Leonardo Antolin v. Walmart Inc.

Opinion

Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 1 of 15 Page ID #:113

1 2 3 4 5 6 9 10 LEONARDO ANTOLIN, CASE NO.: 2:22-cv-06452 SVW (MARx) 11 Plaintiff, STIPULATED PROTECTIVE 12 v. ORDER 13 WALMART INC., a business entity form unknown; WAL-MART 14 STORES INC.; and DOES 1-100, inclusive, 15 Defendants.. 16 17 18 1. INTRODUCTION 19 1.1 PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, proprietary, 21 or private information for which special protection from public disclosure and from 22 use for any purpose, other than prosecuting this litigation, may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the 24 following Stipulated Protective Order. The parties acknowledge that this Order does 25 not confer blanket protections on all disclosures or responses to discovery and that 26 the protection it affords from public disclosure and use extends only to the limited 27 information or items that are entitled to confidential treatment under the applicable 28 legal principles. The parties further acknowledge, as set forth in Section 12.3, 1 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO.2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 2 of 15 Page ID #:114

1 below, that this Stipulated Protective Order does not entitle them to file confidential 2 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 3 followed and the standards that will be applied when a party seeks permission from 4 the court to file material under seal. 5 1.2 GOOD CAUSE STATEMENT 6 WALMART has expressed a willingness to provide the proprietary information, 7 confidential business records and/or trade secrets (“confidential documents and 8 information”) in complying with Plaintiff’s discovery requests, provided that the 9 Court enter the requested protective order. There is good cause to protect said 10 information from public disclosure. It is the intent of the parties that information 11 will not be designated as confidential for tactical reasons and that nothing be so 12 designated without a good faith belief that it has been maintained in a confidential 13 and non-public manner. 14 15 2. DEFINITIONS 16 2.1 Action: This pending federal lawsuit. 17 2.2 Challenging Party: a Party or Non-Party that challenges the 18 designation of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 24 their support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 /// 2 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 3 of 15 Page ID #:115

1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced 4 or generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as 7 an expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.9 Non-Party: any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a 14 party to this Action but are retained to represent or advise a party to this Action and 15 have appeared in this Action on behalf of that party or are affiliated with a law firm 16 which has appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation 23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 and their employees and subcontractors. 26 2.14 Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 /// 3 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 4 of 15 Page ID #:116

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery 2 Material from a Producing Party. 3 4 3. SCOPE 5 The protections conferred by this Stipulation and Order cover not only 6 Protected Material (as defined above), but also (1) any information copied or 7 extracted from Protected Material; (2) all copies, excerpts, summaries, or 8 compilations of Protected Material; and (3) any testimony, conversations, or 9 presentations by Parties or their Counsel that might reveal Protected Material. 10 Any use of Protected Material at trial will be governed by the orders of the 11 trial judge. This Order does not govern the use of Protected Material at trial. 12 13 4. DURATION 14 Confidential documents, things and information may be used at trial or at 15 depositions, in accordance with the following safeguards. If confidential 16 documents, things and information are used in depositions, all portions of the 17 transcript of such depositions and exhibits thereto which refer to or relate to such 18 confidential documents, things or information shall themselves be considered as 19 confidential documents. The party introducing such confidential documents, thing 20 and information shall ensure that the court reporter binds the confidential portions 21 of the transcript and exhibits separately and labels them “confidential.” In addition, 22 each deponent is ordered that he may not divulge any confidential documents, 23 things or information except to qualified persons. 24 At the conclusion of this action, all confidential documents, things and 25 information, and all copies thereof, shall be returned to the counsel for WALMART 26 within thirty (30) days. 27 /// 28 /// 4 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 5 of 15 Page ID #:117

1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 WALMART shall mark as “confidential” or “produced pursuant to protective 4 order” or in some similar fashion any document for which it claims protection 5 under this order. The documents, things and information contained in them or 6 gleaned from them shall only be used, shown and disclosed as provided in this 7 order. The term “confidential documents and information” as used in this order 8 shall be construed to include the documents and materials so marked, and their 9 content, substance and the information contained in or gleaned from them. The term 10 shall also be construed to include any summaries, quotes, excerpts and/or 11 paraphrases of the documents, things or information. The designation shall be made 12 in good faith and shall not be made with respect to any document which is in the 13 public domain, such as patents, or any other document which has previously been 14 produced or disseminated without confidentiality protection. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 25 contains protected material. If only a portion or portions of the material on a page 26 qualifies for protection, the Producing Party also must clearly identify the protected 27 portion(s) (e.g., by making appropriate markings in the margins). 28 A Party or Non-Party that makes original documents available for inspection 5 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 6 of 15 Page ID #:118

1 need not designate them for protection until after the inspecting Party has indicated 2 which documents it would like copied and produced. During the inspection and 3 before the designation, all of the material made available for inspection will be 4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 5 documents it wants copied and produced, the Producing Party must determine 6 which documents, or portions thereof, qualify for protection under this Order. Then, 7 before producing the specified documents, the Producing Party must affix the 8 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 9 portion or portions of the material on a page qualifies for protection, the Producing 10 Party also must clearly identify the protected portion(s) (e.g., by making 11 appropriate markings in the margins). 12 (b) for testimony given in depositions that the Designating Party 13 identify the Disclosure or Discovery Material on the record, before the close of the 14 deposition all protected testimony. 15 (c) for information produced in some form other than documentary and 16 for any other tangible items, that the Producing Party affix in a prominent place on 17 the exterior of the container or containers in which the information is stored the 18 legend “CONFIDENTIAL.” If only a portion or portions of the information 19 warrants protection, the Producing Party, to the extent practicable, will identify the 20 protected portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure to designate qualified information or items does not, standing alone, waive 23 the Designating Party’s right to secure protection under this Order for such 24 material. Upon timely correction of a designation, the Receiving Party must make 25 reasonable efforts to assure that the material is treated in accordance with the 26 provisions of this Order. 27 /// 28 /// 6 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 7 of 15 Page ID #:119

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party will initiate the dispute 6 resolution process under Local Rule 37.1 et seq. 7 6.3 If a party contends that any documents, information or portions of 8 them which another party or third party has designated as confidential are not 9 entitled to protection, he may file a motion to change the designation. As per 10 Stadish v. Superior Court (1999) 71 Cal.App.4th 1130, the motion to change the 11 designation shall provide notice and an opportunity for the proponent of 12 confidentiality to respond. The burden is placed on the proponent of confidentiality 13 to demonstrate good cause. The documents and information shall remain 14 confidential until their status is changed by stipulation or order. 15 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles: This protective order is limited to the context of pre- 18 trial civil discovery. This protective order does not restrict dissemination of 19 information if gained from other public sources outside of pre-trial civil discovery. 20 When the Action has been terminated, a Receiving Party must comply with the 21 provisions of section 13 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 26 otherwise ordered by the court or permitted in writing by the Designating Party, a 27 Receiving Party may disclose any information or item designated 28 “CONFIDENTIAL” only to: 7 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 8 of 15 Page ID #:120

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 2 well as employees of said Outside Counsel of Record to whom it is reasonably 3 necessary to disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of 5 the Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the Court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or 15 a custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in 17 the 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 they will not be permitted to keep any confidential information unless they sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 21 agreed by the Designating Party or ordered by the court. Pages of transcribed 22 deposition testimony or exhibits to depositions that reveal Protected Material may 23 be separately bound by the court reporter and may not be disclosed to anyone 24 except as permitted under this Stipulated Protective Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 /// 28 /// 8 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 9 of 15 Page ID #:121

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 will include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or 9 order to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification will include 11 a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order will not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party will bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 remedies and relief provided by this Order. Nothing in these provisions should be 9 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 10 of 15 Page ID #:122

1 construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, to 3 produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party will: 6 (1) promptly notify in writing the Requesting Party and the Non- 7 Party that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the 10 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 11 reasonably specific description of the information requested; and 12 (3) make the information requested available for inspection by 13 the Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court 15 within 14 days of receiving the notice and accompanying information, the 16 Receiving Party may produce the Non-Party’s confidential information responsive 17 to the discovery request. If the Non-Party timely seeks a protective order, the 18 Receiving Party shall not produce any information in its possession or control that 19 is subject to the confidentiality agreement with the Non-Party before a 20 determination by the court. Absent a court order to the contrary, the Non-Party shall 21 bear the burden and expense of seeking protection in this court of its Protected 22 Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best 28 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 1 0 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 11 of 15 Page ID #:123

1 person or persons to whom unauthorized disclosures were made of all the terms of 2 this Order, and (d) request such person or persons to execute the “Acknowledgment 3 and Agreement to Be Bound” that is attached hereto as Exhibit A. 4 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other 9 protection, the obligations of the Receiving Parties are those set forth in Federal 10 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 11 whatever procedure may be established in an e-discovery order that provides for 12 production without prior privilege review. Pursuant to Federal Rule of Evidence 13 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 14 of a communication or information covered by the attorney-client privilege or work 15 product protection, the parties may incorporate their agreement in the stipulated 16 protective order submitted to the court. 17 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in 24 this Stipulated Protective Order. Similarly, no Party waives any right to object on 25 any ground to use in evidence of any of the material covered by this Protective 26 Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 Protected Material must comply with Civil Local Rule 79-5. Protected Material 1 1 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 12 of 15 Page ID #:124

1 may only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party’s request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 6 13. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in paragraph 4, within 30 8 days of a written request by the Designating Party, each Receiving Party must 9 return all Protected Material to the Producing Party or destroy such material. As 10 used in this subdivision, “all Protected Material” includes all copies, abstracts, 11 compilations, summaries, and any other format reproducing or capturing any of the 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 (1) identifies (by category, where appropriate) all the Protected Material that was 16 returned or destroyed and (2) affirms that the Receiving Party has not retained any 17 copies, abstracts, compilations, summaries or any other format reproducing or 18 capturing any of the Protected Material. Notwithstanding this provision, Counsel 19 are entitled to retain an archival copy of all pleadings, motion papers, trial, 20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 21 and trial exhibits, expert reports, attorney work product, and consultant and expert 22 work product, even if such materials contain Protected Material. Any such archival 23 copies that contain or constitute Protected Material remain subject to this Protective 24 Order as set forth in Section 4 (DURATION). 25 26 14. Any willful violation of this Order may be punished by civil or criminal 27 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 28 authorities, or other appropriate action at the discretion of the Court. 1 2 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document15 Filed 12/02/22 Page130f15 Page ID #:125

1 ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 DATED: November 23, 2022 /s/ Vincent Consolo 4 Attorneys for Plaintiff 6 DATED: November 23, 2022 /s/ Michael F. Colbert 7 Attorneys for Defendant 9 Pursuant to Local Rule 5-4.3.4(a)(2)(1), I hereby certify that the content of 10 this document is acceptable to T. Vincent Consolo, Esq., counsel for LEONARDO 11 ANTOLIN, and that I have obtained Mr. Consolo’s authorization to affix his 12 electronic signature to this Stipulated Protective Order. 13 14 /s/ Michael F. Colbert 15 Michael F. Colbert, Esq. 16 17 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 21 DATED: December 2, 2022 J A > = 22 HON. MARGO A. ROCCONI 23 United States Magistrate Judge 24 25 26 27 28 93549542 J TERE Oa

Case 2:22-cv-06452-SVW-MAR Document 15 Filed 12/02/22 Page 14 of 15 Page ID #:126

3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on _________ [date] in the case of ___________ [insert formal case name and the 8 numbers and initials assigned to it by the court]. I agree to comply with and to 9 be 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 11 punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 1 4 2354-9542 STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX) Case 2:22-cv-06452-SVW-MAR Document15 Filed 12/02/22 Page15o0f15 Page ID#:127

3 I hereby certify that the following document(s):

; was/were served on this date to counsel of record: [ ] BY MAIL: By placing a copy of the same in the United States Mail, 6 postage prepaid, and sent to their last known address(es) listed below. 7 [X] BY E-MAIL DELIVERY: Based on an agreement of the parties to accept service by e-mail or electronic transmission, I sent the above 8 document(s) to the person(s) at the e-mail address(es) listed below. I did not receive, within a reasonable amount of time after the 9 transmission, any electronic message or other indication that the 10 transmission was unsuccessful. [X] BY ELECTRONIC TRANSMISSION: I electronically filed the 1] above document(s) with the Clerk of the Court using the CM/ECF system. The CM/ECF system will send notification of this filing to the 12 person(s) listed below. 13 T. Vincent Consolo, Esq. Law Offices of Gerald L. Marcus 14 24025 Park Sorrento, Suite 430 Calabasas, CA 91302 1S | Tel: (818) 784-8544 Fax: (81 8) 784-5970 16 Email: vinnie@injurynetwork.org; armela RYNETWORK.ORG 17 Attorney for Plainti ig LEONARDO ANTOLIN

19 Executed on November 23, 2022_, at Los Angeles, California. wt} 21 Kaitlyn Laurt 22 23 24 25 26 27 28 2354-9542 pS STIPULATED PROTECTIVE ORDER CASE NO. 2:22-CV-06452 SVW (MARX)