1 Milord A. Keshishian, SBN 197835 [email protected] 2 Shannon Skrzynski, SBN 358342 3 [email protected] MILORD LAW GROUP P.C. 4 333 S. Hope St., Ste. 4025 5 Los Angeles, CA 90071 Tel: (310) 226-7878 6 Fax: (310) 226-7879 7 Attorneys for Plaintiffs/Counter-Defendant ELEGANT OUTDOOR FURNITURE, LLC 8 D/B/A OLLE GARDENS 9 Daniel A. Solitro (SBN: 243908) 10 [email protected] 11 TROUTMAN PEPPER LOCKE LLP 350 South Grand Avenue, Suite 3400 12 Los Angeles, CA 90071 13 Tel. 213-928-9800

14 H. Straat Tenney 15 [email protected] 875 Third Avenue 16 New York, NY 10022 17 Tel. 212-704-6000 Attorneys for Defendants/Counter-Plaintiffs 18 VEGO INNOVATIONS, INC 19 20 UNITED STATES DISTRICT COURT 21 CENTRAL DISTRICT OF CALIFORNIA

22 ELEGANT OUTDOOR 23 FURNITURE, LLC, an Arizona Case No. 2:25-cv-02834-GW-SSC Domestic Limited Liability Company 24 D/B/A OLLE GARDENS; STIPULATED PROTECTIVE 25 Plaintiff, ORDER

26 v.

27 VEGO INNOVATIONS, INC., a GUANGYUAN “ROBERT” XIONG; 1 FRANK ZHANG; KENT XIE; AND JASON ZHANG; and DOES 1-10 2 Defendants. 3 4 5

6 VEGO INNOVATIONS, INC., a Delaware Corporation, 7

Counter-Plaintiff, 8

vs. 9

ELEGANT OUTDOOR FURNITURE, 10 LLC, an Arizona Domestic Limited Liability Company d/b/a Olle Gardens; 11

