1 Tionna Carvalho (SBN 299010) [email protected] 2 Elizabeth Larocque (SBN 219977) 3 [email protected] Strategic Legal Practices, APC 4 1888 Century Park East, 19th Floor 5 Los Angeles, CA 90067 Telephone: (310) 929-4900 6 Facsimile: (310) 943-3838 7 Attorneys for Plaintiff, PAYMAN RAHIMIAN 8

9 Steven D. Park (SBN 215219) 10 [email protected] 11 Vincent Tremonti (SBN 301571) [email protected] 12 PARK LAWLESS & TREMONTI LLP 13 515 S. Flower Street, 18th Floor Los Angeles, CA 90071 14 Telephone: (213) 640-3770 15 Facsimile: (213) 640-3015 Attorney for Defendant, 16 FCA US, LLC 17 UNITED STATES DISTRICT COURT 18 19 CENTRAL DISTRICT OF CALIFORNIA 20 PAYMAN RAHIMIAN, Case No. 5:24-cv-02406-SSS-SHK

21 Plaintiff, 22 STIPULATED PROTECTIVE 23 v. ORDER

24 FCA US, LLC, et al. 25 Defendants. 26 27 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this Order 7 does not confer blanket protections on all disclosures or responses to discovery and 8 that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and from 15 use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 26 such material in preparation for and in the conduct of trial, to address their handling 27 at the end of the litigation, and serve the ends of justice, a protective order for such 1 will not be designated as confidential for tactical reasons and that nothing be so 2 designated without a good faith belief that it has been maintained in a confidential, 3 non-public manner, and there is good cause why it should not be part of the public 4 record of this case. 5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 6 The parties further acknowledge, as set forth in Section 14.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. There is a strong presumption that the public has a right 11 of access to judicial proceedings and records in civil cases. In connection with non- 12 dispositive motions, good cause must be shown to support a filing under seal. See 13 Kamakana v. City and County of Honolulu,

