1 K. Tom Kohan, Esq. (CA BAR NO.: 225420) KOHAN LAW FIRM 2 1310 Westwood Blvd., 2nd Floor Los Angeles, California 90024 3 Tel: (310) 349-1111 NOTE: CHANGES MADE BY THE COURT 4 Fax: (888) 476-7010 Email: [email protected] 5 6 Attorneys for Defendants 7 CRYSTAL LYNN CLOTHING LLC 8 ROSS STORES, INC. 9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

11 GOLD VALUE INTERNATIONAL Case No. 2:25-CV-01319-MEMF-JPR 12 TEXTILE, Assigned for Discovery Purposes 13 Plaintiff, to Hon. Jean P. Rosenbluth 14

15 STIPULATED PROTECTIVE vs. ORDER AND ORDER THEREON 16 CRYSTAL LYNN CLOTHING 17 LLC., ET AL. 18 Defendants. 19 20

21 22 1. INTRODUCTION 23 1.1 PURPOSES AND LIMITATIONS 24 Discovery in this action may involve production of confidential, proprietary, 25 26 or private information for which special protection from public disclosure and from 27 use for any purpose other than prosecuting this litigation may be warranted. 1

2 Accordingly, the Parties hereby stipulate to and petition the Court to enter the 3 following Stipulated Protective Order. The Parties acknowledge that this Order 4 5 does not confer blanket protections on all disclosures or responses to discovery and 6 that the protection it affords from public disclosure and use extends only to the 7 limited information or items that are entitled to confidential treatment under the 8 9 applicable legal principles. The Parties further acknowledge, as set forth in Section 10 12.3 below, that this Order does not entitle them to file Confidential Information 11 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed 12 13 and the standards that will be applied when a Party seeks permission from the 14 Court to file material under seal. 15 1.2 GOOD CAUSE STATEMENT 16 17 This Action is likely to involve trade secrets, customer and pricing lists, 18 other valuable research, customer information, employee and personnel 19 information, financial information (including, without limitation, profit margins, 20 21 sales/subscription data, costs, expenses), vendor lists, order summaries, 22 confidential contracts, product and service specifications and design plans, 23 commercial information, and other confidential, private, or proprietary information 24 25 (including, for example, personal and private information regarding individual 26 2 27 STIPULATED PROTECTIVE ORDER 1

2 personnel records), whether in oral, written, documentary, tangible, intangible, 3 electronic, digitized, or other form for which the parties believe special protection 4 5 from public disclosure and from use for any purpose other than prosecution of this 6 Action is warranted. Such confidential and proprietary materials and information 7 may consist of, among other things, confidential business or financial information, 8 9 information regarding confidential business practices, confidential research or 10 commercial information, information otherwise generally unavailable to the public, 11 or which may be privileged or otherwise protected from disclosure under state or 12 13 federal statutes, court rules, case decisions, or common law. Accordingly, to 14 expedite the flow of information, to facilitate the prompt resolution of disputes 15 over confidentiality of discovery materials, to adequately protect information the 16 17 Parties are entitled to keep confidential, to ensure that the Parties are permitted 18 reasonable necessary uses of such material in preparation for and in the conduct of 19 trial, to address their handling at the end of the litigation, and serve the ends of 20 21 justice, a protective order for such information is justified in this matter. It is the 22 intent of the Parties that information will not be designated as confidential for 23 tactical reasons and that nothing be so designated without a good faith belief that it 24 25 26 3 27 STIPULATED PROTECTIVE ORDER 1

2 has been maintained in a confidential, non-public manner, and there is good cause 3 why it should not be part of the public record of this case. 4 5 2. DEFINITIONS 6 2.1 Action: This pending federal lawsuit. 7 2.2 Challenging Party: a Party or Nonparty that challenges the designation 8 9 of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 how it is generated, stored, or maintained) or tangible things that qualify for 12 13 protection under Federal Rule of Civil Procedure 26(c) and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 17 support staff). 18 2.5 Designating Party: a Party or Nonparty that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 21 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 22 ONLY”. 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 4 27 STIPULATED PROTECTIVE ORDER 1

