1 Rryaomunine sRsi.@ Yyoouunnesessis,i lEaswq..c (oSmB N 175020) 2 Heather N. Phillips, Esq. (SBN 258638) [email protected] 3 Christopher S. Afgani, Esq. (SBN 336750) [email protected] 4 LAW OFFICES OF RAMIN R. YOUNESSI A PROFESSIONAL LAW CORPORATION 5 3435 Wilshire Boulevard, Suite 2200 Los Angeles, California 90010 6 Telephone: (213) 480-6200 Facsimile: (213) 480-6201 7 Attorneys For Plaintiff 8 GONZALO MATA

9 SEYFARTH SHAW LLP Mandana Massoumi (SBN 191359) 10 [email protected] David J. Kim (SBN 349802) 11 [email protected] 2029 Century Park East, Suite 3500 12 Los Angeles, CA 90067-3021 Telephone: (310) 277-7200 13 Facsimile: (310) 201-5219 14 Attorneys for Defendant TARGET CORPORATION 15 16 17 UNITED STATES DISTRICT COURT 18 EASTERN DISTRICT OF CALIFORNIA 19 20 GONZALO MATA, an individual, Case No. 1:25-cv-00667-KES-BAM 21 Plaintiff, DISTRICT JUDGE HON. KIRK E. SHERRIFF 22 v. MAGISTRATE JUDGE HON. BARBARA A. MCAULIFFE 23 TARGET CORPORATION, a Minnesota corporation; and DOES 1 through 20, JOINT STIPULATION FOR 24 inclusive, PROTECTIVE ORDER AND [PROPOSED] ORDER 25 Defendants. Complaint Filed: April 18, 2025 26 Action Removed: June 3, 2025 Trial Date: June 29, 2027 27

