|| AMARO | BALDWIN LLP Michael L. Amaro, Esq. (Bar No. 109514) 2 || Sanaz Cherazaic, Esq. (Bar No. 273944) 3 180 E. Ocean Boulevard, Suite 1150 Long Beach, California 90802 4 || Telephone: (562) 912-4157 5 || Facsimile: (866) 611-6619 [email protected] 6 || [email protected] 7 UNIVO0001 Attorneys for Defendant, Universal City Studios LLC 8 g || JAVAHERI & YAHOUDAIT, APLC Alexander B. Boris, Esq. (Bar No. 313195) 10 || 1880 Century Park East, Suite 717 11 || Los Angeles, CA 90067 Telephone: (310) 407-0766 12 || Facsimile: (310) 407-0767 13 || [email protected] 4 [email protected] Attorneys for Plaintiff, Sanaz Shahbazi 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 WESTERN DIVISION 19 20 SANAZ SHAHBAZI, an individual 21 Plaintiff, Case No. 2:25-cv-06756-JFW-AJR 22 STIPULATED PROTECTIVE NBC UNIVERSAL THEME PARKS; | ORDER 23 UNIVERSAL STUDIOS HOLLYWOOD; COMCAST NBC 24 UNIVERSAL; and DOES 1 to 50, INCLUSIVE, 25 Defendant. 26 27 1. GENERAL 28 1.1 Purposes and Limitations. Discovery in this action is likely to involve

1 || production of confidential, proprietary, or private information for which special 2 || protection from public disclosure and from use for any purpose other than prosecuting 3 || this litigation may be warranted. Accordingly, the parties hereby stipulate to and 4 |) petition the Court to enter the following Stipulated Protective Order. The parties 5 || acknowledge that this Order does not confer blanket protections on all disclosures or 6 || responses to discovery and that the protection it affords from public disclosure and 7 || use extends only to the limited information or items that are entitled to confidential 8 || treatment under the applicable legal principles. The parties further acknowledge, as 9 || set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 10 || them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 11 || procedures that must be followed and the standards that will be applied when a party 12 || seeks permission from the court to file material under seal. 13 1.2. Good Cause Statement. This action is likely to involve the disclosure of 14 || confidential business and operational records of Defendant Universal City Studios, 15 || LLC, including but not limited to video surveillance footage, internal incident reports, 16 || witness statements, and safety-related policies and procedures, for which special 17 || protection from public disclosure—and from use for any purpose other than the 18 || prosecution of this action—is warranted. Such materials include non-public 19 || information concerning security systems, surveillance camera placement, safety 20 || inspection protocols, and incident response procedures, as well as personal identifying 21 || information of employees and non-party witnesses. Public disclosure of this 22 || information could compromise ongoing safety and security operations at Defendant’s 23 || premises, unnecessarily invade the privacy rights of non-parties, and place Defendant 24 || at a competitive or operational disadvantage. Accordingly, good cause exists for entry 25 || of a protective order to expedite the exchange of information, facilitate the prompt 26 || resolution of confidentiality disputes, adequately protect sensitive materials, and 27 || ensure that such information may be reasonably and lawfully used in preparing for 28 || and conducting trial. The parties do not intend that information will be designated as

1 || confidential for tactical reasons, and nothing will be so designated without a good- 2 || faith belief that it has been maintained in a confidential, non-public manner and that 3 || there is good cause for its protection from public disclosure 4 5 |} 2. DEFINITIONS 6 2.1 Action: SANAZ SHAHBAZI v. UNIVERSAL CITY STUDIOS, LLC; 7 || Case No. 2:25-cv-06756-JFW-AJR 8 2.2 Challenging Party: a Party or Non-Party that challenges the designation 9 || of information or items under this Order. 10 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 11 || how it is generated, stored or maintained) or tangible things that qualify for protection 12 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 13 || Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 15 || support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 || items that it produces in disclosures or in responses to discovery as 18 || “CONFIDENTIAL.” 19 2.6 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 2.7 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 2.8 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 28 || counsel.