2 among other things, testimony, transcripts, and tangible things), that are produced 3 or generated in disclosures or responses to discovery in this matter. 4 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 7 as an expert witness or as a consultant in this action. 8 9 2.8 House Counsel: attorneys who are employees of a Party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 13 2.9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 14 Information or Items: extremely sensitive “Confidential Information or Items,” 15 disclosure of which to another Party or Non-Party would create a substantial risk of 16 17 serious harm that could not be avoided by less restrictive means. 18 2.10 Nonparty: any natural person, partnership, corporation, association, 19 or other legal entity not named as a Party to this action. 20 21 2.11 Outside Counsel of Record: attorneys who are not employees of a 22 Party to this Action but are retained to represent or advise a Party and have 23 appeared in this Action on behalf of that Party or are affiliated with a law firm that 24 25 has appeared on behalf of that Party, including support staff. 26 5 27 STIPULATED PROTECTIVE ORDER 1

2 2.12 Party: any Party to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 5 support staffs). 6 2.13 Producing Party: a Party or Nonparty that produces Disclosure or 7 Discovery Material in this Action. 8 9 2.14 Professional Vendors: persons or entities that provide litigation 10 support services (for example, photocopying, videotaping, translating, preparing 11 exhibits or demonstrations, and organizing, storing, or retrieving data in any form 12 13 or medium) and their employees and subcontractors. 14 2.15 Protected Material: any Disclosure or Discovery Material that is 15 designated as “CONFIDENTIAL,” or as “HIGHLY CONFIDENTIAL – 16 17 ATTORNEYS’ EYES ONLY.” 18 2.16 Receiving Party: a Party that receives Disclosure or Discovery 19 Material from a Producing Party. 20 21 3 . SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above) but also (1) any information copied or 24 25 extracted from Protected Material; (2) all copies, excerpts, summaries, or 26 6 27 STIPULATED PROTECTIVE ORDER 1

2 compilations of Protected Material; (3) and any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. 4 5 Any use of Protected Material at trial will be governed by the orders of the 6 trial judge. This Order does not govern the use of Protected Material at trial. 7 4. DURATION 8 9 Once a case proceeds to trial, all the information that was designated as 10 confidential or maintained under this Order becomes public and will be 11 presumptively available to all members of the public, including the press, unless 12 13 the trial judge finds compelling reasons to proceed otherwise. See Kamakana v. 14 City & Cnty. of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing 15 “good cause” showing for sealing documents produced in discovery from 16 17 “compelling reasons” needed for merits-related documents). Accordingly, the 18 terms of this Order do not extend beyond the beginning of trial. 19 Even after final disposition of this litigation, the confidentiality obligations 20 21 imposed by this Order will remain in effect until a Designating Party agrees 22 otherwise in writing or a court order otherwise directs. Final disposition is the later 23 of (1) dismissal of all claims and defenses in this Action, with or without prejudice, 24 25 or (2) final judgment after the completion and exhaustion of all appeals, 26 7 27 STIPULATED PROTECTIVE ORDER 1

2 rehearings, remands, trials, or reviews of this Action, including the time limits for 3 filing any motions or applications for extension of time under applicable law. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Each Party or Nonparty that designates information or items for 7 protection under this Order must take care to limit any such designation to specific 8 9 material that qualifies under the appropriate standards. To the extent practicable, 10 the Designating Party must designate for protection only those parts of material, 11 documents, items, or oral or written communications that qualify so that other 12 13 portions of the material, documents, items, or communications for which 14 protection is not warranted are not swept unjustifiably within the ambit of this 15 Order. 16 17 Indiscriminate or routinized designations are prohibited. Designations that 18 are shown to be clearly unjustified or that have been made for an improper purpose 19 (for example, to unnecessarily encumber the case-development process or to 20 21 impose unnecessary expenses and burdens on other parties) may expose the 22 Designating Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items it 24 25 designated for protection do not qualify for that level of protection, that 26 8 27 STIPULATED PROTECTIVE ORDER 1

2 Designating Party must promptly notify all other Parties that it is withdrawing the 3 inapplicable designation. 4 5 5.2 Except as otherwise provided in this Order, Disclosure or Discovery 6 Material that qualifies for protection under this Order must be clearly so designated 7 before the material is disclosed or produced. 8 9 Designation in conformity with this Order requires the following: 10 (a) for information in documentary form (for example, paper or electronic 11 documents but excluding transcripts of depositions or other pretrial or trial 12 13 proceedings), the Producing Party must affix at a minimum the legend 14 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 15 ONLY” to each page that contains Protected Material. If only a portion or portions 16 17 of the material on a page qualify for protection, the Producing Party should to the 18 extent practicable clearly identify the protected portion(s) (for example, by making 19 appropriate markings in the margins). 20 21 A Party or Nonparty that makes original documents available for inspection 22 need not designate them for protection until after the inspecting Party has indicated 23 which documents it would like copied and produced. During the inspection and 24 25 before the designation, all material made available for inspection must be treated as 26 9 27 STIPULATED PROTECTIVE ORDER 1

