1 GLAIBUSROENN, DMU. NBLNA &S ,C SRBUNT 2C9H6E82R3 LLP MMAATTETRHNEW LA WW. GGORRODUOPN, P, CS BN 267971 2 [email protected] [email protected] 333 South Grand Avenue ERIN R. HUTCHINS, SBN 346557 3 Los Angeles, California 90071-3197 [email protected] Telephone: 213.229.7000 2101 E. El Segundo Blvd., Suite 403 4 Facsimile: 213.229.7520 El Segundo, CA 90245 Telephone: 310.531.1900 5 GIBSON, DUNN & CRUTCHER LLP Facsimile: 310.531.1901 MEGAN COONEY, SBN 295174 6 [email protected] Attorneys for Plaintiffs KATIE M. MAGALLANES, SBN 300277 JONATHAN CHICAS and DARRIUS 7 [email protected] PARRISH, individually, and on behalf of JESSICA M. PEARIGEN, SBN 317286 all others similarly situated 8 [email protected] 3161 Michelson Drive, Suite 1200 9 Irvine, California 92612-4412 Telephone: 949.451.3800 10 Facsimile: 949.451.4220

11 GIBSON, DUNN & CRUTCHER LLP JOSEPH R. ROSE, SBN 279092 12 [email protected] One Embarcadero Center, Suite 2600 13 San Francisco, California 94111-3715 Telephone: 415.393.8200 14 Facsimile: 415.393.8306 15 Attorneys for Defendant AMAZON RETAIL LLC 16 IN THE UNITED STATES DISTRICT COURT 17 FOR THE CENTRAL DISTRICT OF CALIFORNIA 18 JONATHAN CHICAS, an individual; CASE NO. 2:24-cv-10306 FMO (SSCx) 19 and DARRIUS PARRISH, an individual, on behalf of themselves [PROPOSED] STIPULATED 20 and all others similarly situated, PROTECTIVE ORDER1 21 Plaintiffs,

22 v. 23 AMAZON RETAIL LLC, a Delaware limited liability company; 24 and DOES 1 to 10, inclusive, 25 Defendant. 26 27

