1 2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE CENTRAL DISTRICT OF CALIFORNIA 9 WESTERN DIVISION 10 11 JOSUE SANCHEZ, Case No.: 2:24-cv-04656-MCS-PVCx 12 Plaintiff, STIPULATED PROTECTIVE 13 v. ORDER 14 TIMOTHY BALOG, RAYMOND 15 MANFRED A/K/A RAY MANFRED 16 A/K/A RAMIN MANOFARED, HIREWELL SCREENING 17 SOLUTIONS LLC, ACCURATE 18 SOURCE.COM, INC., 19 Defendants. 20 21 The parties to this Stipulated Protective Order have agreed to the terms of 22 this Order; accordingly, it is ORDERED: 23 24 1. Introduction 25 (a)Purposes and Limitations: Discovery in this action is likely to 26 involve production of confidential, proprietary, or private 27 28 information for which special protection from public disclosure 1 and from use for any purpose other than prosecuting this 2 litigation may be warranted. Accordingly, the parties hereby 3 4 stipulate to and petition the Court to enter the following 5 Stipulated Protective Order. The parties acknowledge that this 6 Order does not confer blanket protections on all disclosures or 7 8 responses to discovery and that the protection it affords from 9 public disclosure and use extends only to the limited information 10 or items that are entitled to confidential treatment under the 11 12 applicable legal principles. The parties further acknowledge, as 13 set forth in Section 7, below, that this Stipulated Protective Order 14 does not entitle them to file confidential information under seal; 15 16 Civil Local Rule 79-5 sets forth the procedures that must be 17 followed and the standards that will be applied when a party 18 seeks permission from the court to file material under seal. 19 20 (b) Good Cause Statement: This action is likely to involve trade 21 secrets, customer and pricing lists and other valuable research, 22 development, commercial, technical and/or proprietary 23 24 information for which special protection from public 25 disclosure and from use for any purpose other than prosecution 26 27 of this action is warranted. Such confidential and proprietary 28 materials and information consist of, among other things, 1 confidential business information, information regarding 2 confidential business practices, or other confidential research, 3 4 development, or commercial information (including information 5 implicating privacy rights of third parties), medical records, 6 personal identifying information, information otherwise 7 8 generally unavailable to the public, or which may be privileged 9 or otherwise protected from disclosure under state or federal 10 statutes, court rules, case decisions, or common law. 11 12 Accordingly, to expedite the flow of information, to facilitate 13 the prompt resolution of disputes over confidentiality of 14 discovery materials, to adequately protect information the 15 16 parties are entitled to keep confidential, to ensure that the parties 17 are permitted reasonable necessary uses of such material in 18 preparation for and in the conduct of trial, to address their 19 20 handling at the end of the litigation, and serve the ends of justice, 21 a protective order for such information is justified in this matter. 22 It is the intent of the parties that information will not be 23 24 designated as confidential for tactical reasons and that nothing 25 be so designated without a good faith belief that it has been 26 27 maintained in a confidential, non-public manner, and there is 28 1 good cause why it should not be part of the public record of this 2 case. 3 4 (c) Plaintiff believes if his full personal identifying information is 5 made available on the public docket he will be susceptible to 6 identity theft. As such, all filings should be made in compliance 7 8 with Fed. R. Civ. P. 5.2 in order to protect Plaintiff’s personal 9 identifying information. To the extent that there is medical 10 information that is compelled in this lawsuit, the medical 11 12 examination documents shall also be marked as confidential. See 13 Pate v. Pac. Harbor Line, Inc., No. 5:21-cv-01300-JWH-SHK, 14

, *37-38 (C.D. Cal. Feb. 6, 2023) 15 16 (stating that Plaintiff has a strong privacy interest in his medical 17 records); Tucson Woman's Clinic v. Eden,

, 551 18 (9th Cir. 2004) (“Individuals have a constitutionally protected 19 20 interest in avoiding disclosure of personal matters, including 21 medical information.”); Norman-Bloodsaw v. Lawrence 22 Berkeley Lab’y,

, 1269 (9th Cir. 1998) (“The 23 24 constitutionally protected privacy interest in avoiding disclosure 25 of personal matters clearly encompasses medical information 26 27 and its confidentiality.”); Miesegaes v. Allenby, No. CV 15- 28 01574 CJC (RAO),

