1 Mandour & Associates, APC 2 Joseph A. Mandour, III (SBN 188896) Email: [email protected] 3 Ben T. Lila (SBN 246808) 4 Email: [email protected] Gordon E. Gray (SBN 175209) 5 Email: [email protected] 6 8605 Santa Monica Blvd., Suite 1500 Los Angeles, CA 90069 7 Telephone: (858) 487-9300 8 Attorneys for plaintiff and counterclaim-defendant, Blonde Voyage Salon LLC 9

10 Mark D. Kremer (SB# 100978) Email: [email protected] 11 Zachary T. Page (SB# 293885) 12 Email: [email protected] Thompson Hine LLP 13 3130 Wilshire Boulevard, Suite 500 14 Santa Monica, California 90403 Telephone: 310.998.9100 15 Facsimile: 310.998.9109 16 Attorneys for defendant and counterclaimant, Moroccanoil, Inc. 17 UNITED STATES DISTRICT COURT 18 CENTRAL DISTRICT OF CALIFORNIA

19 )

20 Blonde Voyage Salon LLC, a ) California limited liability ) Civil Case No. 2:25-cv-02391-GW-RAO 21 company, )

22 ) [proposed] STIPULATED Plaintiff, ) 23 ) PROTECTIVE ORDER 24 v. ) ) 25 Moroccanoil, Inc., a California ) 26 corporation, ) ) 27 Defendant. ) ) 1 Moroccanoil, Inc., a California ) 2 corporation, ) ) 3 Counterclaimant, ) 4 v. ) Blonde Voyage Salon LLC, a ) 5 California Limited Liability ) 6 Company, ) ) 7 Counterclaim- Defendant. ) 8 9 10 A. PURPOSES AND LIMITATIONS 11 Discovery in this action is likely to involve production of confidential, 12 proprietary or private information such as private business records, sales data, 13 employee data, banking records and business strategy for which special protection 14 from public disclosure and from use for any purpose other than prosecuting this 15 litigation may be warranted. Accordingly, the parties hereby stipulate to and petition 16 the Court to enter the following Stipulated Protective Order. The parties acknowledge 17 that this Order does not confer blanket protections on all disclosures or responses to 18 discovery and that the protection it affords from public disclosure and use extends 19 only to the limited information or items that are entitled to confidential treatment 20 under the applicable legal principles. 21 22 B. GOOD CAUSE STATEMENT 23 This action is between entities involved in the personal care products industry 24 and likely to involve trade secrets, customer and pricing lists and other valuable 25 research, development, commercial, financial, technical and/or proprietary 26 information for which special protection from public disclosure and from use for any 27 purpose other than prosecution of this action is warranted. Such confidential and 1 proprietary materials and information consist of, among other things, confidential 2 business or financial information, information regarding confidential business 3 practices, or other confidential research, development, or commercial information 4 (including information implicating sales data, employee data, bank records, and 5 privacy rights of third parties), information otherwise generally unavailable to the 6 public, or which may be privileged or otherwise protected from disclosure under state 7 or federal statutes, court rules, case decisions, or common law. Accordingly, to 8 expedite the flow of information, to facilitate the prompt resolution of disputes over 9 confidentiality of discovery materials, to adequately protect business information the 10 parties are entitled to keep confidential, to ensure that the parties are permitted 11 reasonable necessary uses of such material in preparation for and in the conduct of 12 trial, to address their handling at the end of the litigation, and serve the ends of justice, 13 a protective order for such information is justified in this matter. It is the intent of the 14 parties that information will not be designated as confidential for tactical reasons and 15 that nothing be so designated without a good faith belief that it has been maintained 16 in a confidential, non-public manner, and there is good cause why it should not be 17 part of the public record of this case. 18 19 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 20 The parties further acknowledge, as set forth in Section 12.3, below, that this 21 Stipulated Protective Order does not entitle them to file confidential information 22 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 23 the standards that will be applied when a party seeks permission from the court to file 24 material under seal. 25 There is a strong presumption that the public has a right of access to judicial 26 proceedings and records in civil cases. In connection with non-dispositive motions, 27 good cause must be shown to support a filing under seal. See Kamakana v. City and 1 County of Honolulu,

, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 2 Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc., 3

