1 Genevieve Walser-Jolly(SBN 262784) 2 [email protected] Andrew Yu-Chih (SBN 326135) 3 [email protected] 4 WOMBLE BOND DICKINSON (US) LLP 400 Spectrum Center Drive, Suite 1700 5 Irvine, California 92618 6 Telephone: (714) 557-3800 Facsimile: (714) 557-3347 7 8 Derek W. Edwards (SBN 210636) [email protected] 9 WOMBLE BOND DICKINSON (US) LLP 10 1222 Demonbreun, Suite 1201 Nashville, Tennessee 37203 11 Telephone: (629) 312-1810 12 Facsimile: (206) 261-0001

13 Attorneys for Defendant 14 AMERICAN HONDA FINANCE CORPORATION 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17 SHAWN JAFFER, Case No.: 2:25-cv-06870-JLS-AJR 18 Plaintiff, STIPULATED PROTECTIVE 19 ORDER v. 20 [Filed Concurrently With Declaration Of AMERICAN HONDA FINANCE Andrew Yu-Chih] 21 CORPORATION, Complaint Filed: July 28, 2025 22 Defendant. 23 24 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Disclosure and discovery activity in this action is likely to involve production 3 of confidential, proprietary, or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, the parties hereby stipulate to and petition the Court 6 to enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or response to discovery 8 and that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve confidential, proprietary, or private information 13 such as trade secrets, customer information and other valuable research, 14 development, commercial, financial, technical and/or proprietary information for 15 which special protection from public disclosure and from use for any purpose other 16 than prosecution of this action is warranted. Such confidential and proprietary 17 materials and information consist of, among other things, confidential business or 18 financial information, information regarding confidential business practices, or other 19 confidential research, development, or commercial information (including 20 information implicating privacy rights of third parties), information otherwise 21 generally unavailable to the public, or which may be privileged or otherwise 22 protected from disclosure under state or federal statutes, court rules, case decisions, 23 or common law. Accordingly, to expedite the flow of information, to facilitate the 24 prompt resolution of disputes over confidentiality of discovery materials, to 25 adequately protect information the parties are entitled to keep confidential, to ensure 26 that the parties are permitted reasonable necessary uses of such material in 27 preparation for and in the conduct of trial, to address their handling at the end of the 28 litigation, and serve the ends of justice, a protective order for such information is 1 justified in this matter. It is the intent of the parties that information will not be 2 designated as confidential for tactical reasons and that nothing be so designated 3 without a good faith belief that it has been maintained in a confidential, non-public 4 manner, and there is good cause why it should not be part of the public record of this 5 case 6 3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 7 SEAL 8 The parties further acknowledge, as set forth in Section 14.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 11 the standards that will be applied when a party seeks permission from the court to 12 file material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 proceedings and records in civil cases. In connection with non-dispositive motions, 15 good cause must be shown to support a filing under seal. See Kamakana v. City and 16 County of Honolulu,

, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 17 Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 18 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 19 good cause showing), and a specific showing of good cause or compelling reasons 20 with proper evidentiary support and legal justification, must be made with respect to 21 Protected Material that a party seeks to file under seal. The parties’ mere designation 22 of Disclosure of Discovery Material as CONFIDENTIAL does not—without the 23 submission of competent evidence by declaration, establishing that the material 24 sought to be filed under seal qualifies as confidential, privileged, or otherwise 25 protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, then 27 compelling reasons, not only good cause, for the sealing must be shown, and the 28 relief sought shall be narrowly tailored to serve the specific interest to be protected. 1 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 2 item or type of information, document, or thing sought to be filed or introduced under 3 seal in connection with a dispositive motion or trial, the party seeking protection must 4 articulate compelling reasons, supported by specific facts and legal justification, for 5 the requested sealing order. Again, competent evidence supporting the application 6 to file documents under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. If 9 documents can be redacted, then a redacted version for public viewing, omitting only 10 the confidential, privileged, or otherwise protectable portions of the document shall 11 be filed. Any application that seeks to file documents under seal in their entirety 12 should include an explanation of why redaction is not feasible. 13 4. DEFINITIONS 14 4.1 Action: Shawn Jaffer v. American Honda Finance Corporation, United 15 States District Court Central District of California Case No. 2:25-CV-06870-JLS- 16 AJR. 17 4.2 Challenging Party: a Party or Non-Party that challenges the designation 18 of information or items under this Order. 19 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c). 22 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 23 their support staff). 24 4.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 4.6 Disclosure or Discovery Material: all items or information, regardless 28 of the medium or manner in which it is generated, stored, or maintained (including, 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 4.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this action. 6 4.8 House Counsel: attorneys who are employees of a Party to this action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 4.9 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 4.10 Outside Counsel of Record: attorneys who are not employees of a party 12 to this action but are retained to represent or advise a party to this action and have 13 appeared in this action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party (as well as their support staff). 15 4.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this action. 20 4.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 4.14 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 28 /// 1 5. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 However, the protections conferred by this Stipulation and Order do not cover the 8 following information: (a) any information that is in the public domain at the time of 9 disclosure to a Receiving Party or becomes part of the public domain after its 10 disclosure to a Receiving Party as a result of publication not involving a violation of 11 this Order, including becoming part of the public record through trial or otherwise; 12 and (b) any information known to the Receiving Party prior to the disclosure or 13 obtained by the Receiving Party after the disclosure from a source who obtained the 14 information lawfully and under no obligation of confidentiality to the Designating 15 Party. 16 Any use of Protected Material at trial shall be governed by the orders of the 17 trial judge. This Order does not govern the use of Protected Material at trial. 18 6. DURATION 19 Even after final disposition of this litigation, the confidentiality obligations 20 imposed by this Order shall remain in effect until a Designating Party agrees 21 otherwise in writing or a court order otherwise directs. Final disposition shall be 22 deemed to be the later of (1) dismissal of all claims and defenses in this action, with 23 or without prejudice; and (2) final judgment herein after the completion and 24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 25 including the time limits for filing any motions or applications for extension of time 26 pursuant to applicable law. 27 7. DESIGNATING PROTECTED MATERIAL 28 7.1 Exercise of Restraint and Care in Designating Material for Protection. 1 Each Party or Non-Party that designates information or items for protection 2 under this Order must take care to limit any such designation to specific material that 3 qualifies under the appropriate standards. The Designating Party must designate for 4 protection only those parts of material, documents, items, or oral or written 5 communications that qualify – so that other portions of the material, documents, 6 items, or communications for which protection is not warranted are not swept 7 unjustifiably within the ambit of this Order. 8 Mass, indiscriminate, or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber or retard the case development process or 11 to impose unnecessary expenses and burdens on other parties) expose the 12 Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the mistaken designation. 16 7.2 Manner and Timing of Designations. Except as otherwise provided in 17 this Order (see, e.g., second paragraph of Section 7.2(a) below), or as otherwise 18 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 19 under this Order must be clearly so designated before the material is disclosed or 20 produced. 21 Designation in conformity with this Order requires: 22 (a) For information in documentary form (e.g., paper or electronic documents, 23 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 24 Producing Party affix the legend “CONFIDENTIAL” to each page that contains 25 protected material. If only a portion or portions of the material on a page qualifies 26 for protection, the Producing Party also must clearly identify the protected portion(s) 27 (e.g., by making appropriate markings in the margins).

