1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 NANCY LOPEZ, Case No.: 2:25-cv-06056 SSC 5 Plaintiff, 6 STIPULATED PROTECTIVE 7 v. ORDER1

8 TRANSWORLD SYSTEMS INC., 9 10 Defendant. 11

12 13 1. INTRODUCTION 14 1.1 Purposes and Limitations. Discovery in this action is likely to 15 involve production of confidential, proprietary, or private information for 16 which special protection from public disclosure and from use for any 17 purpose other than prosecuting this litigation may be warranted. 18 Accordingly, the parties hereby stipulate to and petition the court to 19 enter the following Stipulated Protective Order. The parties 20 acknowledge that this Order does not confer blanket protections on all 21 disclosures or responses to discovery and that the protection it affords 22 from public disclosure and use extends only to the limited information or 23 items that are entitled to confidential treatment under the applicable 24 legal principles. 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 1.2 Good Cause Statement. 2 This action is likely to involve private, confidential, proprietary, 3 and/or commercially-sensitive information for which special protection 4 from public disclosure and from use for any purpose other than 5 prosecution of this action is warranted. Such confidential and 6 proprietary materials and information consist of, among other things, 7 private financial, credit, and personal identifying information, as well as 8 confidential business, financial, and/or contractual information, 9 information regarding confidential business practices, or other 10 confidential research, development, or commercial information (including 11 information implicating privacy rights of third parties), information 12 otherwise generally unavailable to the public, or which may be privileged 13 or otherwise protected from disclosure under state or federal statutes, 14 court rules, case decisions, or common law. Accordingly, to expedite the 15 flow of information, to facilitate the prompt resolution of disputes over 16 confidentiality of discovery materials, to adequately protect information 17 the parties are entitled to keep confidential, to ensure that the parties 18 are permitted reasonable necessary uses of such material in preparation 19 for and in the conduct of trial, to address their handling at the end of the 20 litigation, and serve the ends of justice, a protective order for such 21 22 information is justified in this matter. It is the intent of the parties that 23 information will not be designated as confidential for tactical reasons 24 and that nothing be so designated without a good faith belief that it has 25 been maintained in a confidential, non-public manner, and there is good 26 cause why it should not be part of the public record of this case. 27 1.3 Acknowledgment of Procedure for Filing Under Seal. The 1 Stipulated Protective Order does not entitle them to file confidential 2 information under seal; Local Rule 79-5 sets forth the procedures that 3 must be followed and the standards that will be applied when a party 4 seeks permission from the court to file material under seal. 5 There is a strong presumption that the public has a right of access 6 to judicial proceedings and records in civil cases. In connection with 7 non-dispositive motions, good cause must be shown to support a filing 8 under seal. See Kamakana v. City and Cnty. of Honolulu,

(9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 10 Corp.,

, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 11 Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 12 protective orders require good cause showing), and a specific showing of 13 good cause or compelling reasons with proper evidentiary support and 14 legal justification, must be made with respect to Protected Material that 15 a party seeks to file under seal. The parties’ mere designation of 16 Disclosure or Discovery Material as CONFIDENTIAL does not— 17 without the submission of competent evidence by declaration, 18 establishing that the material sought to be filed under seal qualifies as 19 confidential, privileged, or otherwise protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion 21 22 or trial, then compelling reasons, not only good cause, for the sealing 23 must be shown, and the relief sought shall be narrowly tailored to serve 24 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 25

, 677–79 (9th Cir. 2010). For each item or type of 26 information, document, or thing sought to be filed or introduced under 27 seal in connection with a dispositive motion or trial, the party seeking 1 facts and legal justification, for the requested sealing order. Again, 2 competent evidence supporting the application to file documents under 3 seal must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise 5 protectable in its entirety will not be filed under seal if the confidential 6 portions can be redacted. If documents can be redacted, then a redacted 7 version for public viewing, omitting only the confidential, privileged, or 8 otherwise protectable portions of the document, shall be filed. Any 9 application that seeks to file documents under seal in their entirety 10 should include an explanation of why redaction is not feasible. 11