Counter-Defendants. 12

13 1. INTRODUCTION 14 1.1 Purposes and Limitations. Discovery in this action is likely to involve 15 production of confidential, proprietary, or private information for which special 16 protection from public disclosure and from use for any purpose other than 17 prosecuting this litigation may be warranted. Accordingly, the parties hereby 18 stipulate to and petition the court to enter the following Stipulated Protective Order. 19 The parties acknowledge that this Order does not confer blanket protections on all 20 disclosures or responses to discovery and that the protection it affords from public 21 disclosure and use extends only to the limited information or items that are entitled 22 to confidential treatment under the applicable legal principles. The parties further 23 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 24 Order does not entitle them to file confidential information under seal; Civil Local 25 Rule 79-5 sets forth the procedures that must be followed and the standards that will 26 be applied when a party seeks permission from the court to file material under seal. 27 1.2 Good Cause Statement. 1 each other for the marketing, distribution, and sale of raised metal garden beds, and 2 licensing of related intellectual property. The Parties have asserted cross-actions 3 against each other for infringement of intellectual property, false advertising, and 4 various business torts. The Parties allege this action is likely to involve trade 5 secrets, customer and pricing lists and other valuable research, development, 6 commercial, financial, technical and/or proprietary information for which special protection from public disclosure and from use for any purpose other than 7 prosecution of this action is warranted. 8 Such confidential and proprietary materials and information consist of, among 9 other things, confidential business or financial information, confidential information 10 concerning the identity of customers and distributors and their preferences, the 11 parties’ costs of goods sold and pricing practices, information regarding confidential 12 business practices, or other confidential research, development, or commercial 13 information (including information implicating privacy rights of third parties), 14 contracts, non-public compilations of retail prices, supplier and vendor agreements, 15 supplier and vendor identities, supplier pricing information and commissions or fees 16 paid to suppliers, personnel files, non-public policies and procedures, as well as 17 other documents and information otherwise generally unavailable to the public, or 18 which may be privileged or otherwise protected from disclosure under state or 19 federal statutes, court rules, case decisions, or common law. 20 Accordingly, to expedite the flow of information, to facilitate the prompt 21 resolution of disputes over confidentiality of discovery materials, to adequately 22 protect information the parties are entitled to keep confidential, to ensure that the 23 parties are permitted reasonable necessary uses of such material in preparation for 24 and in the conduct of trial, to address their handling at the end of the litigation, and serve the ends of justice, a protective order for such information is justified in this 25 matter. It is the intent of the parties that information will not be designated as 26 confidential or attorneys eyes’ only for tactical reasons and that nothing be so 27 1 non-public manner, and there is good cause why it should not be part of the public 2 record of this case, or in the case of the most competitively sensitive material, why it 3 should be produced solely on an attorneys’ eyes only basis. 4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 5 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 6 Protective Order does not entitle them to file confidential information under seal; Local Rule 79-5 sets forth the procedures that must be followed and the standards 7 that will be applied when a party seeks permission from the court to file material 8 under seal. 9 There is a strong presumption that the public has a right of access to judicial 10 proceedings and records in civil cases. In connection with non-dispositive motions, 11 good cause must be shown to support a filing under seal. See Kamakana v. City 12 and Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 13 Byrd v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar- 14 Welbon v. Sony Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 15 protective orders require good cause showing), and a specific showing of good 16 cause or compelling reasons with proper evidentiary support and legal justification, 17 must be made with respect to Protected Material that a party seeks to file under 18 seal. The parties’ mere designation of Disclosure or Discovery Material as 19 CONFIDENTIAL or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 20 ONLY” does not—without the submission of competent evidence by declaration, 21 establishing that the material sought to be filed under seal qualifies as confidential, 22 privileged, or otherwise protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, 24 then compelling reasons, not only good cause, for the sealing must be shown, and the relief sought shall be narrowly tailored to serve the specific interest to be 25 protected. See Pintos v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 26 2010). For each item or type of information, document, or thing sought to be filed 27 1 seeking protection must articulate compelling reasons, supported by specific facts 2 and legal justification, for the requested sealing order. Again, competent evidence 3 supporting the application to file documents under seal must be provided by 4 declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. If documents can be redacted, then a redacted version for public viewing, omitting 7 only the confidential, privileged, or otherwise protectable portions of the document, 8 shall be filed. Any application that seeks to file documents under seal in their 9 entirety should include an explanation of why redaction is not feasible. 10

11 2. DEFINITIONS 12 2.1 Action: the above-captioned pending federal lawsuit. 13 2.2 Challenging Party: a Party or Non-Party that challenges the designation 14 of information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified 18 above in the Good Cause Statement. 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 20 their support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or 22 items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 24 ONLY.” 2.6 Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that are produced or 27 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 5 Information or Items: extremely sensitive “Confidential Information or Items,” 6 disclosure of which to another Party or Non-Party would create a substantial risk of serious harm that could not be avoided by less restrictive means. 7 2.9 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 2.10 Non-Party: any natural person, partnership, corporation, association, or 11 other legal entity not named as a Party to this action. 12 2.11 Outside Counsel of Record: attorneys who are not employees of a party 13 to this Action but are retained to represent or advise a party to this Action and have 14 appeared in this Action on behalf of that party or are affiliated with a law firm which 15 has appeared on behalf of that party, and includes support staff. 16 2.12 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.14 Professional Vendors: persons or entities that provide litigation- 22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 2.15 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 26 ATTORNEYS’ EYES ONLY.” 27 1 from a Producing Party. 2 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or 7 presentations by Parties, Non-Parties, or their Counsel that might reveal Protected 8 Material. 9 Any use of Protected Material at trial shall be governed by the orders of the 10 trial judge. This Stipulated Protective Order does not govern the use of Protected 11 Material at trial. 12

13 4. DURATION 14 Once a case proceeds to trial, all of the information that was designated as 15 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 16 ONLY,” or maintained pursuant to this Stipulated Protective Order and used or 17 introduced as an exhibit at trial becomes public and will be presumptively available 18 to all members of the public, including the press, unless compelling reasons 19 supported by specific factual findings to proceed otherwise are made to the trial 20 judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing 21 “good cause” showing for sealing documents produced in discovery from 22 “compelling reasons” standard when merits-related documents are part of court 23 record). Accordingly, for such materials, the terms of this Stipulated Protective 24 Order do not extend beyond the commencement of the trial.

