C AcaMmIiLloOec [email protected] o(mSt ate Bar No. 192481) 2 JASMINE LOSTON (State Bar No. 362378) 3 [email protected] DAVIS WRIGHT TREMAINE LLP 4 350 South Grand Avenue, 27th Floor Los Angeles, California 90071 5 Telephone: (213) 633-6800 Fax: (213) 633-6899 6 Attorneys for Defendant 7 AMAZON RETAIL, LLC 8 Simon Moshkovich, Esq. (SBN 323584) 9 [email protected] MERCER LEGAL GROUP 10 21031 Ventura Blvd., #103 11 Woodland Hills, CA 91364 Tel: (818) 538-3458 12 Fax: (818) 538-3263 13 Attorney for plaintiff VIVIEN GAMEL 14 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17 18 VIVIEN GAMEL, an individual, Case No. 5:25-cv-02153-SRM (MBKx) 19 Plaintiff, STIPULATION AND PROTECTIVE 20 ORDER – CONFIDENTIAL DESIGNATION vs. ONLY 21 AMAZON RETAIL, LLC, a Delaware limited Assigned to the Hon. Michael B. Kaufman liability company, and DOES 1 through 100, 22 inclusive, Action Filed: July 01, 2025 23 Defendants. 24 25 26 27 28 1 GENERAL 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve production 3 of confidential, proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated 6 Protective Order. The parties acknowledge that this Order does not confer blanket protections on 7 all disclosures or responses to discovery and that the protection it affords from public disclosure 8 and use extends only to the limited information or items that are entitled to confidential treatment 9 under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, 10 below, that this Stipulated Protective Order does not entitle them to file confidential information 11 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards 12 that will be applied when a party seeks permission from the court to file material under seal. 13 1.2 Good Cause Statement. This action is likely to involve protected medical 14 information, confidential employee and human resources information, company policies, trade 15 secrets, and/or proprietary information that warrants special protection from public disclosure and 16 from use for any purpose other than prosecution of this action. Disclosure of the confidential 17 information likely to be produced in this case—including, but not limited to, protected medical 18 documents, company policies, private employee information, investigation reports, promotional 19 structures, and documents related to the interactive process and medical leave—would result in 20 significant harm to the producing party. The release of company policies and procedures would 21 risk providing competitors with insight into proprietary practices and operational strategies, 22 undermining the company’s ability to maintain a competitive edge in the marketplace. Public 23 exposure of investigation reports, leave-related documents, and other sensitive employee-related 24 information could violate the legitimate expectations of employee privacy, potentially damaging 25 morale and trust within the workforce, while also exposing the company to liability or reputational 26 harm. Further, the disclosure of investigative records and internal documents may discourage 27 employees from participating honestly and fully in such processes in the future, undermining efforts 28 to address workplace concerns and comply with applicable legal and regulatory requirements. Such 1 2 public, or which may be privileged or otherwise protected from disclosure under state or federal 3 statutes, court rules, case decisions, or common law. 4 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 5 disputes over confidentiality of discovery materials, to adequately protect information the parties 6 are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses 7 of such material in preparation for and in the conduct of trial, to address their handling at the end 8 of the litigation, and serve the ends of justice, a protective order for such information is justified in 9 this matter. It is the intent of the parties that information will not be designated as confidential for 10 tactical reasons and that nothing be so designated without a good faith belief that it has been 11 maintained in a confidential, non-public manner, and there is good cause why it should not be part 12 of the public record of this case. 13 14 2. DEFINITIONS 15 2.1 Action: Vivien Gamel v. Amazon Retail, LLC, et al., Central District of California 16 Case No.5:25-cv-02153-SRM-MBKx. 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 18 information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 20 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 21 Civil Procedure 26(c), and as specified above in the Good Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support 23 staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or items that it 25 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 26 2.6 Disclosure or Discovery Material: all items or information, regardless of the 27 medium or manner in which it is generated, stored, or maintained (including, among other things, 28 1 2 responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to 4 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 5 consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this Action. House 7 Counsel does not include Outside Counsel of Record or any other outside counsel. 8 2.9 Non-Party: any natural person, partnership, corporation, association, or other legal 9 entity not named as a Party to this action. 10 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 11 Action but are retained to represent or advise a party to this Action and have appeared in this Action 12 on behalf of that party or are affiliated with a law firm that has appeared on behalf of that party, 13 including support staff. 14 2.11 Party: any party to this Action, including all of its officers, directors, employees, 15 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 17 Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support services 19 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 20 storing, or retrieving data in any form or medium) and their employees and subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 22 “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 24 Producing Party. 