Trina Hayes v. Wal-Mart Associates, Inc. et al

Filing 17

STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION by Magistrate Judge Patricia Donahue re Stipulation for Protective Order #16 . (see document for details.) (et)

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1 Seung Yang CA Bar No. 249857 seung.yang@thesentinelfirm.com 2 Brett M. Gunther CA Bar No. 306448 brett.gunther@thesentinelfirm.com 3 Emily Rivadeneira CA Bar No. 354395 emily.rivadeneira@thesentinelfirm.com 4 THE SENTINEL FIRM, APC 355 S. Grand Ave., Suite 1450 5 Los Angeles, CA 90071 Telephone: 213-985-1150 213-985-2155 6 Facsimile: 7 Attorneys for Plaintiff 8 TRINA HAYES James T. Conley CA Bar No. 224174 9 james.conley@ogletree.com Michele J. Bongiovanni Bar No. 309884 10 michele.bongiovanni@ogletree.com Sandra Benlevy Bar No. 211568 11 sandra.benlevy@ogletree.com OGLETREE, DEAKINS, NASH, 12 SMOAK & STEWART, P.C. 400 Capitol Mall, Suite 2800 13 Sacramento, CA 95814 Telephone: 916-840-3150 916-840-3159 14 Facsimile: 15 Attorneys for Defendant 16 WAL-MART ASSOCIATES, INC. UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 19 20 21 22 TRINA HAYES, Case No. 5:24-cv-01856-JLS-PD Plaintiff, v. WAL-MART ASSOCIATES, INC., a 23 corporation; and DOES 1-25, inclusive, 24 STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; [PROPOSED] ORDER Defendant. 25 26 27 28 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 IT IS HEREBY STIPULATED by and between Plaintiff TRINA HAYES 2 (“Plaintiff”) and Defendant WAL-MART ASSOCIATES, INC., (“Defendant”) 3 (collectively, “the Parties”), through their respective attorneys of record, that a 4 Protective Order be entered by this Court as follows: 1. 5 This Stipulation and Protective Order shall apply to the production and 6 exchange of all document requests and documents, interrogatories and answers to 7 interrogatories, depositions, request for admissions and responses to requests for 8 admissions, exhibits, pleadings, admission of evidence at trial, and all other 9 information exchanged and furnished in this action by the Parties that are confidential 10 and/or proprietary. 2. 11 The Parties acknowledge that discovery will require disclosure of 12 information that is private, personal, privileged, confidential, proprietary, or 13 nonpublic. As a result, the Parties agree that they will be required to enter this 14 Stipulation and Protective Order (hereinafter “Order”) on the following terms to 15 ensure the continuing confidentiality of materials designated as Confidential Material 16 in this litigation. Confidential Material, as used in this Order, shall refer to any 17 document or item designated as “Confidential” or “Highly Confidential – Attorneys’ 18 Eyes Only”. The Parties understand that this Order does not confer blanket protections 19 on all disclosures or responses to discovery and that the protection it affords extends 20 only to the limited information or items that are entitled under the applicable legal 21 principles to treatment as confidential. Nothing in this Order shall require any party to 22 produce any specific document or category of documents which a party deems 23 inappropriate for production. 24 I. 25 26 27 28 Definitions of Confidential Material 3. Confidential Material, as used in this Order, consists of the following materials and categories of materials: (a) Materials relating to any privileged, confidential, or nonpublic information, including, but not limited to, trade secrets, research, design, 1 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 64132503.v1-OGLETREE 1 development, financial, technical, marketing, planning, personal, or commercial 2 information, as such terms are used in the Federal Rules of Civil Procedure and 3 any applicable case law interpreting Federal Rule of Civil Procedure 4 26(c)(1)(G), contracts, non-public compilations of retail prices; proprietary 5 information, vendor agreements; personnel files; claim/litigation information; 6 nonpublic policies and procedures; medical records; employment offers; 7 competitive analyses, income statements; client or customer information; 8 financial records and statements; vendor agreements, along with other 9 proprietary or confidential information. (b) 10 Materials containing corporate trade secrets, nonpublic research 11 and development data, including, but not limited to, cost data, pricing formulas, 12 inventory management programs, and other sales or business information 13 known to the public; information obtained from a non-party pursuant to a non- 14 disclosure agreement; and customer-related Protected Data shall be deemed 15 “Highly Confidential – Attorneys’ Eyes Only”. (c) 16 “Protected Data” shall refer to any information that a party believes 17 in good faith to be subject to federal, state or foreign data protection laws or 18 other privacy obligations. Examples of such data protection laws include but are 19 not limited to The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq. (financial 20 information); and, The Health Insurance Portability and Accountability Act and 21 the regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164 22 (medical information). Certain Protected Data may compel alternative or 23 additional protections beyond those afforded “Highly Confidential – Attorneys’ 24 Eyes Only” material, in which event the Parties shall meet and confer in good 25 faith, and, if unsuccessful, shall move the Court for appropriate relief. 