Richard Lyon (Cal. Bar No. 229288) 1 [email protected] 2 Jonas Jacobson (Cal Bar No. 269912) 3 [email protected] Simon Franzini (Cal. Bar No. 287631) 4 [email protected] 5 DOVEL & LUNER, LLP 201 Santa Monica Blvd., Suite 600 6 Santa Monica, California 90401 7 Telephone: (310) 656-7066 Facsimile: (310) 656-7069 8

9 Attorneys for Plaintiff 10

11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13

14 Josh Goldman, each individually and Case No. 2:25-cv-06582-DSF-AJR 15 on behalf of all others similarly situated, 16 [PROPOSED] STIPULATED 17 Plaintiff, PROTECTIVE ORDER

18 v. 19 V Shred, LLC., 20

21 Defendant. 22 23 24 25 26 27 28 1 Plaintiff Josh Goldman, LLC (“Plaintiff”), by and through its counsel of record 2 Dovel & Luner LLP, and Defendant V Shred, LLC (“Defendant”), by and through its 3 counsel of record, Procel Levine LLP, agree to adopt the Model Protective Order 4 appearing on the website of Honorable A. Joel Richlin, the terms of which are set forth 5 below. 6 1. GENERAL 7 1.1 Purposes and Limitations. Discovery in this action is likely to involve 8 production of confidential, proprietary, or private information for which special 9 protection from public disclosure and from use for any purpose other than prosecuting 10 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition 11 the Court to enter the following Stipulated Protective Order. The parties acknowledge 12 that this Order does not confer blanket protections on all disclosures or responses to 13 discovery and that the protection it affords from public disclosure and use extends only 14 to the limited information or items that are entitled to confidential treatment under the 15 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, 16 below, that this Stipulated Protective Order does not entitle them to file confidential 17 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 18 followed and the standards that will be applied when a party seeks permission from the 19 court to file material under seal. 20 1.2 Good Cause Statement. This action is likely to involve trade secrets, 21 customer and pricing lists and other valuable research, development, commercial, 22 financial, technical and/or proprietary information for which special protection from 23 public disclosure and from use for any purpose other than prosecution of this action is 24 warranted. Such confidential and proprietary materials and information consist of, 25 among other things, confidential business or financial information, information 26 regarding confidential business practices, or other confidential research, development, 27 or commercial information (including information implicating privacy rights of third 28 parties), information otherwise generally unavailable to the public, or which may be 1 privileged or otherwise protected from disclosure under state or federal statutes, court 2 rules, case decisions, or common law. Accordingly, to expedite the flow of information, 3 to facilitate the prompt resolution of disputes over confidentiality of discovery materials, 4 to adequately protect information the parties are entitled to keep confidential, to ensure 5 that the parties are permitted reasonable necessary uses of such material in preparation 6 for and in the conduct of trial, to address their handling at the end of the litigation, and 7 serve the ends of justice, a protective order for such information is justified in this matter. 8 It is the intent of the parties that information will not be designated as confidential for 9 tactical reasons and that nothing be so designated without a good faith belief that it has 10 been maintained in a confidential, non-public manner, and there is good cause why it 11 should not be part of the public record of this case. 12 2. DEFINITIONS 13 2.1 Action: this pending federal lawsuit. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 15 information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 17 it is generated, stored or maintained) or tangible things that qualify for protection under 18 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 19 Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless of 25 the medium or manner in which it is generated, stored, or maintained (including, among 26 other things, testimony, transcripts, and tangible things), that are produced or generated 27 in disclosures or responses to discovery in this matter. 28 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association, or 7 other legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 9 this Action but are retained to represent or advise a party to this Action and have 10 appeared in this Action on behalf of that party or are affiliated with a law firm that has 11 appeared on behalf of that party, including support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 16 Discovery Material in this Action. 17 2.13 Professional Vendors: persons or entities that provide litigation support 18 services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 20 their employees and subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is designated 22 as “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 24 from a Producing Party. 25 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only Protected 28 Material (as defined above), but also (1) any information copied or extracted from 1 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 2 Material; and (3) any testimony, conversations, or presentations by Parties or their 3 Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the trial 5 judge. This Order does not govern the use of Protected Material at trial. 6 7 4. DURATION 8 Once a case proceeds to trial, all of the court-filed information to be introduced 9 that was previously designated as confidential or maintained pursuant to this protective 10 order becomes public and will be presumptively available to all members of the public, 11 including the press, unless compelling reasons supported by specific factual findings to 12 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 13 City and Cty. of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good 14 cause” showing for sealing documents produced in discovery from “compelling reasons” 15 standard when merits-related documents are part of court record). Accordingly, the 16 terms of this protective order do not extend beyond the commencement of the trial. 17

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

11 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 Dated: December 24, 2025 Respectfully submitted, 14

15 By: /s/ Richard Lyon 16 Richard Lyon (Cal. Bar No. 229288) [email protected] 17 Jonas Jacobson (Cal. Bar No. 269912) 18 [email protected] Simon Franzini (Cal. Bar No. 287631) 19 [email protected] 20 DOVEL & LUNER, LLP 201 Santa Monica Blvd., Suite 600 21 Santa Monica, California 90401 22 Telephone: (310) 656-7066 23 Facsimile: (310) 656-7069 Attorneys for Plaintiff 24

25 By: /s/ Jeremiah Levine Brian Procel (Cal. Bar No. 218657) 26 [email protected] 27 Marty Pritikin (Cal. Bar No. 210845) [email protected] 28 1 Jeremiah Levine (Cal. Bar No. 288377) [email protected] - PROCEL LEVINE, LLP 3 401 Wilshire Blvd, Floor 12 Santa Monica, CA 90401-1456 4 Phone: (424) 788-4538 5 6 Attorneys for Defendant 4 8 ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 9 10 ||/DATED: 12/29/2025 HQN.A. JOEL RICHLIN 11 United States Magistrate Judge 12 13 14 15 16 17 18 19 20 21 22. 23 24 25 26 27 28 Protective Order 13 Case No. 2:25-cv-06582-DSF-AJR

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3

4 I, _____________________________ [full name], of _________________ [full 5 address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States District 7 Court for the Central District of California on ____________ [date] in the case of 8 ___________ [insert case name and number]. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28