1 2A1n2d1r eAwv Len. uTer eogf etrh e(S SBtaNrs 2, 4S0u6it3e7 8) 00 2 Los Angeles, CA 90067 Tel: (310) 226-7570 3 Fax: (310) 226-7571 Email: [email protected] 4 DOUGLAS AND LONDON, P.C. 5 Chloe Makowsky, Esq. (Admitted Pro Hac Vice) 6 59 Maiden Lane, 6th Floor New York, NY 10038 7 Tel: (212) 566-7500 Fax: (212) 566-7501 8 Email: [email protected]

9 Attorneys for Plaintiff T.B.

10 [Additional Counsel Listed on Signature Page] 11 12 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 WESTERN DIVISION

16

17 T.B., an individual, Case No. 2:24-cv-11220-HDV-AJR 18 Plaintiff, v. [PROPOSED] STIPULATED 19 PROTECTIVE ORDER G6 HOSPITALITY PROPERTY 20 LLC,

21 Defendant. 22 23 1. GENERAL 24 1.1 Purposes and Limitations. Discovery in this action is likely to involve 25 production of confidential, proprietary, or private information for which special 26 protection from public disclosure and from use for any purpose other than prosecuting 27 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 28 petition the Court to enter the following Stipulated Protective Order. The parties 1 acknowledge that this Order does not confer blanket protections on all disclosures or 2 responses to discovery and that the protection it affords from public disclosure and 3 use extends only to the limited information or items that are entitled to confidential 4 treatment under the applicable legal principles. The parties further acknowledge, as 5 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 6 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 7 procedures that must be followed and the standards that will be applied when a party 8 seeks permission from the court to file material under seal. 9 1.2 Good Cause Statement. 10 This action is likely to involve confidential, proprietary, and/or private 11 information for which special protection from public disclosure and from use for any 12 purpose other than prosecution of this action is warranted. Such confidential and 13 proprietary materials and information consist of, among other things, Plaintiff’s 14 Identity, confidential business or financial information, information regarding 15 confidential business practices, information otherwise generally unavailable to the 16 public, or which may be privileged or otherwise protected from disclosure under state 17 or federal statutes, court rules, case decisions, or common law. Accordingly, to 18 expedite the flow of information, to facilitate the prompt resolution of disputes over 19 confidentiality of discovery materials, to adequately protect information the parties 20 are entitled to keep confidential, to ensure that the parties are permitted reasonable 21 necessary uses of such material in preparation for and in the conduct of trial, to address 22 their handling at the end of the litigation, and serve the ends of justice, a protective 23 order for such information is justified in this matter. It is the intent of the parties that 24 information will not be designated as confidential for tactical reasons and that nothing 25 be so designated without a good faith belief that it has been maintained in a 26 confidential, non-public manner, and there is good cause why it should not be part of 27 the public record of this case. 28 Plaintiff further represents that she believes in good faith that the alleged 1 trafficker(s) and the traffickers’ associates present an ongoing threat to the safety of 2 her and her family members, and that the disclosure of Plaintiff’s Identity within the 3 context of this Action will increase that threat as well as the social stigma associated 4 with being a trafficking victim. Plaintiff represents that she has taken steps to prevent 5 disclosure of Plaintiff’s Identity in conjunction with this Action, that she is unaware 6 of any public disclosure of Plaintiff’s Identity in conjunction with this Action, and 7 that she does not intend to publicly disclose her Identity in conjunction with this 8 Action, on social media or otherwise. If Defendants become aware of any public 9 disclosure of Plaintiff’s Identity in conjunction with this Action by Plaintiff or her 10 Counsel, Defendants may apply to the Court for relief from the restrictions imposed 11 in this Protective Order related to non-disclosure of Plaintiff’s Identity. 12 13 2. DEFINITIONS 14 2.1 Action: this pending federal lawsuit, T.B. v. G6 Hospitality Property 15 LLC, case number 2:24-cv-11220, presently pending in the United States District 16 Court for the Central District of California. 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 24 support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced or 4 generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.9 Non-Party: any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 to this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm that 16 has appeared on behalf of that party, including support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.12 “PLAINTIFF’S IDENTITY” Information or Items: Plaintiff’s 21 personally identifiable information, including: [1] names and aliases used by Plaintiff 22 at any time; [2] Plaintiff’s date of birth; [3] Plaintiff’s social security number; [4] 23 Plaintiff’s current and prior residential address; [5] Plaintiff’s current and prior phone 24 numbers and active and inactive social media or online user accounts; [6] Plaintiff’s 25 physical description, including weight, hair color, eye color, ethnicity, tattoos, and 26 piercings; [7] videos, photographs, or other depictions of Plaintiff; and [8] the names 27 of Plaintiff’s biological or adoptive parents, siblings, children, and spouse, if any. 28 1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.14 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, facilitating responses to discovery requests, and organizing, storing, 6 or retrieving data in any form or medium) and their employees and subcontractors. 