1 Boris Treyzon, Esq. (SBN 188893) [email protected] 2 Pinar Kermani, Esq. (SBN 355486) [email protected] 3 Michael Zuzo, Esq. (SBN 356667) [email protected] 4 ABIR COHEN TREYZON SALO, LLP 16001 Ventura Blvd., Ste. 200 5 Encino, CA 91436

6 Attorneys for Plaintiff, JOHN BB ROE (Additional Counsel on Signature Page) 7 Rick Richmond (SBN 194962) 8 [email protected] Andrew E. Calderón (SBN 316673) 9 [email protected] Andrew S. Bledsoe (SBN 332171) 10 [email protected] LARSON LLP 11 555 South Flower Street, 30th Floor Los Angeles, California 90071 12 Attorneys for Defendant The Church of 13 Jesus Christ of Latter-day Saints and Temple Corporation of The Church of 14 Jesus Christ of Latter-day Saints

15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 18 19 JOHN BB ROE, Case No. 2:25-cv-08691-WLH (MARx)

20 Plaintiff, DISCOVERY MATTER Magistrate: Hon. Margo A. Rocconi 21 vs. STIPULATED PROTECTIVE 22 THE CHURCH OF JESUS CHRIST ORDER OF LATTER-DAY SAINTS, a 23 nonprofit corporation; TEMPLE CORPORATION OF THE CHURCH 24 OF LATTER-DAY SAINTS, a nonprofit corporation; CERRITOS 25 CALIFORNIA STAKE OF THE CHURCH OF LATTER-DAY 26 SATINS, an entity of unknown form; and DOES 1 to 100, 27 Defendants. 1 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth in 12 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 13 file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 This Action arises from allegations of childhood sexual abuse and is likely to 18 involve medical records, psychiatric records, confidential church membership 19 records, and other private information implicating the privacy rights of third parties 20 for which special protection from public disclosure and from use for any purpose 21 other than prosecution of this action is warranted. Accordingly, to expedite the flow 22 of information, to facilitate the prompt resolution of disputes over confidentiality of 23 discovery materials, to adequately protect information the parties are entitled to keep 24 confidential, to ensure that the parties are permitted reasonable necessary uses of 25 such material in preparation for and in the conduct of trial, to address their handling 26 at the end of the litigation, and serve the ends of justice, a protective order for such 27 information is justified in this matter. It is the intent of the parties that information 1 designated without a good faith belief that it has been maintained in a confidential, 2 non-public manner, and there is good cause why it should not be part of the public 3 record of this case. 4 2. DEFINITIONS 5 2.1 Action: John BB Roe v. The Church of Jesus Christ of Latter-day 6 Saints, et. al., 2:25-cv-08691-WLH (MARx) (C.D. Cal.) 7 2.2 Challenging Party: a Party or Non-Party that challenges the 8 designation of information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 10 how it is generated, stored or maintained) or tangible things that qualify for 11 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 12 the Good Cause Statement. 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 14 their support staff). 15 2.5 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless 19 of the medium or manner in which it is generated, stored, or maintained (including, 20 among other things, testimony, transcripts, and tangible things), that are produced or 21 generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as 24 an expert witness or as a consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a party to this Action, 26 and, for purposes of Defendants, attorneys from Kirton McConkie and their staff. 27 House Counsel does not include Outside Counsel of Record or any other outside 1 counsel. 2 2.9 Non-Party: any natural person, partnership, corporation, association, or 3 other legal entity not named as a Party to this action. 4 2.10 Outside Counsel of Record: attorneys who are not employees of a 5 party to this Action but are retained to represent or advise a party to this Action and 6 have appeared in this Action on behalf of that party or are affiliated with a law firm 7 which has appeared on behalf of that party, and includes support staff. 8 2.11 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Outside Counsel of Record (and their 10 support staffs). 11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.13 Professional Vendors: persons or entities that provide litigation 14 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) 16 and their employees and subcontractors. 17 2.14 Protected Material: any Disclosure or Discovery Material that is 18 designated as “CONFIDENTIAL.” 19 2.15 Receiving Party: a Party that receives Disclosure or Discovery 20 Material from a Producing Party. 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 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial will be governed by the orders of the 1 4. DURATION 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will 4 be presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are 6 made to the trial judge in advance of the trial. See Kamakana v. City and County of 7 Honolulu,

