Mohammed Elokour v. Safety Holdings, Inc. d/b/a Sambasafety

• Court: District Court, C.D. California
• Decided: December 19, 2025
• Docket: 2:25-cv-09640
• Status: Unknown

Opinion

2 UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA 4

5 Case No. 2:25-cv-09640-JFW-SSC 6 MOHAMMED ELOKOUR,

7 Plaintiff, STIPULATED PROTECTIVE 8 v. ORDER1

10 SAFETY HOLDINGS, INC. d/b/a 11 SAMBASAFETY, 12 Defendant

13 14 1. INTRODUCTION 15 1.1 Purposes and Limitations. Discovery in this action is likely to involve 16 production of confidential, proprietary, or private information for which special 17 protection from public disclosure and from use for any purpose other than prosecuting 18 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 19 petition the court to enter the following Stipulated Protective Order. The parties 20 acknowledge that this Order does not confer blanket protections on all disclosures or 21 responses to discovery and that the protection it affords from public disclosure and 22 use extends only to the limited information or items that are entitled to confidential 23 treatment under the applicable legal principles. 24 25

26 1 This Stipulated Protective Order is substantially based on the model protective order 27 provided under Magistrate Judge Stephanie S. Christensen’s Procedures as of 24 July 1 1.2 Good Cause Statement. 2 This action is likely to involve trade secrets, customer and pricing lists and 3 other valuable research, development, commercial, financial, technical and/or 4 proprietary information for which special protection from public disclosure and from 5 use for any purpose other than prosecution of this action is warranted. Such 6 confidential and proprietary materials and information consist of, among other things, 7 confidential business or financial information, information regarding confidential 8 business practices, or other confidential research, development, or commercial 9 information (including information implicating privacy rights of third parties), 10 information otherwise generally unavailable to the public, or which may be privileged 11 or otherwise protected from disclosure under state or federal statutes, court rules, case 12 decisions, or common law. Accordingly, to expedite the flow of information, to 13 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 14 to adequately protect information the parties are entitled to keep confidential, to 15 ensure that the parties are permitted reasonable necessary uses of such material in 16 preparation for and in the conduct of trial, to address their handling at the end of the 17 litigation, and serve the ends of justice, a protective order for such information is 18 justified in this matter. It is the intent of the parties that information will not be 19 designated as confidential for tactical reasons and that nothing be so designated 20 without a good faith belief that it has been maintained in a confidential, non-public 21 manner, and there is good cause why it should not be part of the public record of this 22 case. 23 Plaintiff believes if his full personal identifying information is made available 24 on the public docket he will be susceptible to identity theft. As such, all filings should 25 be made in compliance with Fed. R. Civ. P. 5.2 in order to protect Plaintiff’s personal 26 identifying information. To the extent that there is medical information that is 27 compelled in this lawsuit, the medical examination documents shall also be marked 1 as confidential. See Pate v. Pac. Harbor Line, Inc., No. 5:21-cv-01300-JWH-SHK, 2 2023 U.S. Dist. LEXIS 52632, *37-38 (C.D. Cal. Feb. 6, 2023) (stating that Plaintiff 3 has a strong privacy interest in hismedical records); Tucson Woman's Clinic v. Eden, 4 379 F.3d 531, 551 (9th Cir. 2004) (“Individuals have a constitutionally protected 5 interest in avoiding disclosure of personal matters, including medical information.”); 6 Norman Bloodsaw v. Lawrence Berkeley Lab’y, 135 F.3d 1260, 1269 (9th Cir. 1998) 7 (“The constitutionally protected privacy interest in avoiding disclosure of personal 8 matters clearly encompasses medical information and its confidentiality.”); 9 Miesegaes v. Allenby, No. CV 15-01574 CJC (RAO), 2020 U.S. Dist. LEXIS 89806, 10 2020 WL 2542064, at *4 (C.D. Cal. Mar. 13, 2020) (In the discovery context, “[t]he 11 Court recognizes the significant privacy interest in medical records.”). 12 13 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 14 further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 15 Order does not entitle them to file confidential information under seal; Local Rule 79- 16 5 sets forth the procedures that must be followed and the standards that will be applied 17 when a party seeks permission from the court to file material under seal. 18 There is a strong presumption that the public has a right of access to judicial 19 proceedings and records in civil cases. In connection with non-dispositive motions, 20 good cause must be shown to support a filing under seal. See Kamakana v. City and 21 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd 22 v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. 