26 4. 27 28 The Parties shall not designate as confidential information that is already public knowledge. 2 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 5. 1 The Parties agree that such Confidential Material as described in 2 paragraph 3 above, should be given the protection of an order of this Court to prevent 3 injury through disclosure to persons other than those persons involved in the 4 prosecution or defense of this litigation. A Protective Order will serve to achieve the 5 following: expedite the flow of information, facilitate the prompt resolution of disputes 6 over confidentiality of discovery materials, adequately protect information the Parties 7 are entitled to keep confidential, ensure that the Parties are permitted reasonable 8 necessary uses of such material in preparation for and in the conduct of trial, and 9 address their handling at the end of the litigation. 10 11 II. Procedure for Designating Information as Confidential 6. To designate information as confidential, the producing party shall mark 12 Confidential Material with the legend “CONFIDENTIAL” or “HIGHLY 13 CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. Parties shall submit confidential 14 discovery responses, such as answers to interrogatories or answers to requests for 15 admissions, in a separate document stamped with the appropriate legend designating 16 those responses as Confidential Material. The Receiving Party may make copies of 17 Confidential Material and such copies shall become subject to the same protections as 18 the Confidential Material from which those copies were made. 19 (a) Information on a disk or other electronic format (e.g., a native 20 format production) may be designated confidential by marking the storage 21 medium itself (or the native file’s title) with the legend “CONFIDENTIAL” or 22 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. The Receiving 23 Party shall mark any hard-copy printouts and the storage medium of any 24 permissible copies of such electronic material with the corresponding legend 25 contained on the original and such copies shall become subject to the same 26 protections, as the Confidential Material from which those copies were made. 27 (b) Information disclosed at any deposition of a party taken in this 28 action may be designated by the party as confidential by indicating on the record 3 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 at the deposition that the information is confidential and subject to the 2 provisions of this Order. Alternatively, the party may designate information 3 disclosed at the deposition as confidential by notifying the court reporter and 4 other parties in writing, within fifteen (15) business days of receipt of the 5 transcript, of the specific pages and lines of the transcript which are designated 6 as confidential. The Parties may agree to a reasonable extension of the 15- 7 business-day period for designation. Designations of transcripts will apply to 8 audio, video, or other recordings of the testimony. During such 15-business- 9 day period, the entire transcript shall receive confidential treatment. Upon such 10 designation, the court reporter and each party shall affix the 11 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 12 ONLY” legend to the designated pages and segregate them as appropriate. 13 7. A producing party may change the confidentiality designation of 14 materials it has produced, as follows: (1) The producing party must give the receiving 15 parties notice of the change by identifying the documents or information at issue. Once 16 notice is given, the receiving party must make good-faith efforts to ensure that the 17 documents or information are accorded treatment under the new designation. (2) 18 Within a reasonable period after giving notice, the producing party must reproduce the 19 documents or information in a format that contains the new designation. (3) If such 20 information has been disclosed to persons not qualified pursuant to paragraph(s) (14- 21 15) below, the party who disclosed such information shall (a) take reasonable efforts 22 to retrieve previously disclosed Confidential Material; (b) advise such persons that the 23 material is Confidential; and (c) give the producing party written assurance that steps 24 (a) and (b) have been completed. 