Jerremy Barrios v. Marriott International Administrative Services, Inc.

United States District Court for the Central District of California

Jerremy Barrios v. Marriott International Administrative Services, Inc.

Trial Court Opinion

1 DANA A. KRAVETZ, ESQ. (SBN 179718) [email protected] 2 AMANDA K. MONROE, ESQ. (SBN 276063) 3 [email protected] ALEXANDRA D. MILLER, ESQ. (SBN 347969) 4 [email protected] MICHELMAN & ROBINSON, LLP 5 10880 Wilshire Blvd., 19th Floor 6 Los Angeles, California 90024 Telephone: (310) 299-5500 7 Facsimile: (310) 299-5600 8 Attorneys for Defendants, 9 MARRIOTT INTERNATIONAL ADMINISTRATIVE SERVICES, INC.; EDITION MANAGEMENT LLC dba THE WEST HOLLYWOOD EDITION 10

11 Joshua I. White, Esq. (SBN 278166) [email protected] 12 Kyle DeCamp, Esq. (SBN 328585) [email protected] 13 LAUREL EMPLOYMENT LAW 808 Wilshire Boulevard, Suite 200 14 Santa Monica, CA 90401 15 Telephone: (323) 551-9221 Facsimile: (310) 564-4093 16 Attorneys for Plaintiff, 17 JERREMY BARRIOS 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA

20 JERREMY BARRIOS, an individual. Case No.: 2:25-cv-05138-SSC 21 Assigned to: Magistrate Judge Stephanie Plaintiff, S. Christensen 22 vs. JOINT STIPULATED PROTECTIVE 23 ORDER REGARDING MARRIOTT INTERNATIONAL CONFIDENTIAL INFORMATION; 24 ADMINISTRATIVE SERVICES, INC., [PROPOSED] ORDER a Delaware corporation; EDITION 25 MANAGEMENT LLC dba THE WEST HOLLYWOOD EDITION, a Delaware Complaint Filed: May 2, 2025 26 Limited Liability Company; and DOES 1 Removed: June 5, 2025 through 10, Inclusive, Trial Date: September 15, 2026 27

28 Defendants.

1 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than 5 prosecuting this litigation may be warranted. Accordingly, the parties hereby 6 stipulate to and petition the court to enter the following Stipulated Protective Order 7 RE: Confidential Information. The parties acknowledge that this Order does not 8 confer blanket protections on all disclosures or responses to discovery and that the 9 protection it affords from public disclosure and use extends only to the limited 10 information or items that are entitled to confidential treatment under the applicable 11 legal principles. 12 1.2 Good Cause Statement. 13 This action is likely to involve confidential employee contact information 14 (including private and confidential contact information of third parties), employee 15 data and related records, and other valuable research, development, commercial, 16 financial, technical and/or proprietary information for which special protection from 17 public disclosure and from use for any purpose other than prosecution of this action is 18 warranted. Such confidential and proprietary materials and information consist of, 19 among other things, confidential business information, information regarding 20 confidential business practices, confidential contact information of third parties 21 (including former employees) or other confidential research, development, or 22 commercial information (including information implicating privacy rights of third 23 parties), information otherwise generally unavailable to the public, or which may be 24 privileged or otherwise protected from disclosure under state or federal statutes, court 25 rules, case decisions, or common law. Accordingly, to expedite the flow of 26 information, to facilitate the prompt resolution of disputes over confidentiality of 27 discovery materials, to adequately protect information the parties are entitled to keep 28 confidential, to ensure that the parties are permitted reasonable necessary uses of such 2 1 material in preparation for and in the conduct of trial, to address their handling at the 2 end of the litigation, and serve the ends of justice, a protective order for such 3 information is justified in this matter. It is the intent of the parties that information 4 will not be designated as confidential for tactical reasons and that nothing be so 5 designated without a good faith belief that it has been maintained in a confidential, 6 non-public manner, and there is good cause why it should not be part of the public 7 record of this case. 8 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 9 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 10 Protective Order does not entitle them to file confidential information under seal; 11 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 12 will be applied when a party seeks permission from the court to file material under 13 seal. 14 There is a strong presumption that the public has a right of access to judicial 15 proceedings and records in civil cases. In connection with non-dispositive motions, 16 good cause must be shown to support a filing under seal. See Kamakana v. City and 17 Cnty. of Honolulu,