12 2. DEFINITIONS 13 2.1 Action: Katie Nancy Lopez v. Transworld Systems Inc., Case 14 No. 2:25-cv-06056. 15 2.2 Challenging Party: a Party or Non-Party that challenges the 16 designation of information or items under this Order. 17 18 2.3 “CONFIDENTIAL” Information or Items: information 19 (regardless of how it is generated, stored or maintained) or tangible 20 things that qualify for protection under Rule 26(c) of the Federal Rules of 21 Civil Procedure, and as specified above in the Good Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as 23 well as their support staff). 24 2.5 Designating Party: a Party or Non-Party that designates 25 information or items that it produces in disclosures or in responses to 26 discovery as “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, 1 regardless of the medium or manner in which it is generated, stored, or 2 maintained (including, among other things, testimony, transcripts, and 3 tangible things), that are produced or generated in disclosures or 4 responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in 6 a matter pertinent to the litigation who has been retained by a Party or 7 its counsel to serve as an expert witness or as a consultant in this Action. 8 2.8 Final Disposition: the later of (1) dismissal of all claims and 9 defenses in this Action, with or without prejudice; and (2) final judgment 10 herein after the completion and exhaustion of all appeals, rehearings, 11 remands, trials, or reviews of this Action, including the time limits for 12 filing any motions or applications for extension of time pursuant to 13 applicable law. 14 2.9 In-House Counsel: attorneys who are employees of a party to 15 this Action. In-House Counsel does not include Outside Counsel of 16 Record or any other outside counsel. 17 2.10 Non-Party: any natural person, partnership, corporation, 18 association, or other legal entity not named as a Party to this action. 19 2.11 Outside Counsel of Record: attorneys who are not employees 20 of a party to this Action but are retained to represent or advise a party to 21 22 this Action and have appeared in this Action on behalf of that party or 23 are affiliated with a law firm which has appeared on behalf of that party, 24 and includes support staff. 25 2.12 Party: any party to this Action, including all of its officers, 26 directors, employees, consultants, retained experts, and Outside Counsel 27 of Record (and their support staffs). 1 Disclosure or Discovery Material in this Action. 2 2.14 Professional Vendors: persons or entities that provide 3 litigation- support services (e.g., photocopying, videotaping, translating, 4 preparing exhibits or demonstrations, and organizing, storing, or 5 retrieving data in any form or medium) and their employees and 6 subcontractors. 7 2.15 Protected Material: any Disclosure or Discovery Material that 8 is designated as “CONFIDENTIAL.” 9 2.16 Receiving Party: a Party that receives Disclosure or Discovery 10 Material from a Producing Party. 11

12 3. SCOPE 13 The protections conferred by this Stipulation and Order cover not 14 only Protected Material (as defined above), but also (1) any information 15 copied or extracted from Protected Material; (2) all copies, excerpts, 16 summaries, or compilations of Protected Material; and (3) any 17 18 testimony, conversations, or presentations by Parties or their Counsel 19 that might reveal Protected Material. 20 Any use of Protected Material at trial shall be governed by the 21 orders of the trial judge. This Stipulated Protective Order does not 22 govern the use of Protected Material at trial. 23 24 4. TRIAL AND DURATION 25 The terms of this Stipulated Protective Order apply through Final 26 Disposition of the Action. 27 1 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 2 Order and used or introduced as an exhibit at trial becomes public and 3 will be presumptively available to all members of the public, including 4 the press, unless compelling reasons supported by specific factual 5 findings to proceed otherwise are made to the trial judge in advance of 6 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 7 cause” showing for sealing documents produced in discovery from 8 “compelling reasons” standard when merits-related documents are part 9 of court record). Accordingly, for such materials, the terms of this 10 Stipulated Protective Order do not extend beyond the commencement of 11 the trial. 12 Even after Final Disposition of this litigation, the confidentiality 13 obligations imposed by this Stipulated Protective Order shall remain in 14 effect until a Designating Party agrees otherwise in writing or a court 15 order otherwise directs. 16