25 III. 26 Data Security 8. The Parties agree to provide adequate security to protect data produced 27 by the other party(ies) or by non-parties. This includes secure data storage systems, 28 established security policies, and security training for employees, contractors and 4 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 experts. Adequate security also includes such measures as data encryption in transit, 2 data encryption at rest, data access controls, and physical security, whether 3 hosted/outsourced to a vendor or on premises. At a minimum, any receiving party 4 subject to the terms of this Order, will provide reasonable measures to protect non- 5 client data consistent with the American Bar Association Standing Committee on 6 Ethics and Professional Responsibility, Formal Opinion 477R. 7 IV. 8 Clawback Provisions 9. The production of privileged or work-product protected documents, 9 electronically stored information (ESI) or information, whether inadvertent or 10 otherwise, is not a waiver of the privilege or protection from discovery in this case or 11 in any other federal or state proceeding. 12 10. This Order shall be interpreted to provide the maximum protection 13 allowed by Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and 14 granted full faith and credit in all other state and federal proceedings by 28 U.S. Code 15 § 1738. In the event of any subsequent conflict of law, the law that is most protective 16 of privilege and work product shall apply. 17 11. Nothing contained herein is intended to or shall serve to limit a party’s 18 right to conduct a review of documents, ESI or information (including metadata) for 19 relevance, responsiveness and/or segregation of privileged and/or protected 20 information before production. 21 12. If the receiving party has reason to believe that a produced document or 22 other information may reasonably be subject to a claim of privilege, then the receiving 23 party shall immediately sequester the document or information, cease using the 24 document or information and cease using any work product containing the 25 information, and shall inform the producing party of the beginning BATES number of 26 the document or, if no BATES number is available, shall otherwise inform the 27 producing party of the information. 28 5 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 13. 1 A producing party must give written notice to any receiving party 2 asserting a claim of privilege, work-product protection, or other ground for reclaiming 3 documents or information (a “clawback request”). 4 received, the receiving party shall immediately sequester the document (if not already 5 sequestered) and shall not review or use that document, or any work product 6 containing information taken from that document, for any purpose. The Parties shall 7 meet and confer regarding any clawback request. 8 V. 9 After a clawback request is Who May Receive Confidential and Highly Confidential Information 14. Confidential Material. Any Confidential Material and the information 10 contained therein shall be disclosed only to the Court, its staff, in-house counsel and 11 outside counsel of record for each party, and also shall be disclosed on a need-to-know 12 basis only to the Parties, counsel’s staff personnel, employees of a party to whom 13 disclosure is necessary in connection with the preparation for and trial of this action, 14 and any witnesses in the case (including consulting and testifying experts) as may from 15 time to time reasonably be necessary in prosecution or defense of this action. 16 15. Highly Confidential—Attorneys’ Eyes Only Material. Material and 17 information designated as “Highly Confidential—Attorneys’ Eyes Only” shall only be 18 disclosed to the Court, its staff, in-house and outside counsel of record for each party, 19 the secretarial, clerical, and paralegal staff of each, and consulting and testifying 20 experts retained by a party in this action. 21 16. Restriction on Disclosure to Direct Competitors. Notwithstanding the 22 foregoing, Confidential Material shall not be disclosed to any current or former 23 employees of, or current or former consultants, advisors, or agents of, a direct 24 competitor of any party named in the litigation. If a Receiving Party is in doubt about 25 whether a particular entity is a direct competitor of a party named in this lawsuit, then 26 before disclosing any Confidential Material to a current or former employee, 27 consultant, advisor, or agent of that entity, the Receiving Party’s counsel must confer 28 with counsel for the Producing Party. 6 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 17. 1 Persons Receiving Confidential Information Must Sign Exhibit A. 2 Counsel for each party shall advise all persons to whom Confidential Material is 3 disclosed pursuant to this Order of the existence of this Order and shall provide all 4 such persons (other than the Court and its staff) with a copy of this Order. Counsel 5 shall also require such persons to execute the Affidavit attached as Exhibit A, prior to 6 the disclosure of Confidential Material. 