23 Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective 24 orders require good cause showing), and a specific showing of good cause or 25 compelling reasons with proper evidentiary support and legal justification, must be 26 made with respect to Protected Material that a party seeks to file under seal. The 27 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 1 does not—without the submission of competent evidence by declaration, 2 establishing that the material sought to be filed under seal qualifies as confidential, 3 privileged, or otherwise protectable—constitute good cause. 4 Further, if a party requests sealing related to a dispositive motion or trial, then 5 compelling reasons, not only good cause, for the sealing must be shown, and the 6 relief sought shall be narrowly tailored to serve the specific interest to be protected. 7 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each 8 item or type of information, document, or thing sought to be filed or introduced under 9 seal in connection with a dispositive motion or trial, the party seeking protection 10 must articulate compelling reasons, supported by specific facts and legal 11 justification, for the requested sealing order. Again, competent evidence supporting 12 the application to file documents under seal must be provided by declaration. 13 Any document that is not confidential, privileged, or otherwise protectable in 14 its entirety will not be filed under seal if the confidential portions can be redacted. 15 If documents can be redacted, then a redacted version for public viewing, omitting 16 only the confidential, privileged, or otherwise protectable portions of the document, 17 shall be filed. Any application that seeks to file documents under seal in their entirety 18 should include an explanation of why 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 designation 23 of information or items under this Order. 24 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 25 how it is generated, stored or maintained) or tangible things that qualify for protection 26 under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in 27 the Good Cause Statement. 1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 2 support staff). 3 2.5 Designating Party: a Party or Non-Party that designates information or 4 items that it produces in disclosures or in responses to discovery as 5 “CONFIDENTIAL.” 6 2.6 Disclosure or Discovery Material: all items or information, regardless of 7 the medium or manner in which it is generated, stored, or maintained (including, 8 among other things, testimony, transcripts, and tangible things), that are produced or 9 generated in disclosures or responses to discovery in this matter. 10 2.7 Expert: a person with specialized knowledge or experience in a matter 11 pertinent to the litigation who has been retained by a Party or its counsel to serve as 12 an expert witness or as a consultant in this Action. 13 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 14 this Action, with or without prejudice; and (2) final judgment herein after the 15 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 16 this Action, including the time limits for filing any motions or applications for 17 extension of time pursuant to applicable law. 18 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 19 In-House Counsel does not include Outside Counsel of Record or any other outside 20 counsel. 21 2.10 Non-Party: any natural person, partnership, corporation, association, or 22 other legal entity not named as a Party to this action. 23 2.11 Outside Counsel of Record: attorneys who are not employees of a party 24 to this Action but are retained to represent or advise a party to this Action and have 25 appeared in this Action on behalf of that party or are affiliated with a law firm which 26 has appeared on behalf of that party, and includes support staff. 27 2.12 Party: any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, and Outside Counsel of Record (and their 2 support staffs). 3 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 2.14 Professional Vendors: persons or entities that provide litigation- support 6 services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or medium) 8 and their employees and subcontractors. 9 2.15 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL.” 11 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 12 from a Producing Party. 13 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 presentations by Parties or their Counsel that might reveal Protected Material. 20 Any use of Protected Material at trial shall be governed by the orders of the 21 trial judge. This Stipulated Protective Order does not govern the use of Protected 22 Material at trial. 23

24 4. TRIAL AND DURATION 25 The terms of this Stipulated Protective Order apply through Final Disposition 26 of the Action. 27 1 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 2 used or introduced as an exhibit at trial becomes public and will be presumptively 3 available to all members of the public, including the press, unless compelling reasons 4 supported by specific factual findings to proceed otherwise are made to the trial judge 5 in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 6 cause” showing for sealing documents produced in discovery from “compelling 7 reasons” standard when merits-related documents are part of court record). 8 Accordingly, for such materials, the terms of this Stipulated Protective Order do not 9 extend beyond the commencement of the trial. 10 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under this 14 Order must take care to limit any such designation to specific material that qualifies 15 under the appropriate standards. The Designating Party must designate for protection 16 only those parts of material, documents, items, or oral or written communications that 17 qualify so that other portions of the material, documents, items, or communications 18 for which protection is not warranted are not swept unjustifiably within the ambit of 19 this Order. 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 impose 23 unnecessary expenses and burdens on other parties) may expose the Designating 24 Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), 3 or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 4 for protection under this Stipulated Protective Order must be clearly so designated 5 before the material is disclosed or produced. 6 Designation in conformity with this Stipulated Protective Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” to each page that contains protected material. If only a portion 11 or portions of the material on a page qualifies for protection, the Producing Party 12 also must clearly identify the protected portion(s) (e.g., by making appropriate 13 markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 19 it wants copied and produced, the Producing Party must determine which documents, 20 or portions thereof, qualify for protection under this Stipulated Protective Order. 21 Then, before producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing 24 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 25 markings in the margins). 26 (b) All deposition testimony taken in this case shall be treated as 27 Confidential Information until the expiration of the following: No later than thirty 1 (30) days after the testimony was given, within this time period, a party may serve a 2 Notice of Designation to all parties of record as to specific portions of the testimony 3 that are designated Confidential, and thereafter only those portions identified in the 4 Notice of Designation shall be protected by the terms of this Order. A party may only 5 designate deposition testimony as confidential after a good faith review of the 6 transcript and a supportable determination that the information warrants a 7 confidential designation. The failure to serve a timely Notice of Designation shall 8 waive any designation of testimony taken in that deposition as Confidential 9 Information, unless otherwise ordered by the Court. 10 (c) for information produced in some form other than documentary and for 11 any other tangible items, that the Producing Party affix in a prominent place on the 12 exterior of the container or containers in which the information is stored the 13 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Stipulated Protective Order. 22 23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 25 designation of confidentiality at any time that is consistent with the court’s 26 Scheduling Order. 27 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 1 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 2 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 3 6.3 The burden of persuasion in any such challenge proceeding shall be on 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 6 may expose the Challenging Party to sanctions. Unless the Designating Party has 7 waived or withdrawn the confidentiality designation, all parties shall continue to 8 afford the material in question the level of protection to which it is entitled under the 9 Producing Party’s designation until the court rules on the challenge. 10 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending, or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under the 16 conditions described in this Order. When the Action reaches a Final Disposition, a 17 Receiving Party must comply with the provisions of section 13 below. 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Stipulated Protective Order. 21 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 22 otherwise ordered by the court or permitted in writing by the Designating Party, a 23 Receiving Party may disclose any information or item designated 24 “CONFIDENTIAL” only: 25 26

27 2 Judge Christensen’s Procedures are available at 1 (a) to 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) to the officers, directors, and employees (including House Counsel) of 5 the Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) to 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) to the court and its personnel; 10 (e) to court reporters and their staff; 11 (f) to 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) to the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 18 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 20 information unless they sign the “Acknowledgment and Agreement to Be Bound” 21 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 22 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 23 Protected Material may be separately bound by the court reporter and may not be 24 disclosed to anyone except as permitted under this Stipulated Protective Order; and 25 (i) to any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 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 shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of 11 this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 with the subpoena or court order shall 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 shall 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 24 PRODUCED IN THIS LITIGATION 25 9.1 Application. The terms of this Stipulated Protective Order are applicable 26 to information produced by a Non-Party in this Action and designated as 27 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 1 this litigation is protected by the remedies and relief provided by this Order. Nothing 2 in these provisions should be construed as prohibiting a Non-Party from seeking 3 additional protections. 4 9.2 Notification. In the event that a Party is required, by a valid discovery 5 request, to produce a Non-Party’s confidential information in its possession, and the 6 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 7 confidential information, then the Party shall: 8 (a) promptly notify in writing the Requesting Party and the Non-Party that 9 some or all of the information requested is subject to a confidentiality agreement with 10 a Non-Party; 11 (b) make the information requested available for inspection by the Non- 12 Party, if requested. 13 9.3 Conditions of Production. If the Non-Party fails to seek a protective 14 order from this court within 14 days of receiving the notice and accompanying 15 information, the Receiving Party may produce the Non-Party’s confidential 16 information responsive to the discovery request. If the Non-Party timely seeks a 17 protective order, the Receiving Party shall not produce any information in its 18 possession or control that is subject to the confidentiality agreement with the Non- 19 Party before a determination by the court. Absent a court order to the contrary, the 20 Non-Party shall bear the burden and expense of seeking protection in this court of its 21 Protected Material. 22 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 efforts 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” (Exhibit A). 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 11 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 14 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of 15 a communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated 17 protective order submitted to the court. 18