(E.D. Wis. 1999) (even stipulated protective orders require good 4 cause showing), and a specific showing of good cause or compelling reasons with 5 proper evidentiary support and legal justification, must be made with respect to 6 Protected Material that a party seeks to file under seal. The parties’ mere designation 7 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 8 submission of competent evidence by declaration, establishing that the material 9 sought to be filed under seal qualifies as confidential, privileged, or otherwise 10 protectable—constitute good cause. 11 Further, if a party requests sealing related to a dispositive motion or trial, then 12 compelling reasons, not only good cause, for the sealing must be shown, and the relief 13 sought shall be narrowly tailored to serve the specific interest to be protected. See 14 Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 15 item or type of information, document, or thing sought to be filed or introduced under 16 seal in connection with a dispositive motion or trial, the party seeking protection must 17 articulate compelling reasons, supported by specific facts and legal justification, for 18 the requested sealing order. Again, competent evidence supporting the application to 19 file documents under seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise protectable in 21 its entirety will not be filed under seal if the confidential portions can be redacted. If 22 documents can be redacted, then a redacted version for public viewing, omitting only 23 the confidential, privileged, or otherwise protectable portions of the document shall 24 be filed. Any application that seeks to file documents under seal in their entirety 25 should include an explanation of why redaction is not feasible. 26 27 2. DEFINITIONS 1 2.1 Action: This pending federal lawsuit, Case No. 2:25-cv-02391-GW- 2 RAO. 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation 4 of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 6 how it is generated, stored or maintained) or tangible things that qualify for protection 7 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 8 Cause Statement. 9 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 10 Information or Items: extremely sensitive “CONFIDENTIAL” Information or Items, 11 the disclosure of which to another Party or Non-Party would create a substantial risk 12 of serious competitive harm that could not be avoided by less restrictive means. 13 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their 14 support staff). 15 2.6 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 18 ONLY.” 19 2.7 Disclosure or Discovery Material: all items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things) that are produced or 22 generated in disclosures or responses to discovery in this matter. 23 2.8 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.9 House Counsel: attorneys who are employees of a party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside 1 counsel. 2 2.10 Non-Party: any natural person, partnership, corporation, association or 3 other legal entity not named as a Party to this action. 4 2.11 Outside Counsel of Record: attorneys who are not employees of a party 5 to this Action but are retained to represent or advise a party to this Action and have 6 appeared in this Action on behalf of that party or are affiliated with a law firm that 7 has appeared on behalf of that party, and includes support staff. 8 2.12 Party: any party to this Action, including all of its officers, directors, 9 owners, managers, employees, consultants, retained experts, and Outside Counsel of 10 Record (and their support staffs). 11 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.14 Professional Vendors: persons or entities that provide litigation support 14 services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) 16 and their employees and subcontractors. 17 2.15 Protected Material: any Disclosure or Discovery Material that is 18 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 19 EYES ONLY.” 20 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 21 from a Producing Party. 22 23 3. 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 extracted 26 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 27 1 Protected Material; and (3) any testimony, conversations, or presentations by Parties 2 or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 trial judge. This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 9 as an exhibit at trial becomes public and will be presumptively available to all 10 members of the public, including the press, unless compelling reasons supported by 11 specific factual findings to proceed otherwise are made to the trial judge in advance 12 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, the 15 terms of this protective order do not extend beyond the commencement of the trial. 16 Even after final disposition of this litigation, the confidentiality obligations 17 imposed by this order shall remain in effect until a designating party agrees otherwise 18 in writing or a court order otherwise directs. Final disposition shall be deemed to be 19 the later of (1) dismissal of all claims and defenses in this action, with or without 20 prejudice; and (2) final judgment herein after the completion and exhaustion of all 21 appeals, rehearings, remands, trials, or reviews of this action, including the time limits 22 for filing any motions or applications for extension of time pursuant to applicable law. 23 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under this 27 Order must take care to limit any such designation to specific material that qualifies 1 under the appropriate standards. The Designating Party must designate for protection 2 only those parts of material, documents, items or oral or written communications that 3 qualify so that other portions of the material, documents, items or communications 4 for which protection is not warranted are not swept unjustifiably within the ambit of 5 this Order. 6 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 impose 9 unnecessary expenses and burdens on other parties) may expose the Designating Party 10 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 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 17 under this Order must be clearly so designated before the material is disclosed or 18 produced. 19 Designation in conformity with this 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 “HIGHLY 25 CONFIDENTIAL legend”) to each page that contains protected material. If only a 26 portion or portions of the material on a page qualifies for protection, the Producing 27 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 1 markings in the margins). 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 documents, 8 or portions thereof, qualify for protection under this Order. Then, before producing 9 the specified documents, the Producing Party must affix the “CONFIDENTIAL 10 legend,” or “HIGHLY CONFIDENTIAL legend to each page that contains Protected 11 Material. If only a portion or portions of the material on a page qualifies for 12 protection, the Producing Party also must clearly identify the protected portion(s) 13 (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party identifies 15 the Disclosure or Discovery Material on the record, before the close of the deposition 16 all protected testimony. 17 (c) for information produced in some form other than documentary and for 18 any other tangible items, that the Producing Party affix in a prominent place on the 19 exterior of the container or containers in which the information is stored the legend 20 “CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 21 ONLY.” If only a portion or portions of the information warrants protection, the 22 Producing Party, to the extent practicable, shall identify the protected portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. 26 Upon timely correction of a designation, the Receiving Party must make reasonable 27 efforts to assure that the material is treated in accordance with the provisions of this 1 Order. 