28 1 This Stipulated Protective Order is substantially based on the model protective order provided under 1 IT IS HEREBY STIPULATED, pursuant to Rule 26 of the Federal Rules of 2 Civil Procedure, by and between Plaintiffs Jonathan Chicas and Darrius Parrish and 3 Defendant Amazon Retail LLC (collectively, the “Parties”), by and through their 4 respective undersigned counsel of record, that in order to facilitate the exchange of 5 information and documents which may be subject to confidentiality limitations on 6 disclosure due to federal laws, state laws, and privacy rights, the Parties respectfully 7 request that the Court sign this [Proposed] Stipulated Protective Order to govern the 8 production of documents and the conduct of discovery in this Action. 9 1. INTRODUCTION 10 1.1 Purposes and Limitations. Disclosure and discovery activity in this 11 Action are likely to involve production of confidential, proprietary, or private 12 information for which special protection from public disclosure and from use for any 13 purpose other than prosecuting this litigation may be warranted. Accordingly, the 14 Parties hereby stipulate to and petition the Court to enter the following Stipulated 15 Protective Order. The Parties acknowledge that this Order does not confer blanket 16 protections on all disclosures or responses to discovery and that the protection it affords 17 from public disclosure and use extends only to the limited information or items that are 18 entitled to confidential treatment under the applicable legal principles. 19 1.2 Good Cause Statement. This Action is likely to involve Plaintiffs’ 20 confidential and sensitive personnel files, payroll records, and medical records, and 21 Defendants’ confidential and sensitive personnel, employment, or commercial 22 information, for which special protection from public disclosure and use for any purpose 23 other than prosecution of this Action is warranted. Accordingly, to expedite the flow of 24 information, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of such 26 material in preparation for and in the conduct of trial, to address their handling at the 27 end of the litigation, and serve the ends of justice, a protective order for such information 28 is justified in this matter. It is the intent of the parties that information will not be 1 designated as confidential for tactical reasons and that nothing be so designated without 2 a good faith belief that it has been maintained in a confidential, non-public manner, and 3 there is good cause why it should not be part of the public record of this case. 4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 5 further acknowledge that Local Rule 79-5 sets forth the procedures that must be followed 6 and the standards that will be applied when a party seeks permission from the court to 7 file material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive motions, 10 good cause must be shown to support a filing under seal. See Kamakana v. City and 11 Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. 12 Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 14 require good cause showing), and a specific showing of good cause or compelling 15 reasons with proper evidentiary support and legal justification, must be made with 16 respect to Protected Material that a party seeks to file under seal. The parties’ mere 17 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 18 without the submission of competent evidence by declaration, establishing that the 19 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 20 protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, then 22 compelling reasons, not only good cause, for the sealing must be shown, and the relief 23 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 24 v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 2010). For each item or type of 25 information, document, or thing sought to be filed or introduced under seal in connection 26 with a dispositive motion or trial, the party seeking protection must articulate compelling 27 reasons, supported by specific facts and legal justification, for the requested sealing 28 1 order. Again, competent evidence supporting the application to file documents under 2 seal must be provided by declaration. 3 Any document that is not confidential, privileged, or otherwise protectable in its 4 entirety will not be filed under seal if the confidential portions can be redacted. If 5 documents can be redacted, then a redacted version for public viewing, omitting only 6 the confidential, privileged, or otherwise protectable portions of the document, shall be 7 filed. Any application that seeks to file documents under seal in their entirety should 8 include an explanation of why redaction is not feasible. 9 2. DEFINITIONS 10 2.1 Action: the above-captioned action. 11 2.2 Challenging Party: a Party that challenges the designation of information 12 or items under this Stipulated Protective Order. 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 14 how it is generated, stored or maintained) or tangible things that qualify for protection 15 under Federal Rule of Civil Procedure 26(c). 16 2.4 Counsel (without qualifier): Outside Counsel of Record and In-House 17 Counsel (as well as their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of 21 the medium or manner in which it is generated, stored, or maintained (including, among 22 other things, testimony, transcripts, and tangible things), that are produced or generated 23 in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 26 expert witness or as a consultant in this Action. 27 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 28 this Action, with or without prejudice; and (2) final judgment herein after the completion 1 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 2 including the time limits for filing any motions or applications for extension of time 3 pursuant to applicable law. 4 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 5 In-House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.10 Non-Party: any natural person, partnership, corporation, association, or 8 other legal entity not named as a Party to this Action. 9 2.11 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm which has 12 appeared on behalf of that party. 13 2.12 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.14 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 21 their employees and subcontractors. 22 2.15 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulated Protective Order cover not only 28 Protected Material (as defined above), but also (1) any information copied or extracted 1 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 2 Protected Material; and (3) any testimony, conversations, or presentations by Parties or 3 their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by a separate agreement 5 or order. This Stipulated Protective Order does not govern the use of Protected Material 6 at trial. 7 4. TRIAL AND DURATION 8 The terms of this Stipulated Protective Order apply through Final Disposition of 9 the Action. 10 Once a case proceeds to trial, information that was designated as 11 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used 12 or introduced as an exhibit at trial becomes public and will be presumptively available 13 to all members of the public, including the press, unless compelling reasons supported 14 by specific factual findings to proceed otherwise are made to the trial judge in advance 15 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing 16 for sealing documents produced in discovery from “compelling reasons” standard when 17 merits-related documents are part of court record). Accordingly, for such materials, the 18 terms of this Stipulated Protective Order do not extend beyond the commencement of 19 the trial. 20 Even after Final Disposition of this litigation, the confidentiality obligations 21 imposed by this Stipulated Protective Order shall remain in effect until a Designating 22 Party agrees otherwise in writing or a court order otherwise directs. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Standard for Designating Material for Protection. Any Party may 25 designate information or items for protection under this order if and only if, in the good 26 faith belief of such Party and its Counsel, the designated material qualifies under the 27 appropriate standards. 