, 1180–81 (9th Cir. 2006) (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial 11 in this matter as to the Protected Material used or introduced as an exhibit at trial. 12 Information that remains confidential and is not made available to the public 13 at trial shall remain subject to the confidentiality obligations imposed by this Order 14 until a Designating Party agrees otherwise in writing or a court order otherwise 15 directs, even after final disposition of this litigation. Even after final disposition of 16 this litigation, the confidentiality obligations imposed by this Order will remain in 17 effect until a Designating Party agrees otherwise in writing or a court order 18 otherwise directs. Final disposition will be deemed to be the later of (1) dismissal of 19 all claims and defenses in this Action, with or without prejudice; and (2) final 20 judgment herein after the completion and exhaustion of all appeals, rehearings, 21 remands, trials, or reviews of this Action, including the time limits for filing any 22 motions or applications for extension of time pursuant to applicable law. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection 26 under this Order must take care to limit any such designation to specific material 27 that qualifies under the appropriate standards. The Designating Party must designate 1 communications that qualify so that other portions of the material, documents, 2 items, or communications for which protection is not warranted are not swept 3 unjustifiably within the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to impose 7 unnecessary expenses and burdens on other parties) may expose the Designating 8 Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 under this Order must be clearly so designated before the material is disclosed or 16 produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix at a minimum, the legend 21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 22 contains protected material. If only a portion or portions of the material on a page 23 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 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and 1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must determine which 3 documents, or portions thereof, qualify for protection under this Order. Then, before 4 producing the specified documents, the Producing Party must affix the 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 (b) for testimony given in depositions that the Designating Party identify 10 the Disclosure or Discovery Material on the record, before the close of the 11 deposition all protected testimony. 12 (c) for information produced in some form other than documentary and 13 for any other tangible items, that the Producing Party affix in a prominent place on 14 the exterior of the container or containers in which the information is stored the 15 legend “CONFIDENTIAL.” If only a portion or portions of the information 16 warrants protection, the Producing Party, to the extent practicable, will identify the 17 protected portion(s). 18 5.3 Inadvertent Failures to Designate. 19 If timely corrected, an inadvertent failure to designate qualified information 20 or items does not, standing alone, waive the Designating Party’s right to secure 21 protection under this Order for such material. Upon timely correction of a 22 designation, the Receiving Party must make reasonable efforts to assure that the 23 material is treated in accordance with the provisions of this Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. 26 Any Party or Non-Party may challenge a designation of confidentiality at any 27 time that is consistent with the Court’s Scheduling Order. 1 6.2 Meet and Confer. 2 The Challenging Party will initiate the dispute resolution process under Local 3 Rule 37.1 et seq. 4 6.3 Burden. 5 The burden of persuasion in any such challenge proceeding will be on the 6 Designating Party. Frivolous challenges, and those made for an improper purpose 7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 8 expose the Challenging Party to sanctions. Unless the Designating Party has waived 9 or withdrawn the confidentiality designation, all parties will continue to afford the 10 material in question the level of protection to which it is entitled under the 11 Producing Party’s designation until the Court rules on the challenge. 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under the 17 conditions described in this Order. When the Action has been terminated, a 18 Receiving Party must comply with the provisions of section 13 below (FINAL 19 DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Order. 23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 24 otherwise ordered by the court or permitted in writing by the Designating Party, a 25 Receiving Party may disclose any information or item designated 26 “CONFIDENTIAL” only to: 27 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 1 necessary to disclose the information for this Action; 2 (b) the officers, directors, and employees (including House Counsel) of 3 the Receiving Party to whom disclosure is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to whom 5 disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the Court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and Professional 10 Vendors to whom disclosure is reasonably necessary for this Action and who have 11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (g) the author or recipient of a document containing the information or a 13 custodian or other person who otherwise possessed or knew the information; 14 (h) during their depositions, witnesses, and attorneys for witnesses, in the 15 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 16 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 17 will not be permitted to keep any confidential information unless they sign the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 19 agreed by the Designating Party or ordered by the court. Pages of transcribed 20 deposition testimony or exhibits to depositions that reveal Protected Material may 21 be separately bound by the court reporter and may not be disclosed to anyone except 22 as permitted under this Stipulated Protective Order; and 23 (i) any mediator or settlement officer, and their supporting personnel, 24 mutually agreed upon by any of the parties engaged in settlement discussions. 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification 3 will include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or order 5 to issue in the other litigation that some or all of the material covered by the 6 subpoena or order is subject to this Protective Order. Such notification will include a 7 copy of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be 9 pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with 11 the subpoena or court order will not produce any information designated in this 12 action as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party will bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this Action 17 to disobey a lawful directive from another court. 18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 19 PRODUCED IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a 21 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 22 produced by Non-Parties in connection with this litigation is protected by the 23 remedies and relief provided by this Order. Nothing in these provisions should be 24 construed as prohibiting a Non-Party from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a Non-Party’s confidential information in its possession, and the Party is 27 subject to an agreement with the Non-Party not to produce the Non-Party’s 1 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (3) make the information requested available for inspection by the 8 Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court within 10 14 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the discovery 12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and 16 expense of seeking protection in this court of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of this Order, 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. 26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 27 PROTECTED MATERIAL 1 inadvertently produced material is subject to a claim of privilege or other protection, 2 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 3 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 4 may be established in an e-discovery order that provides for production without 5 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 6 as the parties reach an agreement on the effect of disclosure of a communication or 7 information covered by the attorney-client privilege or work product protection, the 8 parties may incorporate their agreement in the stipulated protective order submitted 9 to the court. 10 12. MISCELLANEOUS 11 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 12 person to seek its modification by the Court in the future. 13 12.2 Right to Assert Other Objections. By stipulating to the entry of this 14 Protective Order no Party waives any right it otherwise would have to object to 15 disclosing or producing any information or item on any ground not addressed in this 16 Stipulated Protective Order. Similarly, no Party waives any right to object on any 17 ground to use in evidence of any of the material covered by this Protective Order. 18 12.3 Filing Protected Material. A Party that seeks to file under seal any 19 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 20 only be filed under seal pursuant to a court order authorizing the sealing of the 21 specific Protected Material at issue. If a Party’s request to file Protected Material 22 under seal is denied by the court, then the Receiving Party may file the information 23 in the public record unless otherwise instructed by the court. 24 13. FINAL DISPOSITION 25 After the final disposition of this Action, as defined in paragraph 4, within 60 26 days of a written request by the Designating Party, each Receiving Party must return 27 all Protected Material to the Producing Party or destroy such material. As used in 1 summaries, and any other format reproducing or capturing any of the Protected 2 Material. Whether the Protected Material is returned or destroyed, the Receiving 3 Party must submit a written certification to the Producing Party (and, if not the same 4 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 5 (by category, where appropriate) all the Protected Material that was returned or 6 destroyed and (2) affirms that the Receiving Party has not retained any copies, 7 abstracts, compilations, summaries or any other format reproducing or capturing any 8 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 9 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 10 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 11 reports, attorney work product, and consultant and expert work product, even if such 12 materials contain Protected Material. Any such archival copies that contain or 13 constitute Protected Material remain subject to this Protective Order as set forth in 14 Section 4 (DURATION). 15 14. Any willful violation of this Order may be punished by civil or criminal 16 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 17 authorities, or other appropriate action at the discretion of the Court. 18 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 20 21 22 23 24 25 26 27 1 Dated: November 5, 2025 ABIR COHEN TREYZON SALO, LLP & MOTLEY RICE, LLC 2

