BRADLEY & BROWN 1 Attorneys at Law 6780 N. West Ave. 2 Suite 102 Fresno, CA 93711 3 Peter Sean Bradley, Esq. 4 SBN #109258 Tel: (559) 960-5613 5 [email protected]

6 Laura Elizabeth Brown, Esq. SBN #306035 7 Tel: (559) 862-8633 [email protected] 8 Attorneys for Plaintiff 9 Myesha Frazier-Taylor

10 ROGER M. MANSUKHANI (SBN: 164463) [email protected] 11 ANNE-LEITH MATLOCK (SBN 244351) [email protected] 12 GORDON REES SCHULLY MANSUKHANI LLP 13 101 W. Broadway, Suite 200 14 San Diego, CA 92101 Telephone:(619) 230-7701 15 Facsimile: (619) 696-7124 16 Attorneys for Defendants CAMBRIDGE MANAGEMENT, INC. 17 18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA 20 21 MYESHA FRAZIER-TAYLOR Case No. 1:25-CV-00448-BAM

22 Plaintiff, PROTECTIVE ORDER

23 vs. [Fresno County Superior Court – Case No. 18CECG01029] 24 CAMBRIDGE MANAGEMENT, INC.

25 Defendants. Action Filed: April 17, 2025 26 Trial Date: May 4, 2027

27 Initial Scheduling Conference (Supplemental)

28 1 TO ALL PARTIES AND THEIR COUNSEL: 2 WHEREAS, this case involves sensitive matters, including claims of employment 3 discrimination, harassment, and retaliation based on disability and whistleblowing activities; 4 WHEREAS, the parties recognize the importance of protecting private and confidential 5 information while ensuring fair and efficient discovery; 6 WHEREAS, the Court has the authority to issue protective orders to safeguard sensitive 7 information and balance the needs of all parties; 8 9 THEREFORE, THE PARTIES STIPULATE: 10 1. Scope of Protection 11 This Protective Order applies to all documents, materials, information, testimony, and 12 other discovery produced or disclosed in this case that contain or reveal: 13 a. Personnel records and files of current or former employees; 14 b. Confidential personal information, such as home addresses, phone numbers, 15 social security numbers, medical details, and financial data; 16 c. Trade secrets or proprietary business information; 17 d. Internal company policies, procedures, and communications related to personnel 18 matters; 19 e. Any other information designated as "CONFIDENTIAL" under this Order.

20 2. Designation of Confidential Information 21 Any party may mark materials as "CONFIDENTIAL" by clearly labeling them with the 22 designation "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" before production or 23 disclosure. As to previously produced or disclosed documents the parties will have thirty (30) 24 days from date of executing this document to mark such items as “CONFIDENTIAL – 25 SUBJECT TO PROTECTIVE ORDER”. 26 If any party disagrees with a confidentiality designation, the designating party bears the 27 burden of justifying the designation. The parties must meet and confer on any disagreement, and 28 if no agreement is reached, the designating party must move for a protective order. 3. Use and Disclosure of Confidential Information 1 Materials designated as "CONFIDENTIAL" may only be: 2 1. Shared with attorneys of record and their staff directly involved in this case; 3 4 2. Shared with the parties to this case; 5 3. Shared with expert witnesses retained for this case, provided they sign a confidentiality agreement; 6 4. Used solely for purposes of this litigation and not for any other purpose; 7 8 5. Disclosed during depositions, hearings, or trial, with appropriate measures to maintain confidentiality. 9 4. Return or Destruction of Materials 10 Within 30 days after the conclusion of this case, all confidential materials and any copies 11 must be returned to the producing party or destroyed, with written confirmation of such return or 12 destruction. Nothing in this section precludes counsel from retaining a copy of their own file or 13 any client from retaining a copy of their own file. 14 5. Enforcement 15 Any violation of this Protective Order may result in appropriate sanctions, including 16 potential court proceedings. 17 18 6. Modifications This Order may be modified by agreement of the parties or further order of the Court. 19 7. Good Faith Cooperation 20 All parties will work cooperatively to ensure the protection of sensitive information while 21 facilitating the fair resolution of this case. 22 // 23 // 24 // [SIGNATURES ON FOLLOWING PAGE] 25 // 26 // 27 // 28 1 IS SO STIPULATED: 2 3 Dated: 10/14/25 BRADLEY & BROWN 4 /s/ Peter Sean Bradley 5 “PeterSean Bradley Counsel for Plaintiff

7 Dated: _ 10/14/25 GORDON REES, A.P.C. 8 9 Anne~Leith W. Matlock, Anne-Leith Matlock 10 Attorneys for Defendant 11 Oe Ok 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PROTECTIVE ORDER

1 ORDER 2 The Court has reviewed the stipulated Protective Order filed by Plaintiff Myesha 3 Frazier-Taylor (“Plaintiff”) and Defendant Cambridge Management, Inc. (“Defendant”), 4 through their counsel of record, requesting that the Court enter an Order. 5 Having considered the above stipulation, and finding good cause, the Court adopts the 6 signed stipulated Protective Order, (Doc. 18), subject to the following: 7 Page 3, line 19: “This Order may be modified by agreement of the parties or further order 8 of the Court” is hereby struck and replaced with “This Order may be modified by agreement of 9 the parties or further order of the Court, up to and until the termination of this action.” In 10 addition, CONFIDENTIAL information may be shared with the Court. 11 The parties are advised that pursuant to the Local Rules of the United States District 12 Court, Eastern District of California, any documents subject to the protective order to be filed 13 under seal must be accompanied by a written request which complies with Local Rule 141 prior 14 to sealing. The party making a request to file documents under seal shall be required to show 15 16 good cause for documents attached to a non-dispositive motion or compelling reasons for 17 documents attached to a dispositive motion. Pintos v. Pacific Creditors Ass’n,

, 18 677-78 (9th Cir. 2009). Within five (5) days of any approved document filed under seal, the 19 party shall file a redacted copy of the sealed document. The redactions shall be narrowly tailored 20 to protect only the information that is confidential or was deemed confidential. 21 Additionally, the parties shall consider resolving any dispute arising under the protective 22 order according to the Court’s informal discovery dispute procedure. 23 24

25 IT IS SO ORDERED.

26 Dated: October 15, 2025 /s/ Barbara A. McAuliffe _ 27 UNITED STATES MAGISTRATE JUDGE 28