1 || S. BRENT VOGEL Nevada Bar No. 006858 2 || Brent. [email protected] ETHAN M. FEATHERSTONE 3 || Nevada Bar No. 11566 [email protected] 4 || LEWIS BRISBOIS BISGAARD & SMITH LLP 6385 S. Rainbow Boulevard, Suite 600 5 || Las Vegas, Nevada 89118 Telephone: 702.893.3383 6 || Facsimile: 702.893.3789 Attorneys for Defendant 7 || Sweet Home Belmont, LLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 1] 12 || VALERIE SOTO, an individual, Case No. 2:22-cv-00632-BNW 13 Plaintiff, STIPULATION AND ORDER TO 14 VS. PROTECT CONFIDENTIAL MATERIALS AND INFORMATION 15 || INFINITY HOSPICE CARE, LLC, an Arizona limited liability company; NEVADA 16 || HOSPICE AND PALLIATIVE CARE, INC., a Nevada corporation; INFINITY HOSPICE 17 || CARE OF LAS VEGAS, LLC, a Nevada limited liability company; INFINITY 18 || HOSPICE CARE OF RENO, LLC, a Nevada limited liability company; SWEET HOME 19 || BELMONT, LLC, a Nevada limited liability company; DOES I-X; ROE CORPORATIONS 20 || AND/OR ENTITIES I-X, 21 Defendants. 22 IT IS HEREBY STIPULATED AND AGREED, by the undersigned attorneys for the 23 respective parties, that with regard to material disclosed in the course of the above-captioned lawsuit 24 (“Lawsuit”) which constitute or contain trade secrets or other confidential research, development, 25 or commercial information of the parties (“Confidential Material”), the following procedures shall 26 govern: 27 /// 7

] 1. This Order is meant to encompass all forms of disclosure which may contain 2 || Confidential Material, including any document, pleading, motion, exhibit, declaration, affidavit, 3 || deposition transcript, inspection and all other electronic and tangible items. 4 2. The parties may designate any Confidential Material produced or filed in this 5 || Lawsuit as confidential and subject to the terms of this Order by marking such materials 6 || “Confidential.” If any material has multiple pages, this designation need only be placed on the first 7 || page of such material. Any material designated as “Confidential” shall not be disclosed to any 8 || person or entity, except: 9 a. The parties in this matter; 10 b. Counsel for any named party in this matter and their employees and/or staff; 11 c. the Court, jury, and court personnel, including court reporters and 12 |} stenographers and/or videographers employed in connection with this suit; 13 d. experts or consultants retained or employed in good faith to assist any party 14 || in the evaluation, prosecution or defense of this suit; 15 e. any witness or deponent who is asked at his or her deposition or at trial to 16 || testify about documents designated as Confidential Material or the contents thereof, who only may 17 || be shown Confidential Material and may not retain any Confidential Material or copies thereof; 18 f. outside photocopying services engaged by a party or its counsel to assist in 19 || this litigation; 20 g. special masters, arbitrators, mediators, and/or settlement conference judges 21 || and their respective staff; 22 h. the author, addressees, and recipients of the document; 23 i. outside data processing companies or individuals engaged by a party or its 24 || counsel to assist in this litigation; 25 J: any person who authored or properly received in the ordinary course of 26 || business the particular information sought to be disclosed; and 27 k. any other individual that is agreed upon by both parties. 28 || ///

1 3. Any material designated as confidential pursuant to paragraph 2 above shall be used 2 || solely for the purposes of this Lawsuit and for no other purpose. 3 4. Prior to disclosure of any Confidential Material, each person to whom disclosure is 4 || to be made shall execute a written “Confidentiality Agreement” (in the form attached as Ex. A 5 || hereto) consenting to be bound by the terms of this Order. The parties, counsel for the respective 6 || parties (including legal assistants and other personnel) and their retained experts are deemed to be 7 || bound by this Order and are not required to execute a Confidentiality Agreement. 8 5. Only counsel of record in this Lawsuit shall be permitted to disseminate Confidential 9 || Material. Upon dissemination of any Confidential Material, each non-designating counsel of record 10 || in this Lawsuit shall maintain a written record as to: (1) the identity of any person given Confidential 11 || Material, and (2) the identity of the Confidential Material so disseminated (such as by “Bates stamp” 12 |} number). Such record shall be made available to the designating party upon request. 13 6. If additional persons become parties to this Lawsuit, they shall not have access to 14 || any Confidential Material until they execute and file with the Court their written agreement to be 15 || bound by the terms of this Order. 16 7. In the event that any question is asked at a deposition that calls for the disclosure of 17 || Confidential Material, the witness shall answer such question (unless otherwise instructed not to do 18 || so on grounds of privilege) provided that the only persons in attendance at the deposition are persons 19 || who are qualified to receive such information pursuant to this Order. Deposition testimony may be 20 || designated as confidential following the testimony having been given provided that: (1) such 21 || testimony is identified and designated on the record at the deposition, or (2) non-designating counsel 22 | is notified of the designation in writing within thirty days after receipt by the designating party of 23 || the respective deposition transcript. All deposition transcripts in their entirety shall be treated in the 24 interim as “Confidential” pursuant to paragraph 2 above. When Confidential Material is 25 || incorporated in a deposition transcript, the party designating such information confidential shall 26 || make arrangements with the court reporter not to disclose any information except in accordance 27 || with the terms of this Order. 28 || ///