18. 7 Duties in the Event of Unauthorized Disclosures. It shall be the 8 obligation of counsel, upon learning of any unauthorized disclosure or threatened 9 unauthorized disclosure of Confidential Information, or any other breach or threatened 10 breach of the provisions of this Order, to promptly notify counsel for the Producing 11 Party. 12 circumstances of the disclosure in order to permit the producing party to understand 13 and take appropriate steps. Each party and its counsel agree to take reasonable and 14 good-faith efforts to contain or limit any breach promptly upon receiving notice of it, 15 and to make reasonable and good-faith attempts to retrieve any unauthorized 16 disclosure of documents or information. This provision does not limit the producing 17 party’s entitlement to damages resulting from any breach of this Order. 18 VI. Authorized Uses of Confidential Material 19. 19 20 The notification shall be supplemented with reasonable details of the Confidential Material shall only be used for the purpose of litigating the above-captioned lawsuit and may not be used in other lawsuits. 20. 21 Persons having knowledge of Confidential Material and information due 22 to their participation in the conduct of this litigation shall use such knowledge and 23 information only as 24 permitted herein, and shall not disclose such Confidential Material, their contents or 25 any portion or summary thereof to any person(s) not involved in the conduct of this 26 litigation. 27 /// 28 /// 7 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 21. 1 If any person having access to the Confidential Material herein shall 2 violate this Order, he/she may be subject to sanctions by the Court and may be liable 3 to pay for the damages caused by his/her violation. 4 VII. Challenges to the Designation of Confidential Material 22. 5 Any party or interested member of the public may move the Court to 6 modify the designation of any documents or information produced in this litigation 7 (either to include additional protection with respect to confidentiality or to remove a 8 confidential designation). Before making such a motion, the party or an interested 9 member of the public shall first attempt to resolve such dispute with the producing 10 party’s counsel. Pending resolution of any challenges to the designation of documents 11 or information, the material at issue shall continue to be treated as Confidential 12 Material until ordered otherwise by the Court. The burden shall be on the party 13 seeking to modify the designation to show that the producing party’s designation is 14 inappropriate. 15 VIII. Withholding of Information 23. 16 Redactions. The Parties may redact (1) information that is privileged or 17 protected from discovery as work product or by reason of any other applicable 18 privilege or immunity; (2) information subject to non-disclosure obligations imposed 19 by governmental authorities, law or regulation (e.g., protected personal information); 20 and (3) sensitive, non-relevant information, including but not limited to personally 21 identifiable information, trade secrets, or information regarding products, data, or 22 people. Redactions of emails will not redact the names of recipients or the subject line 23 of the emails, unless the subject line is itself privileged or contains the sensitive 24 information described above, in which case only so much of the subject line will be 25 redacted as may be needed. The Parties will produce redacted documents in TIFF 26 format (or searchable PDF if production format dictates; or in native format for file 27 types that do not convert well to TIFF/PDF, such as Excel files) with corresponding 28 /// 8 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 searchable OCR text and the associated metadata for the document, ensuring the 2 redacted content is fully protected from disclosure. 3 IX. 4 Confidential Material In Filings, Hearings, and Trial 24. Confidential Material in Filings. Without written permission from the 5 Producing Party or court order secured after appropriate notice to all interested 6 persons, a party may not file Confidential Material in the public record in this action 7 (or in any other action, such as an appeal). A party that seeks to file under seal any 8 Confidential Material must first comply with Judge Staton’s General Procedures and 9 in compliance with Central District of California Local Rule 79-5. Confidential 10 Material may only be filed under seal in a manner prescribed by the Court for such 11 filings. 12 25. Manner of Sealing. In the event Confidential Materials or portions of 13 transcripts are sealed as confidential by the Court or as described in paragraph (25) 14 above, they shall be filed in an envelope bearing the following designation when 15 deposited: 16 CONFIDENTIAL 17 IN ACCORDANCE WITH THE CONFIDENTIALITY 18 ORDER OF THE COURT, THE CONTENTS OF THIS 19 ENVELOPE SHALL BE TREATED AS CONFIDENTIAL 20 AND MUST NOT BE SHOWN TO A PERSON OTHER 21 THAN THE COURT, ATTORNEYS IN THIS CASE, OR 22 TO PERSONS ASSISTING THOSE ATTORNEYS. 23 26. Confidential Material in Hearings and Trial. The provisions of this 24 Order shall not affect, and this Order does not limit, the admissibility of Confidential 25 Material (or references to that material) as evidence at trial, or during a hearing or 26 similar proceeding in this action. Prior to using Confidential Material or the 27 information contained therein at any hearing that is open to the public, the party 28 seeking to use the Confidential Material must give at least seven (7) days advance 9 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 notice to the producing party of the intent to use the Confidential Material so that the 2 producing party may seek an appropriate Court Order to protect the Confidential 3 Material. 4 X. Continuing Effect of this Order and Duty to Destroy 27. 5 This Order shall continue to be binding throughout and after the 6 conclusion of this litigation, including all appeals. Within thirty (30) days of settlement 7 or final adjudication, including the expiration or exhaustion of all rights to appeal or 8 petitions for extraordinary writs, each party or non-party to whom any materials were 9 produced shall, without further request or direction from the Producing Party, 10 promptly destroy all documents, items or data received including, but not limited to, 11 copies or summaries thereof, in the possession or control of any expert or employee. 12 This requirement to destroy includes all documents, not only those documents 13 designated as Confidential Material. The Receiving Party shall submit a written 14 certification to the Producing Party by the 30-day deadline that (1) confirms the 15 destruction/deletion of all Confidential Material, including any copies of Confidential 16 Materials provided to persons required to execute Exhibit A (Affidavit), and (2) 17 affirms the Receiving Party has not retained any copies, abstracts, compilations, 18 summaries or any other format reproducing or capturing any of the Confidential 19 Material. Notwithstanding this provision, outside counsel is entitled to retain an 20 archival copy of filings, depositions, and deposition exhibits. 21 XI. 22 Procedure if Confidential Material is Required to be Produced 28. If any person receiving documents covered by this Order is served with a 23 subpoena, order, interrogatory, document, or civil investigative demand (collectively, 24 a “Demand”) issued in any other action, investigation, or proceeding, and such 25 Demand seeks material that was produced or designated as Confidential Material by 26 someone other than the Receiving Party, the Receiving Party shall give prompt written 27 notice by hand or electronic transmission within five (5) business days of receipt of 28 such Demand to the party or non-party who produced or designated the material as 10 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 Confidential Material, and shall object to the production of such materials on the 2 grounds of the existence of this Order. At the request of the party or non-party who 3 produced or designated the material as Confidential Material, the Receiving Party shall 4 refuse to comply with the Demand unless (a) ordered to do so by a court with 5 jurisdiction over the Receiving Party; or (b) released in writing by the party or non- 6 party who designated the material as Confidential Material. The burden of opposing 7 the enforcement of the Demand shall fall upon the party or non-party who produced 8 or designated the material as Confidential Material. Compliance by the Receiving 9 Party with any order of a court of competent jurisdiction, directing production of any 10 Confidential Material, shall not constitute a violation of this Order. 11 XII. Application of this Order to Productions by Third Parties 12 29. This Order may be used by third parties producing documents in 13 connection with this action. Third parties may designate information as “Confidential” 14 or “Highly Confidential – Attorneys’ Eyes Only”. 15 30. If a third party produces (or intends to produce) documents and does not 16 designate (or does not intend to designate) those documents as Confidential Material, 17 then any party to this action may seek to designate that third party’s documents or 18 categories of documents as Confidential Material. In that case, it will be the burden 19 of the party seeking protected status to move for a court order designating the materials 20 as Confidential Material after the Parties confer. 21 31. In the event additional parties join or intervene in this litigation, the newly 22 joined party(ies) shall not have access to Confidential Material until its/their counsel 23 has executed and, at the request of any party, filed with the Court the agreement of 24 such party(ies) and such counsel to be fully bound by this Order. 25 32. The Parties agree that nothing in this Order shall be deemed to limit the 26 extent to which counsel for the Parties may advise or represent their respective clients, 27 conduct discovery, prepare for trial, present proof at trial, including any document 28 designated Confidential Material as set forth herein, or oppose the production or 11 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 2 admissibility of any information or documents which have been requested. 33. This Order shall remain in full force and effect until such time as it is 3 modified, amended, or rescinded by the Court. 4 XIII. No Admissions 5 34. Neither entering into this Stipulation for Protective Order, nor receiving 6 any documents or other information designated as “Confidential,” shall be construed 7 as an agreement or admission (1) that any document or information designated as 8 “Confidential” is in fact Confidential Information; (2) as to the correctness or truth of 9 any allegation made or position taken relative to any matter designated as 10 “Confidential”; or (3) as to the authenticity, competency, relevancy, or materiality of 11 any information or document designated as “Confidential.” 12 XIV. Modification – Further Agreements 13 35. Nothing contained herein shall preclude any party from seeking from the 14 Court, modification of this Stipulated Protective Order upon proper notice or shall 15 preclude the Parties from entering into other written agreements designed to protect 16 Confidential Information. 17 XV. Counterparts 18 36. This Stipulation for Protective Order may be executed in counterparts, 19 each of which shall be deemed an original, and which together shall constitute one 20 instrument. 21 22 23 24 25 26 27 28 12 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 2 DATED: October 23, 2024 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 3 4 By: /s/ James T. Conley James T. Conley Michele J. Bongiovanni Sandra Benlevy Attorneys for Defendant WAL-MART ASSOCIATES, INC. 5 6 7 8 9 DATED: October 23, 2024 THE SENTINEL FIRM, APC 10 11 By: /s/ Brett M. Gunther Sueng Yang Brett M. Gunther Emily Rivadeneira Attorneys for Plaintiff TRINA HAYES 12 13 14 15 16 17 ATTESTATION – L.R. 5-4.3.4 18 I attest that all other signatories listed on this signature page, and on whose 19 behalf the filing is submitted, concur in the filing’s content and have authorized the 20 filing. 21 22 23 Date: October 23, 2024 By: /s/ James T. Conley James T. Conley 24 25 26 27 28 13 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER ORDER 1 2 The Court has reviewed the Stipulation Regarding Production of Confidential 3 Documents and Proprietary Information filed by Defendant WAL-MART 4 ASSOCIATES, INC., (“Defendant”) and Plaintiff TRINA HAYES (“Plaintiff”) 5 (collectively, “the Parties”), through their counsel of record, requesting that the Court 6 enter an Order. 7 IT IS SO ORDERED. 8 9 DATED: _October 24, 2024 10 11 12 The Honorable Patricia Donahue USDC, Central District of California 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER 1 Exhibit A 2 ACKNOWLEDGMENT OF RECEIPT OF PROTECTIVE ORDER 3 REGARDING CONFIDENTIAL INFORMATION AND AGREEMENT TO 4 BE BOUND THEREBY 5 I hereby acknowledge receipt of and that I have read a copy of the Stipulation 6 for Protective Order and Order (the “Order”), which I understand was made on 7 _________________, 2024, in the action entitled Trina Hayes v. Wal-Mart Associates, 8 Inc., United States District Court Central District of California, Case No. 5:24-cv- 9 01856-JLS-PD. I agree that I will be bound by the provisions of the Order with respect 10 to any Confidential Information provided to me under the terms thereof. I agree that, 11 if I receive any Confidential Information, I will not make any copies thereof nor 12 disclose such Confidential Information except as permitted by the Order. I further 13 understand that if I fail to comply with the terms of the Order, I may be subject to 14 sanctions by the Court, and I hereby consent to personal jurisdiction in the State of 15 California with respect to any matter relating to or arising out of the Order. 16 17 Executed this _____day of ________, 2024, at __________________, _____. City State 18 _____________________________ Signature 19 20 21 22 Name: 23 Affiliation: ________________________________________ Address: ________________________________________ 24 25 26 ________________________________________ ________________________________________ 27 28 15 Case No. 5:24-cv-01856-JLS-PD STIPULATION REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND PROPRIETARY INFORMATION; ORDER

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