1 2.9 Non-Party: any natural person, partnership, corporation, association, or 2 || other legal entity not named as a Party to this action. 3 2.10 Qutside Counsel of Record: attorneys who are not employees of a party 4 |) to this Action but are retained to represent or advise a party to this Action and have 5 || appeared in this Action on behalf of that party or are affiliated with a law firm that 6 || has appeared on behalf of that party, including support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 || employees, consultants, retained experts, and Outside Counsel of Record (and their 9 || support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 || Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation support 13 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 || and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 || designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 || from a Producing Party. 20 21 || 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 || Protected Material (as defined above), but also (1) any information copied or extracted 24 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of 25 || Protected Material; and (3) any testimony, conversations, or presentations by Parties 26 || or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 || trial judge. This Order does not govern the use of Protected Material at trial.

1 |] 4. DURATION 2 Once a case proceeds to trial, all of the court-filed information to be introduced 3 || that was previously designated as confidential or maintained pursuant to this 4 || protective order becomes public and will be presumptively available to all members 5 || of the public, including the press, unless compelling reasons supported by specific 6 || factual findings to proceed otherwise are made to the trial judge in advance of the 7 || trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 (9th Cir. 8 || 2006) (distinguishing “good cause” showing for sealing documents produced in 9 || discovery from “compelling reasons” standard when merits-related documents are 10 || part of court record). Accordingly, the terms of this protective order do not extend 11 || beyond the commencement of the trial. 12 13 |} 5. DESIGNATING PROTECTED MATERIAL 14 5.1 Exercise of Restraint and Care in Designating Material for Protection. 15 || Each Party or Non-Party that designates information or items for protection under this 16 || Order must take care to limit any such designation to specific material that qualifies 17 || under the appropriate standards. The Designating Party must designate for protection 18 || only those parts of material, documents, items, or oral or written communications that 19 || qualify so that other portions of the material, documents, items, or communications 20 || for which protection is not warranted are not swept unjustifiably within the ambit of 21 || this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations 23 || that are shown to be clearly unjustified or that have been made for an improper 24 || purpose (e.g., to unnecessarily encumber the case development process or to impose 25 || unnecessary expenses and burdens on other parties) may expose the Designating Party 26 || to sanctions. 27 28

1 If it comes to a Designating Party’s attention that information or items that it 2 || designated for protection do not qualify for protection, that Designating Party must 3 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 || under this Order must be clearly so designated before the material is disclosed or 8 || produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 || documents, but excluding transcripts of depositions or other pretrial or trial 12 || proceedings), that the Producing Party affix, at a minimum, the legend 13 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 14 || contains protected material. If only a portion or portions of the material on a page 15 || qualifies for protection, the Producing Party also must clearly identify the protected 16 || portion(s) (e.g., by making appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 || need not designate them for protection until after the inspecting Party has indicated 19 || which documents it would like copied and produced. During the inspection and 20 || before the designation, all of the material made available for inspection shall be 21 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 22 || it wants copied and produced, the Producing Party must determine which documents, 23 || or portions thereof, qualify for protection under this Order. Then, before producing 24 || the specified documents, the Producing Party must affix the “CONFIDENTIAL 25 || legend” to each page that contains Protected Material. If only a portion or portions 26 || of the material on a page qualifies for protection, the Producing Party also must clearly 27 || identify the protected portion(s) (e.g., by making appropriate markings in the 28 || margins).

1 (b) for testimony given in depositions that the Designating Party identify 2 || the Disclosure or Discovery Material on the record, before the close of the deposition. 3 (c) for information produced in some form other than documentary and 4 || for any other tangible items, that the Producing Party affix in a prominent place on 5 || the exterior of the container or containers in which the information is stored the legend 6 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 7 || protection, the Producing Party, to the extent practicable, shall identify the protected 8 || portion(s). 9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 10 || failure to designate qualified information or items does not, standing alone, waive the 11 || Designating Party’s right to secure protection under this Order for such material. 12 || Upon timely correction of a designation, the Receiving Party must make reasonable 13 || efforts to assure that the material is treated in accordance with the provisions of this 14 || Order. 15 16 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 || designation of confidentiality at any time that is consistent with the Court’s 19 || Scheduling Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 || resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 22 || comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 23 6.3 Burden. The burden of persuasion in any such challenge proceeding 24 || shall be on the Designating Party. Frivolous challenges, and those made for an 25 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 26 || other parties) may expose the Challenging Party to sanctions. Unless the Designating 27 || Party has waived or withdrawn the confidentiality designation, all parties shall 28

