Krista J. Nielson (Nevada Bar No. 10698) TIFFANY & BOSCO 2 10100 W. CHARLESTON BLVD., STE. 220 3 || LAS VEGAS, NEVADA 89135 TELEPHONE: (702) 258-8200 4 || FACSIMILE: (702) 258-8787 [email protected] 5 [Additional Counsel Listed on Signature Block] 6 Attorneys for Plaintiffs 7 8 9 IN THE UNITED STATES DISTRICT COURT 10 FOR THE DISTRICT OF NEVADA 11 || STEVEN RAYMOND, KYONG ‘GINA’ Case No. 2:23-cv-01195-CDS-MDC RAYMOND, and CHASE HYON 12 individually and on behalf of all persons PROPOSED JOINT STIPULATED similarly situated, PROTECTIVE ORDER 13 Plaintiffs, 14 15 Vv. 16 || ZACH CONINE, in his official capacity as NEVADA STATE TREASURER & 17 || ADMINISTRATOR OF THE NEVADA UNCLAIMED PROPERTY PROGRAM, 18 ||NEVADA STATE TREASURER’S 19 OFFICE, and DANIELLE ANTHONY, in her official capacity as DEPUTY 20 TREASURER OF UNCLAIMED PROPERTY, NEVADA STATE 21 || TREASURER’S OFFICE, 22 Defendants. 23 Plaintiffs and Defendants (jointly “Parties” and individual a “Party”) in the above 24 captioned matter (the “Litigation’’) stipulate to entry of a protective order (the “Joint 25 || Stipulated Protective Order” or “Protective Order”) pursuant to Fed. R. Civ. P. 26(c) and 26 || L.R. 26-6. The Parties met and conferred on October 23, 2025, and in doing so created 27 ||this Joint Stipulated Protective Order. The Parties each assert that they possess 28

1 information relating to the subject matter of this Litigation that is confidential and 2 proprietary, the Parties recognize that in the course of discovery it may be necessary for 3 the Parties or non-parties to disclose to another Party certain confidential and proprietary 4 information and, in connection with such disclosure, each Party wishes to ensure that the 5 information asserted as confidential and proprietary shall not be made public or otherwise 6 disseminated by another Party. 7 Accordingly, the Parties have agreed to the following Protective Order: 8 1. This Protective Order shall apply to all documents, materials, and information, 9 including without limitation, documents produced, answers to interrogatories, responses 10 to requests for admission, deposition testimony, and other information disclosed pursuant 11 to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 12 2. As used herein, “Confidential Information” shall be information that is confidential 13 and implicates the privacy rights of the Parties and non-parties, including but not limited 14 to: medical and personal financial information, private personnel information, trade 15 secrets, other proprietary information, and information deemed confidential or otherwise 16 protected from public disclosure under the Nevada Revised Statutes and/or Nevada 17 Administrative Code. Confidential Information shall not be disclosed or used for any 18 purpose except the preparation and trial of this case. 19 3. Confidential documents, materials, and/or information (collectively, “Confidential 20 Information”) shall not, without the consent of the designating Party or further Order of 21 the Court, be disclosed except that such information may be disclosed to: 22 a. attorneys actively working on this Litigation and persons regularly employed 23 or associated with said attorneys whose assistance is required by said 24 attorneys in the preparation for trial, at trial, or at other proceedings in this 25 Litigation; 26 b. the Parties, including their designated representatives and counsel; 27 1 c. expert witnesses and consultants retained in connection with this Litigation to 2 whom disclosure is reasonably necessary for this Litigation; 3 d. the Court and its employees (“Court Personnel”) and the jury at trial; 4 e. stenographic and video reporters who are engaged in proceedings necessarily 5 incident to the conduct of this Litigation; 6 f. deponents, witnesses, or potential witnesses; 7 g. anyone as otherwise required by law; and 8 h. other persons by written agreement of the Parties 9 4. Prior to disclosing any Confidential Information to any person identified in sub- 10 paragraph 3(c) (expert witnesses and consultants) or sub-paragraph 3(f) (deponents, 11 witnesses, or potential witnesses), counsel shall provide such person with a copy of this 12 Protective Order an obtain from such person a written acknowledgment, substantially in 13 the form at Appendix A, stating that he or she has read this Protective Order and agrees to 14 be bound by its provisions. 15 5. Documents are designated as Confidential by placing or affixing on them (in a 16 manner that will not interfere with their legibility) the following or other appropriate 17 notice: “CONFIDENTIAL.” Documents which contain additionally sensitive information 18 may also be designated as “ATTORNEYS’ EYES ONLY” by providing similar notice. 19 6. Whenever a deposition involves the disclosure of Confidential Information, the 20 deposition or portions thereof shall be designated as Confidential and shall be subject to 21 the provisions of this Protective Order. A Party may designate portions of depositions as 22 Confidential after transcription, provided written notice of the designation is promptly 23 given to all counsel of record within thirty days after notice by the court reporter of the 24 completion of the transcript. All testimony shall be treated as Confidential Information 25 until the thirty-day period has expired. 26 7. A Party may object to the designation of particular Confidential Information by 27 giving written notice to the Party designating the disputed information. The written notice 1 shall identify the information to which the objection is made and the basis for that 2 objection. Pursuant to L.R. 26-6(c), the Parties shall meet and confer in “good faith” in 3 accordance with L.R. I.A. 1-3(f). If the Parties cannot resolve the discovery dispute after 4 a good-faith effort, the Parties shall jointly contact Chambers pursuant to the discovery 5 dispute procedures in accordance with Standing Order & Chambers Practices of United 6 States Magistrate Judge Maximiliano D. Couvillier III § 2(b) (D. Nev. June 2, 2025). The 7 disputed information shall be treated as Confidential under the terms of this Protective 8 Order until the Court issues a ruling on the dispute. The Party designating the information 9 as Confidential shall bear the burden of establishing that good cause exists for the disputed 10 information to be treated as Confidential. 11 8. Unless other arrangements are agreed upon in writing by the Parties, within thirty 12 days of the final determination of this Litigation, each person or Party who has received 13 Confidential Information shall be obligated to return the Confidential Information, 14 including any copies, to the designating Party, or the receiving Party may elect to destroy 15 the Confidential Information, including any copies, and certify that it has been destroyed. 16 The receiving Party, however, need not destroy or return (a) any Confidential Information 17 that it is required by law to maintain or (b) one archival copy of all deposition transcripts 18 and all materials filed with the Court, regardless of whether such materials (including 19 exhibits and appendices) contain or refer to Confidential Information. The receiving Party 20 also need not destroy their work product that may contain Confidential Information. 21 9. The termination of this Litigation shall not relieve counsel or other persons 22 obligated hereunder from their responsibility to maintain the confidentiality of 23 Confidential Information pursuant to this Protective Order. The Court will retain 24 jurisdiction of enforcing this Protective Order once the case is closed. 25 10. Any request to restrict public access to materials designated as Confidential 26 pursuant to this Protective Order must comply with the requirements of the local rules of 27 this Court. 1 11. This Protective Order may be modified by the Court at any time for good cause 2 shown following notice to all Parties and an opportunity for them to be heard. 3 || ITISSO ORDERED: The parties’ proposed Protective Order at ECF No. 76 is 4 DENIED without prejudice. IT IS ORDERED that the parties file by December 16, 2025, a revised proposed order that addresses filing documents marked 5 || confidential in accordance with LR IA 10-5 and FRCP 5.2, and the substantive 6 standards of Kamakana v. City & Cnty. of Honolulu,