28 1 The dispute in this action involves amongst other claims allegations of age 2 discrimination, ultimately involving the discovery of information relating to private 3 information of Plaintiff, Gonzalo Mata, and confidential business practices of Defendant, 4 Target Corporation. During the course of this litigation, highly confidential and 5 proprietary information will need to be shared through discovery or otherwise between 6 the parties and the Court. So that both parties can continue to protect their proprietary 7 and private information involving descriptions of business methods not generally known 8 to the public and personal information as to the plaintiff, the parties propose this 9 Stipulation. 10 This Stipulation governs the covenant of Plaintiff Gonzalo Mata (“Plaintiff”) and 11 Defendant Target Corporation (“Defendant”) (collectively, “Parties”). The Parties, by 12 and through their respective counsel, hereby stipulate and agree that any documents, 13 information, testimony or transcripts (“Material”) deemed by any Party or by any person 14 or entity that is not a party to this action (“Third-Party”) to be confidential, proprietary, 15 trade secret and/or subject to a right of privacy (“Confidential Information”), shall be 16 designated and protected according to the following terms and conditions: 17 I. DESIGNATING PROTECTED MATERIAL 18 Any Party or Third-Party may determine in good faith whether any Material should 19 be designated as “CONFIDENTIAL” (“Designating Party”). However, such good faith 20 belief must be based on the fact that such information has not been made public and the 21 Designating Party must have a good faith belief that if such information is disclosed it 22 will have the effect of causing harm to a Party’s competitive position or otherwise 23 impinge upon a Party’s right to privacy. 24 Parties and Third Parties shall also have the right to designate as 25 “CONFIDENTIAL” Material produced, served or provided by other Parties or Third 26 Parties, in which case the Designating Party shall notify the other Parties and/or Third- 27 Parties of the Material that should be treated as “CONFIDENTIAL” pursuant to this 28 Stipulated Protective Order. Any Material, or any part thereof, designated as 1 “CONFIDENTIAL” shall be used only for the preparation and trial of this action, 2 including discovery, pre-trial proceedings, trial, appellate proceedings, and petitions for 3 reconsideration and/or review, and shall not be used for any business, commercial or 4 other purpose. Except as otherwise provided in this Stipulated Protective Order, or as 5 otherwise stipulated or ordered, any Material that a Party or Third-Party deems 6 “CONFIDENTIAL” must be clearly so designated. Designation in conformity with this 7 Stipulated Protective Order requires the following: 8 1. For Material in documentary form (apart from transcripts of depositions or 9 other pretrial or trial proceedings), the Designating Party producing the documents shall 10 affix the legend “CONFIDENTIAL” at the top or bottom or by watermarking of each 11 page of a document that contains Confidential Information. The Designating Party that 12 makes original documents available for inspection need not designate them for protection 13 under this Stipulated Protective Order until after the inspecting Party has indicated which 14 documents it would like copied and produced. During the inspection and before the 15 designation, all of the documents made available for inspection shall be deemed 16 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” After the inspecting Party has 17 identified the documents, it wants copied and produced, the Designating Party must 18 determine which documents qualify for protection under this Stipulated Protective Order; 19 then, before producing the specified documents, the producing Party must affix the legend 20 “CONFIDENTIAL” to each page of the documents that contain Confidential Information. 21 If, after production, a Party or Third-Party designates as “CONFIDENTIAL” documents 22 not previously designated, then any Party in possession of such documents shall designate 23 the documents as such in accordance with this Stipulated Protective Order. 24 2. For testimony given in deposition, the Designating Party shall identify either 25 (a) on the record before the close of the deposition, or (b) within 20 days after receiving 26 the transcript of such deposition, all portions of the testimony that it wants to designate 27 as “CONFIDENTIAL.” Only those portions of the testimony that are designated for 28 protection during the deposition, or within the 20 days after receipt of the transcript of 1 such testimony, shall be covered by the provisions of this Stipulated Protective Order. 2 The court reporter shall affix to the top or bottom of each page of a transcript containing 3 Confidential Information the legend “CONFIDENTIAL” as instructed by a Designating 4 Party’s instructions. For testimony given in pretrial, trial proceedings, or any such court 5 proceedings, the Parties will address any Confidential Information with the judicial 6 officer conducting the proceeding at the time of any such proceeding. 7 3. For any Material produced in other than documentary form and for any other 8 tangible items, the Designating Party producing such Material or tangible item shall affix 9 in a prominent place on the exterior of the container or containers in which the material 10 or item is stored the legend “CONFIDENTIAL.” If only portions of the information or 11 item warrant protection, the Designating Party, to the extent practicable, shall identify the 12 protected portions. If, after production, a Party or Third-Party designates as 13 “CONFIDENTIAL” any non-documentary Material or tangible item not previously 14 designated, then any Party in possession of such Material or tangible item shall designate 15 it as such in accordance with this Stipulated Protective Order. 16 II. ACCESS TO AND USE OF CONFIDENTIAL INFORMATION 17 1. Subject to paragraph 3 below, all Material designated as “CONFIDENTIAL” 18 may be disclosed only to: 19 a. Outside counsel for a Party and in-house counsel for Defendant 20 responsible for overseeing this action, as well as their employees and other persons or 21 entities retained by such counsel to provide litigation-related services; 22 b. Experts, consultants, and other independent contractors retained or 23 employed to consult with, advise or assist counsel for a Party in the preparation or trial of 24 this case, as well as their employees; 25 c. The Parties to this action and their current directors, officers, and 26 employees; 27 d. Witnesses who are being prepared by counsel to give testimony at a 28 deposition or at trial, or who are being examined by counsel at a deposition or at trial; and 1 e. Personnel employed by the United States District Court for the 2 Eastern District of California or any appellate court, including, the Ninth Circuit Court of 3 Appeals, appellate court justices, court reporters, clerks, and administrative support 4 personnel; and 5 f. Any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by the parties to assist in dispute resolution. 7 2. A Designating Party may designate as “CONFIDENTIAL-ATTORNEYS 8 EYES ONLY” any Material that contains private, confidential, proprietary and/or trade 9 secret information that is so sensitive that such Material should not be disclosed to the 10 directors, officers, or non-attorney employees of other Parties. Material designated as 11 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” may be disclosed only to those 12 persons and entities identified in paragraph II (1) (a), (b), (e) and (f) above. 13 3. Parties shall take appropriate measures to ensure that all persons permitted 14 access to Material designated as “CONFIDENTIAL” or “CONFIDENTIAL- 15 ATTORNEYS’ EYES ONLY” under paragraph II(1)(b), (c) or (d) of this Stipulated 16 Protective Order have agreed, prior to reviewing any such Confidential Information, to 17 be bound by the terms and conditions hereof with respect to the restricted disclosure and 18 use of such Confidential Information. Prior to receiving any Confidential Information, 19 those persons shall sign a copy of the statement attached hereto as Exhibit A, agreeing to 20 be bound by the terms of this Stipulated Protective Order and submitting to the 21 jurisdiction of the United States District Court for the Eastern District of California to 22 enforce this Stipulated Protective Order. The Party who obtains any such signed 23 statements shall retain possession of the statements and shall provide a copy of the 24 statements at the written request of another Party. However, under no circumstances shall 25 any Party be required to disclose the identity or existence of any expert, consultant, or 26 witness until otherwise required to do so by law or order of the United State District Court 27 for the Eastern District of California. 28 1 III. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 If, at any time during the pendency of this action, counsel for any Party wishes to 3 challenge a Designating Party’s designation of Material as containing Confidential 4 Information, and to exclude such Material from the provisions of this Stipulated 5 Protective Order, the Party shall follow the procedures for seeking judicial intervention 6 for discovery disputes. The Parties shall also first meet and confer in a good faith effort 7 to resolve informally any disputes concerning this Stipulated Protective Order before 8 seeking judicial intervention. 9 IV. INADVERTENT OR UNAUTHORIZED DISCLOSURE OF CONFIDENTIAL INFORMATION 10 11 Inadvertent production without prior designation of any Confidential or privileged 12 Information shall be without prejudice to a Designating Party’s right to later file a joint 13 stipulation seeking to have the Confidential or privileged Information designated as 14 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY,” or to any 15 other Party’s right to argue that production of such Confidential Information constitutes a 16 waiver under applicable law of the right to designate any Confidential Information as 17 “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY,” or that such 18 material must be returned as privileged. The Designating Party seeking to file a joint 19 stipulation shall follow the procedures set forth, including meeting, and conferring in 20 good faith before seeking any relief from the Court. 21 V. MAINTENANCE AND FILING OF CONFIDENTIAL INFORMATION 22 1. All Material designated as “CONFIDENTIAL” or “CONFIDENTIAL- 23 ATTORNEYS’ EYES ONLY,” shall be kept in secure facilities. A “secure facility” is a 24 place where access is restricted to only to those designated persons set forth in paragraphs 25 B(1)(a) and (b) of this Stipulated Protective Order. Such requirement is not applicable to 26 the Court. 27 2. Any information, including, but not limited to, documents, interrogatory 28 responses and depositions designated as containing Confidential Information, where 1 submitted to the Court with a pleading or as evidence, shall be delivered to the Court 2 sealed and not be available for public inspection. Counsel for the respective Parties shall 3 place any documents to be submitted to the Court in an envelope marked “SEALED,” 4 affix a copy of this Stipulated Protective Order to the documents and deliver the 5 documents directly to the clerk or secretary of the Judge assigned to hear this matter. The 6 Parties further agree that any Confidential Information filed under seal shall be 7 accompanied by an application, to file such Confidential Information under seal. The 8 application shall be directed to the judge to whom the Confidential Information is directed. 9 Pending a judicial ruling on the application, the Confidential Information subject to the 10 sealing application shall be lodged under seal. 11 3. Documents or other information designated as containing Confidential 12 Information pursuant to this Stipulated Protective Order shall become public absent a 13 separate Court order upon written motion and sufficient cause shown. 14 4. Nothing in this Stipulation requires the Court to automatically grant a request 15 to file documents labeled “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS’ 16 EYES ONLY” under seal. 17 VI. CONFIDENTIAL INFORMATION SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 18 19 1. The terms of this Stipulated Protective Order shall apply to all manner and 20 means of discovery, including subpoenas duces tecum. 21 2. In the event that a Party is served with a subpoena that seeks to compel the 22 production of Material designated as “CONFIDENTIAL” or “CONFIDENTIAL- 23 ATTORNEYS’ EYES ONLY,” the Party upon whom the subpoena is served shall give 24 written notice of the subpoena to the Designating Party at least seven (7) calendar days 25 before the production date (or, if the subpoena provides less than seven (7) days’ notice, 26 within one (1) business day after service of the subpoena). The Designating Party may 27 then file a petition or motion to quash the subpoena and/or obtain such other relief as will 28 protect the confidential nature of the documents. If the Designating Party files such a 1 petition before the production date specified in the subpoena, the Party upon whom the 2 subpoena is served shall not produce the requested documents until after the United States 3 District Court for the Eastern District of California or appropriate court has ruled on the 4 petition or motion. 5 VII. FINAL DISPOSITION 6 Within thirty (30) days after the final termination of this action, counsel for each 7 Party shall destroy any and all Material designated as “CONFIDENTIAL” or 8 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” and shall destroy all copies, digests 9 or summaries which have been made of, or prepared from, such Confidential 10 Information, and shall provide counsel for the Party or Third-Party who produced such 11 Material (upon request) with a declaration in a written email attesting to such return 12 and/or destruction. For purposes of this Stipulated Protective Order, the term “final 13 termination” shall refer to the time after any final order or award is entered in this action, 14 with no timely petition for reconsideration or petition for review having been filed, or, if 15 any such petition is filed, after a final decision is rendered by the United States District 16 Court or any appellate court with no further petition or appeal pending or possible. 17 VIII. MISCELLANEOUS 18 1. Subject to the Provision of Paragraph VI (2), above, nothing in this 19 Stipulated Protective Order shall be construed to relieve any Party from the obligation to 20 timely respond to a discovery request, nor shall this Stipulated Protective Order be 21 construed as a waiver of the right to assert any objection to a discovery request. 22 2. This Stipulated Protective Order is intended to regulate the production and 23 dissemination of Confidential Information during the entirety of this action, and thereafter 24 shall remain in full force and effect, unless and until modified, superseded or terminated 25 by written agreement of all Parties or by order of the United States District Court. This 26 Stipulated Protective Order shall become effective as among the Parties when executed 27 by all Parties and upon the District Court’s entry of the order approving this Stipulated 28 Protective Order. The United States District Court for the Eastern District of California 1 shall retain jurisdiction to enforce the provisions of this Stipulated Protective Order and 2 to enter amendments, modifications and additions to this Stipulated Protective Order as 3 the United States District Court for the Eastern District of California may from time to 4 time deem appropriate upon noticed motion of a Party or upon the United States District 5 Court for the Eastern District of California’s own motion upon notice to the parties. 6 3. Counsel for both parties shall make every attempt to redact exhibits for use 7 at trial as opposed to marking such exhibits “CONFIDENTIAL” so as to reduce the 8 burden of sealing the Court during trial. 9 4. Nothing in this Stipulation shall be construed as improperly limiting the 10 rights of third parties involved in other actions to conduct discovery or to limit the 11 subpoena power of another court unless a Court grants a properly noticed motion for 12 protective order in such other proceedings. 13 IT IS SO STIPULATED. 14 15 16 [Signatures on the next page] 17 18 19 20 21 22 23 24 25 26 27 28 1 D ATED: September 26, 2025 Respectfully submitted, 2 3 LAW OFFICES OF RAMIN R. YOUNESSI 4 5 By: /s/ Heather N. Phillips 6 Ramin R. Younessi Heather N. Phillips 7 Christopher S. Afgani Attorneys for Plaintiff 8 GONZALO MATA