2 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 3 ONLY.” After the inspecting Party has identified the documents it wants copied 4 5 and produced, the Producing Party must determine which documents, or portions 6 thereof, qualify for protection under this Order. Then, before producing the 7 specified documents, the Producing Party must affix the “CONFIDENTIAL” or 8 9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to each 10 page that contains Protected Material. If only a portion or portions of the material 11 on a page qualify for protection, the Producing Party should to the extent practical 12 13 clearly identify the protected portion(s) (for example, by making appropriate 14 markings in the margins). 15 (b) for testimony given in depositions, the Designating Party must identify 16 17 the Disclosure or Discovery Material that is protected on the record, before the 18 close of the deposition. 19 (c) for information produced in some form other than documentary and for 20 21 any other tangible items, the Producing Party must affix in a prominent place on 22 the exterior of the container or containers in which the information is stored the 23 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 24 25 EYES ONLY.” If only a portion or portions of the information warrant 26 10 27 STIPULATED PROTECTIVE ORDER 1

2 protection, the Producing Party, to the extent practicable, must identify the 3 protected portion(s). 4 5 5.3 If timely corrected, an inadvertent failure to designate qualified 6 information or items does not, standing alone, waive the Designating Party’s right 7 to secure protection under this Order for that material. On timely correction of a 8 9 designation, the Receiving Party must make reasonable efforts to assure that the 10 material is treated in accordance with the provisions of this Order. 11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 13 6.1 Any Party or Nonparty may challenge a designation of confidentiality 14 at any time consistent with the Court’s scheduling order. 15 6.2 The Challenging Party must initiate the dispute-resolution process 16 17 (and, if necessary, file a discovery motion) under Local Rule 37. 18 6.3 The burden of persuasion in any such proceeding is on the 19 Designating Party. Frivolous challenges, and those made for an improper purpose 20 21 (for example, to harass or impose unnecessary expenses and burdens on other 22 parties), may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the confidentiality designation, all parties must 24 25 continue to afford the material in question the level of protection to which it is 26 11 27 STIPULATED PROTECTIVE ORDER 1

2 entitled under the Producing Party’s designation until the Court rules on the 3 challenge. 4 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 A Receiving Party may use Protected Material that is disclosed or 7 produced by another Party or by a Nonparty in connection with this Action only 8 9 for prosecuting, defending, or attempting to settle this Action. Such Protected 10 Material may be disclosed only to the categories of people and under the 11 conditions described in this Order. When the Action has been terminated, a 12 13 Receiving Party must comply with the provisions of Section 13 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 17 location and in a manner sufficiently secure to ensure that access is limited to the 18 people authorized under this Order. 19 7.2 Unless otherwise ordered by the Court or permitted in writing by the 20 21 Designating Party, a Receiving Party may disclose any information or item 22 designated “CONFIDENTIAL” only to the following people: 23 24 25 26 12 27 STIPULATED PROTECTIVE ORDER 1

2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 3 as employees of that Outside Counsel of Record to whom it is reasonably 4 5 necessary to disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 9 (c) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 17 Vendors to whom disclosure is reasonably necessary for this Action and who have 18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) the author or recipient of a document containing the information or a 20 21 custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses and attorneys for witnesses to whom 23 disclosure is reasonably necessary, provided that the deposing party requests that 24 25 the witness sign the form attached as Exhibit A hereto and the witnesses will not be 26 13 27 STIPULATED PROTECTIVE ORDER 1

2 permitted to keep any confidential information unless they sign the form, unless 3 otherwise agreed by the Designating Party or ordered by the Court. Pages of 4 5 transcribed deposition testimony or exhibits to depositions that reveal Protected 6 Material may be separately bound by the court reporter and may not be disclosed 7 to anyone except as permitted under this Order; and 8 9 (i) any mediator or settlement officer, and their supporting personnel, 10 mutually agreed on by any of the Parties engaged in settlement discussions or 11 appointed by the Court. 12 13 7.3 Unless otherwise ordered by the court or permitted in writing by the 14 Designating Party, a Receiving Party may disclose any information or item 15 designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to 16 17 the following people: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 19 well as employees of said Outside Counsel of Record to whom it is 20 21 reasonably necessary to disclose the information for this Action and who 22 have signed the “Acknowledgment and Agreement to Be Bound” that is 23 attached hereto as Exhibit A; 24 25 26 14 27 STIPULATED PROTECTIVE ORDER 1