25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 1 this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items, or oral or written 4 communications that qualify so that other portions of the material, documents, 5 items, or communications for which protection is not warranted are not swept 6 unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited. Designations 7 that are shown to be clearly unjustified or that have been made for an improper 8 purpose (e.g., to unnecessarily encumber the case development process or to 9 impose unnecessary expenses and burdens on other parties) may expose the 10 Designating Party to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it 12 designated for protection do not qualify for protection, that Designating Party must 13 promptly notify all other Parties that it is withdrawing the inapplicable designation. 14 5.2 Manner and Timing of Designations. Except as otherwise provided in 15 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) 16 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 17 qualifies for protection under this Stipulated Protective Order must be clearly so 18 designated before the material is disclosed or produced. 19 Designation in conformity with this Stipulated Protective Order requires: 20 (a) for information in documentary form (e.g., paper or electronic 21 documents, but excluding transcripts of depositions or other pretrial or trial 22 proceedings), that the Producing Party affix at a minimum, the legend 23 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), or “HIGHLY 24 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter “AEO CONFIDENTIAL legend”), to each page that contains protected material. If only a 25 portion or portions of the material on a page qualifies for protection, the Producing 26 Party also must clearly identify the protected portion(s) (e.g., by making 27 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for inspection shall be 5 deemed CONFIDENTIAL or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 6 EYES ONLY”. After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must determine which documents, or 7 portions thereof, qualify for protection under this Stipulated Protective Order. 8 Then, before producing the specified documents, the Producing Party must affix 9 the “CONFIDENTIAL legend” or “AEO CONFIDENTIAL legend” to each page 10 that contains Protected Material. If only a portion or portions of the material on a 11 page qualifies for protection, the Producing Party also must clearly identify the 12 protected portion(s) (e.g., by making appropriate markings in the margins). 13 (b) for testimony given in depositions that the Designating Party identify 14 the Disclosure or Discovery Material on the record, before the close of the 15 deposition all protected testimony and specify the level of protection being asserted. 16 Alternatively, the Designating Party may designate information disclosed at the 17 deposition as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 18 ATTORNEYS’ EYES ONLY” by notifying the court reporter and other parties in 19 writing, within fifteen (15) days of receipt of the transcript, of the specific pages and 20 lines of the transcript which are designated as “CONFIDENTIAL” or “HIGHLY 21 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” The parties may agree to a 22 reasonable extension of the 15-day period for designation. Designations of 23 transcripts will apply to audio, video, or other recordings of the testimony. During 24 such 15-day period, the entire transcript shall receive “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” treatment. Upon such designation, the court 25 reporter and each party shall affix the appropriate legend (“CONFIDENTIAL” or 26 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”) to the designated 27 1 designated for protection within the fifteen-day period shall be covered by the 2 provisions of this Stipulated Protective Order after said designation period. 3 (c) for information produced in some form other than documentary and 4 for any other tangible items, that the Producing Party affix in a prominent place on 5 the exterior of the container or containers in which the information is stored, or for 6 electronic files in the file name or accompanying correspondence, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 7 ONLY,” as the case may be. If only a portion or portions of the information 8 warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). The Receiving Party shall mark any hard-copy printouts and 10 the storage medium of any permissible copies of such electronic material with the 11 corresponding legend contained on the original and such copies shall become 12 subject to the same protections as the information or items from which those copies 13 were made. 14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 failure to designate qualified information or items does not, standing alone, waive 16 the Designating Party’s right to secure protection under this Order for such material. 17 Upon timely correction of a designation, the Receiving Party must make reasonable 18 efforts to assure that the material is treated in accordance with the provisions of this 19 Stipulated Protective Order. 20 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. 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process (and, if necessary, file a discovery motion) under Local Rule 26 37.1 et seq. 27 1 the Designating Party. Frivolous challenges, and those made for an improper 2 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 3 parties) may expose the Challenging Party to sanctions. Unless the Designating 4 Party has waived or withdrawn the confidentiality designation, all parties shall 5 continue to afford the material in question the level of protection to which it is 6 entitled under the Producing Party’s designation until the court rules on the challenge. 7

