A&A Global Imports, LLC v. Lerman Container Corp.

• Court: District Court, C.D. California
• Decided: October 9, 2025
• Docket: 2:25-cv-06321
• Status: Unknown

Opinion

1 Mitchell S. Feller (Admitted pro hac) Colin W. Fraser (SBN CA 266867) 2 msfeller@grr.com frasercw@gtlaw.com Jason R. Wachter (Admitted pro hac) GREENBERG TRAURIG, LLP 3 Patrick B. Monahan (Admitted pro hac) 18565 Jamboree Road, Suite 500 4 pmonahan@grr.com Irvine, California 92612 GOTTLIEB, RACKMAN & REISMAN Tel: 949.732.6500 Fax: 949.732.6501 5 P.C. Bethany Rabe (SBN CA 270682) 6 270 Madison Ave., Suite 1403 rabeb@gtlaw.com New York, New York 10016 GREENBERG TRAURIG, LLP 7 Telephone: (212) 684-3900 10845 Griffith Peak Drive, Suite 600 8 Facsimile: (212) 684-3999 Las Vegas, Nevada 89135 Jason H. Wilson (Bar No. 140269) Tel: 702.792.3773 Fax: 702.792.9002 9 jwilson@willenken.com Jacob G. Horton (Admitted pro hac 10 Ashley L. Kirk (Bar No. 291012) jhorton@blanchard-patent.com akirk@willenken.com BLANCHARD HORTON, PLLC 11 WILLENKEN LLP 40 New York Avenue 12 707 Wilshire Blvd., Suite 4100 Post Office Box 567 Los Angeles, California 90017 Oakridge, Tennessee 37831 13 Telephone: (213) 955-9240 Tel: 865.369.2673 14 Facsimile: (213) 955-9250 Attorneys for Defendant and Counter-Plaintiff 15 Attorneys for Plaintiff and A&A GLOBAL IMPORTS, LLC 16 Counter-Defendant LERMAN CONTAINER CORP. 17

18 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 19

20 LERMAN CONTAINER CORP., CASE NO. 2:25-cv-06321-JFW-RAOx Plaintiff and Counterclaim Defendant, 21 v. Assigned to Hon. John F. Walter A&A GLOBAL IMPORTS, LLC, Mag. Judge: Hon. Rozella A. Oliver 22 Defendant and Counterclaim Plaintiff. STIPULATED PROTECTIVE 23 ORDER1 Complaint Filed: July 10, 2025 24 Trial Date: Feb. 23, 2027

25 26 27 1 This Stipulated Protective Order is substantially based on the model protective 28 1 Plaintiff and Counterclaim Defendant Lerman Container Corp., (“Plaintiff” 2 or “eBottles”) and Defendant and Counterclaim Plaintiff A&A Global Imports 3 4 (“Defendant” or “A&A”) by and through their undersigned counsel, hereby 5 stipulate to the following Protective Order: 6 1. A. PURPOSES AND LIMITATIONS 7 8 Discovery in this action is likely to involve production of confidential, 9 proprietary or private information for which special protection from public 10 disclosure and from use for any purpose other than prosecuting this litigation may 11 12 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 13 enter the following Stipulated Protective Order. The parties acknowledge that this 14 Order does not confer blanket protections on all disclosures or responses to 15 16 discovery and that the protection it affords from public disclosure and use extends 17 only to the limited information or items that are entitled to confidential treatment 18 under the applicable legal principles. 19 20 B. GOOD CAUSE STATEMENT 21 This action is likely to involve trade secrets, customer and pricing lists and 22 other valuable research, development, commercial, financial, technical and/or 23 24 proprietary information for which special protection from public disclosure and 25 from use for any purpose other than prosecution of this action is warranted. Such 26 confidential and proprietary materials and information consist of, among other 27 28 1 things, confidential business or financial information, information regarding 2 confidential business practices, or other confidential research, development, or 3 4 commercial information (including information implicating privacy rights of third 5 parties), information otherwise generally unavailable to the public, or which may 6 be privileged or otherwise protected from disclosure under state or federal statutes, 7 8 court rules, case decisions, or common law. Accordingly, to expedite the flow of 9 information, to facilitate the prompt resolution of disputes over confidentiality of 10 discovery materials, to adequately protect information the parties are entitled to 11 12 keep confidential, to ensure that the parties are permitted reasonable necessary uses 13 of such material in preparation for and in the conduct of trial, to address their 14 handling at the end of the litigation, and serve the ends of justice, a protective order 15 16 for such information is justified in this matter. It is the intent of the parties that 17 information will not be designated as confidential for tactical reasons and that 18 nothing be so designated without a good faith belief that it has been maintained in 19 20 a confidential, non-public manner, and there is good cause why it should not be 21 part of the public record of this case. 22 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 23 24 UNDER SEAL 25 The parties further acknowledge, as set forth in Section 14.3, below, that this 26 Stipulated Protective Order does not entitle them to file confidential information 27 28 1 under seal; Local Civil Rule 79-5 and Section 9 of Judge John F. Walter’s Standing 2 Order dated July 29, 2025 sets forth the procedures that must be followed and the 3 4 standards that will be applied when a party seeks permission from the court to file 5 material under seal. 6 There is a strong presumption that the public has a right of access to judicial 7 8 proceedings and records in civil cases. In connection with non-dispositive 9 motions, good cause must be shown to support a filing under seal. See Kamakana 10 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. 11 12 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. 13 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 14 protective orders require good cause showing), and a specific showing of good 15 16 cause or compelling reasons with proper evidentiary support and legal justification, 17 must be made with respect to Protected Material that a party seeks to file under 18 seal. The parties’ mere designation of Disclosure or Discovery Material as 19 20 CONFIDENTIAL does not—without the submission of competent evidence by 21 declaration, establishing that the material sought to be filed under seal qualifies as 22 confidential, privileged, or otherwise protectable—constitute good cause. 23 24 Further, if a party requests sealing related to a dispositive motion or trial, 25 then compelling reasons, not only good cause, for the sealing must be shown, and 26 the relief sought shall be narrowly tailored to serve the specific interest to be 27 28 1 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2 2010). For each item or type of information, document, or thing sought to be filed 3 4 or introduced under seal in connection with a dispositive motion or trial, the party 5 seeking protection must articulate compelling reasons, supported by specific facts 6 and legal justification, for the requested sealing order. Again, competent evidence 7 8 supporting the application to file documents under seal must be provided by 9 declaration. 10 Any document that is not confidential, privileged, or otherwise protectable 11 12 in its entirety will not be filed under seal if the confidential portions can be 13 redacted. If documents can be redacted, then a redacted version for public 14 viewing, omitting only the confidential, privileged, or otherwise protectable 15 16 portions of the document shall be filed. Any application that seeks to file 17 documents under seal in their entirety should include an explanation of why 18 redaction is not feasible. 19 20 2. DEFINITIONS 21 2.1 Action: This pending federal lawsuit 22 2.2 Challenging Party: a Party or Non-Party that challenges the 23 24 designation of information or items under this Order. 25 2.3a “CONFIDENTIAL” Information or Items: information (regardless of 26 how it is generated, stored or maintained) or tangible things that qualify for 27 28 1 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 2 the Good Cause Statement. 3 4 2.3b “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” 5 Information or Items: Information that contains or discloses information that the 6 Designating Party, in good faith, believes to be extremely commercially sensitive 7 8 or would provide a competitive advantage to competitors or compromise or 9 jeopardize the Designating Party’s business interests if disclosed. 10 2.4 Counsel: Outside Counsel of Record and In-House Counsel (as well 11 12 as their support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 17 ONLY” 18 2.6 Disclosure or Discovery Material: all items or information, regardless 19 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things) that are produced 22 or generated in disclosures or responses to discovery in this matter. 23 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve 26 as an expert witness or as a consultant in this Action. 27 28 1 2.8 In-House Counsel: attorneys who are employees of a party to this 2 Action. In-House Counsel does not include Outside Counsel of Record or any 3 4 other outside counsel. 5 2.9 Non-Party: any natural person, partnership, corporation, association or 6 other legal entity not named as a Party to this action. 7 8 2.10 Outside Counsel of Record: attorneys who are not employees of a 9 party to this Action but are retained to represent 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 11 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 16 support staffs). 17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 18 Discovery Material in this Action. 19 20 2.13 Professional Vendors: persons or entities that provide litigation 21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 24 and their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 27 28 1 ATTORNEY’S EYES ONLY.” 2 2.15 Receiving Party: a Party that receives Disclosure or Discovery 3 4 Material from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 12 presentations by Parties or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 trial judge and other applicable authorities. This Order does not govern the use of 15 16 Protected Material at trial. 17 4. DURATION 18 Even after final disposition of this Action, the confidentiality obligations 19 20 imposed by this Order shall remain in effect until a Designating Party agrees 21 otherwise in writing or a court order otherwise directs. Final disposition shall be 22 deemed to be (1) dismissal of all claims and defenses in this Action, with or 23 24 without prejudice; or (2) final judgment herein after the completion and exhaustion 25 of all appeals, rehearings, remands, trials, or reviews of this Action, including the 26 time limits for filing any motions or applications for extension of time pursuant to 27 28 1 applicable law. 2 Notwithstanding these requirements, the confidentiality obligations imposed 3 4 by this Order shall not apply to designated information used or introduced as an 5 exhibit at trial if such exhibit becomes public and is not sealed in accordance with 6 applicable requirements and procedures. 7 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection 11 12 under this Order must take care to limit any such designation to specific material 13 that qualifies under the appropriate standards. The Designating Party must 14 designate for protection only those parts of material, documents, items or oral or 15 16 written communications that qualify so that other portions of the material, 17 documents, items or communications for which protection is not warranted are not 18 swept unjustifiably within the ambit of this Order. 19 20 Mass, indiscriminate or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to 23 24 impose unnecessary expenses and burdens on other parties) may expose the 25 Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 28 1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection 7 8 under this Order must be clearly so designated before the material is disclosed or 9 produced. 10 Designation in conformity with this Order requires: 11 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 17 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains 18 protected material. If only a portion of the material on a page qualifies for 19 20 protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 28 1 deemed “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” After the 2 inspecting Party has identified the documents it wants copied and produced, the 3 4 Producing Party must determine which documents, or portions thereof, qualify for 5 protection under this Order. Then, before producing the specified documents, the 6 Producing Party must affix the appropriate CONFIDENTIAL legend to each page 7 8 that contains Protected Material. If only a portion of the material on a page 9 qualifies for protection, the Producing Party also must clearly identify the 10 protected portion(s) (e.g., by making appropriate markings in the margins). 11 12 (b) for testimony given in depositions that the Designating Party 13 identifies the Disclosure or Discovery Material on the record, before the close of 14 the deposition all protected testimony. Failure of counsel to designate testimony or 15 16 exhibits at a deposition, however, shall not waive the protected status of the 17 testimony or exhibits. Counsel may designate specific testimony or exhibits as 18 Protected Material within fifteen (15) calendar days after receiving the transcript of 19 20 the deposition. 21 (c) for information produced in some form other than documentary and 22 for any other tangible items, that the Producing Party affix in a prominent place on 23 24 the exterior of the container or containers in which the information is stored the 25 appropriate CONFIDENTIAL Legend. If only a portion or portions of the 26 information warrants protection, the Producing Party, to the extent practicable, 27 28 1 shall identify the protected portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 4 failure to designate qualified information or items does not, standing alone, waive 5 the Designating Party’s right to secure protection under this Order for such 6 material. Upon timely correction of a designation, the Receiving Party must make 7 8 reasonable efforts to assure that the material is treated in accordance with the 9 provisions of this Order. 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s 14 Scheduling Order. 15 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 The burden of persuasion in any such challenge proceeding shall be 19 20 on the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 24 Party has waived or withdrawn the confidentiality designation, all parties shall 25 continue to afford the material in question the level of protection to which it is 26 entitled under the Producing Party’s designation until the Court rules on the 27 28 1 challenge. 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 4 7.1 Basic Principles. A Receiving Party may use Protected Material that 5 is disclosed or produced by another Party or by a Non-Party in connection with this 6 Action only for prosecuting, defending or attempting to settle this Action. Such 7 8 Protected Material may be disclosed only to the categories of persons and under 9 the conditions described in this Order. When the Action has been terminated, a 10 Receiving Party must comply with the provisions of section 13 below (FINAL 11 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 16 authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 18 otherwise ordered by the court or permitted in writing by the Designating Party, a 19 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 23 24 as employees of said Outside Counsel of Record to whom it is reasonably 25 necessary to disclose the information for this Action; 26 (b) the officers, directors, and employees (including In-House Counsel) of 27 28 1 the Receiving Party to whom disclosure is reasonably necessary for this Action; 2 (c) Experts (as defined in this Order) of the Receiving Party to whom 3 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and Professional 10 Vendors to whom disclosure is reasonably necessary for this Action and who have 11 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or a 14 custodian or other person who otherwise possessed or knew the information; 15 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing 18 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 19 20 they will not be permitted to keep any confidential information unless they sign the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 22 agreed by the Designating Party or ordered by the court. Pages of transcribed 23 24 deposition testimony or exhibits to depositions that reveal Protected Material may 25 be separately bound by the court reporter and may not be disclosed to anyone 26 except as permitted under this Stipulated Protective Order; 27 28 1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions; and 3 4 (j) any other person upon written agreement of the producing party. 5 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 6 ONLY” Information or Items 7 8 Unless otherwise ordered by the Court or permitted in writing by the 9 Designating Party, a Receiving Party may disclose any information or item 10 designated “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” only to: 11 12 (a) The Receiving Party’s Outside Counsel of Record in this Action as well 13 as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 16 (b) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 20 (c) In-House Counsel of the Receiving Party to whom disclosure is 21 reasonably necessary for this Action, provided that such In-House Counsel is not 22 involved in product design, pricing, sales, marketing, or other competitive decision 23 24 making activities and who has signed the “Acknowledgment and Agreement to Be 25 Bound” (Exhibit A); 26 (d) The Court and its personnel; 27 28 1 (e) Court reporters and their staff; 2 (f) Professional jury or trial consultants, mock jurors, and Professional 3 4 Vendors to whom disclosure is reasonably necessary or this Action and who have 5 signed the “Acknowledgment and Agreement to be Bound” attached as Exhibit A 6 hereto; 7 8 (g) The author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 (h) Any person who is determined to have been an author and/or previous 11 12 recipient of the information designated as HIGHLY CONFIDENTIAL – 13 ATTORNEY’S EYES ONLY; 14 (i) Any mediator or settlement officer, and their supporting personnel, 15 16 mutually agreed upon by any of the parties engaged in settlement discussions; and 17 (j) any other person upon written agreement of the producing party. 