3 By: /s/Jonathan Orent 4 Jonathan Orent 5 Jonathan Orent (Pro Hac Vice Forthcoming) [email protected] 6 MOTLEY RICE, LLC 40 Westminster Street, 5th Floor 7 Providence, RI 02903 8 Daniel R. Lapinski (Pro Hac Vice Forthcoming) [email protected] 9 MOTLEY RICE, LLC 210 Lake Drive East, Suite 101 10 Cherry Hill, NJ 08002 Carmen Scott (Pro Hac Vice Forthcoming) 11 [email protected] MOTLEY RICE, LLC 12 28 Bridgeside Boulevard Mount Pleasant, SC 29464 13 Attorneys for Plaintiff John BB Roe 14

15 Dated: November 5, 2025 LARSON LLP 16 By: /s/Rick Richmond 17 Rick Richmond1 18 Andrew E. Calderón Andrew S. Bledsoe 19 Attorneys for Defendant The Church of Jesus Christ of Latter-day Saints and Temple 20 Corporation of The Church of Jesus Christ of Latter-day Saints 21

22

23 24 25 26 1 Pursuant to Local Rule 5-4.3.4(a)(2)(i), filer hereby attests that all signatories 27 listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3||DATED: 11/25/2025 4 HON. MARGO A. ROCCONI United States Magistrate Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on _________ [date] in the case of John BB Roe v. The Church of Jesus Christ of 8 Latter-day Saints, et. al., 2:25-cv-08691-WLH (MARx) (C.D. Cal.). I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 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 __________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27