447 F.3d 1172

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 18 v. Gen. Motors Corp.,

307 F.3d 1206

, 1210–11 (9th Cir. 2002), Makar-Welbon v. 19 Sony Elecs., Inc.,

187 F.R.D. 576, 577

(E.D. Wis. 1999) (even stipulated protective 20 orders require good cause showing), and a specific showing of good cause or 21 compelling reasons with proper evidentiary support and legal justification, must be 22 made with respect to Protected Material that a party seeks to file under seal. The 23 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 24 does not—without the submission of competent evidence by declaration, 25 establishing that the material sought to be filed under seal qualifies as confidential, 26 privileged, or otherwise protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, then 28 compelling reasons, not only good cause, for the sealing must be shown, and the 3 1 relief sought shall be narrowly tailored to serve the specific interest to be protected. 2 See Pintos v. Pac. Creditors Ass’n,

605 F.3d 665

, 677–79 (9th Cir. 2010). For each 3 item or type of information, document, or thing sought to be filed or introduced 4 under seal in connection with a dispositive motion or trial, the party seeking 5 protection must articulate compelling reasons, supported by specific facts and legal 6 justification, for the requested sealing order. Again, competent evidence supporting 7 the application to file documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in 9 its entirety will not be filed under seal if the confidential portions can be redacted. If 10 documents can be redacted, then a redacted version for public viewing, omitting 11 only the confidential, privileged, or otherwise protectable portions of the document, 12 shall be filed. Any application that seeks to file documents under seal in their 13 entirety should include an explanation of why redaction is not feasible. 14 2. DEFINITIONS 15 2.1 Action: The Action pending in the U.S. District Court, Central District 16 of California stylized as Jeremy Barrios v. Marriott International Administrative 17 Services, Inc. et al. and bearing Case No.: 2:25-cv-05138-SSC 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation 19 of information or items under this Order. 20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 21 how it is generated, stored or maintained) or tangible things that qualify for protection 22 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in 23 the Good Cause Statement. 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 25 support staff). 26 2.5 Designating Party: a Party or Non-Party that designates information or 27 items that it produces in disclosures or in responses to discovery as 28 4 1 “CONFIDENTIAL.” 2 2.6 Disclosure or Discovery Material: all items or information, regardless of 3 the medium or manner in which it is generated, stored, or maintained (including, 4 among other things, testimony, transcripts, and tangible things), that are produced or 5 generated in disclosures or responses to discovery in this matter. 6 2.7 Expert: a person with specialized knowledge or experience in a matter 7 pertinent to the litigation who has been retained by a Party or its counsel to serve as 8 an expert witness or as a consultant in this Action. 9 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 10 this Action, with or without prejudice; and (2) final judgment herein after the 11 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 12 this Action, including the time limits for filing any motions or applications for 13 extension of time pursuant to applicable law. 14 2.9 In-House Counsel: attorneys who are employees of a party to this 15 Action. In-House Counsel does not include Outside Counsel of Record or any other 16 outside counsel. 17 2.10 Non-Party: any natural person, partnership, corporation, association, or 18 other legal entity not named as a Party to this action. 19 2.11 Outside Counsel of Record: attorneys who are not employees of a party 20 to this Action but are retained to represent or advise a party to this Action and have 21 appeared in this Action on behalf of that party or are affiliated with a law firm which 22 has appeared on behalf of that party, and includes support staff. 23 2.12 Party: any party to this Action, including all of its officers, directors, 24 employees, consultants, retained experts, and Outside Counsel of Record (and their 25 support staffs). 26 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 27 Discovery Material in this Action. 28 2.14 Professional Vendors: persons or entities that provide litigation- support 5 1 services (e.g., photocopying, videotaping, translating, preparing exhibits or 2 demonstrations, and organizing, storing, or retrieving data in any form or medium) 3 and their employees and subcontractors. 