,

2542064, at *4 (C.D. Cal. Mar. 13, 2020) (In the discovery 2 context, “[t]he Court recognizes the significant privacy interest 3 4 in medical records.”). 5 (d) Defendant HireWell’s believes if any information related to 6 trade secrets, client lists, customer and pricing lists, policies and 7 8 procedures, or other valuable research, development, 9 commercial, technical and/or proprietary information is made 10 available on the public docket it will be susceptible to a potential 11 12 breach of privacy into its confidential information. As such, all 13 filings should be made in compliance with Fed. R. Civ. P. 5.2 in 14 order to protect Defendant’s confidential information. (Fed. R 15 16 Civ. P., 26(c)(1)(G) [“The court may, for good cause, issue an 17 order to protect a party or person from annoyance, 18 embarrassment, oppression, or undue burden or expense, 19 20 including one or more of the following: requiring that a trade 21 secret or other confidential research, development, or 22 commercial information not be revealed or be revealed only in a 23 24 specified way.”].) 25 2. Scope. All materials produced or adduced in the course of 26 27 discovery, including initial disclosures, responses to discovery requests, 28 1 (hereinafter collectively “documents”), shall be subject to this Order concerning 2 Confidential Information as defined below. This Order is subject to the Local 3 4 Rules of this District and the Federal Rules of Civil Procedure on matters of 5 procedure and calculation of time periods. 6 3. Confidential Information. As used in this Order, “Confidential 7 8 Information” means information designated as “CONFIDENTIAL-SUBJECT 9 TO PROTECTIVE ORDER” by the producing party that meets the standards 10 of FRCP 26(c) and falls within one or more of the following categories: (a) 11 12 information prohibited from disclosure by statute; (b) information that reveals 13 trade secrets; (c) research, technical, commercial or financial information that the 14 15 party has maintained as confidential; (d) medical information concerning any 16 individual; or (e) personal identity information. Information or documents that 17 are available to the public may not be designated as Confidential Information. 18 19 Information or documents that were previously produced in any other litigation 20 matter to an opposing party without designation may not be designated as 21 Confidential Information. 22 23 4. Designation.

24 (a) A party may designate a document as Confidential 25 Information for protection under this Order by placing or affixing the words 26 27 “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” on the document 28 1 document. As used in this Order, “copies” includes electronic images, duplicates, 2 extracts, summaries or descriptions that contain the Confidential Information. 3 4 The marking “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” shall 5 be applied prior to or at the time of the documents are produced or disclosed. 6 Applying the marking “CONFIDENTIAL - SUBJECT TO PROTECTIVE 7 8 ORDER” to a document does not mean that the document has any status or 9 protection by statute or otherwise except to the extent and for the purposes of this 10 Order. Any copies that are made of any documents marked “CONFIDENTIAL - 11 12 SUBJECT TO PROTECTIVE ORDER” shall also be so marked, except that 13 indices, electronic databases or lists of documents that do not contain substantial 14 portions or images of the text of marked documents and do not otherwise disclose 15 16 the substance of the Confidential Information are not required to be marked. 17 (b) The designation of a document as Confidential Information is 18 a certification by an attorney that the document contains Confidential Information 19 20 as defined in this order.1 21 5. Depositions. 22 All deposition testimony taken in this case shall be treated as Confidential 23 Information until the expiration of the following: No later than thirty (30) days 24 25 after the testimony was given, within this time period, a party may serve a Notice 26 27