28 1 Mass, indiscriminate, or routinized designations are prohibited. Designations that 2 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 3 to unnecessarily encumber the case development process or to impose unnecessary 4 expenses and burdens on other parties) may expose the Designating Party to sanctions. 5 5.2 Manner and Timing of Designations. Except as otherwise provided in 6 this Stipulated Protective Order (see, e.g., Section 5.2(b) below), or as otherwise 7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 8 under this Order must be clearly so designated before the material is disclosed or 9 produced. 10 Designation in conformity with this Stipulated Protective Order requires: 11 (a) for information in documentary form (e.g., paper or electronic documents, 12 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 13 Producing Party affix the legend “CONFIDENTIAL” to each page that contains 14 Protected Material. If only a portion or portions of the material on a page qualify for 15 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 16 by making appropriate markings in the margins). Plaintiffs’ medical records, derived 17 from any source, shall be automatically deemed “CONFIDENTIAL.” 18 (b) a Party or Non-Party that makes original documents or materials available 19 for inspection need not designate them for protection until after the inspecting Party has 20 indicated which material it would like copied and produced. During the inspection and 21 before the designation, all the material made available for inspection shall be deemed 22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 23 copied and produced, the Producing Party must determine which documents, or portions 24 thereof, qualify for protection under this Order. Then, before producing the specified 25 documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 26 that contains Protected Material. If only a portion or portions of the material on a page 27 qualifies for protection, the Producing Party also must clearly identify the protected 28 portion(s) (e.g., by making appropriate markings in the margins). 1 (c) for testimony given in deposition or in other pretrial or trial proceedings, 2 that the Designating Party shall either (1) identify on the record, before the close of the 3 deposition, hearing, or other proceeding, all protected testimony, or (2) designate the 4 entirety of the testimony as “confidential” (before the proceedings is concluded) with 5 the right to identify more specific portions of the testimony as to which protection is 6 sought within 30 days following receipt of the deposition transcript or the date by which 7 any review by the witness and corrections to the transcript are to be completed under 8 Federal Rule of Civil Procedure 30. 9 (d) for information produced in some form other than documentary and for any 10 other tangible items, that the Producing Party shall affix in a prominent place on the 11 exterior of the container or containers in which the information or item is stored the 12 legend “CONFIDENTIAL.” If only a portion or portions of the information or item 13 warrant protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not waive the Designating 17 Party’s right to secure protection under this Stipulated Protective Order for such 18 material. Upon timely correction of a designation, the Receiving Party must make 19 reasonable efforts to assure that the material is treated in accordance with the provisions 20 of this Order. The Receiving Party shall also promptly destroy or return the 21 inadvertently produced material, and all copies thereof, and shall retain only the 22 materials designated as “CONFIDENTIAL.” 23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 25 designation of confidentiality as soon as practicable so as not to prejudice or harm the 26 opposing party or otherwise disrupt the litigation. 27 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 28 resolution process by notifying the Designating Party of each designation it is 1 challenging and describing the basis for each challenge. The parties shall attempt to 2 resolve each challenge in good faith and must begin the process by conferring directly 3 within 14 days of the date of notification. In conferring, the Challenging Party must 4 explain the basis for its belief that the confidentiality designation was not proper and 5 must give the Designating Party an opportunity to review the designated material, to 6 reconsider the circumstances, and, if no change in designation is offered, to explain the 7 basis for the chosen designation. A Challenging Party may proceed to the next stage of 8 the challenge process only if it has engaged in this meet and confer process first or 9 establishes that the Designating Party is unwilling to participate in the meet and confer 10 process in a timely manner. Unless the Designating Party waives or withdraws the 11 designation, all parties shall continue to afford the material in question the level of 12 protection to which it is entitled under the Producing Party’s designation until the court 13 rules on the challenge in accordance with Section 6.3. 14 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without 15 Court intervention, the Challenging Party shall file and serve a motion challenging 16 confidentiality within 14 days of the parties agreeing that the meet and confer process 17 will not resolve their dispute in accordance with the procedures set forth by the United 18 States District Court for the Central District of California. The burden of persuasion in 19 any such challenge proceeding shall be on the Designating Party. Frivolous challenges, 20 and those made for an improper purpose (e.g., to harass or impose unnecessary expenses 21 and burdens on other parties) may expose the Challenging Party to sanctions. Sanctions 22 will not be pursued where a challenge is resolved through the meet and confer process 23 set forth herein. All parties shall continue to afford the material in question the level of 24 protection to which it is entitled under the Producing Party’s designation until the Court 25 rules on the challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this case 1 only for prosecuting, defending, or attempting to settle this litigation, and for no other 2 purposes and no other client. Such Protected Material may be disclosed only to the 3 categories of persons and under the conditions described in this Order. When the 4 litigation has been terminated, a Receiving Party must comply with the provisions of 5 Section 13 below. 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the Court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 12 only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 14 employees of said Outside Counsel of Record to whom it is reasonably necessary to 15 disclose the information for this litigation as well as non-attorney employees of said 16 Outside Counsel of Record to whom it is reasonably necessary to disclose the 17 information for this litigation; 18 (b) the Receiving Party’s the officers, directors, and employees (including In- 19 House Counsel) to whom disclosure is reasonably necessary for this litigation; 20 (c) Experts (as defined in this Order) (i) to whom disclosure is reasonably 21 necessary for this litigation and (ii) who have signed the “Acknowledgment and 22 Agreement to Be Bound” (Exhibit A), provided that any portion of any Expert Report 23 that reproduces information designated as CONFIDENTIAL must be redacted if 24 allowed by the Court before the Expert Report is filed with the Court or must be redacted 25 if otherwise disclosed to any person not bound by this Agreement; 26 (d) the Court and its personnel; 27 (e) court reporters and their staff; 28 1 (f) professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this litigation and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information, or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses in the Action to whom disclosure is 7 reasonably necessary, unless otherwise agreed by the Designating Party or ordered by 8 the Court. Pages of transcribed deposition testimony or exhibits to depositions that 9 reveal Protected Material must be separately bound by the court reporter and may not be 10 disclosed to anyone except as permitted under this Stipulated Protective Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, mutually 12 agreed upon by any of the Parties engaged in settlement discussions. 