1 AanMasIsRih [email protected] (S BN 235936) 2 RODRIGO E. SALAS (SBN 194462) 3 [email protected] CASEY DOUGLAS (SBN 349623) 4 [email protected] SHOOK, HARDY & BACON L.L.P. 5 555 Mission Street, Suite 2300 San Francisco, CA 94105 6 TEL: (415) 544-1900 | FAX: (415) 391-0281 7 KRISTINE AVENA (SBN 328593) 8 [email protected] SHOOK, HARDY & BACON L.L.P. 9 Jamboree Center 10 5 Park Plaza, Suite 1600 Irvine, CA 92614 11 Tel: (949) 475-1500 | Fax: (949) 475-0016 [email protected] 12 Attorneys for Defendant 13 NISSAN NORTH AMERICA, INC. 14

15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17

18 ANGELICA H. ROMERO, an Case No. 1:25-cv-00336-HBK individual, 19 Assigned to the Honorable Helena M. 20 Plaintiff, Barch-Kuchta

21 vs. APPROVED STIPULATED PROTECTIVE ORDER 22 NISSAN NORTH AMERICA, INC., a 23 Delaware Corporation, and DOES 1 (Doc. No. 8) through 10, inclusive, 24 Defendants. 25 26 27 1. GENERAL 28 1.1 Purposes and Limitations. Discovery in this action is likely to involve 1 production of confidential, proprietary, or private information for which special 2 protection from public disclosure and from use for any purpose other than prosecuting 3 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 4 petition the Court to enter the following Stipulated Protective Order. The parties 5 acknowledge that this Order does not confer blanket protections on all disclosures or 6 responses to discovery and that the protection it affords from public disclosure and 7 use extends only to the limited information or items that are entitled to confidential 8 treatment under the applicable legal principles. 9 1.2 Good Cause Statement. 10 This action is likely to involve trade secrets, customer and pricing lists and 11 other valuable research, development, commercial, financial, technical and/or 12 proprietary information for which special protection from public disclosure and from 13 use for any purpose other than prosecution of this action is warranted. Such 14 confidential and proprietary materials and information consist of, among other things, 15 confidential business or financial information, information regarding confidential 16 business practices, or other confidential research, development, or commercial 17 information (including information implicating privacy rights of third parties), 18 information otherwise generally unavailable to the public, or which may be privileged 19 or otherwise protected from disclosure under state or federal statutes, court rules, case 20 decisions, or common law. Accordingly, to expedite the flow of information, to 21 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 22 to adequately protect information the parties are entitled to keep confidential, to 23 ensure that the parties are permitted reasonable necessary uses of such material in 24 preparation for and in the conduct of trial, to address their handling at the end of the 25 litigation, and serve the ends of justice, a protective order for such information is 26 justified in this matter. It is the intent of the parties that information will not be 27 designated as confidential for tactical reasons and that nothing be so designated 28 without a good faith belief that it has been maintained in a confidential, non-public 1 manner, and there is good cause why it should not be part of the public record of this 2 case. 3 2. DEFINITIONS 4 2.1 Action: this pending federal lawsuit, Case no. 1:25-cv-00336-HBK. 5 2.2 Challenging Party: a Party or Non-Party that challenges the designation 6 of information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for protection 9 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 10 Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 12 support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 28 2.10 Outside Counsel of Record: attorneys who are not employees of a party 1 to this Action but are retained to represent or advise a party to this Action and have 2 appeared in this Action on behalf of that party or are affiliated with a law firm that 3 has appeared on behalf of that party, including support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record (and their 6 support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation support 10 services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 and their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 16 from a Producing Party. 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or extracted 20 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 21 Protected Material; and (3) any testimony, conversations, or presentations by Parties 22 or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 4. DURATION 26 Once a case proceeds to trial, all of the court-filed information to be introduced 27 that was previously designated as confidential or maintained pursuant to this 28 protective order becomes public and will be presumptively available to all members 1 of the public, including the press, unless compelling reasons supported by specific 2 factual findings to proceed otherwise are made to the trial judge in advance of the 3 trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 (9th Cir. 4 2006) (distinguishing “good cause” showing for sealing documents produced in 5 discovery from “compelling reasons” standard when merits-related documents are 6 part of court record). Accordingly, the terms of this protective order do not extend 7 beyond the commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection under this 11 Order must take care to limit any such designation to specific material that qualifies 12 under the appropriate standards. The Designating Party must designate for protection 13 only those parts of material, documents, items, or oral or written communications that 14 qualify so that other portions of the material, documents, items, or communications 15 for which protection is not warranted are not swept unjustifiably within the ambit of 16 this Order. 