9

10 DATED: September 26, 2025 SEYFARTH SHAW LLP

11 12 By: /s/ David J. Kim Mandana Massoumi 13 David J. Kim Attorneys for Defendant 14 TARGET CORPORATION

15 16

17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT “A” 2 3 I, ________________________________, have received and reviewed a copy of 4 the Stipulated Protective Order entered in the case entitled Gonzalo Mata v. Target 5 Corporation, Case No. 1:25-cv-00667-KES-BAM, pending in the United States District 6 Court for the Eastern District of California (“USED”) and am familiar with its terms. I 7 agree to comply with the terms and conditions of the Stipulated Protective Order unless 8 and until I am notified that it has been modified or vacated by the Court, at which time I 9 will comply with such further order. I further consent and submit to the jurisdiction of the 10 USED for the purpose of enforcing the Stipulated Protective Order, if necessary. 11 12 DATED: ______________________________

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 ORDER 2 The Court has reviewed the Joint Stipulation for Protective Order filed by Plaintiff 3 4 Gonzalo Mata (“Plaintiff”) and Defendant Target Corporation (“Defendant”), through 5 their counsel of record, requesting that the Court enter an Order. 6 Having considered the above stipulation, and finding good cause, the Court adopts 7 8 the signed stipulated protective order, (Doc. 21), subject to the following: 9 Exhibit A, lines 9-10: “I further consent and submit to the jurisdiction of the USED 10 for the purpose of enforcing the Stipulated Protective Order, if necessary” is hereby 11 12 struck and replaced with “I further consent and submit to the jurisdiction of the USED for 13 the purpose of enforcing the Stipulated Protective Order, if necessary, up to and until 14 the termination of this action.” 15 16 The parties are advised that pursuant to the Local Rules of the United States 17 District Court, Eastern District of California, any documents subject to the protective 18 order to be filed under seal must be accompanied by a written request which complies 19 20 with Local Rule 141 prior to sealing. The party making a request to file documents under 21 seal shall be required to show good cause for documents attached to a non-dispositive 22 motion or compelling reasons for documents attached to a dispositive motion. Pintos v. 23 24 Pacific Creditors Ass’n,

(9th Cir. 2009). Within five (5) days of 25 any approved document filed under seal, the party shall file a redacted copy of the sealed 26 document. The redactions shall be narrowly tailored to protect only the information that 27 28 is confidential or was deemed confidential. 1 Additionally, the parties shall consider resolving any dispute arising under the 2 protective order according to the Court’s informal discovery dispute procedure. 3 4 IT IS SO ORDERED. 5 6 Dated: September 29, 2025 /s/ Barbara A. McAuliffe _ UNITED STATES MAGISTRATE JUDGE 7

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