1 JOHN W. HOWARD (SBN 80200) MOLLY M. LENS (SB #283867) SCOTT J. STREET (SBN 258962) [email protected] 2 JW Howard/ Attorneys, Ltd. SAM H.S. DONOHUE (SB #329526) 600 West Broadway, Suite 1400 [email protected] 3 San Diego, CA 92101 PAOLA MÉNDEZ (SB #353372) Tel: 619-234-2842; Fax 619-234-1716 [email protected] 4 [email protected] O’Melveny & Myers LLP [email protected] 1999 Avenue of the Stars, 8th Floor 5 Los Angeles, California 90067-6035 NICHOLAS R. BARRY (pro hac vice) Tel: (310) 553-6700 6 IAN PRIOR (pro hac vice) Fax: (310) 246-6779 America First Legal Foundation 7 611 Pennsylvania Ave, SE #231 NATASHA W. TELEANU (pro hac Washington, DC 20003 vice) 8 Telephone: (615) 431-9303 O’MELVENY & MYERS LLP [email protected] 1301 Avenue of the Americas, 17th Fl. 9 [email protected] New York, New York 10019 Telephone: +1 212 326 2000 10 Counsel for Plaintiff Facsimile: +1 212 326 2061 [email protected] 11 Attorneys for Defendants 12

13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15

16 JEFF VAUGHN Case No.: 2:24-cv-05570-HDV-RAO 17 Plaintiff,

18 v. DISCOVERY MATTER:

19 CBS BROADCASTING, INC., a AMENDED STIPULATED Delaware Corporation, and PROTECTIVE ORDER1 20 PARAMOUNT GLOBAL, a Delaware Corporation, Wendy 21 McMahon, an individual, 22 Defendants. 23

