm, and for good cause shown, the Court hereby enters the following 6 ORDER: 7 1. This Order shall govern the treatment and handling of all documents or 8 9 other products of discovery produced by either party, or other information derived 10 from discovery. The term “Documents,” as used in this Order, shall mean all 11 documents produced and information supplied in any form, including but not limited 12 13 to documents produced and information produced by the Parties, disclosed through 14 discovery, disclosed through testimony, or contained in briefs, or other documents 15 filed with the Court in this litigation for the purposes of discovery or otherwise. 16 17 Documents as used herein is intended to be comprehensive and includes any and all 18 materials in the broadest sense contemplated by the Federal Rules of Civil 19 20 Procedure. Documents also includes interrogatory answers, responses to requests 21 for admission, and deposition transcripts and exhibits. Documents also includes any 22 pleading, filing, motion, affidavit, declaration, or brief that quotes or summarizes a 23 24 Document. Documents also includes documents or data made available for initial 25 inspection but not chosen by the inspecting Party for copying. 26 1. The term "Confidential Information", as used in this Order, shall mean 27 an individual’s: 1 a. Social Security number, driver’s license, information contained on a 2 state-issued personal or voter identification card; 3 b. Date of birth; 4 5 c. Home or mobile telephone number; 6 d. Email address or addresses; 7 e. Home address or addresses; and 8 9 f. Any other document or information designated as confidential by either 10 party. 11 Any information or Documents may be designated as confidential if a party in 12 13 good faith believes it to be confidential. The parties and their counsel shall act in 14 good faith to restrict the documents, responses and other information designated as 15 confidential to the smallest number possible. In the event any party objects to any 16 17 confidential designation, the objecting party shall notify opposing counsel in writing 18 of the objection within ten (10) days of receipt of the information designated 19 20 confidential. Counsel for the parties then shall confer promptly and, if necessary, the 21 party claiming confidentiality shall seek an Order of the Court pursuant to Local 22 Rule 141 and Rule 26(c) of the Federal Rules of Civil Procedure within ten (10) days 23 24 from the date the party claiming confidentiality receives notice of the objection, 25 unless the parties agree to other arrangements. Where a party makes an objection 26 within the provisions of this Order, no disclosure of the information designated as 27 confidential shall be made until the objection is determined by a court. 1 2. At the time of production, any Document deemed confidential shall be 2 designated as “CONFIDENTIAL” on the front of each one-page Document and on 3 each page of each multi-page document that contains confidential information. Any 4 5 nondocumentary information deemed confidential that is provided in written form 6 shall be noted with the legend “CONFIDENTIAL.” Any Document or written 7 nondocumentary information so designated shall be accorded the confidential 8 9 treatment provided in this Order. If a party desires to designate any Document 10 produced to date in discovery as “CONFIDENTIAL,” counsel shall serve a 11 designation in writing on opposing counsel within fifteen (15) days of execution of 12 13 this Order. 14 3. The failure to designate Documents or information as provided in 15 Paragraphs 2 and 3 of this Order as confidential shall not constitute a waiver of a 16 17 party’s later designation of such records or information as subject to the provisions of 18 this Order. 19 20 4. Should any Confidential Information be used or elicited during the 21 taking of any deposition, counsel shall be afforded an opportunity to designate as 22 confidential any portion of the transcript containing any reference to such 23 24 information. Any portions so designated will be deemed Confidential Information 25 and accorded the protection of this Order. The court reporter or other official making 26 a transcript of the deposition will be advised to identify those pages of the transcript 27 afforded confidential treatment in the table of contents or other appropriate location 1 at the front of the transcript. 2 5. All summaries and exhibits prepared from Confidential Information 3 shall be stamped “CONFIDENTIAL” by counsel causing them to be prepared. 4 5 6. Access to Confidential Information is on a strict “need-to-know” basis 6 and is restricted to the following persons: 7 (a) Counsel of record in this litigation, and their partners, associates, 8 9 and employees who are working on this litigation; 10 (b) Experts and consultants actually retained or employed to consult 11 with, advise, or assist counsel in the preparation or trial of this litigation, provided 12 13 that any such expert or consultant shall be shown a copy of this Stipulated Protective 14 Order and must sign a declaration in the form of Exhibit A; 15 (c) Parties, 16 17 (d) Any witness whom the parties intend to call at trial; 18 (e) The Court; 19 20 (f) Any deponent noticed by either party; and 21 (g) The jury at trial. 22 7. Disclosure or use of Confidential Information is prohibited except as 23 24 provided in paragraphs 7(a)-7(g) unless written consent from the parties is obtained 25 prior to disclosure or use. 26 8. All persons having access to Confidential Information made available 27 pursuant to this Order shall agree not to make any use of Confidential Information 1 except in connection with this litigation and further shall agree not to deliver or 2 transfer Confidential Information to any person not previously authorized by the 3 terms of this Order. 4 5 9. All copies of Confidential Information disclosed under this Order shall 6 be subject to the same restrictions as imposed on the original information. 7 11. The inadvertent or unintentional disclosure of Documents containing 8 9 Confidential Information shall not be construed to be a waiver, in whole or in part, 10 of the Parties’ claims of confidentiality, either as to specific Confidential 11 Information and Documents or as related to Confidential Information and 12 13 Documents. If a party discovers that Documents previously produced should have 14 been designated Confidential, that party shall promptly identify the Documents it 15 intends to designate as Confidential and the basis for designating the Documents as 16 17 such. The Documents shall thereafter be treated as Confidential in accordance with 18 this Order. 19 20 12. In accordance with Local Rule 141, no party shall file a document under 21 seal without first having obtained an order granting leave to file under seal on a 22 showing of particularized need. 23 24 13. Upon the final termination of this litigation (either by settlement, the 25 expiration of time to appeal from an adverse ruling, or the exhaustion of all appellate 26 remedies), counsel shall forward on demand to opposing counsel all Confidential 27 Information, or any extract, summary, or copy of such Confidential Information. 1 Counsel is responsible under the provisions of this paragraph for the return of any 2 Confidential Information given to any person identified in paragraph 7. Counsel may 3 retain attorney work product concerning Confidential Information. 4 5 14. No modification or amendment of this Order is permitted except by a 6 writing signed by counsel for the parties. 7 15. The failure to insist upon full compliance with any of the terms of this 8 9 Order in any instance shall not be deemed to be a waiver of the subsequent right to 10 insist upon full compliance with those terms. 11 16. Nothing contained in this Order shall restrict a party’s use of its own 12 13 Documents and Confidential Information designated as confidential. 14