7 2.15 Protected Material: any Disclosure or Discovery Material that is 8 designated as “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY”. 9 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 10 from a Producing Party. 11 12 3. SCOPE 13 The protections conferred by this Stipulation and Order cover not only 14 Protected Material (as defined above), but also (1) any information copied or extracted 15 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 16 Protected Material; and (3) any testimony, conversations, or presentations by Parties 17 or their Counsel that might reveal Protected Material. 18 Any use of Protected Material at trial shall be governed by the orders of the 19 trial judge. This Order does not govern the use of Protected Material at trial. 20 21 4. DURATION 22 Once a case proceeds to trial, all of the court-filed information to be introduced 23 that was previously designated as Protected Material or maintained pursuant to this 24 protective order becomes public and will be presumptively available to all members 25 of the public, including the press, unless compelling reasons supported by specific 26 factual findings to proceed otherwise are made to the trial judge in advance of the 27 trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 (9th Cir. 28 2006) (distinguishing “good cause” showing for sealing documents produced in 1 discovery from “compelling reasons” standard when merits-related documents are 2 part of court record). Accordingly, the terms of this protective order do not extend 3 beyond the commencement of the trial. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under this 8 Order must take care to limit any such designation to specific material that qualifies 9 under the appropriate standards. The Designating Party must designate for protection 10 only those parts of material, documents, items, or oral or written communications that 11 qualify so that other portions of the material, documents, items, or communications 12 for which protection is not warranted are not swept unjustifiably within the ambit of 13 this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating Party 18 to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 25 under this Order must be clearly so designated before the material is disclosed or 26 produced. 27 Designation in conformity with this Order requires: 28 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix, at a minimum, the legend 4 “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY” (hereinafter “Protected Material 5 legend”), to each page that contains protected material. If only a portion or portions 6 of the material on a page qualifies for protection, the Producing Party also must clearly 7 identify the protected portion(s) (e.g., by making appropriate markings in the 8 margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and 12 before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY”. After the inspecting 14 Party has identified the documents it wants copied and produced, the Producing Party 15 must determine which documents, or portions thereof, qualify for protection under 16 this Order. Then, before producing the specified documents, the Producing Party 17 must affix the “Protected Material legend” to each page that contains Protected 18 Material. If only a portion or portions of the material on a page qualifies for 19 protection, the Producing Party also must clearly identify the protected portion(s) 20 (e.g., by making appropriate markings in the margins). 21 (b) for testimony given in depositions that the Designating Party identify 22 the Disclosure or Discovery Material on the record, before the close of the deposition. 23 (c) for information produced in some form other than documentary and 24 for any other tangible items, that the Producing Party affix in a prominent place on 25 the exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY”. If only a portion or portions of 27 the information warrants protection, the Producing Party, to the extent practicable, 28 shall identify the protected portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 8 6. CHALLENGING PROTECTED MATERIAL DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of Protected Material at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 14 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 15 6.3 Burden. The burden of persuasion in any such challenge proceeding 16 shall be on the Designating Party. Frivolous challenges, and those made for an 17 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 18 other parties) may expose the Challenging Party to sanctions. Unless the Designating 19 Party has waived or withdrawn the confidentiality designation, all parties shall 20 continue to afford the material in question the level of protection to which it is entitled 21 under the Producing Party’s designation until the Court rules on the challenge. 