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

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 16 Byrd v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar- 17 Welbon v. Sony Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 18 protective orders require good cause showing), and a specific showing of good 19 cause or compelling reasons with proper evidentiary support and legal justification, 20 must be made with respect to Protected Material that a party seeks to file under 21 seal. The parties’ mere designation of Disclosure or Discovery Material as 22 CONFIDENTIAL does not—without the submission of competent evidence by 23 declaration, establishing that the material sought to be filed under seal qualifies as 24 confidential, privileged, or otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, 26 then compelling reasons, not only good cause, for the sealing must be shown, and 27 the relief sought shall be narrowly tailored to serve the specific interest to be 1 2010). For each item or type of information, document, or thing sought to be filed 2 or introduced under seal in connection with a dispositive motion or trial, the party 3 seeking protection must articulate compelling reasons, supported by specific facts 4 and legal justification, for the requested sealing order. Again, competent evidence 5 supporting the application to file documents under seal must be provided by 6 declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. 9 If documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document, 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 14 2. DEFINITIONS 15 2.1 Action: Jeff Vaughn v. CBS Broadcasting et al., No. 2:24-cv-05570- 16 HDV-RAO. 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified 22 above in the Good Cause Statement. 23 2.4 “ATTORNEYS’ EYES ONLY” Information or Items: information 24 designated as “ATTORNEYS’ EYES ONLY” pursuant to this Stipulated Protective 25 Order (hereinafter “Attorneys’ Eyes Only Information”) includes Disclosures or 26 Discovery Material that (a) constitutes Confidential Information and (b) the 27 Designating Party believes in good faith to be extremely confidential and/or 1 and other paragraphs of this Stipulated Protective Order. 2 2.5 Counsel: Outside Counsel of Record and In-House Counsel (as well as 3 their support staff). 4 2.6 Designating Party: a Party or Non-Party that designates information or 5 items that it produces in disclosures or in responses to discovery as 6 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 7 2.7 Disclosure or Discovery Material: all items or information, regardless 8 of the medium or manner in which it is generated, stored, or maintained (including, 9 among other things, testimony, transcripts, and tangible things), that are produced or 10 generated in disclosures or responses to discovery in this matter. 11 2.8 Expert: a person with specialized knowledge or experience in a matter 12 pertinent to the litigation who has been retained by a Party or its counsel to serve as 13 an expert witness or as a consultant in this Action. 14 2.9 Final Disposition: the later of (1) dismissal of all claims and defenses 15 in this Action, with or without prejudice; and (2) final judgment herein after the 16 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 17 this Action, including the time limits for filing any motions or applications for 18 extension of time pursuant to applicable law. 19 2.10 In-House Counsel: attorneys who are employees of a party to this 20 Action. In-House Counsel does not include Outside Counsel of Record or any other 21 outside counsel. 22 2.11 Non-Party: any natural person, partnership, corporation, association, or 23 other legal entity not named as a Party to this action. 24 2.12 Outside Counsel of Record: attorneys who are not employees of a party 25 to this Action but are retained to represent or advise a party to this Action and have 26 appeared in this Action on behalf of that party or are affiliated with a law firm which 27 has appeared on behalf of that party, and includes support staff. 1 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 support staffs). 3 2.14 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 2.15 Professional Vendors: persons or entities that provide litigation- 6 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or medium) 8 and their employees and subcontractors. 9 2.16 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 11 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material 12 from a Producing Party. 13 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 presentations by Parties or their Counsel that might reveal Protected Material. 20 For the avoidance of doubt, the designation of any documents or information 21 as “Confidential” or “Attorneys’ Eyes Only” under this Stipulation and Order does 22 not cover the following information: (a) any information that is independently in 23 the public domain at the time of disclosure to a Receiving Party or becomes part of 24 the public domain after its disclosure to a Receiving Party as a result of publication 25 not involving a violation of this Order and (b) any information independently 26 known to the Receiving Party prior to the disclosure or obtained by the Receiving 27 Party after the disclosure from a source who obtained the information lawfully and 1 of doubt, however, any documents designated as “Confidential” or “Attorneys’ 2 Eyes Only” pursuant to this Stipulation and Order must be treated as such, unless 3 and until the designation is withdrawn and/or the Court rules otherwise or the 4 document is otherwise independently in the possession of the author or intended 5 recipient(s) of a document (including persons who are “CC’d” or “BCC’d”) prior 6 to the designation of the document as “Confidential” or “Attorneys’ Eyes Only.” 