2 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on 10 the Designating Party. Frivolous challenges, and those made for an improper purpose 11 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 12 expose the Challenging Party to sanctions. Unless the Designating Party has waived 13 or withdrawn the confidentiality designation, all parties shall continue to afford the 14 material in question the level of protection to which it is entitled under the Producing 15 Party’s designation until the Court rules on the challenge. 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a Receiving 23 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 5 as employees of said Outside Counsel of Record to whom it is reasonably necessary 6 to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of the 8 Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) the Court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 (h) during their depositions, witnesses, and attorneys for witnesses, in the 20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 21 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 22 not be permitted to keep any confidential information unless they sign the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 24 agreed by the Designating Party or ordered by the court. Pages of transcribed 25 deposition testimony or exhibits to depositions that reveal Protected Material may be 26 separately bound by the court reporter and may not be disclosed to anyone except as 27 permitted under this Stipulated Protective Order; and 1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 4 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 5 writing by the Designating Party, a Receiving Party may disclose any information or 6 item designated “HIGHLY CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 8 as employees of said Outside Counsel of Record to whom it is reasonably necessary 9 to disclose the information for this Action; 10 (b) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (c) the Court and its personnel; 14 (d) court reporters and their staff; 15 (e) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (f) the author or recipient of a document containing the information or a 19 custodian or other person who otherwise possessed or knew the information; 20 (g) during their depositions, witnesses, and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 23 not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 agreed by the Designating Party or ordered by the court. Pages of transcribed 26 deposition testimony or exhibits to depositions that reveal Protected Material may be 27 separately bound by the court reporter and may not be disclosed to anyone except as 1 permitted under this Stipulated Protective Order; and 2 (h) any mediator or settlement officer, and their supporting personnel, mutually 3 agreed upon by any of the parties engaged in settlement discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 5 OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 9 ONLY,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification shall 11 include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by the subpoena 14 or order is subject to this Protective Order. Such notification shall include a copy of 15 this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued 17 by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with the 19 subpoena or court order shall not produce any information designated in this action 20 as “CONFIDENTIAL,” or ‘HIGHLY CONFIFDENTIAL – ATTORNEYS’ EYES 21 ONLY” before a determination by the court from which the subpoena or order 22 issued, unless the Party has obtained the Designating Party’s permission. The 23 Designating Party shall bear the burden and expense of seeking protection in that 24 court of its confidential material and nothing in these provisions should be construed 25 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 26 directive from another court. 27 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 1 PRODUCED IN THIS LITIGATION 2 (a) The terms of this Order are applicable to information produced by a 3 Non-Party in this Action and designated as “CONFIDENTIAL,” or “HIGHLY 4 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 5 Non-Parties in connection with this litigation is protected by the remedies and relief 6 provided by this Order. Nothing in these provisions should be construed as 7 prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 21 14 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 27 of seeking protection in this court of its Protected Material. 1 2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 4 Protected Material to any person or in any circumstance not authorized under this 5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 6 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 7 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 8 persons to whom unauthorized disclosures were made of all the terms of this Order, 9 and (d) request such person or persons to execute the “Acknowledgment and 10 Agreement to Be Bound” that is attached hereto as Exhibit A. 11 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13 PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain 15 inadvertently produced material is subject to a claim of privilege or other protection, 16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 18 may be established in an e-discovery order that provides for production without prior 19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 20 parties reach an agreement on the effect of disclosure of a communication or 21 information covered by the attorney-client privilege or work product protection, the 22 parties may incorporate their agreement in the stipulated protective order submitted 23 to the court. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 1 12.2 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 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 8 only be filed under seal pursuant to a court order authorizing the sealing of the specific 9 Protected Material at issue. If a Party’s request to file Protected Material under seal 10 is denied by the court, then the Receiving Party may file the information in the public 11 record unless otherwise instructed by the court. 12 13 13. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraph 4, within 60 15 days of a written request by the Designating Party, each Receiving Party must return 16 all Protected Material to the Producing Party or destroy such material. As used in this 17 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected 19 Material. Whether the Protected Material is returned or destroyed, the Receiving 20 Party must submit a written certification to the Producing Party (and, if not the same 21 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 22 (by category, where appropriate) all the Protected Material that was returned or 23 destroyed and (2) affirms that the Receiving Party has not retained any copies, 24 abstracts, compilations, summaries or any other format reproducing or capturing any 25 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 26 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 27 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 1 reports, attorney work product, and consultant and expert work product, even if such 2 materials contain Protected Material. Any such archival copies that contain or 3 constitute Protected Material remain subject to this Protective Order as set forth in 4 Section 4 (DURATION). 5 6 14. VIOLATION 7 Any violation of this Order may be punished by appropriate measures 8 including, without limitation, contempt proceedings and/or monetary sanctions. 9 10 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 11 12 DATED: October 20, 2025 13 14 /s/ Ben T. Lila Attorneys for Plaintiff BLONDE VOYAGE SALON, LLC 15 16 17 DATED: October 20, 2025 18 19 /s/ Zachery T. Page Attorneys for Defendant MOROCCANOIL, INC. 20 21 22 23 24 [THE COURT’S SIGNATURE IS ON THE FOLLOWING PAGE] 25 26 27 1 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || DATED: 1020/2025 4 5 | Royelh., QC— HON. ROZELLA A. OLIVER 6 || United States Magistrate Judge 7 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Blonde Voyage Salon, LLC v. Moroccanoil, Inc., Case No. 9 25-cv-02391-GW-RAO. I agree to comply with and to be bound by all the terms of 10 this Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 Signature: __________________________________ 27