8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that 10 is 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 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Stipulated Protective Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only: 23 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 24 well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action; 25 (b) to the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) to the court and its personnel; 4 (e) to court reporters and their staff; 5 (f) to professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (g) to the author or recipient of a document containing the information or 8 a custodian or other person who otherwise possessed or knew the information; 9 (h) during their depositions, to witnesses, and attorneys for witnesses, in 10 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing 11 party requests that the witness sign the “Acknowledgment and Agreement to Be 12 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any 13 confidential information unless they sign the “Acknowledgment and Agreement to 14 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 15 ordered by the court. Pages of transcribed deposition testimony or exhibits to 16 depositions that reveal Protected Material may be separately bound by the court 17 reporter and may not be disclosed to anyone except as permitted under this 18 Stipulated Protective Order; and 19 (i) to any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 22 ONLY” Information or Items. Unless otherwise ordered by the court or permitted 23 in writing by the Designating Party, a Receiving Party may disclose any 24 information or item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to: 25 (a) the Receiving Party’s Outside Counsel of Record, and employees of 26 the Outside Counsel of Record to whom it is reasonably necessary to disclose the 27 1 (b) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A) prior to receiving 4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” materials; provided, 5 however, that before a Receiving Party may disclose, directly or indirectly, any 6 information designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” the Receiving Party must email written notice to the Designating Party’s 7 outside counsel of record the following information regarding such expert or 8 consultant: (i) an Executed Exhibit A; (ii) confirmation that the expert or consultant 9 has been advised in writing that his or her disclosure of information designated 10 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to the Receiving 11 Party is prohibited; and (iii) the outside consultant’s current curriculum vitae or 12 other description setting forth the person’s name and office address, his or her 13 present employer with job title and job description, any business or personal 14 relationship to any of the Parties (aside from being retained to consult and/or 15 provide testimony in the Action), and a brief job history for the past five years; 16 (c) the Court and its personnel; 17 (d) court reporters and their staff; 18 (e) professional jury or trial consultants and Professional Vendors to 19 whom disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (f) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (g) the Designating Party’s own employees, officers, and directors, solely 24 as to the Designating Party’s own “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material; 25 (h) during their depositions, third-party witnesses, and attorneys for third- 26 party witnesses, in the Action to whom disclosure is reasonably necessary 27 1 party witness or attorney for the third-party witness; (2) the deposing party requests 2 that the third-party witness sign the form attached hereto as Exhibit A; (3) prior to 3 any disclosure, the deposing party consults with the Designating Party and counsel 4 participating in the deposition in order to determine whether a party or nonparty 5 objects to the disclosure; and (4) the third-party witness and his or her attorney may 6 not keep any confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 7 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits 8 to depositions that reveal Protected Material may be separately bound by the court 9 reporter and may not be disclosed to anyone except as permitted under this 10 Stipulated Protective Order; and 11 (i) any mediator or settlement officer, and their supporting personnel, 12 mutually agreed upon by the parties engaged in settlement discussions. 13 7.4 Data Security. The Parties agree to provide adequate security to protect 14 data produced by the other Party(ies) or by Non-Parties. At a minimum, any 15 Receiving Party subject to the terms of this Protective Order, will provide 16 reasonable measures to protect non-client data consistent with the American Bar 17 Association Standing Committee on Ethics and Professional Responsibility, Formal 18 Opinion 477R. 19 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,” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification 26 shall include a copy of the subpoena or court order; 27 1 to issue in the other litigation that some or all of the material covered by the 2 subpoena or order is subject to this Protective Order. Such notification shall include 3 a copy of this Stipulated Protective Order; and 4 (c) cooperate with respect to all reasonable procedures sought to be 5 pursued by the Designating Party whose Protected Material may be affected. 6 If the Designating Party timely seeks a protective order, the Party served with the subpoena or court order shall not produce any information designated in 7 this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 8 ATTORNEYS’ EYES ONLY” before a determination by the court from which the 9 subpoena or order issued, unless the Party has obtained the Designating Party’s 10 permission. The Designating Party shall bear the burden and expense of seeking 11 protection in that court of its confidential material and nothing in these provisions 12 should be construed as authorizing or encouraging a Receiving Party in this Action 13 to disobey a lawful directive from another court. 14