, 1176 (9th Cir. 2006), 14 Phillips v. Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar- 15 Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 1999) (even 16 stipulated protective orders require good cause showing), and a specific showing of 17 good cause or compelling reasons with proper evidentiary support and legal 18 justification, must be made with respect to Protected Material that a party seeks to 19 file under seal. The parties’ mere designation of Disclosure or Discovery Material 20 as CONFIDENTIAL does not— without the submission of competent evidence by 21 declaration, establishing that the material sought to be filed under seal qualifies as 22 confidential, privileged, or otherwise protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the 25 relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For 27 each item or type of information, document, or thing sought to be filed or introduced 1 supported by specific facts and legal justification, for the requested sealing order. 2 Again, competent evidence supporting the application to file documents under seal 3 must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in 5 its entirety will not be filed under seal if the confidential portions can be redacted. If 6 documents can be redacted, then a redacted version for public viewing, omitting only 7 the confidential, privileged, or otherwise protectable portions of the document, shall 8 be filed. Any application that seeks to file documents under seal in their entirety 9 should include an explanation of why redaction is not feasible. 10 4. DEFINITIONS 11 4.1 Action: Payman Rahimian vs. FCA US LLC, et al; Case No. 5:24-cv-02406- 12 SSS-SHK 13 4.2 Challenging Party: a Party or Non-Party that challenges the designation of 14 information or items under this Order. 15 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 16 is generated, stored or maintained) or tangible things that qualify for protection 17 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 18 Cause Statement. 19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff). 21 4.5 Designating Party: a Party or Non-Party that designates information or items 22 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 23 4.6 Disclosure or Discovery Material: all items or information, regardless of the 24 medium or manner in which it is generated, stored, or maintained (including, among 25 other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery. 27 4.7 Expert: a person with specialized knowledge or experience in a matter 1 an expert witness or as a consultant in this Action. 2 4.8 House Counsel: attorneys who are employees of a party to this Action. House 3 Counsel does not include Outside Counsel of Record or any other outside counsel. 4 4.9 Non-Party: any natural person, partnership, corporation, association or other 5 legal entity not named as a Party to this action. 6 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 7 this Action but are retained to represent a party to this Action and have appeared in 8 this Action on behalf of that party or are affiliated with a law firm that has appeared 9 on behalf of that party, and includes support staff. 10 4.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 4.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 4.14 Protected Material: any Disclosure or Discovery Material that is designated 20 as “CONFIDENTIAL.” 21 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 22 a Producing Party. 23 5. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or 26 extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 compilations of Protected Material; and (3) any testimony, conversations, or 1 use of Protected Material at trial shall be governed by the orders of the trial judge 2 and other applicable authorities. This Order does not govern the use of Protected 3 Material at trial. 4 6. DURATION 5 Once a case proceeds to trial, information that was designated as 6 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 7 as an exhibit at trial becomes public and will be presumptively available to all 8 members of the public, including the press, unless compelling reasons supported by 9 specific factual findings to proceed otherwise are made to the trial judge in advance 10 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 11 showing for sealing documents produced in discovery from “compelling reasons” 12 standard when merits-related documents are part of court record). Accordingly, the 13 terms of this protective order do not extend beyond the commencement of the trial. 14 7. DESIGNATING PROTECTED MATERIAL 15 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 16 Party or Non-Party that designates information or items for protection under this 17 Order must take care to limit any such designation to specific material that qualifies 18 under the appropriate standards. 19 The Designating Party must designate for protection only those parts of 20 material, documents, items or oral or written communications that qualify so that 21 other portions of the material, documents, items or communications for which 22 protection is not warranted are not swept unjustifiably within the ambit of this Order. 23 Mass, indiscriminate or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper 25 purpose (e.g., to unnecessarily encumber the case development process or to impose 26 unnecessary expenses and burdens on other parties) may expose the Designating 27 Party to sanctions. 1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 7.2 Manner and Timing of Designations. Except as otherwise provided in this 4 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 5 qualifies for protection under this Order must be clearly so designated before the 6 material is disclosed or produced. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or electronic documents, 9 but excluding transcripts of depositions or other pretrial or trial proceedings), that 10 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 11 “CONFIDENTIAL legend”), to each page that contains protected material. If only 12 a portion of the material on a page qualifies for protection, the Producing Party also 13 must clearly identify the protected portion(s) (e.g., by making appropriate markings 14 in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. 18 During the inspection and before the designation, all of the material made available 19 for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 20 identified the documents it wants copied and produced, the Producing Party must 21 determine which documents, or portions thereof, qualify for protection under this 22 Order. Then, before producing the specified documents, the Producing Party must 23 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 24 If only a portion of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 (b) for testimony given in depositions that the Designating Party identifies the 1 all protected testimony. 2 (c) for information produced in some form other than documentary and for 3 any other tangible items, that the Producing Party affix in a prominent place on the 4 exterior of the container or containers in which the information is stored the legend 5 “CONFIDENTIAL.” If only a portion or portions of the information warrants 6 protection, the Producing Party, to the extent practicable, shall identify the protected 7 portion(s). 8 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 9 to designate qualified information or items does not, standing alone, waive the 10 Designating Party’s right to secure protection under this Order for such material. 11 Upon timely correction of a designation, the 12 Receiving Party must make reasonable efforts to assure that the material is treated 13 in accordance with the provisions of this Order. 14 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 16 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 17 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 18 process under Local Rule 37-1 et seq. 19 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 20 stipulation pursuant to Local Rule 37-2. 