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Stipulated Protective Order does not govern the use of Protected 9 Material at trial. 10 11 4. TRIAL AND DURATION 12 The terms of this Stipulated Protective Order apply through Final Disposition 13 of the Action. 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or “ATTORNEYS’ EYES ONLY” or maintained pursuant to 16 this Stipulated Protective Order and used or introduced as an exhibit at trial 17 becomes public and will be presumptively available to all members of the public, 18 including the press, unless compelling reasons supported by specific factual 19 findings to proceed otherwise are made to the trial judge in advance of the trial. 20 See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing for 21 sealing documents produced in discovery from “compelling reasons” standard 22 when merits-related documents are part of court record). Accordingly, for such 23 materials, the terms of this Stipulated Protective Order do not extend beyond the 24 commencement of the trial. 25 Even after Final Disposition of this litigation, the confidentiality obligations 26 imposed by this Stipulated Protective Order shall remain in effect until a 27 Designating Party agrees otherwise in writing or a court order otherwise directs. 1 defenses in this Action, with or without prejudice; and (2) final judgment herein 2 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 3 reviews of this Action, including the time limits for filing any motions or 4 applications for extension of time pursuant to applicable law. 5 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 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. 11 Mass, indiscriminate, or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper 13 purpose (e.g., to unnecessarily encumber the case development process or to 14 impose unnecessary expenses and burdens on other parties) may expose the 15 Designating Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) 21 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 22 qualifies for protection under this Stipulated Protective Order must be clearly so 23 designated before the material is disclosed or produced. 24 Designation in conformity with this Stipulated Protective Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 proceedings), that the Producing Party affix at a minimum, the legend 1 that contains protected material. 2 A Party or Non-Party that makes original documents available for inspection 3 need not designate them for protection until after the inspecting Party has indicated 4 which documents it would like copied and produced. During the inspection and 5 before the designation, all of the material made available for inspection shall be 6 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 7 it wants copied and produced, the Producing Party must determine which 8 documents qualify for protection under this Stipulated Protective Order. Then, 9 before producing the specified documents, the Producing Party must affix the 10 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” legend to each page that 11 contains Protected Material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions, the Designating Party may 15 provisionally designate the entirety of deposition testimony as “CONFIDENTIAL” 16 OR “ATTORNEYS’ EYES ONLY,” with the obligation to identify more specific 17 portions of the testimony as to which protection is sought within 30 days following 18 receipt of the deposition transcript (or within the time otherwise agreed by the 19 Parties). 20 (c) for information produced in some form other than documentary and 21 for any other tangible items, that the Producing Party affix in a prominent place on 22 the exterior of the container or containers in which the information is stored the 23 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” legend. If only a portion or 24 portions of the information warrants protection, the Producing Party, to the extent 25 practicable, shall identify the protected portion(s). 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 failure to designate qualified information or items does not, standing alone, waive 1 Upon timely correction of a designation, the Receiving Party must make reasonable 2 efforts to assure that the material is treated in accordance with the provisions of this 3 Stipulated Protective Order. 4 5 6. CHALLENGING CONFIDENTIALITY AND ATTORNEYS’ EYES 6 ONLY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 designation of Confidential or Attorneys’ Eyes Only at any time that is consistent 9 with the court’s Scheduling Order. Unless a prompt challenge to a Designating 10 Party’s confidentiality designation is necessary to avoid foreseeable, substantial 11 unfairness, unnecessary economic burdens, or a significant disruption or delay of 12 the litigation, a Party does not waive its right to challenge a confidentiality 13 designation by electing not to mount a challenge promptly after the original 14 designation is disclosed. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 17 Oliver’s Law and Motion Procedures titled “Informal Discovery Dispute 18 Resolution.”2 19 6.3 The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the Confidential or Attorneys’ Eyes Only 24 designation (including by failing to file the stipulation required by Local Rule 37- 25 2.1), all parties shall continue to afford the material in question the level of 26

27 2 Judge Oliver’s Procedures are available at 1 protection to which it is entitled under the Producing Party’s designation until the 2 court rules on the challenge. 3 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that 6 is disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending, or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action reaches a Final Disposition, a 10 Receiving Party must comply with the provisions of section 13 below. 11 Protected Material must be stored and maintained by a Receiving Party at a 12 location and in a secure manner that ensures that access is limited to the persons 13 authorized under this Stipulated Protective Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 15 otherwise ordered by the court or permitted in writing by the Designating Party, a 16 Receiving Party may disclose any information or item designated 17 “CONFIDENTIAL” only: 18 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 19 well as employees of said Outside Counsel of Record to whom it is reasonably 20 necessary to disclose the information for this Action; 21 (b) to the Receiving Party (if an individual), or officers, directors, and 22 employees (including In-House Counsel) of the Receiving Party to whom 23 disclosure is reasonably necessary for this Action; 24 (c) to Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) to the court and its personnel; 1 (f) to professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) to the author or recipient of a document containing the information or 5 a custodian or other person who otherwise possessed or knew the information; 6 (h) any deposition or non-trial hearing witness in the Action (including, 7 for the avoidance of doubt, in preparation for such testimony) who previously did 8 not have access to the Confidential Materials (including any counsel for such 9 individuals); provided, provided: (1) the witness signs the “Acknowledgment and 10 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to 11 keep any confidential information unless they sign the “Acknowledgment and 12 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 13 Party or ordered by the court; and 14 (i) to any mediator or settlement officer, and their supporting personnel, 15 mutually agreed upon by any of the parties engaged in settlement discussions. 16 7.3 Disclosure of “ATTORNEYS’ EYES ONLY” Information or Item. 17 Unless otherwise ordered by the Court or permitted in writing by the Designating 18 Party, a Receiving Party may disclose any information or item designated 19 “ATTORNEYS’ EYES ONLY” only: 20 (a) to those persons described in sub-paragraphs (a), (c), (d), (e), and (i), 21 and of Paragraph 7.2 of this Stipulated Protective Order; 22 (b) to In-House Counsel from the Receiving Party not otherwise covered 23 in paragraph 7.3(a) of this Stipulated Protective Order who have responsibilities in 24 connection with litigating these actions, provided that such persons (i) are first 25 advised of the terms of this Stipulated Protective Order and their obligation under 26 this Stipulated Protective Order to keep the Protected Material confidential, (ii) 27 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), and 1 server hosted by the Receiving Party’s Outside Counsel and its vendors and may 2 not copy, download, or otherwise receive or possess such documents; and 3 (c) to those persons described in sub-paragraphs (f) and (g) of Paragraph 4 7.2 of this Stipulated Protective Order not otherwise covered in Paragraph 7.3(a) of 5 this Stipulated Protective Order, provided that such persons (i) do not retain copies 6 of the materials designated “ATTORNEYS’ EYES ONLY,” (ii) are first advised of 7 the terms of this Stipulated Protective Order and his or her obligation under this 8 Stipulated Protective Order to keep the “ATTORNEYS’ EYES ONLY” documents 9 confidential, and (iii) have signed the “Acknowledgment and Agreement to Be 10 Bound” (Exhibit A). 11 The procedures for maintaining the confidentiality of Attorneys’ Eyes Only 12 Information during any hearing or trial in these actions shall be determined by the 13 Parties and the Court in advance of the hearing or trial. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification 20 shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order 22 to issue in the other litigation that some or all of the material covered by the 23 subpoena or order is subject to this Protective Order. Such notification shall 24 include a copy of this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served 1 this action as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” before a 2 determination by the court from which the subpoena or order issued, unless the 3 Party has obtained the Designating Party’s permission. The Designating Party 4 shall bear the burden and expense of seeking protection in that court of its 5 Protected Material and nothing in these provisions should be construed as 6 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 7 directive from another court. 8 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 9.1 Application. The terms of this Stipulated Protective Order are 12 applicable to information produced by a Non-Party in this Action and designated as 13 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” Such information 14 produced by Non-Parties in connection with this litigation is protected by the 15 remedies and relief provided by this Order. Nothing in these provisions should be 16 construed as prohibiting a Non-Party from seeking additional protections. 17 9.2 Notification. In the event that a Party is required, by a valid discovery 18 request, to produce a Non-Party’s confidential information in its possession, and the 19 Party is subject to an agreement with the Non-Party not to produce the Non- 20 Party’s confidential information, then the Party shall: 21 (a) promptly notify in writing the Requesting Party and the Non-Party 22 that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (b) make the information requested available for inspection by the Non- 25 Party, if requested. 26 9.3 Conditions of Production. If the Non-Party fails to seek a protective 27 order from this court within 14 days of receiving the notice and accompanying 1 information responsive to the discovery request. If the Non-Party timely seeks a 2 protective order, the Receiving Party shall not produce any information in its 3 possession or control that is subject to the confidentiality agreement with the Non- 4 Party before a determination by the court. Absent a court order to the contrary, with 5 the court having discretion to shift costs, the Non-Party shall bear the burden and 6 expense of seeking protection in this court of its Protected Material. 7 8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 9 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 10 Protected Material to any person or in any circumstance not authorized under this 11 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 12 writing the Designating Party of the unauthorized disclosures, (b) use its best 13 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 14 person or persons to whom unauthorized disclosures were made of all the terms of 15 this Order, and (d) request such person or persons to execute the “Acknowledgment 16 and Agreement to Be Bound” (Exhibit A). 17 18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other 22 protection, the obligations of the Receiving Parties are those set forth in Rule 23 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended 24 to modify whatever procedure may be established in an e-discovery order that 25 provides for production without prior privilege review. Pursuant to Federal Rule of 26 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of 27 disclosure of a communication or information covered by the attorney-client 1 the stipulated protective order submitted to the court. 2 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 5 abridges the right of any person to seek its modification by the court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Stipulated Protective Order no Party waives any right it otherwise would have to 8 object to disclosing or producing any information or item on any ground not 9 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 10 to object on any ground to use in evidence of any of the material covered by this 11 Stipulated Protective Order. And nothing in these provisions should be construed 12 as prohibiting a Party from seeking additional protections. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Local Rule 79-5. Protected Material may 15 only be filed under seal pursuant to a court order authorizing the sealing of the 16 specific Protected Material at issue. If a Party's request to file Protected Material 17 under seal is denied by the court, then the Receiving Party may file the information 18 in the public record unless otherwise instructed by the court. 19 20 13. FINAL DISPOSITION 21 After the Final Disposition of this Action, as defined in paragraph 4, within 22 60 days of a written request by the Designating Party, each Receiving Party must 23 return all Protected Material to the Producing Party or destroy such material. As 24 used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of the 26 Protected Material. Whether the Protected Material is returned or destroyed, the 27 Receiving Party must submit a written certification to the Producing Party (and, if 1 (1) identifies (by category, where appropriate) all the Protected Material that was 2 returned or destroyed and (2) affirms that the Receiving Party has not retained any 3 copies, abstracts, compilations, summaries or any other format reproducing or 4 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 5 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 6 and hearing transcripts, legal memoranda, correspondence, deposition and trial 7 exhibits, expert reports, attorney work product, and consultant and expert work 8 product, even if such materials contain Protected Material. Any such archival 9 copies that contain or constitute Protected Material remain subject to this Protective 10 Order as set forth in Section 4. 11 14. VIOLATION 12 Any violation of this Stipulated Protective Order may be punished by any 13 and all appropriate measures including, without limitation, contempt proceedings 14 and/or monetary sanctions. 15 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17