17 Mass, indiscriminate, or routinized designations are prohibited. Designations 18 that are shown to be clearly unjustified or that have been made for an improper 19 purpose (e.g., to unnecessarily encumber the case development process or to impose 20 unnecessary expenses and burdens on other parties) may expose the Designating Party 21 to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 designated for protection do not qualify for protection, that Designating Party must 24 promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 5.2 Manner and Timing of Designations. Except as otherwise provided in 26 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 27 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 28 under this Order must be clearly so designated before the material is disclosed or 1 produced. 2 Designation in conformity with this Order requires: 3 (a) for information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other pretrial or trial 5 proceedings), that the Producing Party affix, at a minimum, the legend 6 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 7 contains protected material. If only a portion or portions of the material on a page 8 qualifies for protection, the Producing Party also must clearly identify the protected 9 portion(s) (e.g., by making appropriate markings in the margins). 10 A Party or Non-Party that makes original documents available for inspection 11 need not designate them for protection until after the inspecting Party has indicated 12 which documents it would like copied and produced. During the inspection and 13 before the designation, all of the material made available for inspection shall be 14 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 15 it wants copied and produced, the Producing Party must determine which documents, 16 or portions thereof, qualify for protection under this Order. Then, before producing 17 the specified documents, the Producing Party must affix the “CONFIDENTIAL 18 legend” to each page that contains Protected Material. If only a portion or portions 19 of the material on a page qualifies for protection, the Producing Party also must clearly 20 identify the protected portion(s) (e.g., by making appropriate markings in the 21 margins). 22 (b) for testimony given in depositions that the Designating Party identify 23 the Disclosure or Discovery Material on the record, before the close of the deposition. 24 (c) for information produced in some form other than documentary and 25 for any other tangible items, that the Producing Party affix in a prominent place on 26 the exterior of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 28 protection, the Producing Party, to the extent practicable, shall identify the protected 1 portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items does not, standing alone, waive the 4 Designating Party’s right to secure protection under this Order for such material. 5 Upon timely correction of a designation, the Receiving Party must make reasonable 6 efforts to assure that the material is treated in accordance with the provisions of this 7 Order. 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality 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. Any discovery motion must comply with local rules. 14 6.3 Burden. The burden of persuasion in any such challenge proceeding 15 shall be on the Designating Party. Frivolous challenges, and those made for an 16 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 17 other parties) may expose the Challenging Party to sanctions. Unless the Designating 18 Party has waived or withdrawn the confidentiality designation, all parties shall 19 continue to afford the material in question the level of protection to which it is entitled 20 under the Producing Party’s designation until the Court rules on the challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending, or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. When the Action has been terminated, a Receiving 27 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 28 Protected Material must be stored and maintained by a Receiving Party at a 1 location and in a secure manner that ensures that access is limited to the persons 2 authorized under this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 4 otherwise ordered by the Court or permitted in writing by the Designating Party, a 5 Receiving Party may disclose any information or item designated 6 “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably 9 necessary to disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of 11 the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the Court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the information or 21 a custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in 23 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 24 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 25 will not be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 27 agreed by the Designating Party or ordered by the Court. Pages of transcribed 28 deposition testimony or exhibits to depositions that reveal Protected Material may be 1 separately bound by the court reporter and may not be disclosed to anyone except as 2 permitted under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 6 PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification shall 11 include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order to 13 issue in the other litigation that some or all of the material covered by the subpoena 14 or order is subject to this Protective Order. Such notification shall include a copy of 15 this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued 17 by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 the subpoena or court order shall not produce any information designated in this action 20 as “CONFIDENTIAL” before a determination by the court from which the subpoena 21 or order issued, unless the Party has obtained the Designating Party’s permission. The 22 Designating Party shall bear the burden and expense of seeking protection in that court 23 of its confidential material and nothing in these provisions should be construed as 24 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 25 directive from another court. 