22 23 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material that is 25 disclosed or produced by another Party or by a Non-Party in connection with this 26 Action only for prosecuting, defending, or attempting to settle this Action. Such 27 Protected Material may be disclosed only to the categories of persons and under the 28 1 conditions described in this Order. When the Action has been terminated, a Receiving 2 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the Court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 11 well as employees of said Outside Counsel of Record to whom it is reasonably 12 necessary to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of 14 the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the Court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or 24 a custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in 26 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 27 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 28 will not be permitted to keep any confidential information unless they sign the 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the Court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may be 4 separately bound by the court reporter and may not be disclosed to anyone except as 5 permitted under this Stipulated Protective Order; 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions; 8 (j) Professional Vendors retained by the Parties, so long as a 9 representative with authority to bind the Professional Vendor has signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (k) Government agencies and agency personnel, but only to the extent 12 that the Party reasonably believes disclosure of the Protected Material is potentially 13 necessary to litigate any claims or defenses or to comply with any obligations or 14 requirements; and 15 (l) such other persons as hereafter may be designated by written 16 agreement in this Action or by order of the Court and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 18 7.3 Accessing and Use of Plaintiff’s Identity. 19 (a) During all pre-trial proceedings in this Action and in any pre-trial 20 public filing, the Parties must either redact Plaintiff’s Identity or use the pseudonym 21 “Jane Doe” or “T.B.” in place of Plaintiff’s Identity. 22 (b) Within three days of the entry of this Order by the Court, Plaintiff 23 shall provide Defendant, through its Counsel, with the following: 24 (1) Plaintiff’s full name, maiden name, and alias names used at 25 any time; 26 (2) Plaintiff’s date of birth; 27 (3) The last four digits of Plaintiff’s Social Security Number; 28 1 (4) Plaintiff’s current address and prior addresses from 2018 to 2 present; and 3 (5) The names and aliases of Plaintiff’s trafficker(s), including any 4 known associates of the trafficker(s). 5 Nothing in this Order shall prevent a Party from requesting from Plaintiff 6 during the course of discovery any other information that is linked or linkable to the 7 true identity of Plaintiff or her trafficker(s) and their known associates, such as, but 8 not limited to, any medical, educational, financial, employment, or other information. 9 Relatedly, nothing in this Order relieves Plaintiff of the obligation to produce any 10 discoverable documents or information that Plaintiff intends to rely upon at trial. The 11 protections conferred by this Order do not cover information that is in the public 12 domain or becomes part of the public domain through trial or otherwise. 13 7.4 Disclosure of “PLAINTIFF’S IDENTITY” Information or Items. 14 Unless otherwise ordered by the Court or permitted in writing by the Designating 15 Party, a Receiving Party may disclose any information or item designated 16 “PLAINTIFF’S IDENTITY” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 18 well as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) law enforcement agencies and agency personnel, but only to the 21 extent that the Party reasonably believes disclosure of Plaintiff’s Identity is necessary 22 to litigate any claims or defenses or to comply with any Party’s discovery obligations 23 or requirements; 24 (c) the officers, directors, and employees (including House Counsel) of 25 the Receiving Party to whom disclosure is reasonably necessary for this Action; 26 (d) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (e) Insurers for any of the Parties, including coverage counsel for the 2 insurers, who have or may provide indemnity or other coverage in connection with 3 the claims asserted in this Action so long as a representative with authority to bind 4 the insurer signs the “Acknowledgment and Agreement to Be Bound” (Exhibit A) on 5 behalf of the insurer; 6 (f) the Court and its personnel; 7 (g) court reporters and their staff; 8 (h) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (i) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (j) during their depositions, witnesses, and attorneys for witnesses in the 14 Action, except and excluding Plaintiff’s traffickers and their associates, to whom 15 disclosure is reasonably necessarily provided: (1) the deposing party requests that the 16 witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 17 to keep any “Plaintiff’s Identity” information unless they sign the “Acknowledgment 18 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 19 Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits 20 to depositions that reveal Protected Material may be separately bound by the court 21 reporter and may not be disclosed to anyone except as permitted under this Stipulated 22 Protective Order; 23 (k) any mediator or settlement officer, and their supporting personnel, 24 mutually agreed upon by any of the parties engaged in settlement discussions. 25 (l) government agencies and agency personnel, but only to the extent 26 that the Party reasonably believes disclosure of Plaintiff’s Identity is necessary to 27 litigate any claims or defenses or to comply with any obligations or requirements; 28 1 (m) the Plaintiff’s alleged trafficker(s) and/or the alleged trafficker(s)’ 2 associates (as disclosed by Plaintiff pursuant to Section 7.3(b) of this Protective 3 Order), but only after providing 30-day notice to Plaintiff of the intention to contact 4 the trafficker to permit Plaintiff to seek further protection from the Court should it be 5 necessary. Neither Plaintiff nor any person or entity acting on Plaintiff’s behalf may 6 communicate with the trafficker or the trafficker’s identified associates during the 7 notice period. Plaintiff’s Identity will be revealed to the trafficker and/or the 8 trafficker’s identified associates only to the extent necessary to