28 /// 1 A Party or Non-Party that makes original documents or materials available for 2 inspection need not designate them for protection until after the inspecting Party has 3 indicated which material it would like copied and produced. During the inspection 4 and before the designation, all of the material made available for inspection shall be 5 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 6 documents it wants copied and produced, the Producing Party must determine which 7 documents, or portions thereof, qualify for protection under this Order. Then, before 8 producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 10 portion or portions of the material on a page qualifies for protection, the Producing 11 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 12 markings in the margins). 13 (b) for testimony given in deposition or in other pretrial or trial proceedings, 14 that the Designating Party shall either: 15 (i) identify on the record, before the close of the deposition, hearing, 16 or other proceeding, all protected testimony; or 17 (ii) designate at the outset of the deposition that all testimony given shall 18 be presumed confidential subject to the Designating Party identifying within 19 thirty (30) days after receipt of the deposition transcript the pages and lines of 20 protected testimony. Prior to the Designating Party identifying by page and 21 line the protected testimony, all testimony shall be treated as protected 22 testimony. Any pages and/or lines not identified by the Designating Party as 23 protected testimony within thirty (30) days after receipt of the transcript shall 24 not be treated as protected testimony. 25 (c) for information produced in some form other than documentary and for any 26 other tangible items, that the Producing Party affix in a prominent place on the 27 exterior of the container or containers in which the information or item is 28 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 1 information or item warrant protection, the Producing Party, to the extent 2 practicable, shall identify the protected portion(s). 3 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 failure to designate qualified information or items does not, standing alone, waive 5 the Designating Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must make reasonable 7 efforts to assure that the material is treated in accordance with the provisions of this 8 Order. 9 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 8.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 designation of confidentiality at any time. Unless a prompt challenge to a 12 Designating Party’s confidentiality designation is necessary to avoid foreseeable, 13 substantial unfairness, unnecessary economic burdens, or a significant disruption or 14 delay of the litigation, a Party does not waive its right to challenge a confidentiality 15 designation by electing not to mount a challenge promptly after the original 16 designation is disclosed. 17 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process by providing written notice of each designation it is challenging 19 and describing the basis for each challenge. To avoid ambiguity as to whether a 20 challenge has been made, the written notice must recite that the challenge to 21 confidentiality is being made in accordance with this specific paragraph of the 22 Protective Order. The parties shall attempt to resolve each challenge in good faith 23 and must begin the process by conferring directly (in voice to voice dialogue; other 24 forms of communication are not sufficient) within 14 days of the date of service of 25 notice. In conferring, the Challenging Party must explain the basis for its belief that 26 the confidentiality designation was not proper and must give the Designating Party 27 an opportunity to review the designated material, to reconsider the circumstances, 28 and, if no change in designation is offered, to explain the basis for the chosen 1 designation. A Challenging Party may proceed to the next stage of the challenge 2 process only if it has engaged in this meet and confer process first or establishes that 3 the Designating Party is unwilling to participate in the meet and confer process in a 4 timely manner. 5 8.3 Judicial Intervention. If the Parties cannot resolve a challenge without 6 court intervention, the Designating Party shall file and serve a motion to retain 7 confidentiality under Civil Local Rule 7 (and in compliance with Civil Local Rule 8 79-5, if applicable) within 21 days of the initial notice of challenge or within 14 days 9 of the parties agreeing that the meet and confer process will not resolve their dispute, 10 whichever is earlier. Each such motion must be accompanied by a competent 11 declaration affirming that the movant has complied with the meet and confer 12 requirements imposed in the preceding paragraph. Failure by the Designating Party 13 to make such a motion including the required declaration within 21 days (or 14 days, 14 if applicable) shall automatically waive the confidentiality designation for each 15 challenged designation. In addition, the Challenging Party may file a motion 16 challenging a confidentiality designation at any time if there is good cause for doing 17 so, including a challenge to the designation of a deposition transcript or any portions 18 thereof. Any motion brought pursuant to this provision must be accompanied by a 19 competent declaration affirming that the movant has complied with the meet and 20 confer requirements imposed by the preceding paragraph. 21 The burden of persuasion in any such challenge proceeding shall be on the 22 Designating Party. Frivolous challenges, and those made for an improper purpose 23 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 24 expose the Challenging Party to sanctions. Unless the Designating Party has waived 25 the confidentiality designation by failing to file a motion to retain confidentiality as 26 described above, all parties shall continue to afford the material in question the level 27 of protection to which it is entitled under the Producing Party’s designation until the 28 court rules on the challenge. 1 9. ACCESS TO AND USE OF PROTECTED MATERIAL 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 case only for prosecuting, defending, or attempting to settle this litigation. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the litigation has been terminated, a 7 Receiving Party must comply with the provisions of Section 15 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this action, as 17 well as employees of said Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this litigation; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this litigation; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this litigation and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) mediators; 26 (f) court reporters and their staff, professional jury or trial consultants, 27 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary 28 1 for this litigation and who have signed the “Acknowledgment and Agreement to Be 2 Bound” (Exhibit A); 3 (g) during their depositions, witnesses in the action to whom disclosure 4 is reasonably necessary and who have signed the “Acknowledgment and Agreement 5 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 6 ordered by the court. Pages of transcribed deposition testimony or exhibits to 7 depositions that reveal Protected Material must be separately bound by the court 8 reporter and may not be disclosed to anyone except as permitted under this Stipulated 9 Protective Order; 10 (h) the author or recipient of a document containing the information or 11 a custodian or other person who otherwise possessed or knew the information; and 12 (i) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification shall 20 include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order to 22 issue in the other litigation that some or all of the material covered by the subpoena 23 or order is subject to this Protective Order. Such notification shall include a copy of 24 this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be pursued 26 by the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served with 28 the subpoena or court order shall not produce any information designated in this 1 action as “CONFIDENTIAL” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material – and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this action to 6 disobey a lawful directive from another court. 7 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a Non- 10 Party in this action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to produce 15 a Non-Party’s confidential information in its possession, and the Party is subject to 16 an agreement with the Non-Party not to produce the Non-Party’s confidential 17 information, then the Party shall: 18 (1) promptly notify in writing the Requesting Party and the Non-Party 19 that some or all of the information requested is subject to a confidentiality agreement 20 with a Non-Party; 21 (2) promptly provide the Non-Party with a copy of the Stipulated 22 Protective Order in this litigation, the relevant discovery request(s), and a reasonably 23 specific description of the information requested; and 24 (3) make the information requested available for inspection by the Non- 25 Party. 26 (c) If the Non-Party fails to object or seek a protective order from this court 27 within 14 days of receiving the notice and accompanying information, the Receiving 28 Party may produce the Non-Party’s confidential information responsive to the 1 discovery request. If the Non-Party timely seeks a protective order, the Receiving 2 Party shall not produce any information in its possession or control that is subject to 3 the confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 5 of seeking protection in this court of its Protected Material. 6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 10 writing the Designating Party of the unauthorized disclosures; (b) use its best efforts 11 to retrieve all unauthorized copies of the Protected Material; (c) inform the person or 12 persons to whom unauthorized disclosures were made of all the terms of this Order; 13 and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” that is attached hereto as Exhibit A. 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 /// 28 /// 1 14. MISCELLANEOUS 2 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 14.3 Filing Protected Material. Without written permission from the 10 Designating Party or a court order secured after appropriate notice to all interested 11 persons, a Party may not file in the public record in this action any Protected Material. 12 A Party that seeks to file under seal any Protected Material must comply with Civil 13 Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court 14 order authorizing the sealing of the specific Protected Material at issue. Pursuant to 15 Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that 16 the Protected Material at issue is privileged, protectable as a trade secret, or otherwise 17 entitled to protection under the law. If a Receiving Party’s request to file Protected 18 Material under seal pursuant to Civil Local Rule 79-5 is denied by the court, then the 19 Receiving Party may file the information in the public record pursuant to Civil Local 20 Rule 79-5 unless otherwise instructed by the court. 21 15. FINAL DISPOSITION 22 Within one year after the final disposition of this action, as defined in 23 paragraph 4, each Receiving Party must return all Protected Material to the Producing 24 Party or destroy such material. As used in this subdivision, “all Protected Material” 25 includes all copies, abstracts, compilations, summaries, and any other format 26 reproducing or capturing any of the Protected Material. Whether the Protected 27 Material is returned or destroyed, the Receiving Party must submit a written 28 certification to the Producing Party (and, if not the same person or entity, to the 1 Designating Party) by the 60 day deadline that (1) identifies (by category, where 2 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 3 that the Receiving Party has not retained any copies, abstracts, compilations, 4 summaries or any other format reproducing or capturing any of the Protected 5 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 6 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 7 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 8 work product, and consultant and expert work product, even if such materials contain 9 Protected Material. Any such archival copies that contain or constitute Protected 10 Material remain subject to this Protective Order as set forth in Section 4 11 (DURATION). 12 13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 DATED: 10/23/2025 /s/ Stephen T. Jones 15 Attorney for Plaintiff 16 17 18 DATED: 10/23/2025 /s/ Andrew Yu-Chih Attorney for Defendant 19 20 21 PURSUANT TO STIPULATION, IT IS SO ORDERED. 22 23 DATED: _1_0_/2_4_/_2_02_5________ __________________________________ 24 Hon. A. Joel Richlin 25 United States District/Magistrate Judge 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of Shawn Jaffer v. American Honda Finance Corporation, Case 8 No. 2:25-cv-06870. I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 19 Date: ______________________________________ 20 21 City and State where sworn and signed: _________________________________ 22 23 Printed name: _______________________________ 24 25 Signature: __________________________________ 26 27 28