17 5. DESIGNATING PROTECTED MATERIAL 18 19 5.1 Exercise of Restraint and Care in Designating Material for 20 Protection. Each Party or Non-Party that designates information or 21 items for protection under this Order must take care to limit any such 22 designation to specific material that qualifies under the appropriate 23 standards. The Designating Party must designate for protection only 24 those parts of material, documents, items, or oral or written 25 communications that qualify so that other portions of the material, 26 documents, items, or communications for which protection is not 27 warranted are not swept unjustifiably within the ambit of this Order. 1 Mass, indiscriminate, or routinized designations are prohibited. 2 Designations that are shown to be clearly unjustified or that have been 3 made for an improper purpose (e.g., to unnecessarily encumber the case 4 development process or to impose unnecessary expenses and burdens on 5 other parties) may expose the Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or 7 items that it designated for protection do not qualify for protection, that 8 Designating Party must promptly notify all other Parties that it is 9 withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise 11 provided in this Stipulated Protective Order (see, e.g., second paragraph 12 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 13 or Discovery Material that qualifies for protection under this Stipulated 14 Protective Order must be clearly so designated before the material is 15 disclosed or produced. 16 Designation in conformity with this Stipulated Protective Order 17 18 requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or 21 trial proceedings), that the Producing Party affix at a minimum, the 22 legend “CONFIDENTIAL” to each page that contains protected 23 material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify 25 the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 A Party or Non-Party that makes original documents available for 1 inspection need not designate them for protection until after the 2 inspecting Party has indicated which documents it would like copied 3 and produced. During the inspection and before the designation, all of 4 the material made available for inspection shall be deemed 5 CONFIDENTIAL. After the inspecting Party has identified the 6 documents it wants copied and produced, the Producing Party must 7 determine which documents, or portions thereof, qualify for protection 8 under this Stipulated Protective Order. Then, before producing the 9 specified documents, the Producing Party must affix the 10 “CONFIDENTIAL” legend to each page that contains Protected 11 Material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify 13 the protected portion(s) (e.g., by making appropriate markings in the 14 margins). 15 (b) for testimony given in depositions that the Designating Party 16 identify the Disclosure or Discovery Material either on the record, or 17 within 30 days of the Designating Party’s receipt of the certified 18 transcript of the deposition from the court reporter preparing the 19 transcript. 20 (c) for information produced in some form other than 21 22 documentary and for any other tangible items, that the Producing Party 23 affix in a prominent place on the exterior of the container or containers 24 in which the information is stored the “CONFIDENTIAL” legend. If only 25 a portion or portions of the information warrants protection, the 26 Producing Party, to the extent practicable, shall identify the protected 27 portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an 2 inadvertent failure to designate qualified information or items does not, 3 standing alone, waive the Designating Party’s right to secure protection 4 under this Order for such material. Upon timely correction of a 5 designation, the Receiving Party must make reasonable efforts to assure 6 that the material is treated in accordance with the provisions of this 7 Stipulated Protective Order. 8

9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may 11 challenge a designation of confidentiality at any time that is consistent 12 with the court’s Scheduling Order. 13 6.2 Meet and Confer. The Challenging Party shall initiate the 14 dispute resolution process under Local Rule 37.1 et seq. and with 15 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 16 Discovery Motion Conference.”2 17 18 6.3 The burden of persuasion in any such challenge proceeding 19 shall be on the Designating Party. Frivolous challenges, and those 20 made for an improper purpose (e.g., to harass or impose unnecessary 21 expenses and burdens on other parties) may expose the Challenging 22 Party to sanctions. Unless the Designating Party has waived or 23 withdrawn the confidentiality designation, all parties shall continue to 24 afford the material in question the level of protection to which it is 25 entitled under the Producing Party’s designation until the court rules on 26

27 2 Judge Christensen’s Procedures are available at 1 the challenge. 2 3 7. ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected 5 Material that is disclosed or produced by another Party or by a Non- 6 Party in connection with this Action only for prosecuting, defending, or 7 attempting to settle this Action. Such Protected Material may be 8 disclosed only to the categories of persons and under the conditions 9 described in this Order. When the Action reaches a Final Disposition, a 10 Receiving Party must comply with the provisions of section 13 below. 11 Protected Material must be stored and maintained by a Receiving 12 Party at a location and in a secure manner that ensures that access is 13 limited to the persons authorized under this Stipulated Protective 14 Order. 15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 16 17 Unless otherwise ordered by the court or permitted in writing by the 18 Designating Party, a Receiving Party may disclose any information or 19 item designated “CONFIDENTIAL” only: 20 (a) to the Receiving Party’s Outside Counsel of Record in this 21 Action, as well as employees of said Outside Counsel of Record to whom 22 it is reasonably necessary to disclose the information for this Action; 23 (b) to the officers, directors, and employees (including House 24 Counsel) of the Receiving Party to whom disclosure is reasonably 25 necessary for this Action; 26 (c) to Experts (as defined in this Order) of the Receiving Party to 27 whom disclosure is reasonably necessary for this Action and who have 1 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (d) to the court and its personnel; 3 (e) to court reporters and their staff; 4 (f) to professional jury or trial consultants, mock jurors, and 5 Professional Vendors to whom disclosure is reasonably necessary for 6 this Action and who have signed the “Acknowledgment and Agreement 7 to Be Bound” (Exhibit A); 8 (g) to the author or recipient of a document containing the 9 information or a custodian or other person who otherwise possessed or 10 knew the information; 11 (h) during their depositions, to witnesses, and attorneys for 12 witnesses, in the Action to whom disclosure is reasonably necessary, 13 provided: (1) the deposing party requests that the witness sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 15 witness will not be permitted to keep any confidential information 16 unless they sign the “Acknowledgment and Agreement to Be Bound” 17 (Exhibit A), unless otherwise agreed by the Designating Party or 18 ordered by the court. Pages of transcribed deposition testimony or 19 exhibits to depositions that reveal Protected Material may be separately 20 bound by the court reporter and may not be disclosed to anyone except 21 22 as permitted under this Stipulated Protective Order; and 23 (i) to any mediator or settlement officer, and their supporting 24 personnel, mutually agreed upon by any of the parties engaged in 25 settlement discussions. 26 27 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 1 PRODUCED IN OTHER LITIGATION 2 If a Party is served with a subpoena or a court order issued in 3 other litigation that compels disclosure of any information or items 4 designated in this Action as “CONFIDENTIAL,” that Party must: 5 (a) promptly notify in writing the Designating Party. Such 6 notification shall include a copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the 8 subpoena or order to issue in the other litigation that some or all of the 9 material covered by the subpoena or order is subject to this Protective 10 Order. Such notification shall include a copy of this Stipulated 11 Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to 13 14 be pursued by the Designating Party whose Protected Material may be 15 affected. 16 If the Designating Party timely seeks a protective order, the 17 Party served with the subpoena or court order shall not produce any 18 information designated in this action as “CONFIDENTIAL” before a 19 determination by the court from which the subpoena or order issued, 20 unless the Party has obtained the Designating Party’s permission. The 21 Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these 23 provisions should be construed as authorizing or encouraging a 24 Receiving Party in this Action to disobey a lawful directive from another 25 court. 26

27 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 1 PRODUCED IN THIS LITIGATION 2 9.1 Application. The terms of this Stipulated Protective Order 3 are applicable to information produced by a Non-Party in this Action and 4 designated as “CONFIDENTIAL.” Such information produced by Non- 5 Parties in connection with this litigation is protected by the remedies 6 and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional 8 protections. 9 9.2 Notification. In the event that a Party is required, by a valid 10 discovery request, to produce a Non-Party’s confidential information in 11 its possession, and the Party is subject to an agreement with the Non- 12 Party not to produce the Non-Party’s confidential information, then the 13 Party shall: 14 (a) promptly notify in writing the Requesting Party and the 15 Non-Party that some or all of the information requested is subject to a 16 confidentiality agreement with a Non-Party; 17 (b) make the information requested available for inspection by 18 the Non-Party, if requested. 19 9.3 Conditions of Production. If the Non-Party fails to seek a 20 protective order from this court within 14 days of receiving the notice 21 22 and accompanying information, the Receiving Party may produce the 23 Non-Party’s confidential information responsive to the discovery request. 24 If the Non-Party timely seeks a protective order, the Receiving Party 25 shall not produce any information in its possession or control that is 26 subject to the confidentiality agreement with the Non-Party before a 27 determination by the court. Absent a court order to the contrary, the 1 this court of its Protected Material. 2 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 4 MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it 6 has disclosed Protected Material to any person or in any circumstance 7 not authorized under this Stipulated Protective Order, the Receiving 8 Party must immediately (a) notify in writing the Designating Party of 9 the unauthorized disclosures, (b) use its best efforts to retrieve all 10 unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of 12 this Order, and (d) request such person or persons to execute the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 14

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

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

8 9 DATED: December 19, 2025 10 STEPHANIE S. CHRISTENSEN United States Magistrate Judge

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the 8 case of __________ Nancy Lopez v. Transworld Systems Inc., 9 United States District Court for the Central District of 10 California, Case No. 2:25-cv-06056. I agree to comply with and to 11 be bound by all the terms of this Stipulated Protective Order and I 12 understand and acknowledge that failure to so comply could expose me 13 14 to sanctions and punishment in the nature of contempt. I solemnly 15 promise that I will not disclose in any manner any information or item 16 that is subject to this Stipulated Protective Order to any person or 17 entity except in strict compliance with the provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such 21 enforcement proceedings occur after termination of this action. I 22 hereby appoint ________________________ [print or type full name] 23 of _________ [print or type full address and telephone number] as 24 my California agent for service of process in connection with this action 25 or any proceedings related to enforcement of this Stipulated Protective 26 Order. 27 1 Date: ___________________________ 2 City and State where sworn and ___________________________ 3 signed: 4 Printed name: ___________________________ 5 Signature: ___________________________ 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27