assist in their 9 recollection of Plaintiff and/or her trafficking history. Plaintiff’s and Plaintiff’s 10 family’s physical location will never be disclosed to Plaintiff’s trafficker and/or the 11 trafficker’s identified associates; and 12 (o) such other persons as hereafter may be designated by written 13 agreement in this Action or by order of the Court and who execute the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 15 16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in other litigation 19 that compels disclosure of any information or items designated in this Action as 20 “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY” that Party must: 21 (a) promptly notify in writing the Designating Party. Such notification shall 22 include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the subpoena or order to 24 issue in the other litigation that some or all of the material covered by the subpoena 25 or order is subject to this Protective Order. Such notification shall include a copy of 26 this Stipulated Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to be pursued 28 by the Designating Party whose Protected Material may be affected. 1 If the Designating Party timely seeks a protective order, the Party served with 2 the subpoena or court order shall not produce any information designated in this action 3 as “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY” before a determination by the 4 court from which the subpoena or order issued, unless the Party has obtained the 5 Designating Party’s permission. The Designating Party shall bear the burden and 6 expense of seeking protection in that court of its confidential material and nothing in 7 these provisions should be construed as authorizing or encouraging a Receiving Party 8 in this Action to disobey a lawful directive from another court. 9 10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a Non- 13 Party in this Action and designated as “CONFIDENTIAL” or “PLAINTIFF’S 14 IDENTITY.” Such information produced by Non-Parties in connection with this 15 litigation is protected by the remedies and relief provided by this Order. Nothing in 16 these provisions should be construed as prohibiting a Non-Party from seeking 17 additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to produce 19 a Non-Party’s confidential information in its possession, and the Party is subject to an 20 agreement with the Non-Party not to produce the Non-Party’s confidential 21 information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the Non-Party 23 that some or all of the information requested is subject to a confidentiality agreement 24 with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated 26 Protective Order in this Action, the relevant discovery request(s), and a reasonably 27 specific description of the information requested; and 28 1 (3) make the information requested available for inspection by the Non- 2 Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this Court within 14 4 days of receiving the notice and accompanying information, the Receiving Party may 5 produce the Non-Party’s confidential information responsive to the discovery request. 6 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 7 any information in its possession or control that is subject to the confidentiality 8 agreement with the Non-Party before a determination by the Court. Absent a court 9 order to the contrary, the Non-Party shall bear the burden and expense of seeking 10 protection in this Court of its Protected Material. 11 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of this Order, 19 and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 may be established in an e-discovery order that provides for production without prior 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted 5 to the Court. 6 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order, no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the specific 18 Protected Material at issue; good cause must be shown in the request to file under 19 seal. If a Party’s request to file Protected Material under seal is denied by the Court, 20 then the Receiving Party may file the information in the public record unless 21 otherwise instructed by the Court. 22 23 13. FINAL DISPOSITION 24 After the final disposition of this Action, within 60 days of a written request by 25 the Designating Party, each Receiving Party must return all Protected Material to the 26 Producing Party or destroy such material. As used in this subdivision, “all Protected 27 Material” includes all copies, abstracts, compilations, summaries, and any other 28 format reproducing or capturing any of the Protected Material. Whether the Protected 1 Material is returned or destroyed, the Receiving Party must submit a written 2 certification to the Producing Party (and, if not the same person or entity, to the 3 Designating Party) by the 60 day deadline that (1) identifies (by category, where 4 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 5 that the Receiving Party has not retained any copies, abstracts, compilations, 6 summaries or any other format reproducing or capturing any of the Protected Material. 7 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 8 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 9 correspondence, deposition and trial exhibits, expert reports, attorney work product, 10 and consultant and expert work product, even if such materials contain Protected 11 Material. Any such archival copies that contain or constitute Protected Material 12 remain subject to this Protective Order as set forth in Section 4 (DURATION). 13 14 14. VIOLATION OF ORDER 15 Any violation of this Order may be punished by any and all appropriate 16 measures including, without limitation, contempt proceedings and/or monetary 17 sanctions.