18 DATED: August 15, 2025 /s/ Michelle D. Volk 19 Attorney(s) for Plaintiff(s) 20 21 22 DATED: August 15, 2025 /s/ Molly M. Lens 23 Attorney(s) for Defendant(s) 24

25

26 27 1 ATTESTATION OF FILING 2 Pursuant to Local Rule 5-4.3.4 regarding signatures, I, Molly M. Lens, hereby 3 || attest that concurrence in the filing has been obtained from counsel with conformed 4 || signatures above. 5 Molly M. Lens 6 Molly M. Lens 7 8 ? || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. " DATED: _ 8/18/2025 Re elf s, Q : HON. ROZELLA A. OLIVER 13 United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10

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 Amended Stipulated 6 Protective Order that was issued by the United States District Court for the 7 Central District of California on ___________[date] in the case of Jeff Vaughn 8 v. CBS Studios et al., Case No. 2:24-cv-05570-HDV-RAO. I agree to comply with 9 and to be bound by all the terms of this Amended Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Amended 13 Stipulated Protective Order to any person or entity except in strict compliance with 14 the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms of 17 this Amended Stipulated Protective Order, even if such enforcement proceedings 18 occur after termination of this action. I hereby appoint 19 ________________________ [print or type full name] of _________ [print or 20 type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Amended Stipulated Protective Order. 23 24 Date: ___________________________ 25 City and State where sworn and 26 signed: ___________________________ 27 Printed name: ___________________________ 1 2 CERTIFICATE OF SERVICE 3 I am over 18 years of age and not a party to this action. I am employed by 4 O’Melveny & Myers LLP in the City and County of Los Angeles, State of 5 California. My business address is 1999 Avenue of the Stars, 8th Floor, Los 6 Angeles, California 90067. 7 On August 15, 2025, I electronically served the STIPULATED 8 PROTECTIVE ORDER and served the documents using the Court’s Electronic 9 CM/ECF Service which will send electronic notification of such filing to all 10 registered counsel. 11 I declare under penalty of perjury under the laws of the United States that the 12 foregoing is true and correct. Executed on August 15, at Los Angeles, California.

13 14 /s/ Sam H.S. Donohue Sam H.S. Donohue 15 16 17 18 19 20 21 22 23 24 25 26 27