1 8. If a deponent refuses to execute a Confidentiality Agreement, disclosure of 2 || Confidential Material during the deposition shall not constitute a waiver of confidentiality. Under 3 || such circumstances, the witness shall sign the original deposition transcript in the presence of the 4 || court reporter and no copy of the transcript or exhibits shall be given to the deponent. 5 9. Ifa party wishes to attach Confidential Material to a non-dispositive motion or other 6 || filing (excluding dispositive motions) with the Court, then that party will notify the designating 7 || party of its intent to attach the Confidential Material to the filing in writing at least three (3) days 8 || before filing. Alternatively, the party wishing to attach Confidential Material to a non-dispositive 9 || motion or other filing (excluding dispositive motions) with the Court can submit without notification 10 || of the designating party as long the filing is submitted with a request to file under seal pursuant to 11 || applicable rules. 12 10. ‘If any party makes inadvertent disclosure of any document or information that is 13 || subject to an objection on the basis of privilege or the attorney work product doctrine, the disclosure 14 || will not be deemed to waive that party's claim to its privileged or protected nature or estop that party 15 || or privilege holder from designating the information or document as privileged or subject to the 16 || attorney work product doctrine. Any party receiving any such information or documents shall return 17 || the information or documents and any copies of the same upon written request from the producing 18 || party. Upon receiving such a request as to specific information or documents, the receiving party 19 || shall return the information or documents and any copies of the same to the producing party within 20 || five (5) business days, regardless of whether the receiving party agrees with the claim of privilege 21 || and/or work-product protection. If the information or document is disclosed by the non-producing 22 || party to a third party in accordance with the provisions of this Order prior to the designation as 23 || subject to privilege and/or the attorney work product doctrine, the party that inadvertently disclosed 24 || the document or information is not deemed to waive its claim to the privileged or protected nature 25 || and is not estopped from designating the information or document as privileged and/or subject to 26 || the attorney work product doctrine. Furthermore, the non-producing party must send a request in 27 || writing to the third party to whom the document or information was disclosed no later than five (5) 28 || days after a request for return of the documents or information and any copies of the same from the

1 || producing party, requesting that the third party to whom it was produced return the information or 2 || documents and any copies of the same to the non-producing party. Upon receipt of the documents 3 || or information and any copies of the same from the third party, the non-producing party must return 4 || the documents and/or information and any copies of the same to the producing party within five (5) 5 || days of the non-producing party's receipt of the same from the third party. As outlined in paragraph 6 || 15 below, nothing in this Order prevents the parties from challenging any assertion of privilege. 7 11.‘ Ifa party wishes to submit into the written record of this case any document marked 8 || "CONFIDENTIAL" or "SUBJECT TO PROTECTIVE ORDER" or excerpts from any such 9 || document, that party shall seek to submit the document under seal. 10 12. Papers filed with the Court under seal shall be accompanied by a motion for leave to 11 || file those documents under seal addressing the specific reasons for filing these documents under 12 || seal pursuant to Kamakana v. City of Cnty. Of Honolulu,

(9th Cir. 2006), and shall 13 || be filed in accordance with the Court's electronic filing procedures. If papers are filed under seal 14 || pursuant to prior Court order, the papers shall bear the following notation on the first page, directly 15 |] under the case number: "FILED UNDER SEAL PURSUANT TO COURT ORDER DATED 16 || INSERT DATE]." All papers filed under seal will remain sealed until such time as the Court may 17 || deny the motion to seal or enter an order to unseal them, or the documents are unsealed pursuant to 18 || Local Rule. Notwithstanding the foregoing in this paragraph, if allowed by the Court, a party may 19 || submit documents designated as Confidential to the department in camera in lieu of filing the 20 || documents under seal. 21 13. Ifanon-designating party is subpoenaed or ordered to produce Confidential Material 22 || by another court or administrative agency, such party shall promptly notify the designating party of 23 || the pending subpoena or order and shall not produce any Confidential Material until the designating 24 || party has had reasonable time to object or otherwise take appropriate steps to protect such 25 || Confidential Material. 26 14. ‘If a party believes that any Confidential Material does not contain confidential 27 || information, it may contest the applicability of this Order to such information by notifying the 28 || designating party’s counsel in writing and identifying the information contested. The parties shall

