1 RAYMOND H. HUA (SBN 222466) [email protected] 2 JI HONG SOHN (SBN 354482) [email protected] 3 YUKEVICH | CAVANAUGH 355 S. Grand Avenue. 15th Floor 4 Los Angeles, California 90071-1560 Telephone: (213) 362-7777 5 Facsimile: (213) 362-7788 Email: [email protected] 6 Attorneys for GARFIELD BEACH CVS, 7 L.L.C.

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 MARY BRYANT, CASE NO. 2:25-cv-05130-KS

12 Plaintiff, AMENDED STIPULATED PROTECTIVE ORDER 13 vs. Assigned to Judge Karen L. Stevenson 14 GARFIELD BEACH CVS, L.L.C., and Courtroom 580 DOES 1-100, 15 Trial Date: None Set Defendant. 16

17 18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary, or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 23 enter the following Amended Stipulated Protective Order. The parties acknowledge 24 that this Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 only to the limited information or items that are entitled to confidential treatment 27 under the applicable legal principles. The parties further acknowledge, as set forth in 1 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 2 procedures that must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets, commercial, and/or proprietary 6 information for which special protection from public disclosure and from use for 7 any purpose other than prosecution of this action is warranted. Such confidential and 8 proprietary materials and information consist of, among other things, confidential 9 business or financial information, information regarding confidential business 10 practices, or commercial information (including information implicating privacy 11 rights of third parties), information otherwise generally unavailable to the public, or 12 which may be privileged or otherwise protected from disclosure under state or 13 federal statutes, court rules, case decisions, or common law. For instance, Defendant 14 is a nationwide pharmacy company, and thus employs numerous employees in each 15 of its stores and also maintains confidential business related records, which may be 16 pertinent to the instant action. Such records and materials may include items such as 17 store surveillance footage, which visually captures images of customers who would 18 be third-parties to their actions and implicates their privacy rights, internal policies 19 which Defendant may not wish customers to be aware of, and timesheets of 20 employees who are also third parties to the action. 21 Accordingly, to expedite the flow of information, to facilitate the prompt 22 resolution of disputes over confidentiality of discovery materials, to adequately 23 protect information the parties are entitled to keep confidential, to ensure that the 24 parties are permitted reasonable necessary uses of such material in preparation for 25 and in the conduct of trial, to address their handling at the end of the litigation, and 26 serve the ends of justice, a protective order for such information is justified in this 27 matter. It is the intent of the parties that information will not be designated as 1 faith belief that it has been maintained in a confidential, non-public manner, and 2 there is good cause why it should not be part of the public record of this case. 3 2. DEFINITIONS 4 2.1 Action: this pending federal law suit. 5 2.2 Challenging Party: a Party or Non-Party that challenges the designation 6 of information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 1 to this Action but are retained to represent or advise a party to this Action and have 2 appeared in this Action on behalf of that party or are affiliated with a law firm which 3 has appeared on behalf of that party, and includes support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record (and their 6 support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation support 10 services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 and their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 16 from a Producing Party. 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 4. DURATION 26 Once a case proceeds to trial, all of the information that was designated as 27 confidential or maintained pursuant to this protective order becomes public and will 1 compelling reasons supported by specific factual findings to proceed otherwise are 2 made to the trial judge in advance of the trial. See Kamakana v. City and County of 3 Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 4 showing for sealing documents produced in discovery from “compelling reasons” 5 standard when merits-related documents are part of court record). Accordingly, the 6 terms of this protective order do not extend beyond the commencement of the trial 7 5. DESIGNATING PROTECTED MATERIAL 8 5.1 Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Non-Party that designates information or items for protection under 10 this Order must take care to limit any such designation to specific material that 11 qualifies under the appropriate standards. The Designating Party must designate for 12 protection only those parts of material, documents, items, or oral or written 13 communications that qualify so that other portions of the material, documents, 14 items, or communications for which protection is not warranted are not swept 15 unjustifiably within the ambit of this Order. 16 Mass, indiscriminate, or routinized designations are prohibited. Designations 17 that are shown to be clearly unjustified or that have been made for an improper 18 purpose (e.g., to unnecessarily encumber the case development process or to impose 19 unnecessary expenses and burdens on other parties) may expose the Designating 20 Party to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 designated for protection do not qualify for protection, that Designating Party must 23 promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2 Manner and Timing of Designations. Except as otherwise provided in 25 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 26 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 27 under this Order must be clearly so designated before the material is disclosed or 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that 4 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and 12 before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must determine which 15 documents, or portions thereof, qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 18 portion or portions of the material on a page qualifies for protection, the Producing 19 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 20 markings in the margins). 21 (b) for testimony given in depositions that the Designating Party identify the 22 Disclosure or Discovery Material on the record, before the close of the deposition all 23 protected testimony. 24 (c) for information produced in some form other than documentary and for 25 any other tangible items, that the Producing Party affix in a prominent place on the 26 exterior of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 1 portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items does not, standing alone, waive 4 the Designating Party’s right to secure protection under this Order for such material. 5 Upon timely correction of a designation, the Receiving Party must make reasonable 6 efforts to assure that the material is treated in accordance with the provisions of this 7 Order. 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37.1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on 15 the Designating Party. Frivolous challenges, and those made for an improper 16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 17 parties) may expose the Challenging Party to sanctions. Unless the Designating 18 Party has waived or withdrawn the confidentiality designation, all parties shall 19 continue to afford the material in question the level of protection to which it is 20 entitled under the Producing Party’s designation until the Court rules on the 21 challenge. 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this 25 Action only for prosecuting, defending, or attempting to settle this Action. Such 26 Protected Material may be disclosed only to the categories of persons and under the 27 conditions described in this Order. When the Action has been terminated, a 1 DISPOSITION). 