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 19 20 PRODUCED IN OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation 22 that compels disclosure of any Protected Material designated in this Action, that 23 24 Party must: 25 (a) promptly notify in writing the Designating Party. Such notification shall 26 include a copy of the subpoena or court order; 27 28 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena 3 4 or order is subject to this Protective Order. Such notification shall include a copy 5 of this Stipulated Protective Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be pursued 7 8 by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served 10 with the subpoena or court order shall not produce any Protected Material 11 12 designated in this action before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 16 protection in that court of its confidential material and nothing in these provisions 17 should be construed as authorizing or encouraging a Receiving Party in this Action 18 to disobey a lawful directive from another court. 19 20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 21 PRODUCED IN THIS LITIGATION 22 (a) The terms of this Order are applicable to information produced by a 23 24 Non-Party in this Action and designated as “CONFIDENTIAL” or HIGHLY 25 CONFIDENTIAL – ATTORNEY’S EYES ONLY. Such information produced by 26 Non-Parties in connection with this litigation is protected by the remedies and 27 28 1 relief provided by this Order. Nothing in these provisions should be construed as 2 prohibiting a Non-Party from seeking additional protections. 3 4 (b) In the event that a Party is required, by a valid discovery request, to 5 produce a Non-Party’s confidential information in its possession, and the Party is 6 subject to an agreement with the Non-Party not to produce the Non-Party’s 7 8 confidential information, then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non-Party that 10 some or all of the information requested is subject to a confidentiality agreement 11 12 with a Non-Party; 13 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 14 Order in this Action, the relevant discovery request(s), and a reasonably specific 15 16 description of the information requested; and 17 (3) make the information requested available for inspection by the Non- 18 Party, if requested. 19 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 24 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 25 not produce any information in its possession or control that is subject to the 26 confidentiality agreement with the Non-Party before a determination by the court. 27 28 1 Absent a court order to the contrary, the Non-Party shall bear the burden and 2 expense of seeking protection in this court of its Protected Material. 3 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has 6 disclosed Protected Material to any person or in any circumstance not authorized 7 8 under this Stipulated Protective Order, the Receiving Party must immediately (a) 9 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 10 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 11 12 the person or persons to whom unauthorized disclosures were made of all the terms 13 of this Order, and (d) request such person or persons to execute the 14 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 15 16 A. 17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 18 OTHERWISE PROTECTED MATERIAL 19 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other 22 protection, the obligations of the Receiving Parties are those set forth in Federal 23 24 Rule of Civil Procedure 26(b)(5)(B), including immediately sequestering the 25 document and shall not review or use that document, or any work product 26 containing information taken from that document, for any purpose. The Parties 27 28 1 shall meet and confer regarding any Clawback Request. This provision is not 2 intended to modify whatever procedure may be established in an e-discovery order 3 4 that provides for production without prior privilege review. Pursuant to Federal 5 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 6 effect of disclosure of a communication or information covered by the attorney- 7 8 client privilege or work product protection, the parties may incorporate their 9 agreement in the stipulated protective order submitted to the court. 10 12. MISCELLANEOUS 11 12 12.1 Right to Further Relief. Nothing in this Order abridges the right of 13 any person to seek its modification by the Court in the future. 14 12.2 Right to Assert Other Objections. By stipulating to the entry of this 15 16 Protective Order, no Party waives any right it otherwise would have to object to 17 disclosing or producing any information or item on any ground not addressed in 18 this Stipulated Protective Order. Similarly, no Party waives any right to object on 19 20 any ground to use in evidence of any of the material covered by this Protective 21 Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material 25 may only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material at issue. If a Party’s request to file Protected Material 27 28 1 under seal is denied by the court, then the Receiving Party may file the information 2 in the public record unless otherwise instructed by the court. 3 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, as defined in paragraph 4, within 6 60 days of a written request by the Designating Party, each Receiving Party must 7 8 return all Protected Material to the Producing Party or destroy such material. As 9 used in this subdivision, “all Protected Material” includes all copies, abstracts, 10 compilations, summaries, and any other format reproducing or capturing any of the 11 12 Protected Material. Whether the Protected Material is returned or destroyed, the 13 Receiving Party must submit a written certification to the Producing Party (and, if 14 not the same person or entity, to the Designating Party) by the 60 day deadline that 15 16 (1) identifies (by category, where appropriate) all the Protected Material that was 17 returned or destroyed and (2) affirms that the Receiving Party has not retained any 18 copies, abstracts, compilations, summaries or any other format reproducing or 19 20 capturing any of the Protected Material. Notwithstanding this provision, Counsel 21 are entitled to retain an archival copy of all pleadings, motion papers, trial, 22 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 23 24 and trial exhibits, expert reports, attorney work product, and consultant and expert 25 work product, even if such materials contain Protected Material. Any such 26 archival copies that contain or constitute Protected Material remain subject to this 27 28 1 Protective Order as set forth in Section 4 (DURATION). 2 14. VIOLATION 3 4 Any violation of this Order may be punished by appropriate measures 5 including, without limitation, contempt proceedings and/or monetary sanctions. 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 DATED: September 18, 2025 By: /Mitchell S. Feller/ Mitchell S. Feller (Admitted pro hac vice) 9 Jason R. Wachter (Admitted pro hac vice) 10 Patrick B. Monahan (Admitted pro hac vice) GOTTLIEB, RACKMAN & REISMAN P.C. 11 12 Jason H. Wilson Ashley L. Kirk 13 WILLENKEN LLP 14 Attorneys for Plaintiff 15 LERMAN CONTAINER CORP. 16 DATED: September 18, 2025 By: /Jacob G. Horton/ 17 Jacob. G. Horton (Admitted pro hac vice) BLANCHARD HORTON PLLC 18 Colin W. Fraser 19 Bethany Rabe GREENBERG TRAURIG, LLP 20 Attorneys for Defendant 21 A&A GLOBAL IMPORTS, LLC 22 ECF CERTIFICATION 23 Pursuant to Local Civil Rule 5-4.3.4(a)(2)(i), I hereby attest that Jacob G. 24 Horton and Mitchell S. Feller, on whose behalf this filing is jointly submitted, have 25 concurred in this filing’s content and have authorized me to file this document. 26 By: /Jason H. Wilson/ Jason H. Wilson 27