] || have thirty days after such notice to meet and confer and attempt to resolve the issue. If the dispute 2 || is not resolved within such period, the party seeking the protection shall have fourteen (14) days in 3 || which to make a motion for a protective order with respect to contested information. Information 4 || that is subject to a dispute as to whether it is properly designated shall be treated as designated in 5 || accordance with the provisions of this Order until the Court issues a ruling. 6 15. Inadvertent failure to designate any material “Confidential” shall not constitute a 7 || waiver of an otherwise valid claim of confidentiality pursuant to this Order, so long as a claim of 8 || confidentiality is asserted within fifteen days after discovery of the inadvertent failure. At such time, 9 || arrangements shall be made by the parties to designate the material “Confidential” in accordance 10 || with this Order. 11 16. This Order shall be without prejudice to the right of any party to oppose production 12 || of any information or object to its admissibility into evidence. 13 17. When any counsel of record in this Lawsuit or any attorney who has executed a 14 || Confidentiality Agreement becomes aware of any violation of this Order, or of facts constituting 15 || good cause to believe that a violation of this Order may have occurred, such attorney shall report 16 || that there may have been a violation of this Order to the Court and all counsel of record. 17 18. Within thirty days after the termination of this Lawsuit (whether by dismissal or final 18 || judgment) and at request of the designating party, all Confidential Material (including all copies) 19 || shall be returned to counsel for the designating party or individuals and/or counsel in possession can 20 || certify as to the destruction of all Confidential Material in writing within fourteen (14) days of the 21 || request. Notwithstanding this provision, Counsel for each party shall be entitled to retain archival 22 || copy of all pleadings, motions, trial documents and exhibits, deposition transcripts, videos and 23 || exhibits, hearing transcripts, legal memorandum, correspondence and work product, expert reports, 24 || and consultant or expert work product, provided that the material is handled in accordance with the 25 || terms of this Agreement. 26 || /// 27 | /// 28 || ///

1 □□□ After the termination of this Lawsuit, the provisions of this Order shall continue to 2 || be binding and this Court shall retain jurisdiction over the parties and any other person who has 3 || access to documents and information produced pursuant to this Order for the sole purpose of 4 || enforcement of its provisions. 6 || DATED this 4" day of February, 2025. DATED this 4" day of February, 2025. 7|\| LEWIS BRISBOIS BISGAARD & SMITH PAUL PADDA LAW, PLLC LLP g || □□□ Ethan M. Featherstone /s/ Eric Larsen S. BRENT VOGEL ERIC LARSEN 10 || Nevada Bar No. 006858 Nevada Bar No. 009423 ETHAN M. FEATHERSTONE 4560 S. Decatur Blvd., Suite 300 Nevada Bar No. 11566 Las Vegas, Nevada 89103 12 || 6385 S. Rainbow Boulevard, Suite 600 Tel. (702) 366-1888 Las Vegas, Nevada 89118 [email protected] 13 || Tel. 702.893.3383 Brent. [email protected] Attorneys for Plaintiff 14 [email protected] 15 Attorneys for Defendant 16 || Sweet Home Belmont, LLC 17 18 IT IS SO ORDERED: 19 20 la WOE, 21 UNITED STATES MAGISTRATE JUDGE DATED: February 5, 2025 23 24 25 26 27 7

1 EXHIBIT A 2 CONFIDENTIALITY AGREEMENT 3 I, , affirm that I have read the foregoing Stipulation and 4 || Order to Protect Confidential Materials and Information entered in Valerie Soto vs. Sweet Home 5 || Belmont, Case No. 2:22-cv-00632-BNW (“Protective Order”), currently pending before the United 6 || States District Court of Nevada (“District Court”), governing the documents produced by the parties 7 || in this case. I have read the Protective Order governing documents produced by the parties in this 8 || case. I understand its terms and agree to be bound by the terms of the Protective Order. I understand 9 || that my duties under the Protective Order will survive the termination of this case and that failure 10 || to comply with its terms may result in the District Court imposing sanctions on me. I consent to 11 |} personal jurisdiction of the District Court for the purpose of enforcing the Protective Order. 12 I hereby affirm under the pains and penalties of perjury under the law of the State of Nevada 13 || that the foregoing is true and correct to the best of my knowledge and belief. 14 DATED this day of , 2025. 15 16 17 Signature 18 19 20 Printed Name 21 22 23 24 25 26 27