25 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only Protected Material 28 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all 1 2 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial judge. This 4 Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 Once a case proceeds to trial, all of the court-filed information to be introduced that was 8 previously designated as confidential or maintained pursuant to this protective order becomes public 9 and will be presumptively available to all members of the public, including the press, unless 10 compelling reasons supported by specific factual findings to proceed otherwise are made to the trial 11 judge in advance of the trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 12 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in discovery 13 from “compelling reasons” standard when merits-related documents are part of court record). 14 Accordingly, the terms of this protective order do not extend beyond the commencement of the 15 trial. 16 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 19 or Non-Party that designates information or items for protection under this Order must take care to 20 limit any such designation to specific material that qualifies under the appropriate standards. The 21 Designating Party must designate for protection only those parts of material, documents, items, or 22 oral or written communications that qualify so that other portions of the material, documents, items, 23 or communications for which protection is not warranted are not swept unjustifiably within the 24 ambit of this Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 26 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 27 encumber the case development process or to impose unnecessary expenses and burdens on other 28 parties) may expose the Designating Party to sanctions. 1 2 protection do not qualify for protection, that Designating Party must promptly notify all other 3 Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 5 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 6 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 7 designated before the material is disclosed or produced. 8 Designation in conformity with this Order requires: 9 (a) for information in documentary form (e.g., paper or electronic documents, but 10 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 11 affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to 12 each page that contains protected material. If only a portion or portions of the material on a page 13 qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 14 by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection need not 16 designate them for protection until after the inspecting Party has indicated which documents it 17 would like copied and produced. During the inspection and before the designation, all of the 18 material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting 19 Party has identified the documents it wants copied and produced, the Producing Party must 20 determine which documents, or portions thereof, qualify for protection under this Order. Then, 21 before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL 22 legend” to each page that contains Protected Material. If only a portion or portions of the material 23 on a page qualifies for protection, the Producing Party also must clearly identify the protected 24 portion(s) (e.g., by making appropriate markings in the margins). 25 (b) for testimony given in depositions that the Designating Party identify the 26 Disclosure or Discovery Material on the record, before the close of the deposition. 27 (c) for information produced in some form other than documentary and for any other 28 tangible items, that the Producing Party affix in a prominent place on the exterior of the container 1 2 or portions of the information warrants protection, the Producing Party, to the extent practicable, 3 shall identify the protected portion(s). 4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 5 designate qualified information or items does not, standing alone, waive the Designating Party’s 6 right to secure protection under this Order for such material. Upon timely correction of a 7 designation, the Receiving Party must make reasonable efforts to assure that the material is treated 8 in accordance with the provisions of this Order. 9 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 12 confidentiality at any time that is consistent with the Court’s Scheduling Order. 13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 14 under Local Rule 37-1, et seq, as modified by Judge Kaufman’s Procedures. See 15 https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any discovery motion must strictly 16 comply with these procedures. 17 6.3 Burden. The burden of persuasion in any such challenge proceeding shall be on the 18 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass 19 or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party 20 to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality designation, 21 all parties shall continue to afford the material in question the level of protection to which it is 22 entitled under the Producing Party’s designation until the Court rules on the challenge. 23 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 26 produced by another Party or by a Non-Party in connection with this Action only for prosecuting, 27 defending, or attempting to settle this Action. Such Protected Material may be disclosed only to 28 the categories of persons and under the conditions described in this Order. When the Action has 1 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a location and in 4 a secure manner that ensures that access is limited to the persons authorized under this Order. 5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 6 by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any 7 information or item designated “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 9 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 10 information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 14 reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement 15 to Be Bound” (Exhibit A); 16 (d) the Court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 19 whom disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a custodian 22 or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to 24 whom disclosure is reasonably necessary provided: (1) the deposing party requests that the witness 25 sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any 26 confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” 27 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the Court. Pages of 28 transcribed deposition testimony or exhibits to depositions that reveal Protected Material may be 1 2 under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, mutually 4 agreed upon by any of the parties engaged in settlement discussions. 