28 1

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

4|| DATED: 10/9/2025 RapeOln OC~ 6 HON. ROZELLA A. OLIVER

g || United States Magistrate Judge 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 23 STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 8 was issued by the United States District Court for the Central District of California 9 on [date] in the case of Lerman Container Corp. v. A&A Global Imports, Ltd. 10 (Case No. 2:25-cv-06321-JFW-RAOx). I agree to comply with and to be bound 11 12 by all the terms of this Stipulated Protective Order and I understand and 13 acknowledge that failure to so comply could expose me to sanctions and 14 punishment in the nature of contempt. I solemnly promise that I will not disclose 15 16 in any manner any information or item that is subject to this Stipulated Protective 17 Order to any person or entity except in strict compliance with the provisions of this 18 Order. 19 20 I further agree to submit to the jurisdiction of the United States District 21 Court for the Central District of California for enforcing the terms of this 22 Stipulated Protective Order, even if such enforcement proceedings occur after 23 24 termination of this action. I hereby appoint __________________________ [print 25 or type full name] of _______________________________________ [print or 26 type full address and telephone number] as my California agent for service of 27 28 1 process in connection with this action or any proceedings related to enforcement of 2 this Stipulated Protective Order. 3 4 Date: ______________________________________ 5 City and State where sworn and signed: 6 _________________________________ 7 8 Printed name: _______________________________ 9 Signature: __________________________________ 10

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