4 2.15 Protected Material: any Disclosure or Discovery Material that is 5 designated as “CONFIDENTIAL.” 6 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 7 from a Producing Party. 8 3. SCOPE 9 The protections conferred by this Stipulation and Order cover not only 10 Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 compilations of Protected Material; and (3) any testimony, conversations, or 13 presentations by Parties or their Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the 15 trial judge. This Stipulated Protective Order does not govern the use of Protected 16 Material at trial. 17 4. TRIAL AND DURATION 18 The terms of this Stipulated Protective Order apply through Final Disposition 19 of the Action. 20 Once a case proceeds to trial, information that was designated as 21 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 22 used or introduced as an exhibit at trial becomes public and will be presumptively 23 available to all members of the public, including the press, unless compelling 24 reasons supported by specific factual findings to proceed otherwise are made to the 25 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 26 (distinguishing “good cause” showing for sealing documents produced in discovery 27 from “compelling reasons” standard when merits-related documents are part of court 28 6 1 record). Accordingly, for such materials, the terms of this Stipulated Protective 2 Order do not extend beyond the commencement of the trial. 3 Even after Final Disposition of this litigation, the confidentiality obligations 4 imposed by this Stipulated Protective Order shall remain in effect until a Designating 5 Party agrees otherwise in writing or a court order otherwise directs. 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under this 9 Order must take care to limit any such designation to specific material that qualifies 10 under the appropriate standards. The Designating Party must designate for protection 11 only those parts of material, documents, items, or oral or written communications that 12 qualify so that other portions of the material, documents, items, or communications 13 for which protection is not warranted are not swept unjustifiably within the ambit of 14 this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), 25 or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 26 for protection under this Stipulated Protective Order must be clearly so designated 27 before the material is disclosed or produced. 28 7 1 Designation in conformity with this Stipulated Protective Order requires: 2 (a) for information in documentary form (e.g., paper or electronic 3 documents, but excluding transcripts of depositions or other pretrial or trial 4 proceedings), that the Producing Party affix at a minimum, the legend 5 “CONFIDENTIAL” to each page that contains protected material. If only a portion 6 or portions of the material on a page qualifies for protection, the Producing Party 7 also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the 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. After the inspecting Party has identified the documents 14 it wants copied and produced, the Producing Party must determine which 15 documents, or portions thereof, qualify for protection under this Stipulated 16 Protective Order. Then, before producing the specified documents, the Producing 17 Party must affix the “CONFIDENTIAL” 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 all protected testimony. 24 (c) for information produced in some form other than documentary and for 25 any other tangible items, that the Producing Party affix in a prominent place on the 26 exterior of the container or containers in which the information is stored the 27 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 28 protection, the Producing Party, to the extent practicable, shall identify the protected 8 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 Stipulated Protective 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 under Local Rule 37.1 et seq. and with Section 2 of Judge 14 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”1 15 6.3 The burden of persuasion in any such challenge proceeding shall be on 16 the Designating Party. Frivolous challenges, and those made for an improper 17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 18 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 21 entitled under the Producing Party’s designation until the court rules on the 22 challenge. 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