21 8.4 The burden of persuasion in any such challenge proceeding shall be on the 22 Designating Party. Frivolous challenges, and those made for an improper purpose 23 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 24 expose the Challenging Party to sanctions. Unless the Designating Party has waived 25 or withdrawn the confidentiality designation, all parties shall continue to afford the 26 material in question the level of protection to which it is entitled under the Producing 27 Party’s designation until the Court rules on the challenge. 1 9.1 Basic Principles. A Receiving Party may use Protected Material that is 2 disclosed or produced by another Party or by a Non-Party in connection with this 3 Action only for prosecuting, defending or attempting to settle this Action. Such 4 Protected Material may be disclosed only to the categories of persons and under the 5 conditions described in this Order. When the Action has been terminated, a 6 Receiving Party must comply with the provisions of section 15 below (FINAL 7 DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons 10 authorized under this Order. 11 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 12 ordered by the court or permitted in writing by the Designating Party, a Receiving 13 Party may disclose any information or item designated “CONFIDENTIAL” only to: 14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 15 employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this Action; 17 (b) the officers, directors, and employees (including House Counsel) of the 18 Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 1 (h) during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 4 will not be permitted to keep any confidential information unless they sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit 6 A), unless otherwise agreed by the Designating Party or ordered by the court. 7 Pages of transcribed deposition testimony or exhibits to depositions that 8 reveal Protected Material may be separately bound by the court reporter and may not 9 be disclosed to anyone except as permitted under this Stipulated Protective Order; 10 and 11 (i) any mediators or settlement officers and their supporting personnel, 12 mutually agreed upon by any of the parties engaged in settlement discussions. 13 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to 21 issue in the other litigation that some or all of the material covered by the subpoena 22 or order is subject to this Protective Order. Such notification shall include a copy of 23 this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued 25 by the Designating Party whose Protected Material may be affected. If the 26 Designating Party timely seeks a protective order, the Party served with the 27 subpoena or court order shall not produce any information designated in this 1 subpoena or order issued, unless the Party has obtained the Designating Party’s 2 permission. The Designating Party shall bear the burden and expense of seeking 3 protection in that court of its confidential material and nothing in these provisions 4 should be construed as authorizing or encouraging a 5 Receiving Party in this Action to disobey a lawful directive from another court. 6 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a Non- 9 Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party’s 16 confidential information, then the Party shall: 17 (1) 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 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 21 Order in this Action, the relevant discovery request(s), and a reasonably specific 22 description of the information requested; and 23 (3) make the information requested available for inspection by the Non-Party, 24 if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party’s confidential information responsive to the discovery 1 not produce any information in its possession or control that is subject to the 2 confidentiality agreement with the Non-Party before a determination by the court. 3 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 4 of seeking protection in this court of its Protected Material. 5 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 11 or persons to whom unauthorized disclosures were made of all the terms of this 12 Order, and (d) request such person or persons to execute the “Acknowledgment an 13 Agreement to Be Bound” attached hereto as Exhibit A. 14 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 22 parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted 25 to the court. 26 14. MISCELLANEOUS 27 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 1 14.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective Order. 6 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected 7 Material must comply with Local Civil Rule 79-5. Protected Material may only be 8 filed under seal pursuant to a court order authorizing the sealing of the specific 9 Protected Material. If a Party’s request to file Protected Material under seal is denied 10 by the court, then the Receiving Party may file the information in the public record 11 unless otherwise instructed by the court. 12 15. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 6, within 14 60 days of a written request by the Designating Party, each Receiving Party must 15 return all Protected Material to the Producing Party or destroy such material. As used 16 in this subdivision, “all Protected Material” includes all copies, abstracts, 17 compilations, summaries, and any other format reproducing or capturing any of the 18 Protected Material. Whether the Protected Material is returned or destroyed, the 19 Receiving Party must submit a written certification to the Producing Party (and, if 20 not the same person or entity, to the Designating Party) by the 60-day deadline that 21 (1) identifies (by category, where appropriate) all the Protected Material that was 22 returned or destroyed and (2) affirms that the Receiving Party has not retained any 23 copies, abstracts, compilations, summaries or any other format reproducing or 24 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 25 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 26 and hearing transcripts, legal memoranda, correspondence, deposition and trial 27 exhibits, expert reports, attorney work product, and consultant and expert work that contain or constitute Protected Material remain subject to this Protective Order |! as set forth in Section 6 (DURATION). 16. VIOLATION 4 Any violation of this Order may be punished by appropriate measures > including, without limitation, contempt proceedings and/or monetary sanctions. 6 THT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 STRATEGIC LEGAL PRACTICES, APC 10 DATED: August 20, 2025 /s/ Elizabeth Larocque 12 TIONNA CARVALHO 3 ELIZABETH LAROCQUE Attorneys for Plaintiff, 14 PAYMAN RAHIMIAN 15 16 PARK LAWLESS & TREMONTI LLP 17 18 |} DATED: August 20, 2025 /s/ Steven D. Park 19 STEVEN D. PARK VINCENT TREMONTI 20 Attorneys for Defendant, FCA US, LLC 22 93 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 ZA 25 DATED: August 22, 2025 Hon. Stephanie S. Christensen 26 United States Magistrate Judge 27 28 14

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 5 under penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on ___________ in the case of Payman Rahimian vs. FCA 8 US LLC, et al; Case No. 5:24-cv-02406-SSS-SHK. I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with 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 18 [print or type full name] of 19 [print or type full address and telephone number] as my California agent for service 20 21 of process in connection with this action or any proceedings related to enforcement 22 of this Stipulated Protective Order. 23 24 Date: ________________________ 25 City and State where sworn and signed: 26 Printed name: 27 Signature: