1 Jordan Ashley Duncan-Smith, Esq. (SBN 354658) DOWNTOWN L.A. LAW GROUP 2 612 S Broadway Los Angeles, CA 90014 3 Tel: (213) 389-3765 Fax: (877) 389-2775 4 [email protected]

5 Attorneys for Plaintiff, SHAWN MCSPADDEN

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7 ZACHARY S. TOLSON, ESQUIRE - State Bar #242824 GANETTE M. GENETTI - State Bar #256707 8 GOODMAN NEUMAN HAMILTON LLP 100 Bush Street, Suite 1800 9 San Francisco, California 94104 Telephone: (415) 705-0400 10 Facsimile: (415) 705-0411 [email protected]; [email protected] 11 Attorneys for Defendant, HOME DEPOT U.S.A., INC. 12 13 UNITED STATES DISTRICT COURT 14 EASTERN DISTRICT OF CALIFORNIA 15 16 SHAWN MCSPADDEN, an Case No. 1:25-cv-01021-BAM individual, 17 [PROPOSED] STIPULATED Plaintiff, 18 PROTECTIVE ORDER vs. 19 HOME DEPOT U.S.A., INC., a 20 Delaware corporation; DOE 1 (STORE MANAGER); DOES 2-50, inclusive, 21 Defendants. 22

23 24 25 1. PURPOSES AND LIMITATIONS 26 Disclosure and discovery activity in this action are likely to involve production of 27 confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be 1 warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the 2 following Stipulated Protective Order. The parties acknowledge that this Order does not 3 confer blanket protections on all disclosures or responses to discovery and that the 4 protection it affords from public disclosure and use extends only to the limited 5 information or items that are entitled to confidential treatment under the applicable legal 6 principles. The parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information under 8 seal; Civil Local Rules 140, 141 and 141.1 set forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court to file 10 material under seal. 11 2. DEFINITIONS 12 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 13 information or items under this Order. 14 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it 15 is generated, stored or maintained) or tangible things that qualify for protection under 16 Federal Rule of Civil Procedure 26(c). 17 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel 18 (as well as their support staff). 19 2.4 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 21 2.5 Disclosure or Discovery Material: all items or information, regardless of the 22 medium or manner in which it is generated, stored, or maintained (including, among other 23 things, testimony, transcripts, and tangible things), that are produced or generated in 24 disclosures or responses to discovery in this matter. 25 2.6 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 27 expert witness or as a consultant in this action. 2.7 House Counsel: attorneys who are employees of a party to this action. 1 House Counsel does not include Outside Counsel of Record or any other outside counsel. 2 2.8 Non-Party: any natural person, partnership, corporation, association, or 3 other legal entity not named as a Party to this action. 4 2.9 Outside Counsel of Record: attorneys who are not employees of a party to 5 this action but are retained to represent or advise a party to this action and have appeared 6 in this action on behalf of that party or are affiliated with a law firm which has appeared 7 on behalf of that party. 8 2.10 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 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this action. 13 2.12 Professional Vendors: persons or entities that provide litigation support 14 services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 16 their employees and subcontractors. 17 2.13 Protected Material: any Disclosure or Discovery Material that is designated 18 as “CONFIDENTIAL.” 19 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material 20 from a Producing Party. 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only Protected 23 Material (as defined above), but also (1) any information copied or extracted from 24 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 25 Material; and (3) any testimony, conversations, or presentations by Parties or their 26 Counsel that might reveal Protected Material. However, the protections conferred by this 27 Stipulation and Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the 1 public domain after its disclosure to a Receiving Party as a result of publication not 2 involving a violation of this Order, including becoming part of the public record through 3 trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who 5 obtained the information lawfully and under no obligation of confidentiality to the 6 Designating Party. Any use of Protected Material at trial shall be governed by a separate 7 agreement or order. 8 4. DURATION 9 Even after final disposition of this litigation, the confidentiality obligations 10 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in 11 writing or a court order otherwise directs. Final disposition shall be deemed to be the later 12 of (1) dismissal of all claims and defenses in this action, with or without prejudice; and (2) 13 final judgment herein after the completion and exhaustion of all appeals, rehearings, 14 remands, trials, or reviews of this action, including the time limits for filing any motions 15 or applications for extension of time pursuant to applicable law. 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 18 Party or Non-Party that designates information or items for protection under this Order 19 must take care to limit any such designation to specific material that qualifies under the 20 appropriate standards. The Designating Party must designate for protection only those 21 parts of material, documents, items, or oral or written communications that qualify – so 22 that other portions of the material, documents, items, or communications for which 23 protection is not warranted are not swept unjustifiably within the ambit of this Order. 24 Mass, indiscriminate, or routinized designations are prohibited. Designations that 25 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 26 to unnecessarily encumber or delay the case development process or to impose 27 unnecessary expenses and burdens on other parties) expose the Designating Party to sanctions. 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the mistaken designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in this 5 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 6 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 7 must be clearly so 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 11 Producing Party affix the legend “CONFIDENTIAL” to each page that contains protected 12 material. If only a portion or portions of the material on a page qualifies for protection, the 13 Producing Party also must clearly identify the protected portion(s) (e.g., by making 14 appropriate markings in the margins). A Party or Non-Party that makes original 15 documents or materials available for inspection need not designate them for protection 16 until after the inspecting Party has indicated which material it would like copied and 17 produced. During the inspection and before the designation, all of the material made 18 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party 19 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. 21 Then, before producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing Party 24 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 25 in the margins). 26 (b) for testimony given in deposition or in other pretrial or trial proceedings, that 27 the Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, all protected testimony. 1 (c) for information produced in some form other than documentary and for any 2 other tangible items, that the Producing Party affix in a prominent place on the exterior of 3 the container or containers in which the information or item is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 8 to designate qualified information or items does not, standing alone, waive the 9 Designating Party’s right to secure protection under this Order for such material. Upon 10 timely correction of a designation, the Receiving Party must make reasonable efforts to 11 assure that the material is treated in accordance with the provisions of this Order. 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 14 of confidentiality at any time. Unless a prompt challenge to a Designating Party’s 15 confidentiality designation is necessary to avoid foreseeable, substantial unfairness, 16 unnecessary economic burdens, or a significant disruption or delay of the litigation, a 17 Party does not waive its right to challenge a confidentiality designation by electing not to 18 mount a challenge promptly after the original designation is disclosed. 19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 20 process by providing written notice of each designation it is challenging and describing 21 the basis for each challenge. To avoid ambiguity as to whether a challenge has been made, 22 the written notice must recite that the challenge to confidentiality is being made in 23 accordance with this specific paragraph of the Protective Order. The parties shall attempt 24 to resolve each challenge in good faith and must begin the process by conferring directly 25 (in voice-to-voice dialogue; other forms of communication are not sufficient) within 14 26 days of the date of service of notice. In conferring, the Challenging Party must explain the 27 basis for its belief that the confidentiality designation was not proper and must give the Designating Party an opportunity to review the designated material, to reconsider the 1 circumstances, and, if no change in designation is offered, to explain the basis for the 2 chosen designation. A Challenging Party may proceed to the next stage of the challenge 3 process only if it has engaged in this meet and confer process first or establishes that the 4 Designating Party is unwilling to participate in the meet and confer process in a timely 5 manner. 6 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 7 intervention, the Designating Party shall file and serve a motion to retain confidentiality 8 under Civil Local Rules 140, 141, and 141.1 (and in compliance with Civil Local Rule 9 230, if applicable) within 21 days of the initial notice of challenge or within 14 days of the 10 parties agreeing that the meet and confer process will not resolve their dispute, whichever 11 is earlier. Each such motion must be accompanied by a competent declaration affirming 12 that the movant has complied with the meet and confer requirements imposed in the 13 preceding paragraph. Failure by the Designating Party to make such a motion including 14 the required declaration within 21 days (or 14 days, if applicable) shall automatically 15 waive the confidentiality designation for each challenged designation. In addition, the 16 Challenging Party may file a motion challenging a confidentiality designation at any time 17 if there is good cause for doing so, including a challenge to the designation of a deposition 18 transcript or any portions thereof. Any motion brought pursuant to this provision must be 19 accompanied by a competent declaration affirming that the movant has complied with the 20 meet and confer requirements imposed by the preceding paragraph. 21 The burden of persuasion in any such challenge proceeding shall be on the 22 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 23 harass or impose unnecessary expenses and burdens on other parties) may expose the 24 Challenging Party to sanctions. Unless the Designating Party has waived the 25 confidentiality designation by failing to file a motion to retain confidentiality as described 26 above, all parties shall continue to afford the material in question the level of protection to 27 which it is entitled under the Producing Party’s designation until the court rules on the challenge. 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this case 4 only for prosecuting, defending, or attempting to settle this litigation. Such Protected 5 Material may be disclosed only to the categories of persons and under the conditions 6 described in this Order. When the litigation has been terminated, a Receiving Party must 7 comply with the provisions of section 13 below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a location and 9 in a secure manner that ensures that access is limited to the persons authorized under this 10 Order. 11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 12 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 13 may disclose any information or item designated “CONFIDENTIAL” only to: 14 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 15 employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this litigation and who have signed the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A; 18 (b) the officers, directors, and employees (including House Counsel) of the 19 Receiving Party to whom disclosure is reasonably necessary for this litigation and who 20 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 22 reasonably necessary for this litigation and who have signed the “Acknowledgment and 23 Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff, professional jury or trial consultants, mock 26 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this 27 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (f) during their depositions, witnesses in the action to whom disclosure is 2 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be 3 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 4 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 5 Protected Material must be separately bound by the court reporter and may not be 6 disclosed to anyone except as permitted under this Stipulated Protective Order. 7 (g) the author or recipient of a document containing the information or a custodian 8 or other person who otherwise possessed or knew the information. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 10 OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that 12 compels disclosure of any information or items designated in this action as 13 “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification shall 15 include a copy of the subpoena or court order; 16 (b) promptly notify in writing the party who caused the subpoena or order to issue 17 in the other litigation that some or all of the material covered by the subpoena or order is 18 subject to this Protective Order. Such notification shall include a copy of this Stipulated 19 Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 21 Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with the 23 subpoena or court order shall not produce any information designated in this action as 24 “CONFIDENTIAL” before a determination by the court from which the subpoena or 25 order issued, unless the Party has obtained the Designating Party’s permission. The 26 Designating Party shall bear the burden and expense of seeking protection in that court of 27 its confidential material – and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive 1 from another court. 2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 3 PRODUCED IN THIS LITIGATION 4 (a) The terms of this Order are applicable to information produced by a Non-Party 5 in this action and designated as “CONFIDENTIAL.” Such information produced by Non- 6 Parties in connection with this litigation is protected by the remedies and relief provided 7 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party 8 from seeking additional protections. 9 (b) In the event that a Party is required, by a valid discovery request, to produce a 10 Non-Party’s confidential information in its possession, and the Party is subject to an 11 agreement with the Non-Party not to produce the Non-Party’s confidential information, 12 then the Party shall: 13 (1) promptly notify in writing the Requesting Party and the Non-Party that some or 14 all of the information requested is subject to a confidentiality agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 16 in this litigation, the relevant discovery request(s), and a reasonably specific description of 17 the information requested; and 18 (3) make the information requested available for inspection by the Non-Party. 19 (c) If the Non-Party fails to object or seek a protective order from this court within 20 14 days of receiving the notice and accompanying information, the Receiving Party may 21 produce the Non-Party’s confidential information responsive to the discovery request. If 22 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 23 information in its possession or control that is subject to the confidentiality agreement 24 with the Non-Party before a determination by the court. Absent a court order to the 25 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 26 court of its Protected Material. 27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 1 Protected Material to any person or in any circumstance not authorized under this 2 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 3 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 4 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 5 unauthorized disclosures were made of all the terms of this Order, and (d) request such 6 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 7 attached hereto as Exhibit A. 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 9 PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that certain inadvertently 11 produced material is subject to a claim of privilege or other protection, the obligations of 12 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 13 This provision is not intended to modify whatever procedure may be established in an e- 14 discovery order that provides for production without prior privilege review. Pursuant to 15 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 16 effect of disclosure of a communication or information covered by the attorney-client 17 privilege or work product protection, the parties may incorporate their agreement in the 18 stipulated protective order submitted to the court. 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 person to seek its modification by the court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order no Party waives any right it otherwise would have to object to disclosing 24 or producing any information or item on any ground not addressed in this Stipulated 25 Protective Order. Similarly, no Party waives any right to object on any ground to use in 26 evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. Without a court order a Party may not file in the public record in this action any Protected Material. A Party that seeks to file under seal 1 any Protected Material must comply with Civil Local Rules 140, 141 and 141.1. 2 Protected Material may only be filed under seal pursuant to a court order authorizing the 3 sealing of the specific Protected Material at issue. If a Receiving Party’s request to file 4 Protected Material under seal pursuant to Civil Local Rules 140, 141 and 141.1 is denied 5 by the court, then the Receiving Party may file the information in the public record 6 pursuant to Civil Local Rules 140, 141 and 141.1, unless otherwise instructed by the court. 7 13. FINAL DISPOSITION 8 Within 60 days after the final disposition of this action, as defined in paragraph 4, 9 each Receiving Party must return all Protected Material to the Producing Party or destroy 10 such material. As used in this subdivision, “all Protected Material” includes all copies, 11 abstracts, compilations, summaries, and any other format reproducing or capturing any of 12 the Protected Material. Whether the Protected Material is returned or destroyed, the 13 Receiving Party must submit a written certification to the Producing Party (and, if not the 14 same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 15 (by category, where appropriate) all the Protected Material that was returned or destroyed 16 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 17 compilations, summaries or any other format reproducing or capturing any of the 18 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 19 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 20 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 21 work product, and consultant and expert work product, even if such materials contain 22 Protected Material. Any such archival copies that contain or constitute Protected Material 23 remain subject to this Protective Order as set forth in Section 4 (DURATION). 24 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 25 /// 26 /// 27 /// /// 1 ECF CERTIFICATION 2 I, Ganette M. Genetti, certify that the content of this document (Stipulated 3 Protective Order) is acceptable to the undersigned counsel of record to affix my 4 electronic signature hereto. 5 DATED: December 11, 2025 GOODMAN NEUMAN HAMILTON LLP 6 7 By: /s/ Ganette M. Genetti 8 ZACHARY S. TOLSON GANETTE M. GENETTI 9 Attorneys for Defendant HOME DEPOT U.S.A., INC. 10 11 ECF CERTIFICATION 12 I, Jordan Ashley Duncan-Smith, certify that the content of this document 13 (Stipulated Protective Order) is acceptable to the undersigned counsel of record to 14 affix my electronic signature hereto. 15 DATED: December 11, 2025 DOWNTOWN LA LAW GROUP 16 17 By: /s/ Jordan Ashley Duncan-Smith 18 JORDAN ASHLEY DUNCAN-SMITH Attorneys for Plaintiff 19 SHAWN MCSPADDEN

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21 22 23 24 25 26 27 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 that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States District 6 Court for the Eastern District of California on [date] in the case of ___________ [insert 7 formal name of the case and the number and initials assigned to it by the court]. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order and I 9 understand and acknowledge that failure to so comply could expose me to sanctions and 10 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 11 manner any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Eastern District of California for the purpose of enforcing the terms of this Stipulated 15 Protective Order, even if such enforcement proceedings occur after termination of this 16 action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 1 2 3 4 5 6 ORDER 7 The Court has reviewed the Stipulated Protective Order filed by Plaintiff Shawn 8 McSpadden (“Plaintiff”) and Defendant Home Depot USA, Inc. (“Defendant”), 9 through their counsel of record, requesting that the Court enter an Order. 10 Having considered the above stipulation, and finding good cause, the Court 11 adopts the signed Stipulated Protective Order, (Doc. 19), subject to the following: 12 Exhibit A, lines 13-16: “I further agree to submit to the jurisdiction of the United 13 States District Court for the Eastern District of California for the purpose of enforcing the 14 terms of this Stipulated Protective Order, even if such enforcement proceedings occur after 15 termination of this action” is hereby struck and replaced with “I further agree to submit to 16 the jurisdiction of the United States District Court for the Eastern District of California for 17 the purpose of enforcing the terms of this Stipulated Protective Order, up to and until the 18 termination of this action.” 19 The parties are advised that pursuant to the Local Rules of the United States 20 District Court, Eastern District of California, any documents subject to the protective 21 order to be filed under seal must be accompanied by a written request which complies 22 with Local Rule 141 prior to sealing. The party making a request to file documents 23 under seal shall be required to show good cause for documents attached to a non- 24 dispositive motion or compelling reasons for documents attached to a dispositive 25 motion. Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2009). 26 Within five (5) days of any approved document filed under seal, the party shall file a 27 redacted copy of the sealed document. The redactions shall be narrowly tailored to protect only the information that 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 Dated: December 11, 2025 /s/ Barbara A. McAuliffe _ 6 UNITED STATES MAGISTRATE JUDGE

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