1 || continue to afford the material in question the level of protection to which it is entitled 2 || under the Producing Party’s designation until the Court rules on the challenge. 3 4 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 || disclosed or produced by another Party or by a Non-Party in connection with this 7 || Action only for prosecuting, defending, or attempting to settle this Action. Such 8 || Protected Material may be disclosed only to the categories of persons and under the 9 || conditions described in this Order. When the Action has been terminated, a Receiving 10 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at a 12 || location and in a secure manner that ensures that access is limited to the persons 13 || authorized under this Order. 14 7.2. Disclosure _of “CONFIDENTIAL” Information or Items. Unless 15 || otherwise ordered by the Court or permitted in writing by the Designating Party, a 16 || Receiving Party may _ disclose any information or item designated 17 || “CONFIDENTIAL” only to: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 19 || well as employees of said Outside Counsel of Record to whom it is reasonably 20 || necessary to disclose the information for this Action; 21 (b) the officers, directors, and employees (including House Counsel) of 22 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 || disclosure is reasonably necessary for this Action and who have signed the 25 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the Court and its personnel; 27 (e) court reporters and their staff; 28

1 (f) professional jury or trial consultants, mock jurors, and Professional 2 || Vendors to whom disclosure is reasonably necessary for this Action and who have 3 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or 5 || acustodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in 7 || the Action to whom disclosure is reasonably necessary provided: (1) the deposing 8 || party requests that the witness sign the form attached as Exhibit A hereto, although if 9 || the witness refuses to sign Exhibit A, the examining party may show the witness the 10 || document for identification and testimony purposes only, and may retain it as a 11 || deposition exhibit so long as it separately bound by the Court reporter; and they will 12 || not be permitted to keep any confidential information unless they sign the 13 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 14 || agreed by the Designating Party or ordered by the Court. Pages of transcribed 15 || deposition testimony or exhibits to depositions that reveal Protected Material shall be 16 || separately bound by the Court Reporter, clearly marked “CONFIDENTIAL,” and 17 || may not be disclosed to anyone except as permitted under this Stipulated Protective 18 || Order; and (2) they will not be permitted to keep any confidential information unless 19 || they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 20 || otherwise agreed by the Designating Party or ordered by the Court. Pages of 21 || transcribed deposition testimony or exhibits to depositions that reveal Protected 22 || Material may be separately bound by the court reporter and may not be disclosed to 23 || anyone except as permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, 25 || mutually agreed upon by any of the parties engaged in settlement discussions. 26 27 || /// 28

1 || 8. PROTECTED _MATERIAL □ SUBPOENAED _OR_ ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 || that compels disclosure of any information or items designated in this Action as 5 || “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 || include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 || issue in the other litigation that some or all of the material covered by the subpoena 10 || or order is subject to this Protective Order. Such notification shall include a copy of 11 || this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 || by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 || the subpoena or court order shall not produce any information designated in this action 16 || as “CONFIDENTIAL” before a determination by the court from which the subpoena 17 || or order issued, unless the Party has obtained the Designating Party’s permission. The 18 || Designating Party shall bear the burden and expense of seeking protection in that court 19 || of its confidential material and nothing in these provisions should be construed as 20 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 || directive from another court. 22 23 || 9. A_NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a Non- 26 || Party in this Action and designated as “CONFIDENTIAL.” Such information 27 || produced by Non-Parties in connection with this litigation is protected by the 28 10

1 || remedies and relief provided by this Order. Nothing in these provisions should be 2 || construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce 4 || aNon-Party’s confidential information in its possession, and the Party is subject to an 5 || agreement with the Non-Party not to produce the Non-Party’s confidential 6 || information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 || that some or all of the information requested is subject to a confidentiality agreement 9 || with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 || specific description of the information requested; and 13 (3) make the information requested available for inspection by the Non- 14 || Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this Court within 14 16 || days of receiving the notice and accompanying information, the Receiving Party may 17 || produce the Non-Party’s confidential information responsive to the discovery request. 18 || Ifthe Non-Party timely seeks a protective order, the Receiving Party shall not produce 19 || any information in its possession or control that is subject to the confidentiality 20 || agreement with the Non-Party before a determination by the Court. Absent a court 21 || order to the contrary, the Non-Party shall bear the burden and expense of seeking 22 || protection in this Court of its Protected Material. 23 24 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 || Protected Material to any person or in any circumstance not authorized under this 27 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11