18 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 20 DATED: 6/17/2025 21 /s/ Chloe Makowsky 22 Counsel for Plaintiff 23 DOUGLAS AND LONDON, P.C. 24 Chloe Makowsky, Esq. (Admitted Pro Hac Vice) 25 59 Maiden Lane, 6th Floor New York, NY 10038 26 Tel: (212) 566-7500 Fax: (212) 566-7501 27 Email: [email protected]

28 BAER TREGER LLP 1 2L1o2s1 A Angveelneuse, CofA t h9e0 0S6ta7r s, Suite 800 2 Tel: (310) 226-7570 Fax: (310) 226-7571 3 Email: [email protected]

4

5 6 DATED: 6/17/2025 7 /s/ Kate Wallace 8 Counsel for G6 Hospitality Property LLC 9 Kathleen (Kate) Wallace (Cal. Bar. No. 234949) 10 [email protected] 11 Massachusetts Bar No. 665503 JONES DAY 12 100 High Street, 21st Floor 13 Boston, MA 02110 Telephone: +1.617.449.6893 14 Facsimile: +1.617.449.6999 15

16 Tyler J. Scott (Cal. Bar No. 341039) 17 [email protected] JONES DAY 18 555 South Flower Street, 50th Floor 19 Los Angeles, California 90071 Telephone:+1.213.243.2987 20 Facsimile:+ 1.213.243.2539 21

22 Taylor C. Lodise (NY Bar No. 6047070) 23 JONES DAY 250 Vesey Street 24 New York, NY 10281 25 Telephone: (212) 326-3939 [email protected] 26

27 Attorneys for Defendant

28 1 2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 4 DATED:_6_/1_8_/_2_0_25________ __________________________________ 5 Honorable A. Joel Richlin United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full 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 8 case of T.B. v. G6 Hospitality Property LLC, Case No. 2:24-cv-11220 (C.D. Cal.). I 9 agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me 11 to sanctions and punishment in the nature of contempt. I solemnly promise that I 12 will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance with 14 the provisions of this 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 of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________