1 By designating documents confidential pursuant to this Order, counsel submits to the jurisdiction 28 1 of Designation to all parties of record as to specific portions of the testimony that 2 are designated Confidential Information, and thereafter only those portions 3 4 identified in the Notice of Designation shall be protected by the terms of this 5 Order. A party may only designate deposition testimony as confidential after a 6 good faith review of the transcript and a supportable determination that the 7 8 information warrants a confidential designation. The failure to serve a timely 9 Notice of Designation shall waive any designation of testimony taken in that 10 deposition as Confidential Information, unless otherwise ordered by the Court. 11 12 6. Protection of Confidential Material. 13 (a) General Protections. Confidential Information shall not be 14 used or disclosed by the parties, counsel for the parties or any other persons 15 16 identified in subparagraph (b) for any purpose whatsoever other than in this 17 litigation, including any appeal thereof. 18 19 (b) Limited Third-Party Disclosures. The parties and counsel for 20 the parties shall not disclose or permit the disclosure of any Confidential 21 Information to any third person or entity except as set forth in subparagraphs (1)- 22 23 (10). Subject to these requirements, the following categories of persons may be 24 allowed to review Confidential Information: 25 (1) Counsel. Counsel for the parties and employees of counsel who 26 have responsibility for the action; 27 (2) Parties. Individual parties and employees of a party but only to the 28 extent counsel determines in good faith that the employee’s 1 assistance is reasonably necessary to the conduct of the litigation in which the information is disclosed; 2 (3) The Court and its personnel; 3 (4) Court Reporters and Recorders. Court reporters and recorders 4 engaged for depositions; 5 (5) Contractors. Those persons specifically engaged for the limited 6 purpose of making copies of documents or organizing or processing documents, including outside vendors hired to process 7 electronically stored documents; 8 (6) Consultants and Experts. Consultants, investigators, or experts 9 employed by the parties or counsel for the parties to assist in the preparation and trial of this action but only after such persons have 10 completed the certification contained in Attachment A, 11 Acknowledgment of Understanding and Agreement to Be Bound; (7) Mediators. Those individuals engaged by any party to assist the 12 parties to resolve the matter. 13 (8) Witnesses at depositions. During their depositions, witnesses in this 14 action to whom disclosure is reasonably necessary. Witnesses shall not retain a copy of documents containing Confidential Information, 15 except witnesses may receive a copy of all exhibits marked at their 16 depositions in connection with review of the transcripts. Pages of transcribed deposition testimony or exhibits to depositions that are 17 designated as Confidential Information pursuant to the process set out 18 in this Order must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Order. 19 (9) Author or recipient. The author or recipient of the document (not 20 including a person who received the document in the course of 21 litigation); and 22 (10) Others by Consent. Other persons only by written consent of the producing party or upon order of the Court and on such conditions as 23 may be agreed or ordered. 24 25 (c) Control of Documents. Counsel for the parties shall make 26 reasonable efforts to prevent unauthorized or inadvertent disclosure of 27 Confidential Information. Counsel shall maintain the originals of the forms 28 1 signed by persons acknowledging their obligations under this Order for a period 2 of three years after the termination of the case. 3 4 7. Inadvertent Failure to Designate. An inadvertent failure to 5 designate a document as Confidential Information does not, standing alone, 6 waive the right to so designate the document; provided, however, that a failure to 7 8 serve a timely Notice of Designation of deposition testimony as required by 9 this Order, even if inadvertent, waives any protection for deposition testimony. 10 A party or non-party who discloses or produces Confidential Information 11 12 without designation may, within seven (7) days of discovering the failure to 13 designate or within 7 days of having had reason to discover the error, provide 14 notice of the error and produce a designated copy of the same. 15 16 8. Filing of Confidential Information. To the extent any motions, 17 briefs, pleadings, deposition transcripts, or other papers to be filed with the 18 Court incorporate documents or information subject to this Order, the party 19 20 filing such papers shall designate such materials, or portions thereof, as 21 “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” and shall file 22 them with the Court Clerk under seal. This Order does not, by itself, authorize 23 24 the filing of any document under seal. Any party wishing to file a document 25 designated as Confidential Information in connection with a motion, brief or 26 other submission to the Court must comply with Civil Local Rule 79-5. 27 28 9. No Greater Protection of Specific Documents. Except on privilege 1 grounds not addressed by this Order, no party may withhold information from 2 discovery on the ground that it requires protection greater than that afforded 3 4 by this Order unless the party moves for an order providing such special 5 protection. 6 10. Challenges by a Party to Designation as Confidential Information. 7 8 (a) Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time that is consistent with the Court’s 10 Scheduling Order. 11 12 (b) Meet and Confer. The Challenging Party will initiate the dispute 13 resolution process (and, if necessary, file a discovery motion) under Local Rule 14 37.1 et seq. 15 16 (c) The burden of persuasion in any such challenge proceeding will 17 be on the Designating Party. Frivolous challenges, and those made for an 18 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 19 20 on other parties) may expose the Challenging Party to sanctions. Unless the 21 Designating Party has waived or withdrawn the confidentiality designation, all 22 parties will continue to afford the material in question the level of protection 23 24 to which it is entitled under the Producing Party’s designation until the Court 25 rules on the challenge. 26