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a Non- 1 Party in this Action and designated as “CONFIDENTIAL.” Such information 2 produced by Non-Parties in connection with this litigation is protected by the 3 remedies and relief provided by this Order. Nothing in these provisions should be 4 construed as prohibiting a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to produce 6 a Non-Party’s confidential information in its possession, and the Party is subject to an 7 agreement with the Non-Party not to produce the Non-Party’s confidential 8 information, then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non-Party 10 that some or all of the information requested is subject to a confidentiality agreement 11 with a Non-Party; 12 (2) promptly provide the Non-Party with a copy of the Stipulated 13 Protective Order in this Action, the relevant discovery request(s), and a reasonably 14 specific description of the information requested; and 15 (3) make the information requested available for inspection by the Non- 16 Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this Court within 14 18 days of receiving the notice and accompanying information, the Receiving Party may 19 produce the Non-Party’s confidential information responsive to the discovery request. 20 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 21 any information in its possession or control that is subject to the confidentiality 22 agreement with the Non-Party before a determination by the Court. Absent a court 23 order to the contrary, the Non-Party shall bear the burden and expense of seeking 24 protection in this Court of its Protected Material. 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” that is attached hereto as Exhibit A. 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 may be established in an e-discovery order that provides for production without prior 13 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 parties reach an agreement on the effect of disclosure of a communication or 15 information covered by the attorney-client privilege or work product protection, the 16 parties may incorporate their agreement in the stipulated protective order submitted 17 to the Court. 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order, no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this Protective Order. 26 13. FINAL DISPOSITION 27 After the final disposition of this Action, within 60 days of a written request by 28 the Designating Party, each Receiving Party must return all Protected Material to the 1 Producing Party or destroy such material. As used in this subdivision, “all Protected 2 Material” includes all copies, abstracts, compilations, summaries, and any other 3 format reproducing or capturing any of the Protected Material. Whether the Protected 4 Material is returned or destroyed, the Receiving Party must submit a written 5 certification to the Producing Party (and, if not the same person or entity, to the 6 Designating Party) by the 60 day deadline that (1) identifies (by category, where 7 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 8 that the Receiving Party has not retained any copies, abstracts, compilations, 9 summaries or any other format reproducing or capturing any of the Protected Material. 10 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 11 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 12 correspondence, deposition and trial exhibits, expert reports, attorney work product, 13 and consultant and expert work product, even if such materials contain Protected 14 Material. Any such archival copies that contain or constitute Protected Material 15 remain subject to this Protective Order as set forth in Section 4 (DURATION). 16 14. VIOLATION OF ORDER 17 Any violation of this Order may be punished by any and all appropriate 18 measures including, without limitation, contempt proceedings and/or monetary 19 sanctions. 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 || Dated: _July 11, 2025 QUILL & ARROW, LLP 4 5 By /s/Andrew Jung 6 KEVIN Y. JACOBSON ANDREW C. JUNG 7 DANJA STOCCA 8 Attorneys for Plaintiff 9 ANGELICA H. ROMERO 10 11 D Dated: July 14, 2025 SHOOK, HARDY & BACON L.L.P. 13 14 By /S/ Kristine Avenea AMIR NASSIHI 15 RODRIGO E. SALAS CASEY DOUGLAS 16 KRISTINE AVENA 17 Attorneys for Defendant 18 NISSAN NORTH AMERICA, INC. 19 20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 || Dated: _ July 18, 2025 Mote WN. BareA Bact 73 HELENA M. BARCH-KUCHTA UNITED STATES MAGISTRATE 24 JUDGE 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 Eastern District of California on ____________ [date] in the 8 case of Angelica H. Romero v. Nissan North America, Inc., Case No. 1:25-cv- 9 00336-HBK. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Eastern 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 24 Date: ______________________________________ 25 City and State where signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28