5 6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 7 OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation that compels 9 disclosure of any information or items designated in this Action as “CONFIDENTIAL,” that Party 10 must: 11 (a) promptly notify in writing the Designating Party. Such notification shall include a copy 12 of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or order to issue in the 14 other litigation that some or all of the material covered by the subpoena or order is subject to this 15 Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 17 Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with the subpoena 19 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 20 before a determination by the court from which the subpoena or order issued, unless the Party has 21 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 22 expense of seeking protection in that court of its confidential material and nothing in these 23 provisions should be construed as authorizing or encouraging a Receiving Party in this Action to 24 disobey a lawful directive from another court. 25 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 27 THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a Non-Party in this 1 2 connection with this litigation is protected by the remedies and relief provided by this Order. 3 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional 4 protections. 5 (b) In the event that a Party is required, by a valid discovery request, to produce a Non- 6 Party’s confidential information in its possession, and the Party is subject to an agreement with the 7 Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 8 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 9 all of the information requested is subject to a confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 11 in this Action, the relevant discovery request(s), and a reasonably specific description of the 12 information requested; and 13 (3) make the information requested available for inspection by the Non-Party, if 14 requested. 15 (c) If the Non-Party fails to seek a protective order from this Court within 14 days of 16 receiving the notice and accompanying information, the Receiving Party may produce the Non- 17 Party’s confidential information responsive to the discovery request. If the Non-Party timely seeks 18 a protective order, the Receiving Party shall not produce any information in its possession or control 19 that is subject to the confidentiality agreement with the Non-Party before a determination by the 20 Court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 21 seeking protection in this Court of its Protected Material. 22 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 25 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 26 the Receiving Party must immediately (a) notify in writing the Designating Party of the 27 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 28 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the 1 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain inadvertently 7 produced material is subject to a claim of privilege or other protection, the obligations of the 8 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 9 is not intended to modify whatever procedure may be established in an e-discovery order that 10 provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a 12 communication or information covered by the attorney-client privilege or work product protection, 13 the parties may incorporate their agreement in the stipulated protective order submitted to the Court. 14 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 17 seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, 19 no Party waives any right it otherwise would have to object to disclosing or producing any 20 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 21 Party waives any right to object on any ground to use in evidence of any of the material covered by 22 this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 24 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 25 pursuant to a court order authorizing the sealing of the specific Protected Material at issue; good 26 cause must be shown in the request to file under seal. If a Party’s request to file Protected Material 27 under seal is denied by the Court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the Court. 1 2 13. FINAL DISPOSITION 3 After the final disposition of this Action, within sixty (60) days of a written request by the 4 Designating Party, each Receiving Party must return all Protected Material to the Producing Party 5 or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, 6 abstracts, compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person or entity, to 9 the Designating Party) by the sixty (60) day deadline that (1) identifies (by category, where 10 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms that the 11 Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format 12 reproducing or capturing any of the Protected Material. Notwithstanding this provision, counsel 13 are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 14 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 15 work product, and consultant and expert work product, even if such materials contain Protected 16 Material. Any such archival copies that contain or constitute Protected Material remain subject to 17 this Protective Order as set forth in Section 4 (DURATION). 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // 14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate measures including, 3|| without limitation, contempt proceedings and/or monetary sanctions. 4 5|| 1T IS SO STIPULATED, THROUGH COUNSEL OF RECORD. DATED: November 17, 2025 MERCER LEGAL GROUP 7 8 /s/ Simon Moskovich ? Simon Moskovich 10 Attorney for Plaintiff VIVIEN GAMEL 1] DATED: November 17, 2025 Davis WRIGHT TREMAINE LLP 13 CAMILO ECHAVARRIA JASMINE LOSTON 14 Is /s/ Camilo Echavarria 16 Camilo Echavarria Attorneys for Defendant 17 AMAZON RETAIL, LLC 18 19 ATTESTATION 20 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Camilo Echavarria, attest that other signatory listed, on whose behalf this filing is submitted, concurs in the filing’s content and has authorized 22|| this filing. By: /s/ Camilo Echvarria 23 IT IS SO ORDERED. DATED: November 18, 2025 LA Ag p~_ MICHAEL KAUFMAN 26 UNITED STATES MAGISTRATE JUDGE 27 28

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