27 28 1 11. Use of Confidential Documents or Information at Trial. Nothing 2 in this Order shall be construed to affect the use of any document, material, or 3 4 information at any trial or hearing. A party that intends to present or that 5 anticipates that another party may present Confidential Information at a 6 hearing or trial shall bring that issue to the Court’s and parties’ attention by 7 8 motion or in a pretrial memorandum without disclosing the Confidential 9 Information. The Court may thereafter make such orders as are necessary to 10 govern the use of such documents or information at trial. 11 12 12. Confidential Information Subpoenaed or Ordered Produced in Other Litigation. 13 (a) If a receiving party is served with a subpoena or an order 14 15 issued in other litigation that would compel disclosure of any material or 16 document designated in this action as Confidential Information, the receiving 17 party must so notify the designating party, in writing, immediately and in no 18 19 event more than three court days after receiving the subpoena or order. Such 20 notification must include a copy of the subpoena or court order. 21 (b) The receiving party also must immediately inform in writing 22 23 the party who caused the subpoena or order to issue in the other litigation that 24 some or all of the material covered by the subpoena or order is the subject of this 25 Order. In addition, the receiving party must deliver a copy of this Order promptly 26 27 to the party in the other action that caused the subpoena to issue. 28 1 interested persons to the existence of this Order and to afford the designating 2 party in this case an opportunity to try to protect its Confidential Information in 3 4 the court from which the subpoena or order issued. The designating party shall 5 bear the burden and the expense of seeking protection in that court of its 6 Confidential Information, and nothing in these provisions should be construed 7 8 as authorizing or encouraging a receiving party in this action to disobey a lawful 9 directive from another court. The obligations set forth in this paragraph remain 10 in effect while the party has in its possession, custody or control Confidential 11 12 Information by the other party to this case. 13 13. Protections Extended to Third-Party’s Confidential Information. 14 The Parties agree to extend the provisions of this Protective Order to Confidential 15 16 Information produced in this case by third parties, if timely requested by the third 17 party. 18 14. Applicability to Parties Later Joined. If additional persons or 19 20 entities become parties to this lawsuit, they must not be given access to any 21 Confidential Information until they execute and file their written agreement to be 22 bound by the provisions of this Order. 23 24 15. Obligations on Conclusion of Litigation. 25 (a) Order Continues in Force. Unless otherwise agreed or 26 ordered, this Order shall remain in force after dismissal or entry of final 27 judgment not subject to further appeal. 28 1 (b) Obligations at Conclusion of Litigation. Within sixty-three 2 (63) days after dismissal or entry of final judgment not subject to further appeal, 3 4 all Confidential Information and documents marked “CONFIDENTIAL - 5 SUBJECT TO PROTECTIVE ORDER” under this Order, including copies as 6 defined in ¶ 3(a), shall be destroyed unless the document has been offered into 7 8 evidence or filed without restriction as to disclosure. 9 (c) Retention of Confidential Information. Notwithstanding the 10 above requirements to destroy documents, each attorney may retain a copy of any 11 12 Confidential Information submitted to the court. Further, and irrespective of 13 whether the Confidential Information was submitted to the court, each attorney 14 may retain Confidential Information as required by the professional rules of 15 16 conduct for lawyers or as necessary for the attorney or attorney’s law firm to 17 defend against, including but not limited to, potential claims of malpractice, 18 breach of contract, ethics disputes, bar complaints or grievance. Any retained 19 20 Confidential Information shall continue to be protected under this Order. The 21 retention period is for seven years. 22 16. Order Subject to Modification. This Order shall be subject to 23 24 modification by the Court on its own initiative or on motion of a party or any 25 other person with standing concerning the subject matter. 26 27 17. No Prior Judicial Determination. This Order is entered based on the 28 representations and agreements of the parties and for the purpose of facilitating l discovery. Nothing herein shall be construed or presented as a judicial 2 determination that any document or material designated Confidential Information 3 4 by counsel or the parties is entitled to protection under Rule 26(c) of the Federal 5 Rules of Civil Procedure or otherwise until such time as the Court may rule on a 6 specific document or issue. 7 8 18. Persons Bound. This Order shall take effect when entered and shall be binding upon all counsel of record and their law firms, the parties, and persons 10 made subject to this Order by its terms. 12 !3 | FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS SO 14 | ORDERED. 15 16 | DATED: September 24, 2025 fuk 18 19 HON. PEDRO V. CASTILLO UNITED STATES MAGISTRATE JUDGE 20 21 22 23 24 25 26 27 28

1

2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE CENTRAL DISTRICT OF CALIFORNIA 4 WESTERN DIVISION

5 6 JOSUE SANCHEZ, Case No.: 2:24-cv-04656-MCS-PVC

7 Plaintiff, Honorable District Judge Mark C. 8 v. Scarsi

9 TIMOTHY BALOG, RAYMOND Honorable Magistrate Judge Pedro V. 10 MANFRED A/K/A RAY MANFRED Castillo A/K/A RAMIN MANOFARED, 11 HIREWELL SCREENING ACKNOWLEDGEMENT OF 12 SOLUTIONS LLC, ACCURATE UNDERSTANDING SOURCE.COM, INC., 13 14 Defendants. 15 I have read and understand the protective order in the case captioned Sanchez, 16 Joshue v BackChecked™ LLC et al, case no. 2:24-cv-04656-MCS-PVC in the 17 United States District Court for the Central District of California. As soon as my 18 work in connection with that action has ended, but not later than 30 days after the 19 termination of that action (including any appeals), I will return or destroy any 20 confidential document that I received, any copy of or excerpt from a confidential 21 document, and any notes or other document that contains information from a 22 confidential document.

23 Date: _______________ ________________________________ 24 Signature

25 ___________________________________ 26 Printed Name 27 28