2 (b) Designated House Counsel of the Receiving Party (1) who has no 3 involvement in competitive decision-making, (2) to whom disclosure is 4 5 reasonably necessary for this Action , (3) who has signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A), and (4) as to 7 whom the procedures set forth in paragraph 7.4(a)(1), below, have been 8 9 followed; 10 (c) Experts of the Receiving Party (1) to whom disclosure is 11 reasonably necessary for this Action , (2) who have signed the 12 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A), and (3) as to 14 whom the procedures set forth in paragraph 7.4(a)(2), below, have been 15 followed; 16 17 (d) witnesses at depositions (1) who are directors, officers, or 18 employees of the designating party or (2) who have been qualified on the 19 record as having previously seen or had access to and as having knowledge 20 21 of the underlying designated material and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A). Witnesses 23 shall not retain a copy of documents containing Confidential Information, 24 25 26 15 27 STIPULATED PROTECTIVE ORDER 1

2 except witnesses may receive a copy of all exhibits marked at their 3 depositions in connection with review of the transcripts; 4 5 (e) the court and its personnel; 6 (f) court reporters and their staff, professional jury or trial consultants, 7 mock jurors, and Professional Vendors to whom disclosure is reasonably 8 9 necessary for this Action and who have signed the “Acknowledgment and 10 Agreement to Be Bound” (Exhibit A); and 11 (g) the author or recipient of a document containing the information or 12 13 a custodian or other person who otherwise possessed or knew the 14 information. 15 7.4 (a)(1) Unless otherwise ordered by the court or agreed to in writing by 16 17 the Designating Party, a Party that seeks to disclose to Designated House Counsel 18 any information or item that has been designated “HIGHLY CONFIDENTIAL – 19 ATTORNEYS’ EYES ONLY” pursuant to paragraph 7.3(b) first must make a 20 21 written request to the Designating Party that (1) sets forth the full name of the 22 Designated House Counsel and the city and state of his or her residence, and (2) 23 describes the Designated House Counsel’s current and reasonably foreseeable 24 25 future primary job duties and responsibilities in sufficient detail to determine if 26 16 27 STIPULATED PROTECTIVE ORDER 1

2 House Counsel is involved, or may become involved, in any competitive decision- 3 making. 4 5 (a)(2) Unless otherwise ordered by the court or agreed to in writing by the 6 Designating Party, a Party that seeks to disclose to an Expert (as defined in this 7 Order) any information or item that has been designated “HIGHLY 8 9 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” pursuant to paragraph 7.3(c) 10 first must make a written request to the Designating Party that (1) identifies the 11 general categories of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 12 13 ONLY” information that the Receiving Party seeks permission to disclose to the 14 Expert, (2) sets forth the full name of the Expert and the city and state of his or her 15 primary residence, (3) attaches a copy of the Expert’s current resume, (4) identifies 16 17 the Expert’s current employer(s), (5) identifies each person or entity from whom 18 the Expert has received compensation or funding for work in his or her areas of 19 expertise or to whom the expert has provided professional services, including in 20 21 connection with a litigation, at any time during the preceding five years, and (6) 22 identifies (by name and number of the case, filing date, and location of court) any 23 litigation in connection with which the Expert has offered expert testimony, 24 25 26 17 27 STIPULATED PROTECTIVE ORDER 1

2 including through a declaration, report, or testimony at a deposition or trial, during 3 the preceding five years. 4 5 (b) A Party that makes a request and provides the information specified in 6 the preceding respective paragraphs may disclose the subject Protected Material to 7 the identified Designated House Counsel or Expert unless, within 14 days of 8 9 delivering the request, the Party receives a written objection from the Designating 10 Party. Any such objection must set forth in detail the grounds on which it is based. 11 (c) A Party that receives a timely written objection must meet and confer 12 13 with the Designating Party (through direct voice to voice dialogue) to try to resolve 14 the matter by agreement within seven days of the written objection. If no 15 agreement is reached, the Party seeking to make the disclosure to Designated 16 17 House Counsel or the Expert may file a motion as provided in Civil Local Rule 37 18 (and in compliance with Civil Local Rule 79-5, if applicable) seeking permission 19 from the court to do so. Any such motion must describe the circumstances with 20 21 specificity, set forth in detail the reasons why the disclosure to Designated House 22 Counsel or the Expert is reasonably necessary, assess the risk of harm that the 23 disclosure would entail, and suggest any additional means that could be used to 24 25 reduce that risk. In addition, any such motion must be accompanied by a competent 26 18 27 STIPULATED PROTECTIVE ORDER 1