2 Protected Material must be stored and maintained by a Receiving Party at a 3 location and in a secure manner that ensures that access is limited to the persons 4 authorized under this Order. 5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 6 otherwise ordered by the court or permitted in writing by the Designating Party, a 7 Receiving Party may disclose any information or item designated 8 “CONFIDENTIAL” only to: 9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 10 employees of said Outside Counsel of Record to whom it is reasonably necessary to 11 disclose the information for this Action; 12 (b) the officers, directors, and employees (including House Counsel) of the 13 Receiving Party to whom disclosure is reasonably necessary for this Action; 14 (c) Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this Action and who have signed the 16 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (d) the court and its personnel; 18 (e) court reporters and their staff; 19 (f) professional jury or trial consultants, mock jurors, and Professional 20 Vendors to whom disclosure is reasonably necessary for this Action and who have 21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (g) the author or recipient of a document containing the information or a 23 custodian or other person who otherwise possessed or knew the information; 24 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 25 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 26 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 27 not be permitted to keep any confidential information unless they sign the 1 agreed by the Designating Party or ordered by the court. Pages of transcribed 2 deposition testimony or exhibits to depositions that reveal Protected Material may 3 be separately bound by the court reporter and may not be disclosed to anyone except 4 as permitted under this Amended Stipulated Protective Order; and 5 (i) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions. 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 8 IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 that compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification shall 13 include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or order to 15 issue in the other litigation that some or all of the material covered by the subpoena 16 or order is subject to this Protective Order. Such notification shall include a copy of 17 this Amended Stipulated Protective Order; and 18 (c) cooperate with respect to all reasonable procedures sought to be pursued 19 by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely seeks a protective order, the Party served with 21 the subpoena or court order shall not produce any information designated in this 22 action as “CONFIDENTIAL” before a determination by the court from which the 23 subpoena or order issued, unless the Party has obtained the Designating Party’s 24 permission. The Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these provisions 26 should be construed as authorizing or encouraging a Receiving Party in this Action 27 to disobey a lawful directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality 14 agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Amended 16 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 17 reasonably specific description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and 27 expense of seeking protection in this court of its Protected Material. 1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Amended Stipulated Protective Order, the Receiving Party must immediately (a) 5 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 6 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 7 the person or persons to whom unauthorized disclosures were made of all the terms 8 of this Order, and (d) request such person or persons to execute the 9 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 12 PROTECTED MATERIAL 13 When a Producing Party gives notice to Receiving Parties that certain 14 inadvertently produced material is subject to a claim of privilege or other protection, 15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 17 may be established in an e-discovery order that provides for production without 18 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 19 as the parties reach an agreement on the effect of disclosure of a communication or 20 information covered by the attorney-client privilege or work product protection, the 21 parties may incorporate their agreement in the amended stipulated protective order 22 submitted to the court. 23 12. MISCELLANEOUS 24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 25 person to seek its modification by the Court in the future. 26 12.2 Right to Assert Other Objections. By stipulating to the entry of this 27 Protective Order no Party waives any right it otherwise would have to object to 1 Amended Stipulated Protective Order. Similarly, no Party waives any right to object 2 on any ground to use in evidence of any of the material covered by this Protective 3 Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 6 only be filed under seal pursuant to a court order authorizing the sealing of the 7 specific Protected Material at issue. If a Party's request to file Protected Material 8 under seal is denied by the court, then the Receiving Party may file the information 9 in the public record unless otherwise instructed by the court. 10 13. FINAL DISPOSITION 11 After the final disposition of this Action, as defined in paragraph 4, within 60 12 days of a written request by the Designating Party, each Receiving Party must return 13 all Protected Material to the Producing Party or destroy such material. As used in 14 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 15 summaries, and any other format reproducing or capturing any of the Protected 16 Material. Whether the Protected Material is returned or destroyed, the Receiving 17 Party must submit a written certification to the Producing Party (and, if not the same 18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 19 (by category, where appropriate) all the Protected Material that was returned or 20 destroyed and (2)affirms that the Receiving Party has not retained any copies, 21 abstracts, compilations, summaries or any other format reproducing or capturing any 22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 25 reports, attorney work product, and consultant and expert work product, even if such 26 materials contain Protected Material. Any such archival copies that contain or 27 constitute Protected Material remain subject to this Protective Order as set forth in 1 14. Any violation of this Order may be punished by any and all appropriate 2 || measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 4 IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 DATED 11-7-2025 Vega 9||JasonS. Halpern Attorneys for Plaintiff MARY BRYANT 10 8 11 DATED: November 10, 2025 a TNmN—rOv09eze D-wee

Raymond H. Hua z62 14||Ji Hong Sohn Attorneys for Defendant GARFIELD BEACH CVS, L.L.C.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 19 DATED: November 13, 2025

20 lasanson Hon. Karen L. Stevenson 21 || United States Magistrate Judge 22 23 24 25 26 27 28

EXHIBIT A 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 Amended Stipulated Protective 6 Order that was issued by the United States District Court for the Central District of 7 California on [date] in the case of ___________ [insert formal name of the case 8 and the number and initials assigned to it by the court]. I agree to comply with 9 and to be bound by all the terms of this Amended Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Amended 13 Stipulated Protective Order to any person or entity except in strict compliance with 14 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 Amended Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [print or type full name] of _______________________________________ [print 20 or type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Amended Stipulated Protective Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________