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 that 16 compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to 21 issue in the other litigation that some or all of the material covered by the subpoena or 22 order is subject to this Stipulated Protective Order. Such notification shall include a 23 copy of this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by 25 the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with the 27 subpoena or court order shall not produce any information designated in this Action as 28 “CONFIDENTIAL” before a determination by the court from which the subpoena or 1 order issued, unless the Party has obtained the Designating Party’s permission. The 2 Designating Party shall bear the burden and expense of seeking protection in that court 3 of its confidential material—and nothing in these provisions should be construed as 4 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 5 from another court. 6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 9.1 Application. The terms of this Stipulated Protective Order are applicable 9 to information produced by a Non-Party in this Action and designated as 10 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this 11 litigation is protected by the remedies and relief provided by this Order. Nothing in 12 these provisions should be construed as prohibiting a Non-Party from seeking additional 13 protections. 14 9.2 Notification. If a Party is required, by a valid discovery request, to produce 15 a Non-Party’s confidential information in its possession, and the Party is subject to an 16 agreement with the Non-Party not to produce the Non-Party’s confidential information, 17 then the Party shall: 18 (a) promptly notify in writing the Requesting Party and the Non-Party that 19 some or all of the information requested is subject to a confidentiality agreement with a 20 Non-Party; 21 (b) promptly provide the Non-Party with a copy of the Stipulated Protective 22 Order in this litigation, the relevant discovery request(s), and a reasonably specific 23 description of the information requested; and 24 (c) make the information requested available for inspection by the Non-Party. 25 9.3 Conditions of Production. If the Non-Party fails to object or seek a 26 protective order from this Court within 14 days of receiving the notice and 27 accompanying information, the Receiving Party may produce the Non-Party’s 28 confidential information responsive to the discovery request. If the Non-Party timely 1 seeks a protective order, the Receiving Party shall not produce any information in its 2 possession or control that is subject to the confidentiality agreement with the Non-Party 3 before a determination by the Court. Absent a court order to the contrary, the Non-Party 4 shall bear the burden and expense of seeking protection in this Court of its Protected 5 Material. 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 10 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 11 all unauthorized copies of the Protected Material, (c) inform the person or persons to 12 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 13 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 14 that is attached hereto as Exhibit A. 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 Pursuant to Federal Rule of Evidence 502(d) and (e), disclosure (including 18 production) of information that a Party or Non-Party later claims should not have been 19 disclosed because of a privilege, including but not limited to the attorney-client privilege 20 or attorney work product doctrine, shall not by itself constitute a waiver of any claim of 21 attorney-client privilege, attorney work product, or other ground for withholding 22 production as to which the Producing Party would be entitled in this action or any other 23 federal or state proceeding. If a Producing Party identifies inadvertently produced 24 Disclosure or Discovery Material that it believes is privileged, it shall notify the 25 Receiving Party’s counsel in writing, and identify the Disclosure or Discovery Material 26 that it claims is privileged. Upon receipt of notification that privileged Disclosure or 27 Discovery Material was produced, the Receiving Party shall immediately return the 28 Disclosure or Discovery Material claimed to be privileged, and any copies thereof, and 1 confirm to the Producing Party in writing that all electronic copies of the document have 2 been deleted or otherwise destroyed. The Producing Party shall update its privilege log 3 to reflect the Disclosure or Discovery Material that it produced. The failure of any Party 4 to provide notice or instructions under this provision shall not by itself constitute a 5 waiver of any claim of attorney-client privilege, attorney work product, or other ground 6 for withholding production as to which the Producing Party would be entitled in this 7 Action or any other federal or state proceeding. This paragraph does not constitute a 8 waiver of the Receiving Party’s right to challenge the claim of privilege. 9 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 11 abridges the right of any person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Stipulated Protective Order no Party waives any right it otherwise would have to object 14 to disclosing or producing any information or item on any ground not addressed in this 15 Stipulated Protective Order. The production of Protected Material shall not constitute 16 an admission or concession by the Producing or Designating Party that such Protected 17 Material is relevant or probative of any issue or is admissible at any proceedings for any 18 purpose. 19 12.3 Publicly Available Materials. Nothing in this Stipulated Protective Order 20 shall be deemed in any way to restrict the use of documents or information that are 21 lawfully obtained or publicly available to a Party independently from discovery in this 22 Action, whether or not the same material has been obtained during the course of 23 discovery in the Action and whether or not such documents or information have been 24 designated as Protected Material. 25 12.4 Filing Protected Material. Without written permission from the 26 Designating Party or a Court order secured after appropriate notice to all interested 27 persons, a Party may not file in the public record in this Action any Protected Material. 28 A Party that seeks to file under seal any Protected Material must comply with the 1 procedures set forth by the United States District Court for the Central District of 2 California. 3 13. FINAL DISPOSITION 4 Within 60 days after the Final Disposition of this Action, each Receiving Party 5 must return all Protected Material to the Producing Party or destroy such material. As 6 used in this subdivision, “all Protected Material” includes all copies, abstracts, 7 compilations, summaries, and any other format reproducing or capturing any of the 8 Protected Material. Whether the Protected Material is returned or destroyed, the 9 Receiving Party must submit a written certification to the Producing Party (and, if not 10 the same person or entity, to the Designating Party) by the 60 day deadline that affirms 11 that the Receiving Party has not retained any copies, abstracts, compilations, summaries 12 or any other format reproducing or capturing any of the Protected Material. 13 Notwithstanding this provision, Counsel are entitled to retain one archival copy of all 14 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 15 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 16 consultant and expert work product, even if such materials contain Protected Material. 17 Any such archival copies that contain or constitute Protected Material remain subject to 18 this Stipulated Protective Order as set forth in Section 4. 19 IT IS SO STIPULATED. 20 21 Dated: July 10, 2025 GIBSON, DUNN & CRUTCHER LLP 22 23 By: /s/ Joseph R. Rose 2 Joseph R. Rose 24 Attorneys for Defendant 25 AMAZON RETAIL LLC