15 SEEN AND AGREED TO: SEEN AND AGREED TO: 16

17 By: /s/ Michael Freiman, with permission By: /s/ Eric A. Welter Michael Freiman Eric A. Welter 18 Attorney for Plaintiff Attorney for Defendant 19 7-Eleven, Inc. 20

21 22 23 24 25 26 27 1 EXHIBIT A – AGREEMENT AND ACKNOWLEDGEMENT TO BE BOUND

2 3 I, [Print or type full name], 4 of (Address) (City) 5 (Zip Code), declare under penalty of perjury that I have read in its entirety 6 7 and understand the Stipulated Protective Order that was issued by the United States 8 District Court for the Eastern District of California on [date] in the case of Diana 9 Boss v. 7-Eleven, Inc. et al. (Case No. 1:25-cv-00074-JLT-BAM). I agree to 10 11 comply with and to be bound by all the terms of this Stipulated Protective Order and 12 I understand and acknowledge that failure to so comply could expose me to 13 sanctions and punishment in the nature of contempt. I solemnly promise that I will 14 15 not disclose in any manner any information or item that is subject to this Stipulated 16 Protective Order to any person or entity except in strict compliance with the 17 provisions of this Order. I further agree to submit to the jurisdiction of the United 18 19 States District Court for the Eastern District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such enforcement 21 22 proceedings occur after termination of this action. 23 24 25 26 27 1 2 Date: ______________________________________ 3 City and State where sworn and signed: _________________________________ 4 5 6 Printed name: _______________________________ 7

8 9 Signature: __________________________________ 10

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12 13 14

15

16 17 18

19 20 21 22

23 24 25 26

27 1 In addition to the foregoing order, the parties are advised that pursuant to the 2 Local Rules of the United States District Court, Eastern District of California, any 3 documents subject to the protective order to be filed under seal must be 4 5 accompanied by a written request which complies with Local Rule 141 prior to 6 sealing. The party making a request to file documents under seal shall be required to 7 show good cause for documents attached to a non-dispositive motion or compelling 8 9 reasons for documents attached to a dispositive motion. Pintos v. Pacific Creditors 10 Ass’n,

(9th Cir. 2009). Within five (5) days of any approved 11 document filed under seal, the party shall file a redacted copy of the sealed 12 13 document. The redactions shall be narrowly tailored to protect only the information 14 that is confidential or was deemed confidential. 15 Further, the parties shall consider resolving any dispute arising under the 16 17 stipulated protective order according to the Court’s informal discovery dispute 18 procedure. 19 20 21 IT IS SO ORDERED.

22 Dated: May 27, 2025 /s/ Barbara A. McAuliffe _ 23 UNITED STATES MAGISTRATE JUDGE

24 25 26 27