1 AMIR NASSIHI (SBN 235936) [email protected] 2 SHOOK, HARDY & BACON L.L.P. 3 555 Mission Street, Suite 2300 San Francisco, CA 94105 4 TEL: (415) 544-1900 | FAX: (415) 391-0281

5 NAOKI S. KANEKO (SBN 252285) 6 [email protected] SARAH GARBUZOV (SBN 345909) 7 [email protected] SHOOK, HARDY & BACON L.L.P. 8 Jamboree Center 5 Park Plaza, Suite 1600 9 Irvine, CA 92614 10 Tel: (949) 475-1500 | Fax: (949) 475-0016 [email protected] 11 Attorneys for Defendant 12 NISSAN NORTH AMERICA, INC. 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 YANILEYSI CHAVEZ, an 17 individual, Case No. 2:25-cv-03824-SSC

18 Plaintiff, STIPULATED PROTECTIVE 19 v. ORDER1

20 NISSAN NORTH AMERICA, INC., a Delaware Corporation; and DOES 1 21 through 10, inclusive, 22

23 Defendants. 24

25

26

27 1 This Stipulated Protective Order is substantially based on the model protective 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 prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. The parties further acknowledge, as 11 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a party 14 seeks permission from the court to file material under seal. 15 1.2 Good Cause Statement. This action is likely to involve trade secrets, 16 customer and pricing lists and other valuable research, development, commercial, 17 financial, technical and/or proprietary information for which special protection from 18 public disclosure and from use for any purpose other than prosecution of this action 19 is warranted. Such confidential and proprietary materials and information consist of, 20 among other things, confidential business or financial information, information 21 regarding confidential business practices, or other confidential research, 22 development, or commercial information (including information implicating privacy 23 rights of third parties), information otherwise generally unavailable to the public, or 24 which may be privileged or otherwise protected from disclosure under state or federal 25 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 26 flow of information, to facilitate the prompt resolution of disputes over confidentiality 27 of discovery materials, to adequately protect information the parties are entitled to 1 of such material in preparation for and in the conduct of trial, to address their handling 2 at the 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 further 9 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 10 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 11 forth the procedures that must be followed and the standards that will be applied when 12 a party seeks permission from the court to file material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 proceedings and records in civil cases. In connection with non-dispositive motions, 15 good cause must be shown to support a filing under seal. See Kamakana v. City and 16 Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 17 v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar-Welbon v. 18 Sony Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated protective 19 orders require good cause showing), and a specific showing of good cause or 20 compelling reasons with proper evidentiary support and legal justification, must be 21 made with respect to Protected Material that a party seeks to file under seal. The 22 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 23 does not—without the submission of competent evidence by declaration, establishing 24 that the material sought to be filed under seal qualifies as confidential, privileged, or 25 otherwise protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, then 27 compelling reasons, not only good cause, for the sealing must be shown, and the relief 1 Pintos v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 2010). For each item 2 or type of information, document, or thing sought to be filed or introduced under seal 3 in connection with a dispositive motion or trial, the party seeking protection must 4 articulate compelling reasons, supported by specific facts and legal justification, for 5 the requested sealing order. Again, competent evidence supporting the application to 6 file documents under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in its 8 entirety will not be filed under seal if the confidential portions can be redacted. If 9 documents can be redacted, then a redacted version for public viewing, omitting only 10 the confidential, privileged, or otherwise protectable portions of the document, shall 11 be filed. Any application that seeks to file documents under seal in their entirety 12 should include an explanation of why redaction is not feasible. 13 2. DEFINITIONS 14 2.1 Action: this pending federal lawsuit, Case no. 2:25-cv-03824-SSC. 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation 16 of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for protection 19 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 20 Cause Statement 21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 22 support staff). 23 2.5 Designating Party: a Party or Non-Party that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 2.6 Disclosure or Discovery Material: all items or information, regardless of 27 the medium or manner in which it is generated, stored, or maintained (including, 1 generated in disclosures or responses to discovery in this matter. 2 2.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 an expert witness or as a consultant in this Action. 5 2.8 House Counsel: attorneys who are employees of a party to this Action. 6 House Counsel does not include Outside Counsel of Record or any other outside 7 counsel. 8 2.9 Non-Party: any natural person, partnership, corporation, association, or 9 other legal entity not named as a Party to this action. 10 2.10 Outside Counsel of Record: attorneys who are not employees of a party 11 to this Action but are retained to represent or advise a party to this Action and have 12 appeared in this Action on behalf of that party or are affiliated with a law firm which 13 has appeared on behalf of that party, and includes support staff. 14 2.11 Party: any party to this Action, including all of its officers, directors, 15 employees, consultants, retained experts, and Outside Counsel of Record (and their 16 support staffs). 