27 1 Judge Christensen’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen. 9 1 Action only for prosecuting, defending, or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action reaches a Final Disposition, a 4 Receiving Party must comply with the provisions of section 13 below. 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Stipulated Protective Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 otherwise ordered by the court or permitted in writing by the Designating Party, a 10 Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only: 12 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 13 well as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 (b) to the officers, directors, and employees (including House Counsel) of 16 the Receiving Party to whom disclosure is reasonably necessary for this Action; 17 (c) to Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) to the court and its personnel; 21 (e) to court reporters and their staff; 22 (f) to professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) to the author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information; 27 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 28 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 10 1 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 2 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 3 information unless they sign the “Acknowledgment and Agreement to Be Bound” 4 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 5 court. Pages of transcribed deposition testimony or exhibits to depositions that 6 reveal Protected Material may be separately bound by the court reporter and may not 7 be disclosed to anyone except as permitted under this Stipulated Protective Order; 8 and 9 (i) to any mediator or settlement officer, and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement discussions. 11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 12 PRODUCED IN OTHER LITIGATION 13 If a Party is served with a subpoena or a court order issued in other litigation 14 that compels disclosure of any information or items designated in this Action as 15 “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party. Such notification shall 17 include a copy of the subpoena or court order; 18 (b) promptly notify in writing the party who caused the subpoena or order 19 to issue in the other litigation that some or all of the material covered by the 20 subpoena or order is subject to this Protective Order. Such notification shall include 21 a copy of this Stipulated Protective Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be pursued 23 by the Designating Party whose Protected Material may be affected. 24 If the Designating Party timely seeks a protective order, the Party served 25 with the subpoena or court order shall not produce any information designated in this 26 action as “CONFIDENTIAL” before a determination by the court from which the 27 subpoena or order issued, unless the Party has obtained the Designating Party’s 28 11 1 permission. The Designating Party shall bear the burden and expense of seeking 2 protection in that court of its confidential material and nothing in these provisions 3 should be construed as authorizing or encouraging a Receiving Party in this Action 4 to disobey a lawful directive from another court. 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED IN THIS LITIGATION 7 9.1 Application. The terms of this Stipulated Protective Order are applicable 8 to information produced by a Non-Party in this Action and designated as 9 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 10 this litigation is protected by the remedies and relief provided by this Order. Nothing 11 in these provisions should be construed as prohibiting a Non-Party from seeking 12 additional protections. 13 9.2 Notification. In the event that a Party is required, by a valid discovery 14 request, to produce a Non-Party’s confidential information in its possession, and the 15 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 16 confidential information, then the Party shall: 17 (a) promptly notify in writing the Requesting Party and the Non-Party that 18 some or all of the information requested is subject to a confidentiality agreement 19 with a Non-Party; 20 (b) make the information requested available for inspection by the Non- 21 Party, if requested. 22 9.3 Conditions of Production. If the Non-Party fails to seek a protective 23 order from this court within 14 days of receiving the notice and accompanying 24 information, the Receiving Party may produce the Non-Party’s confidential 25 information responsive to the discovery request. If the Non-Party timely seeks a 26 protective order, the Receiving Party shall not produce any information in its 27 possession or control that is subject to the confidentiality agreement with the Non- 28 Party before a determination by the court. Absent a court order to the contrary, the 12 1 Non-Party shall bear the burden and expense of seeking protection in this court of its 2 Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of this Order, 10 and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” (Exhibit A). 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other protection, 16 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 17 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 18 procedure may be established in an e-discovery order that provides for production 19 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 20 Rules of Evidence, insofar as the parties reach an agreement on the effect of 21 disclosure of a communication or information covered by the attorney-client 22 privilege or work product protection, the parties may incorporate their agreement in 23 the stipulated protective order submitted to the court. 24 12. MISCELLANEOUS 25 26 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 27 abridges the right of any person to seek its modification by the court in the future. 28 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 1 Stipulated Protective Order no Party waives any right it otherwise would have to 2 object to disclosing or producing any information or item on any ground not 3 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 4 to object on any ground to use in evidence of any of the material covered by this 5 Stipulated Protective Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Local Rule 79-5. Protected Material may only 8 be filed under seal pursuant to a court order authorizing the sealing of the specific 9 Protected Material at issue. If a Party's request to file Protected Material under seal 10 is denied by the court, then the Receiving Party may file the information in the 11 public record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the Final Disposition of this Action, as defined in paragraph 4, within 60 14 days of a written request by the Designating Party, each Receiving Party must return 15 all Protected Material to the Producing Party or destroy such material. As used in 16 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 17 summaries, and any other format reproducing or capturing any of the Protected 18 Material. Whether the Protected Material is returned or destroyed, the Receiving 19 Party must submit a written certification to the Producing Party (and, if not the same 20 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 21 (by category, where appropriate) all the Protected Material that was returned or 22 destroyed and (2) affirms that the Receiving Party has not retained any copies, 23 abstracts, compilations, summaries or any other format reproducing or capturing any 24 of the Protected Material. Notwithstanding this provision, Counsel is entitled to 25 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 26 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 27 reports, attorney work product, and consultant and expert work product, even if such 28 14 1 materials contain Protected Material. Any such archival copies that contain or 2 constitute Protected Material remain subject to this Protective Order as set forth in 3 Section 4. 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 15 114. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any and 3 all appropriate measures including, without limitation, contempt proceedings and/or 4 ||monetary sanctions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 LAUREL EMPLOYMENT LAW APC: 7 8 || Dated: July 23, 2025 By: /s/ Kyle DeCamp 9 Kyle DeCamp, Esq. Joshua L. White, Esq 10 Attorneys for Plaintiff, Jeremy Barrios 1] 12 MICHELMAN & ROBINSON, LLP: 13 14 || Dated: July 23, 2025 By: /s/ Amanda Monroe Dana A. Kravetz, Esq. 15 Amanda K. Monroe, Esq. 16 Attorneys for Defendants, Marriott 17 International Administrative Services, Inc.; Edition Management LLC dba The 18 West Hollywood Edition 19 20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 Z— 93 || DATED: July 24, 2025 STEPHANIE S. CHRISTENSEN 24 United States Magistrate Judge 25 26 27 28 16 JOINT STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION; [PROPOSED] ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective 6 Order that was issued by the United States District Court for the Central District 7 of California on July ____, 2025 in the case of Jeremy Barrios v. Marriott 8 International Administrative Services, Inc. et al. and bearing Case No.: 2:25-cv- 9 05138-SSC. 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 13 that is subject to this Stipulated Protective Order to any person or entity except in 14 strict 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 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 ________________________ [print 19 or type full name] of _________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23

24 Date: ___________________________ 25 City and State where sworn and signed: ___________________________ 26 Printed name: ___________________________ 27 Signature: ___________________________

28 17

Reference

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