19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 21 abridges the right of any person to seek its modification by the court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Stipulated Protective Order no Party waives any right it otherwise would have to 24 object to disclosing or producing any information or item on any ground not 25 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 26 to object on any ground to use in evidence of any of the material covered by this 27 Stipulated Protective Order. 1 12.3 Filing Protected Material. To the extent any motions, briefs, pleadings, 2 deposition transcripts, or other papers to be filed with the Court incorporate 3 documents or information subject to this Order, the party filing such papers shall 4 seek to file them under seal. A Party that seeks to file under seal any Protected 5 Material must comply with Local Rule 79-5. Protected Material may only be filed 6 under seal pursuant to a court order authorizing the sealing of the specific Protected 7 Material at issue. If a Party's request to file Protected Material under seal is denied 8 by the court, then the Receiving Party may file the information in the public record 9 unless otherwise instructed by the court. 10 12.4 No Prior Judicial Determination. This Order is entered based on the 11 representations and agreements of the parties and for the purpose of facilitating 12 discovery. Nothing herein shall be construed or presented as a judicial determination 13 that any document or material designated Confidential Information by counsel or the 14 parties is entitled to protection under Rule 26(c) of the Federal Rules of Civil 15 Procedure or otherwise until such time as the Court may rule on a specific document 16 or issue. 17 12.5 Persons Bound. This Order shall take effect when entered and shall be 18 binding upon all counsel of record and their law firms, the parties, and persons made 19 subject to this Order by its terms. 20 12.6 Applicability to Parties Later Joined. If additional persons or entities 21 become parties to this lawsuit, they must not be given access to any Confidential 22 Information until they execute and file their written agreement to be bound by the 23 provisions of this Order. 24 25 13. FINAL DISPOSITION 26 After the Final Disposition of this Action, as defined in paragraph 4, within 27 60 days of a written request by the Designating Party, each Receiving Party destroy 1 All Protected Material. As used in this subdivision, “all Protected Material” includes 2 all copies, abstracts, compilations, summaries, and any other format reproducing or 3 capturing any of the Protected Material. Notwithstanding this provision, Counsel 4 may retain a copy of any Protected Material submitted to the court. Further, Counsel 5 is entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 6 and hearing transcripts, legal memoranda, correspondence, deposition and trial 7 exhibits, expert reports, attorney work product, and consultant and expert work 8 product, and any other material as required by the professional rules of conduct for 9 lawyers or as necessary for the attorney or attorney’s law firm to defend against, 10 including but not limited to, potential claims of malpractice, breach of contract, 11 ethics disputes, bar complaints or grievance, even if such materials contain Protected 12 Material. Any such archival copies that contain or constitute Protected Material 13 remain subject to this Protective Order as set forth in Section 4. 14 14. VIOLATION 15 Any violation of this Stipulated Protective Order may be punished by any and 16 all appropriate measures including, without limitation, contempt proceedings and/or 17 monetary sanctions. 18 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 20 21 DATED: December 18, 2025 /s/ Jenna Dakroub 22 Attorney for Plaintiff Mohammed Elokour 23 24 DATED: December 18, 2025 /s/ Andrick J. Zeen 25 Attorney for Defendant Safety Holdings, 26 Inc. d/b/a SambaSafety

27 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 LZ 3 DATED: December 19, 2025 4 STEPHANIE S. CHRISTENSEN ; United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 8 17

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

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 name of the case and the 8 number 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 in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 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 full address and telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22

23 Date: ___________________________ 24 City and State where sworn and signed: ___________________________ 25 Printed name: ___________________________ 26 Signature: ___________________________ 27