1 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 || persons to whom unauthorized disclosures were made of all the terms of this Order, 3 || and (d) request such person or persons to execute the “Acknowledgment and 4 || Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6 |} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 || inadvertently produced material is subject to a claim of privilege or other protection, 10 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 || may be established in an e-discovery order that provides for production without prior 13 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 || parties reach an agreement on the effect of disclosure of a communication or 15 || information covered by the attorney-client privilege or work product protection, the 16 || parties may incorporate their agreement in the stipulated protective order submitted 17 || to the Court. 18 19 |} 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 || person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 || Protective Order, no Party waives any right it otherwise would have to object to 24 || disclosing or producing any information or item on any ground not addressed in this 25 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 || ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 12

1 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 2 || Protected Material at issue; good cause must be shown in the request to file under 3 || seal. Ifa Party’s request to file Protected Material under seal is denied by the Court, 4 || then the Receiving Party may file the information in the public record unless 5 || otherwise instructed by the Court. 6 7 || 13. FINAL DISPOSITION 8 After the final disposition of this Action, within 60 days of a written request by 9 || the Designating Party, each Receiving Party must return all Protected Material to the 10 || Producing Party or destroy such material. As used in this subdivision, “all Protected 11 || Material” includes all copies, abstracts, compilations, summaries, and any other 12 || format reproducing or capturing any of the Protected Material. Whether the Protected 13 || Material is returned or destroyed, the Receiving Party must submit a written 14 || certification to the Producing Party (and, if not the same person or entity, to the 15 || Designating Party) by the 60 day deadline that (1) identifies (by category, where 16 || appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 17 || that the Receiving Party has not retained any copies, abstracts, compilations, 18 || summaries or any other format reproducing or capturing any of the Protected Material. 19 || Notwithstanding this provision, counsel are entitled to retain an archival copy of all 20 || pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 21 || correspondence, deposition and trial exhibits, expert reports, attorney work product, 22 || and consultant and expert work product, even if such materials contain Protected 23 || Material. Any such archival copies that contain or constitute Protected Material 24 || remain subject to this Protective Order as set forth in Section 4 (DURATION). 25 26 /// 27 /// 28 /// 13

1 || 14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate 3 || measures including, without limitation, contempt proceedings and/or monetary 4 || sanctions. 5 6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 g || DATED:_10/29/2025 10 || /s/ Alex Boris 11 || Attorneys for Plaintiff(s) 12

DATED:_ 10/29/2025 14 15 aby 6 Attorneys for Defendant(s)

17 18 19 20 21 22 23 24 25 26 27 28 14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [full name], of 5 || [full address], declare under penalty of perjury that I have read in its entirety and 6 || understand the Stipulated Protective Order that was issued by the United States 7 || District Court for the Central District of California on [date] in the 8 || case of SANAZ SHAHBAZI v. UNIVERSAL CITY STUDIOS, LLC; Case No. 9 || 2:25-cv-06756-JFW-AJR .I agree to comply with and to be bound by all the terms 10 || of this Stipulated Protective Order and I understand and acknowledge that failure to 11 || so comply could expose me to sanctions and punishment in the nature of contempt. 12 || I solemnly promise that I will not disclose in any manner any information or item 13 || that is subject to this Stipulated Protective Order to any person or entity except in 14 || strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 || for the Central District of California for the purpose of enforcing the terms of this 17 || Stipulated Protective Order, even if such enforcement proceedings occur after 18 || termination of this action. I hereby appoint [full 19 || name] of [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 signed: 25 26 || Printed name: 27 28 || Signature: 15

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA (WESTERN DIVISION)

SANAZ SHAHBAZI, an individual, CASE NO. 2:25-cv-06756-JFW-AJR 11 Plaintiff, (Case Assigned to District judge John F. «2 alter; Magistrate Judge . Joel Richlin) V. PROPOSED! ORDER RE NBC UNIVERSAL THEME PARKS; TIPULATION AND PROTECTIVE 14 |] UNIVERSAL STUDIOS ORDER HOLLYWOOD; COMCAST NBC 15 || UNIVERSAL; and DOES 1 TO 50, INCLUSIVE, (Removed from Los Angeles County 16 uperior Court Case No. 25NNCV04048) Defendants. 17 Complaint Filed: June 12, 2025 Trial Date: Not Assigned 19 20 ORDER 21 GOOD CAUSE APPEARING, the Court hereby approves this Stipulation 22 || and Protective Order. 23 24 IT IS SO ORDERED. 25 26 || Dated: 10/30/25 \oe { un Le. 27 Magistrate Judge A. Joel Richlin 28