2 declaration describing the parties’ efforts to resolve the matter by agreement (i.e., 3 the extent and the content of the meet and confer discussions) and setting forth the 4 5 reasons advanced by the Designating Party for its refusal to approve the disclosure. 6 In any such proceeding, the Party opposing disclosure to Designated House 7 Counsel or the Expert shall bear the burden of proving that the risk of harm that the 8 9 disclosure would entail (under the safeguards proposed) outweighs the Receiving 10 Party’s need to disclose the Protected Material to its Designated House Counsel or 11 Expert. 12 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 19 ONLY” that Party must: 20 21 (a) promptly notify in writing the Designating Party. Such notification must 22 include a copy of the subpoena or court order unless prohibited by law; 23 (b) promptly notify in writing the party who caused the subpoena or order to 24 25 issue in the other litigation that some or all of the material covered by the subpoena 26 19 27 STIPULATED PROTECTIVE ORDER 1

2 or order is subject to this Protective Order. Such notification must include a copy 3 of this Order; and 4 5 (c) cooperate with respect to all reasonable procedures sought to be pursued 6 by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served 8 9 with the subpoena or court order should not produce any information designated in 10 this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 11 ATTORNEYS’ EYES ONLY” before a determination on the protective-order 12 13 request by the relevant court unless the Party has obtained the Designating Party’s 14 permission. The Designating Party bears the burden and expense of seeking 15 protection of its Confidential Material, and nothing in these provisions should be 16 17 construed as authorizing or encouraging a Receiving Party in this Action to 18 disobey a lawful directive from another court. 19 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 21 PRODUCED IN THIS LITIGATION 22 (a) The terms of this Order are applicable to information produced by a 23 Nonparty in this Action and designated as “CONFIDENTIAL” or “HIGHLY 24 25 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information is 26 20 27 STIPULATED PROTECTIVE ORDER 1

2 protected by the remedies and relief provided by this Order. Nothing in these 3 provisions should be construed as prohibiting a Nonparty from seeking additional 4 5 protections. 6 (b) In the event that a Party is required by a valid discovery request to 7 produce a Nonparty’s Confidential Information in its possession and the Party is 8 9 subject to an agreement with the Nonparty not to produce the Nonparty’s 10 Confidential Information, then the Party must 11 (1) promptly notify in writing the Requesting Party and the Nonparty 12 13 that some or all of the information requested is subject to a confidentiality 14 agreement with a Nonparty; 15 (2) promptly provide the Nonparty with a copy of this Order, the 16 17 relevant discovery request(s), and a reasonably specific description of the 18 information requested; and 19 (3) make the information requested available for inspection by the 20 21 Nonparty, if requested. 22 (c) If the Nonparty fails to seek a protective order within 21 days of 23 receiving the notice and accompanying information, the Receiving Party may 24 25 produce the Nonparty’s Confidential Information responsive to the discovery 26 21 27 STIPULATED PROTECTIVE ORDER 1

2 request. If the Nonparty timely seeks a protective order, the Receiving Party must 3 not produce any information in its possession or control that is subject to the 4 5 confidentiality agreement with the Nonparty before a ruling on the protective-order 6 request. Absent a court order to the contrary, the Nonparty must bear the burden 7 and expense of seeking protection of its Protected Material. 8 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 13 Order, the Receiving Party must immediately notify the Designating Party in 14 writing of the unauthorized disclosures, use its best efforts to retrieve all 15 unauthorized copies of the Protected Material, inform the person or people to 16 17 whom unauthorized disclosures were made of the terms of this Order, and ask that 18 person or people to execute the “Acknowledgment and Agreement to Be Bound” 19 that is attached hereto as Exhibit A. 20 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 25 inadvertently produced material is subject to a claim of privilege or other 26 22 27 STIPULATED PROTECTIVE ORDER 1

2 protection, the obligations of the Receiving Parties are those set forth in Federal 3 Rule of Civil Procedure 26(b)(5)(B). 4 5 12. MISCELLANEOUS 6 12.1 Nothing in this Order abridges the right of any person to seek its 7 modification by the Court. 8 9 12.2 By stipulating to the entry of this Order, no Party waives any right it 10 otherwise would have to object to disclosing or producing any information or item 11 on any ground not addressed in this Order. Similarly, no Party waives any right to 12 13 object on any ground to use in evidence of any of the material covered by this 14 Order. 15 12.3 A Party that seeks to file under seal any Protected Material must 16 17 comply with Civil Local Rule 79-5. Protected Material may be filed under seal 18 only pursuant to a court order authorizing the sealing of the specific Protected 19 Material at issue. If a Party's request to file Protected Material under seal is denied, 20 21 then the Receiving Party may file the information in the public record unless 22 otherwise instructed by the Court. 23