(9th Cir. 2006) and its progeny. The parties are also strongly encouraged to address the use of 7 || Artificial Intelligence ("AI") in their protective order. In particular, the parties may want to include protocols addressing the type of permissible AI systems (e.g., 8 |] closed AI system v. open AI system) and any limitations relative to using AI tools 9 || for processing discovery materials that contain personal-data identifiers, 10 confidential material, trade secrets, or similar. 4 7 ‘7D □ 12 . (fe J” 13 Mt \ United StateyMagistrate Jug Jugeé Maximiliané’D. Couvillier III 14 LZ Uf Dated: “12-3-25 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE DISTRICT OF NEVADA 4 STEVEN RAYMOND, KYONG ‘GINA’ Case No. 2:23-cv-01195-CDS-MDC 5 RAYMOND, and CHASE HYON individually and on behalf of all persons APPENDIX A TO JOINT, STIPULATED 6 similarly situated, PROTECTIVE ORDER

7 Plaintiffs, 8

v.

9 ZACH CONINE, in his official capacity as 10 NEVADA STATE TREASURER & ADMINISTRATOR OF THE NEVADA 11 UNCLAIMED PROPERTY PROGRAM, 12 NEVADA STATE TREASURER’S OFFICE, and DANIELLE ANTHONY, in 13 her official capacity as DEPUTY TREASURER OF UNCLAIMED 14 PROPERTY, NEVADA STATE TREASURER’S OFFICE, 15 Defendants. 16

17 AGREEMENT CONCERNING CONFIDENTIALITY 18 1. I have read the Protective Order entered in the above-captioned 19 Litigation and understand its terms. 20 2. I agree to be bound by the terms of the Protective Order. I agree to use the 21 information provided to me only as explicitly permitted by the Protective Order. 22 3. I understand that my failure to abide by the terms of this Protective Order will 23 subject me, without limitation, to civil and criminal penalties for contempt of Court. 24 4. I submit to the jurisdiction of this Court solely for the purpose of enforcing the 25 terms of the Protective Order and freely and knowingly waive any right I may 26 otherwise have to object to the jurisdiction of this Court. 27 1 Dated: ______________________, 20__ 2 Signed: ____________________________ 3 IT IS SO STIPULATED. 4 5 /s/ Laura C. Fellows AARON D. FORD 6 Attorney General Laura C. Fellows (pro hac vice)

7 PAUL LLP By: /s/ Kyle J. Hoyt 600 Broadway Boulevard, Suite 600 Jessica E. Whelan (Bar No. 14781) 8 Kansas City, Missouri 64105 Chief Deputy Solicitor General 9 Phone: (816) 984-8100 K S y e le n i J o . r H D o e y p t u ( t B y a A r t N to o r . n 1 e 4 y 8 G 86 e ) n eral Fax: (816) 984-8101 1 State of Nevada Way, Suite 100 10 [email protected] Las Vegas, NV 89119 Phone: (702) 486-3420 11 Fax: (702) 486-3773 [email protected] 12 COUNSEL FOR PLAINTIFFS [email protected]

13 Attorneys for Zach Conine, Danielle 14 Anthony and Nevada State 15 Treasurer’s Office 16

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