15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 16 PRODUCED IN THIS LITIGATION 17 9.1 Application. The terms of this Stipulated Protective Order are 18 applicable to information produced by a Non-Party in this Action and designated as 19 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 20 ONLY.” Such information produced by Non-Parties in connection with this 21 litigation is protected by the remedies and relief provided by this Order. Nothing in 22 these provisions should be construed as prohibiting a Non-Party from seeking 23 additional protections. 24 9.2 Notification. In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s confidential information in its possession, and the 25 Party is subject to an agreement with the Non-Party not to produce the Non- 26 Party’s confidential information, then the Party shall: 27 1 that some or all of the information requested is subject to a confidentiality 2 agreement with a Non-Party; 3 (b) promptly provide the Non-Party with a copy of the Stipulated 4 Protective Order in this Action, the relevant discovery request(s), and a 5 reasonably specific description of the information requested; and 6 (c) make the information requested available for inspection by the Non- Party, if requested. 7 9.3 Conditions of Production. If the Non-Party fails to seek a protective 8 order from this court within 14 days of receiving the notice and accompanying 9 information, the Receiving Party may produce the Non-Party’s confidential 10 information responsive to the discovery request. If the Non-Party timely seeks a 11 protective order, the Receiving Party shall not produce any information in its 12 possession or control that is subject to the confidentiality agreement with the Non- 13 Party before a determination by the court. Absent a court order to the contrary, the 14 Non-Party shall bear the burden and expense of seeking protection in this court of its 15 Protected Material. 16

17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has 19 disclosed Protected Material to any person or in any circumstance not authorized 20 under this Stipulated Protective Order, the Receiving Party must immediately (a) 21 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 22 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 23 the person or persons to whom unauthorized disclosures were made of all the terms 24 of this Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 25 Protected Material shall only be used for the purpose of litigating the Action 26 and shall not be used in other actions or proceedings. 27 1 participation in the conduct of this Action shall use such knowledge and information 2 only as permitted herein, and shall not disclose such Protected Material, their 3 contents or any portion or summary thereof to any person(s) not involved in the 4 conduct of the Action. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 7 The inadvertent production of privileged or work-product protected 8 documents, electronically stored information (ESI) or information is not a waiver 9 of the privilege or protection from discovery in this case or in any other federal or 10 state proceeding. When a Producing Party gives notice to Receiving Parties that 11 certain inadvertently produced material is subject to a claim of privilege or other 12 protection, the obligations of the Receiving Parties are those set forth in Rule 13 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended 14 to modify whatever procedure may be established in an e-discovery order that 15 provides for production without prior privilege review. Pursuant to Rules 502(d) 16 and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement 17 on the effect of disclosure of a communication or information covered by the 18 attorney-client privilege or work product protection, the parties may incorporate 19 their agreement in the stipulated protective order submitted to the court. 20 This Order shall be interpreted to provide the maximum protection allowed by 21 Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and granted full 22 faith and credit in all other state and federal proceedings by