24 25 26 23 27 STIPULATED PROTECTIVE ORDER 1

2 13. FINAL DISPOSITION 3 After the final disposition of this Action, as defined in paragraph 4, within 4 5 60 days of a written request by the Designating Party, each Receiving Party must 6 return all Protected Material to the Producing Party or destroy such material. As 7 used in this subdivision, “all Protected Material” includes all copies, abstracts, 8 9 compilations, summaries, and any other format reproducing or capturing any of the 10 Protected Material. Whether the Protected Material is returned or destroyed, the 11 Receiving Party must submit a written certification to the Producing Party (and, if 12 13 not the same person or entity, to the Designating Party) by the 60-day deadline that 14 identifies (by category, when appropriate) all the Protected Material that was 15 returned or destroyed and affirms that the Receiving Party has not retained any 16 17 copies, abstracts, compilations, summaries, or any other format reproducing or 18 capturing any of the Protected Material. Notwithstanding this provision, Counsel 19 are entitled to retain an archival copy of all pleadings; motion papers; trial, 20 21 deposition, and hearing transcripts; legal memoranda; correspondence; deposition 22 and trial exhibits; expert reports; attorney work product; and consultant and expert 23 work product even if such materials contain Protected Material. Any such archival 24 25 26 24 27 STIPULATED PROTECTIVE ORDER I copies that contain or constitute Protected Material remain subject to this Order as 3 4 set forth in Section 4 (DURATION). 5 SANCTIONS 6 Any willful violation of this Order may be punished by civil or criminal 7 g contempt, financial or evidentiary sanctions, reference to disciplinary authorities, 9 || or other appropriate action at the discretion of the Court. 10 11 |} SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 Date: June 10, 2025 LAW OFFICES OF ALBERT CHANG 13 By: /s/ Hyunsuk Albert Chang 14 Hyunsuk Albert Chang 15 Attorney for Plaintiff GOLD VALUE INTERNATIONAL 16 TEXTILE 17 12 Date: June 10, 2025 KOHAN LAW FIRM

19 By: /s/_K. Tom Kohan K. Tom Kohan 20 Attorneys for Defendants 21 CRYSTAL LYNN CLOTHING LLC and ROSS STORES, INC.

23 || PURSUANT TO STIPULATION, IT IS SO ORDERED. 24 || DATED: 6/24/2025 fe frendlate~ Honorable Jean P. Rosenbluth 25 United States Magistrate Judge 26 25 27 STIPULATED PROTECTIVE ORDER 28

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3 EXHIBIT A 4 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 5 6 I, _____________________________ [full name], of _________________ [full 7 8 address], declare under penalty of perjury that I have read in its entirety and 9 understand the Stipulated Protective Order that was issued by the U.S. District 10 Court for the Central District of California on [date] in the case of Gold Value 11 12 International Textile v. Crystal Lynn Clothing, LLC, et al, Case No. 2:25-CV- 13 01319-MEMF-JPR. I agree to comply with and to be bound by all terms of this 14 Stipulated Protective Order, and I understand and acknowledge that failure to so 15 16 comply could expose me to sanctions and punishment, including contempt. I 17 solemnly promise that I will not disclose in any manner any information or item 18 that is subject to this Stipulated Protective Order to any person or entity except in 19 20 strict compliance with the provisions of this Order. I further agree to submit to the 21 jurisdiction of the U.S. District Court for the Central District of California for the 22 purpose of enforcing the terms of this Stipulated Protective Order, even if such 23 24 enforcement proceedings occur after termination of this action. I hereby appoint 25 __________________________ [full name] of 26 26 27 STIPULATED PROTECTIVE ORDER 1

2 ____________________________________ [full address and telephone 3 number] as my California agent for service of process in connection with this 4 5 action or any proceedings related to enforcement of this Stipulated Protective 6 Order. 7 Date: ______________________________________ 8 9 City and State where signed: _________________________________ 10 Printed name: _______________________________ 11 Signature: ______________________________ 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 27 STIPULATED PROTECTIVE ORDER