17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 18 Discovery Material in this Action. 19 2.13 Professional Vendors: persons or entities that provide litigation support 20 services (e.g., photocopying, videotaping, translating, preparing exhibits or 21 demonstrations, and organizing, storing, or retrieving data in any form or medium) 22 and their employees and subcontractors. 23 2.14 Protected Material: any Disclosure or Discovery Material that is 24 designated as “CONFIDENTIAL.” 25 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 26 from a Producing Party. 27 3. SCOPE 1 Protected Material (as defined above), but also (1) any information copied or extracted 2 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 3 Protected Material; and (3) any testimony, conversations, or presentations by Parties 4 or their Counsel that might reveal Protected Material. 5 Any use of Protected Material at trial will be governed by the orders of the trial 6 judge. This Order does not govern the use of Protected Material at trial. 7 4. TRIAL AND DURATION 8 The terms of this Stipulated Protective Order apply through Final Disposition 9 of 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” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record). Accordingly, for 18 such materials, the terms of this Stipulated Protective Order do not extend beyond the 19 commencement of the trial. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under this 23 Order must take care to limit any such designation to specific material that qualifies 24 under the appropriate standards. The Designating Party must designate for protection 25 only those parts of material, documents, items, or oral or written communications that 26 qualify so that other portions of the material, documents, items, or communications 27 for which protection is not warranted are not swept unjustifiably within the ambit of 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating Party 5 to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic documents, 16 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 17 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 18 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 19 portion or portions of the material on a page qualifies for protection, the Producing 20 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 21 markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and before 25 the designation, all of the material made available for inspection will be deemed 26 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 27 copied and produced, the Producing Party must determine which documents, or 1 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 2 to each page that contains Protected Material. If only a portion or portions of the 3 material on a page qualifies for protection, the Producing Party also must clearly 4 identify the protected portion(s) (e.g., by making appropriate markings in the 5 margins). 6 (b) for testimony given in depositions that the Designating Party identify the 7 Disclosure or Discovery Material on the record, before the close of the deposition all 8 protected testimony. 9 (c) for information produced in some form other than documentary and for any 10 other tangible items, that the Producing Party affix in a prominent place on the exterior 11 of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, will identify the protected 14 portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive the 17 Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the Court’s 24 Scheduling Order. 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 26 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 27 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.” 1 6.3 The burden of persuasion in any such challenge proceeding shall be on 2 the Designating Party. Frivolous challenges, and those made for an improper purpose 3 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 expose the Challenging Party to sanctions. Unless the Designating Party has waived 5 or withdrawn the confidentiality designation, all parties shall continue to afford the 6 material in question the level of protection to which it is entitled under the Producing 7 Party’s designation until the court rules on the challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending, or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a Receiving 14 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 23 as employees of said Outside Counsel of Record to whom it is reasonably necessary 24 to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of the 26 Receiving Party to whom disclosure is reasonably necessary for this Action; 27 (c) Experts (as defined in this Order) of the Receiving Party to whom 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (d) the Court and its personnel; 3 (e) court reporters and their staff; 4 (f) professional jury or trial consultants, mock jurors, and Professional 5 Vendors to whom disclosure is reasonably necessary for this Action and who have 6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (g) the author or recipient of a document containing the information or a 8 custodian or other person who otherwise possessed or knew the information; 9 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 10 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 11 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 12 not be permitted to keep any confidential information unless they sign the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 14 agreed by the Designating Party or ordered by the court. Pages of transcribed 15 deposition testimony or exhibits to depositions that reveal Protected Material may be 16 separately bound by the court reporter and may not be disclosed to anyone except as 17 permitted under this Stipulated Protective Order; and 18 (i) any mediator or settlement officer, and their supporting personnel, 19 mutually agreed upon by any of the parties engaged in settlement discussions. 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 21 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification will 26 include a copy of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or order 1 or order is subject to this Protective Order. Such notification will include a copy of 2 this Stipulated Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be pursued 4 by the Designating Party whose Protected Material may be affected. 5 If the Designating Party timely seeks a protective order, the Party served with 6 the subpoena or court order will not produce any information designated in this action 7 as “CONFIDENTIAL” before a determination by the court from which the subpoena 8 or order issued, unless the Party has obtained the Designating Party’s permission. The 9 Designating Party will bear the burden and expense of seeking protection in that court 10 of its confidential material and nothing in these provisions should be construed as 11 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 12 directive from another court. 13 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 9.1 Application. The terms of this Stipulated Protective Order are applicable 16 to information produced by a Non-Party in this Action and designated as 17 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 18 this litigation is protected by the remedies and relief provided by this Order. Nothing 19 in these provisions should be construed as prohibiting a Non-Party from seeking 20 additional protections. 21 9.2 Notification. In the event that a Party is required, by a valid discovery 22 request, to produce a Non-Party’s confidential information in its possession, and the 23 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (a) promptly notify in writing the Requesting Party and the Non-Party that 26 some or all of the information requested is subject to a confidentiality agreement with 27 a Non-Party; 1 Party, if requested. 2 9.3 Conditions of Production. If the Non-Party fails to seek a protective 3 order from this court within 14 days of receiving the notice and accompanying 4 information, the Receiving Party may produce the Non-Party’s confidential 5 information responsive to the discovery request. If the Non-Party timely seeks a 6 protective order, the Receiving Party shall not produce any information in its 7 possession or control that is subject to the confidentiality agreement with the Non- 8 Party before a determination by the court. Absent a court order to the contrary, the 9 Non-Party shall bear the burden and expense of seeking protection in this court of its 10 Protected Material. 11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and 19 Agreement to Be Bound” (Exhibit A). 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 25 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 26 procedure may be established in an e-discovery order that provides for production 27 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 1 communication or information covered by the attorney-client privilege or work 2 product protection, the parties may incorporate their agreement in the stipulated 3 protective order submitted to the court. 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in this 10 Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 ground to use in evidence of any of the material covered by this Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 14 only be filed under seal pursuant to a court order authorizing the sealing of the specific 15 Protected Material at issue. If a Party's request to file Protected Material under seal is 16 denied by the court, then the Receiving Party may file the information in the public 17 record unless otherwise instructed by the court. 18 13. FINAL DISPOSITION 19 After the final disposition of this Action, as defined in paragraph 4, within 60 20 days of a written request by the Designating Party, each Receiving Party must return 21 all Protected Material to the Producing Party or destroy such material. As used in this 22 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 23 summaries, and any other format reproducing or capturing any of the Protected 24 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 25 must submit a written certification to the Producing Party (and, if not the same person 26 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 27 category, where appropriate) all the Protected Material that was returned or destroyed 1 compilations, summaries or any other format reproducing or capturing any of the 2 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 3 archival copy of all pleadings, motion papers, trial, deposition, and hearing 4 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 5 reports, attorney work product, and consultant and expert work product, even if such 6 materials contain Protected Material. Any such archival copies that contain or 7 constitute Protected Material remain subject to this Protective Order as set forth in 8 Section 4 (DURATION). 9 14. VIOLATION 10 Any violation of this Stipulated Protective Order may be punished by any and 11 all appropriate measures including, without limitation, contempt proceedings and/or 12 monetary sanctions. 13 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 16 Dated: July 9, 2025 QUILL & ARROW, LLP.

17

18 By /s/Andrew Jung ANDREW JUNG 19 DANJA STOCCA 20 Attorneys for Plaintiff 21 YANILEYSI CHAVEZ 22 23 24 25 26 27 1 Dated: July 31, 2025 SHOOK, HARDY & BACON L.L.P.

2

3 By /s/ Sarah Garbuzov AMIR NASSIHI 4 NAOKI S. KANEKO 5 SARAH GARBUZOV

6 Attorneys for Defendant NISSAN NORTH AMERICA, INC 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 DATED: August 4, 2025 4 STEPHANIE S. CHRISTENSEN ; United States Magistrate Judge

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

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of _________________ 4 [full address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on _________ [date] in the case 7 of Yanileysi Chavez v. Nissan North America, Inc., Case No. 2:25-cv-03824-SSC. 8 I agree to comply with and to be bound by all the terms of this Stipulated Protective 9 Order and I understand and acknowledge that failure to so comply could expose me 10 to sanctions and punishment in the nature of contempt. I solemnly promise that I 11 will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance with 13 the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27