. In 23 the event of any subsequent conflict of law, the law that is most protective of 24 privilege and work product shall apply. Nothing contained in this Order is intended to or shall serve to limit a Party’s 25 right to conduct a review of documents, ESI or information (including metadata) for 26 relevance, responsiveness and/or segregation of privileged and/or protected 27 1 If a Receiving Party has reason to believe that a produced document or other 2 information may reasonably be subject to a claim of privilege, then the Receiving 3 Party shall immediately sequester the document or information, cease using the 4 document or information and cease using any work product containing the 5 information, and shall inform the Producing Party of the beginning BATES number 6 of the document or, if no BATES number is available, shall otherwise inform the Producing Party of the information. 7 A Producing Party must give written notice to any Receiving Party asserting a 8 claim of privilege, work-product protection, or other ground for reclaiming 9 documents or information (a “clawback request”). After a clawback request is 10 received, the Receiving Party shall immediately sequester the document (if not 11 already sequestered) and shall not review or use that document, or any work product 12 containing information taken from that document, for any purpose. The Parties shall 13 meet and confer regarding any clawback request. 14

15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 17 abridges the right of any person to seek its modification by the court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Stipulated Protective Order no Party waives any right it otherwise would have to 20 object to disclosing or producing any information or item on any ground not 21 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 22 to object on any ground to use in evidence of any of the material covered by this 23 Stipulated Protective Order. 24 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Local Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material at issue. If a Party's request to file Protected Material 27 1 in the public record unless otherwise instructed by the court. 2 3 13. FINAL DISPOSITION 4 After the Final Disposition of this Action, within 60 days of a written request 5 by the Designating Party, each Receiving Party must return all Protected Material 6 to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and 7 any other format reproducing or capturing any of the Protected Material. Whether 8 the Protected Material is returned or destroyed, the Receiving Party must submit a 9 written certification to the Producing Party (and, if not the same person or entity, to 10 the Designating Party) by the 60 day deadline that (1) identifies (by category, 11 where appropriate) all the Protected Material that was returned or destroyed and (2) 12 affirms that the Receiving Party has not retained any copies, abstracts, 13 compilations, summaries or any other format reproducing or capturing any of the 14 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 15 archival copy of all pleadings, motion papers, trial, deposition, and hearing 16 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 17 reports, attorney work product, and consultant and expert work product, even if 18 such materials contain Protected Material. Any such archival copies that contain or 19 constitute Protected Material remain subject to this Protective Order as set forth in 20 Section 4 (DURATION). 21 22 14. VIOLATION 23 Any violation of this Stipulated Protective Order may be punished by by 24 civil or criminal contempt proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, or other appropriate action at the discretion of the Court. 25 / / / 26 27 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 DATED: August 25, 2025 MILORD LAW GROUP, P.C. 4 /s/ Milord A. Keshishian 5 Milord A. Keshishian Attorney(s) for Plaintiff/Counter-Defendant, 6 ELEGANT OUTDOOR FURNITURE, LLC 7 D/B/A OLLE GARDENS 8 7 DATED: August 25, 2025 TROUTMAN PEPPER LOCKE 10 /s/ H. Street Tenne H. Street Tenney 12 Attorney(s) for Defendant(s)/Counter-Plaintiffs 3 VEGO INNOVATIONS, INC., GUANGYUAN “ROBERT” XIONG, FRANK 14 ZHANG, KENT XIE, AND JASON ZHANG 15 16 Pursuant to L.R. 5-4.3.4(a)(2)(1), the e-filer of this document hereby attests that all 18 other signatories listed, on whose behalf this stipulation is submitted, concur in the 19 filing’s content and have authorized the filing. 20 21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 Za 23 DATED: August 25, 2025 24 STEPHANIE S. CHRISTENSEN 95 United States Magistrate Judge 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

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 _________________ [date] in the case of Olle Gardens v Vego 8 Innovation, Inc. et al.; Case No. 2:25-cv-02834-GW-SSC . I agree to comply 9 with and to be bound by all the terms of this 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 12 will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance 14 with 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 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint ________________________ 19 [print or type full name] of _________ [print or type full address and 20 telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 Date: ___________________________ 24 City and State where sworn and signed: 25 ___________________________ Printed name: ___________________________ 26 Signature: ___________________________ 27