26 27 2 Pursuant to L.R. 5-4.3.4(a)(2)(i), counsel for Defendant, Joseph R. Rose, certifies that 28 the undersigned counsel has concurred in this filing’s content and authorized this 1 2|| Dated: July 10, 2025 MATERN LAW GROUP, PC 3 By: /s/ Erin Hutchins 4 Erin Hutchins 5 Attorneys for Plaintiffs J ONATHAN CHICAS and DARRIUS 6 PARRISH, individually, and on behalf of all 4 others similarly situated

8 9 IT IS SO ORDERED.

11 Dated: July 11, 2025 12 HON. STEPHANIE S. CHRISTENSEN 3 UNITED STATES MAGISTRATE JUDGE

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 2 EXHIBIT A 3 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 4 The undersigned hereby acknowledges under penalty of perjury that he/she has 5 read in its entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California in the case of Jonathan 7 Chicas et al v. Amazon Retail LLC et al, Case No. 2:24-cv-10306 FMO (SSCx). The 8 undersigned agrees to comply with and to be bound by all the terms of this Stipulated 9 Protective Order and understands and acknowledges that failure to so comply could 10 expose him/her to sanctions and punishment in the nature of contempt. The undersigned 11 solemnly promises that he/she will not disclose in any manner any information or item 12 that is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 The undersigned further agrees to submit to the jurisdiction of the United States 15 District Court for the Central District of California for the purpose of enforcing the terms 16 of this Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this Action. 18 Name: 19 Job Title: 20 Employer: 21 Business Address: 22 23 Signature: 24 Date: 25 26

27

28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28