1 MORGAN, LEWIS & BOCKIUS LLP Arjun P. Rao, Bar No. 265347 2 [email protected] Marcos D. Sasso, Bar No. 228905 3 [email protected] 4 2049 Century Park East, Suite 700 Los Angeles, CA 90067-3109 5 Tel: +1.310.907.1000 Fax: +1.310.907.1001 6 7 Madison G. Marshall, Bar No. 359485 [email protected] 8 600 Anton Boulevard, Suite 1800 Costa Mesa, CA 92626-7653 9 Tel: +1.714.830.0600 Fax: +1.714.830.0700 10 11 Attorneys for Defendant JPMORGAN CHASE BANK, N.A. 12 13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 MORTEZA REZAEI, ) Case No. 2:25-cv-04487-JLS-MBK ) 17 ) Plaintiff, ) 18 ) 19 v. ) ) STIPULATED PROTECTIVE ORDER ) 20 ) JPMORGAN CHASE BANK, N.A., ) 21 TRANS UNION, LLC, EQUIFAX ) INFORMATION SERVICES, LLC, ) 22 and DOES 1 THROUGH 10, inclusive, ) ) 23 ) Defendants. ) 24 ) 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to 25 keep confidential, to ensure that the parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a protective order 1 information will not be designated as confidential for tactical reasons and that 2 nothing be so designated without a good faith belief that it has been maintained in a 3 confidential, non-public manner, and there is good cause why it should not be part 4 of the public record of this case. 5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 6 The parties further acknowledge, as set forth in Section 14.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. There is a strong presumption that the public has a right 11 of access to judicial proceedings and records in civil cases. In connection with non- 12 dispositive motions, good cause must be shown to support a filing under seal. See 13 Kamakana v. City and County of Honolulu,

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

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

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

(9th Cir. 27 2010). For each item or type of information, document, or thing sought to be filed 1 reasons, supported by specific facts and legal justification, for the requested sealing 2 order. Again, competent evidence supporting the application to file documents 3 under seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in 5 its entirety will not be filed under seal if the confidential portions can be redacted. 6 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 4. DEFINITIONS 11 4.1 Action: Morteza Rezaei v. JPMorgan Chase Bank, N.A., Trans Union, 12 LLC, Equifax Information Services, LLC, Case No.: 2:25-cv-04487-JLS-MBK 13 4.2 Challenging Party: a Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 18 the Good Cause Statement. 19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 20 their support staff). 21 4.5 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.” 24 4.6 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 27 or generated in disclosures or responses to discovery. 1 4.7 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 4.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 4.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 4.10 Outside Counsel of Record: attorneys who are not employees of a 10 party to this Action but are retained to represent a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that 12 has appeared on behalf of that party, and includes support staff. 13 4.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 4.13 Professional Vendors: persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 4.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 4.15 Receiving Party: a Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 5. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 1 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 compilations of Protected Material; and (3) any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge and other applicable authorities. This Order does not govern the use of 6 Protected Material at trial. 7 6. DURATION 8 Once a case proceeds to trial, information that was designated as 9 CONFIDENTIAL or maintained pursuant to this protective order used or 10 introduced as an exhibit at trial becomes public and will be presumptively available 11 to all members of the public, including the press, unless compelling reasons 12 supported by specific factual findings to proceed otherwise are made to the trial 13 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 14 “good cause” showing for sealing documents produced in discovery from 15 “compelling reasons” standard when merits-related documents are part of court 16 record). Accordingly, the terms of this protective order do not extend beyond the 17 commencement of the trial. 18 7. DESIGNATING PROTECTED MATERIAL 19 7.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection under 21 this Order must take care to limit any such designation to specific material that 22 qualifies under the appropriate standards. The Designating Party must designate for 23 protection only those parts of material, documents, items or oral or written 24 communications that qualify so that other portions of the material, documents, 25 items or communications for which protection is not warranted are not swept 26 unjustifiably within the ambit of this Order. 27 Mass, indiscriminate or routinized designations are prohibited. Designations 1 purpose (e.g., to unnecessarily encumber the case development process or to 2 impose unnecessary expenses and burdens on other parties) may expose the 3 Designating Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 designated for protection do not qualify for protection, that Designating Party must 6 promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 7.2 Manner and Timing of Designations. Except as otherwise provided in 8 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 9 that qualifies for protection under this Order must be clearly so designated before 10 the material is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a)for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) 18 (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 24 documents it wants copied and produced, the Producing Party must determine 25 which documents, or portions thereof, qualify for protection under this Order. Then, 26 before producing the specified documents, the Producing Party must affix the 27 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 1 must clearly identify the protected portion(s) (e.g., by making appropriate markings 2 in the margins). 3 (b) for testimony given in depositions that the Designating Party 4 identifies the Disclosure or Discovery Material on the record, before the close of 5 the deposition all protected testimony, or within 30 days after the deposition 6 transcript is received by counsel. 7 (c) for information produced in some form other than documentary and 8 for any other tangible items, that the Producing Party affix in a prominent place on 9 the exterior of the container or containers in which the information is stored the 10 legend “CONFIDENTIAL.” If only a portion or portions of the information 11 warrants protection, the Producing Party, to the extent practicable, shall identify the 12 protected portion(s). 13 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 14 failure to designate qualified information or items does not, standing alone, waive 15 the Designating Party’s right to secure protection under this Order for such 16 material. Upon timely correction of a designation, the Receiving Party must make 17 reasonable efforts to assure that the material is treated in accordance with the 18 provisions of this Order. 19 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 8.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 24 resolution process under Local Rule 37-1 et seq. 25 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 26 joint stipulation pursuant to Local Rule 37-2. 27 8.4 The burden of persuasion in any such challenge proceeding shall be on 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 9. ACCESS TO AND USE OF PROTECTED MATERIAL 8 9.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 15 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 1 (c) 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) 4 (d) the court and its personnel; 5 (e) court reporters and their staff 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or 10 a custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in 12 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 13 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 14 they will not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone 19 except as permitted under this Stipulated Protective Order; and 20 (i) any mediators or settlement officers and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 23 PRODUCED IN OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation 25 that compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL,” that Party must: 27 (a) promptly notify in writing the Designating Party. Such notification 1 (b) promptly notify in writing the party who caused the subpoena or 2 order to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall include 4 a copy of this Stipulated Protective Order; and 5 (c)cooperate with respect to all reasonable procedures sought to be 6 pursued by the Designating Party whose Protected Material may be affected. If the 7 Designating Party timely seeks a protective order, the Party served with the 8 subpoena or court order shall not produce any information designated in this action 9 as “CONFIDENTIAL” before a determination by the court from which the 10 subpoena or order issued, unless the Party has obtained the Designating Party’s 11 permission. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material and nothing in these provisions 13 should be construed as authorizing or encouraging a Receiving Party in this Action 14 to disobey a lawful directive from another court. 15 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 16 PRODUCED IN THIS LITIGATION 17 (a)The terms of this Order are applicable to information produced by a 18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 19 produced by Non-Parties in connection with this litigation is protected by the 20 remedies and relief provided by this Order. Nothing in these provisions should be 21 construed as prohibiting a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non-Party 27 that some or all of the information requested is subject to a confidentiality 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 (3) make the information requested available for inspection by the 5 Non-Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this court 7 within 14 days of receiving the notice and accompanying information, the 8 Receiving Party may produce the Non-Party’s confidential information responsive 9 to the discovery request. If the Non-Party timely seeks a protective order, the 10 Receiving Party shall not produce any information in its possession or control that 11 is subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the Non-Party shall 13 bear the burden and expense of seeking protection in this court of its Protected 14 Material. 15 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best 20 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 21 person or persons to whom unauthorized disclosures were made of all the terms of 22 this Order, and (d) request such person or persons to execute the “Acknowledgment 23 an Agreement to Be Bound” attached hereto as Exhibit A. 24 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 25 OTHERWISE PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other 1 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify 2 whatever procedure may be established in an e-discovery order that provides for 3 production without prior privilege review. Pursuant to Federal Rule of Evidence 4 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 5 of a communication or information covered by the attorney-client privilege or work 6 product protection, the parties may incorporate their agreement in the stipulated 7 protective order submitted to the court. 8 14. MISCELLANEOUS 9 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 10 person to seek its modification by the Court in the future. 11 14.2 Right to Assert Other Objections. By stipulating to the entry of this 12 Protective Order, no Party waives any right it otherwise would have to object to 13 disclosing or producing any information or item on any ground not addressed in 14 this Stipulated Protective Order. Similarly, no Party waives any right to object on 15 any ground to use in evidence of any of the material covered by this Protective 16 Order. 17 14.3 Filing Protected Material. A Party that seeks to file under seal any 18 Protected Material must comply with Local Civil Rule 79-5. Protected Material 19 may only be filed under seal pursuant to a court order authorizing the sealing of the 20 specific Protected Material. If a Party’s request to file Protected Material under seal 21 is denied by the court, then the Receiving Party may file the information in the 22 public record unless otherwise instructed by the court. 23 15. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in paragraph 6, within 60 25 days of a written request by the Designating Party, each Receiving Party must 26 return all Protected Material to the Producing Party or destroy such material. As 27 used in this subdivision, “all Protected Material” includes all copies, abstracts, 1 Protected Material. Whether the Protected Material is returned or destroyed, the 2 Receiving Party must submit a written certification to the Producing Party (and, if 3 not the same person or entity, to the Designating Party) by the 60-day deadline that 4 (1) identifies (by category, where appropriate) all the Protected Material that was 5 returned or destroyed and (2) affirms that the Receiving Party has not retained any 6 copies, abstracts, compilations, summaries or any other format reproducing or 7 capturing any of the Protected Material. Notwithstanding this provision, Counsel 8 are entitled to retain an archival copy of all pleadings, motion papers, trial, 9 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 10 and trial exhibits, expert reports, attorney work product, and consultant and expert 11 work product, even if such materials contain Protected Material. Any such archival 12 copies that contain or constitute Protected Material remain subject to this Protective 13 Order as set forth in Section 6 (DURATION). 14 16. VIOLATION 15 Any violation of this Order may be punished by appropriate measures 16 including, without limitation, contempt proceedings and/or monetary sanctions. 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 THE LAW OFFICES OF AMIR J. MORGAN, LEWIS & BOCKIUS 19 GOLDSTEIN, ESQ. LLP 20 /s/ Amir J. Goldstein /s/ Arjun P. Rao 21 Amir J. Goldstein, Bar No. 255620 Arjun P. Rao, Bar No. 265347 22 [email protected] [email protected] 7304 Beverly Blvd., Suite 212 Marcos Sasso, Bar No. 228905 23 Los Angeles, CA 90036 [email protected] 24 Tel: +1.323.937.0400 2049 Century Park East, Suite 700 Fax: +1.866.288.9194 Los Angeles, CA 90067-3109 25 Tel: +1.310.907.1000 26 Attorney for Plaintiff Fax: +1.310.907.1001 MORTEZA REZAEI 27 Madison G. Marshall, Bar No. 359485 1 6 C 0 o 0 s t A a n M to e n s a B , o C u A le 9 v 2 a 6 rd 2 , 6 S -7 u 6 it 5 e 3 1 800 Tel: +1.714.830.0600 2 Fax: +1.714.830.0700 3 Attorneys for Defendant 4 JPMORGAN CHASE BANK, N.A. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 ; 4 || DATED: October 23 _, 2025 LA LEY; ~~ 5 Hon. Magistrate Judge Michael B. Kaufman 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER