Opinion

1

Steven A. Heath (SBN 250867)

2 saheath@heathsteinbeck.com

Uyen N. Nguyen (SBN 209753)

3

unguyen@heathsteinbeck.com

4 HEATH STEINBECK, LLP

407 N. Maple Drive, Ground Floor

5

Beverly Hills, CA 90210

6 Tel: (213) 335-6245

7

Attorneys for Plaintiff BYOAPPS, LLC

8

Genevieve Walser-Jolly (SBN 262784)

9

Genevieve.Walser-Jolly@wbd-us.com

10 Stephen P. Farkas (SBN 234060)

Stephen.Farkas@wbd-us.com

11

Andrew Yu-Chih (SBN 326135)

12 Andrew.Yu-Chih@wbd-us.com

WOMBLE BOND DICKINSON (US) LLP

13

400 Spectrum Center Drive, Suite 1700

14 Irvine, California 92618

Telephone: (714) 557-3800

15

16 Attorneys for Defendants

TIMELESS COSMETICS, LLC,

17 TIMELESS SKIN CARE LLC,

VERONICA PEDERSEN, AND

18 ALEX PEDERSON

UNITED STATES DISTRICT COURT

19

20

CENTRAL DISTRICT OF CALIFORNIA

21

Case No.: 2:25-CV-1925-RAO

22 BYOAPPS, LLC,

23 STIPULATED PROTECTIVE

Plaintiff, ORDER1

24

v.

25

26 TIMELESS COSMETICS, LLC;

27

TIMELESS SKIN CARE, LLC;

1

VERONICA PEDERSEN; ALEX

2 PEDERSON; AND DOES 1

THROUGHT 20, INCLUSIVE

3

4 Defendants.

5 1. A. PURPOSES AND LIMITATIONS

6 Discovery in this action is likely to involve production of confidential,

7 proprietary or private information for which special protection from public disclosure

8 and from use for any purpose other than prosecuting this litigation may be warranted.

9 Accordingly, the parties hereby stipulate to and petition the Court to enter the

10 following Stipulated Protective Order. The parties acknowledge that this Order does

11 not confer blanket protections on all disclosures or responses to discovery and that

12 the protection it affords from public disclosure and use extends only to the limited

13 information or items that are entitled to confidential treatment under the applicable

14 legal principles.

15 B. GOOD CAUSE STATEMENT

16 This action is likely to involve trade secrets, customer and pricing lists and

17 other valuable research, development, commercial, financial, technical and/or

18 proprietary information for which special protection from public disclosure and from

19 use for any purpose other than prosecution of this action is warranted. Such

20 confidential and proprietary materials and information consist of, among other things,

21 confidential business or financial information, information regarding confidential

22 business practices, or other confidential research, development, or commercial

23 information (including information implicating privacy rights of third parties),

24 information otherwise generally unavailable to the public, or which may be privileged

25 or otherwise protected from disclosure under state or federal statutes, court rules, case

26 decisions, or common law. Accordingly, to expedite the flow of information, to

27 facilitate the prompt resolution of disputes over confidentiality of discovery materials,

1 to adequately protect information the parties are entitled to keep confidential, to

2 ensure that the parties are permitted reasonable necessary uses of such material in

3 preparation for and in the conduct of trial, to address their handling at the end of the

4 litigation, and serve the ends of justice, a protective order for such information is

5 justified in this matter. It is the intent of the parties that information will not be

6 designated as confidential for tactical reasons and that nothing be so designated

7 without a good faith belief that it has been maintained in a confidential, non-public

8 manner, and there is good cause why it should not be part of the public record of this

9 case.

10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

11 The parties further acknowledge, as set forth in Section 12.3, below, that this

12 Stipulated Protective Order does not entitle them to file confidential information

13 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and

14 the standards that will be applied when a party seeks permission from the court to file

15 material under seal.

16 There is a strong presumption that the public has a right of access to judicial

17 proceedings and records in civil cases. In connection with non-dispositive motions,

18 good cause must be shown to support a filing under seal. See Kamakana v. City and

19 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors

20 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,

21 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

22 cause showing), and a specific showing of good cause or compelling reasons with

23 proper evidentiary support and legal justification, must be made with respect to

24 Protected Material that a party seeks to file under seal. The parties’ mere designation

25 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

26 submission of competent evidence by declaration, establishing that the material

27 sought to be filed under seal qualifies as confidential, privileged, or otherwise

1 Further, if a party requests sealing related to a dispositive motion or trial, then

2 compelling reasons, not only good cause, for the sealing must be shown, and the relief

3 sought shall be narrowly tailored to serve the specific interest to be protected. See

4 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each

5 item or type of information, document, or thing sought to be filed or introduced under

6 seal in connection with a dispositive motion or trial, the party seeking protection must

7 articulate compelling reasons, supported by specific facts and legal justification, for

8 the requested sealing order. Again, competent evidence supporting the application to

9 file documents under seal must be provided by declaration.

10 Any document that is not confidential, privileged, or otherwise protectable in

11 its entirety will not be filed under seal if the confidential portions can be redacted. If

12 documents can be redacted, then a redacted version for public viewing, omitting only

13 the confidential, privileged, or otherwise protectable portions of the document shall

14 be filed. Any application that seeks to file documents under seal in their entirety

15 should include an explanation of why redaction is not feasible.

16 2. DEFINITIONS

17 2.1 Action: BYOAPPS, LLC v. TIMELESS COSMETICS, LLC, et al;

18 United States District Court Central District of California Case No. 2:25-CV-1925-

19 RAO.

20 2.2 Challenging Party: a Party or Non-Party that challenges the designation

21 of information or items under this Order.

22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

23 how it is generated, stored or maintained) or tangible things that qualify for protection

24 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

25 Cause Statement.

26 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY (“AEO”)”

27 Information or Items: extremely sensitive “CONFIDENTIAL” Information or Items,

1 serious harm that could not be avoided by less restrictive means, such as trade secrets

2 or other proprietary research, technical, marketing, development, or commercial

3 information. Access shall be limited to Outside Counsel of Record, their staff, experts,

4 and the Court.”

5 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their

6 support staff).

7 2.6 Designating Party: a Party or Non-Party that designates information or

8 items that it produces in disclosures or in responses to discovery as

9 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-AEO.”

10 2.7 Disclosure or Discovery Material: all items or information, regardless

11 of the medium or manner in which it is generated, stored, or maintained (including,

12 among other things, testimony, transcripts, and tangible things) that are produced or

13 generated in disclosures or responses to discovery in this matter.

14 2.8 Expert: a person with specialized knowledge or experience in a matter

15 pertinent to the litigation who has been retained by a Party or its counsel to serve as

16 an expert witness or as a consultant in this Action.

17 2.9 House Counsel: attorneys who are employees of a party to this Action.

18 House Counsel does not include Outside Counsel of Record or any other outside

19 counsel.

20 2.10 Non-Party: any natural person, partnership, corporation, association or

21 other legal entity not named as a Party to this action.

22 2.11 Outside Counsel of Record: attorneys who are not employees of a party

23 to this Action but are retained to represent or advise a party to this Action and have

24 appeared in this Action on behalf of that party or are affiliated with a law firm that

25 has appeared on behalf of that party, and includes support staff.

26 2.12 Party: any party to this Action, including all of its officers, directors,

27 employees, consultants, retained experts, and Outside Counsel of Record (and their

1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this Action.

3 2.14 Professional Vendors: persons or entities that provide litigation support

4 services (e.g., photocopying, videotaping, translating, preparing exhibits or

5 demonstrations, and organizing, storing, or retrieving data in any form or medium)

6 and their employees and subcontractors.

7 2.15 Protected Material: any Disclosure or Discovery Material that is

8 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-AEO.”

9 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material

10 from a Producing Party.

11 3. SCOPE

12 The protections conferred by this Stipulation and Order cover not only

13 Protected Material (as defined above), but also (1) any information copied or extracted

14 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

15 Protected Material; and (3) any testimony, conversations, or presentations by Parties

16 or their Counsel that might reveal Protected Material.

17 Any use of Protected Material at trial shall be governed by the orders of the

18 trial judge. This Order does not govern the use of Protected Material at trial.

19 4. DURATION

20 Once a case proceeds to trial, information that was designated as

21 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-AEO” or maintained pursuant

22 to this protective order used or introduced as an exhibit at trial becomes public and

23 will be presumptively available to all members of the public, including the press,

24 unless compelling reasons supported by specific factual findings to proceed otherwise

25 are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-

26 81 (distinguishing “good cause” showing for sealing documents produced in

27 discovery from “compelling reasons” standard when merits-related documents are

1 beyond the commencement of the trial.

2 5. DESIGNATING PROTECTED MATERIAL

3 5.1 Exercise of Restraint and Care in Designating Material for Protection.

4 Each Party or Non-Party that designates information or items for protection

5 under this Order must take care to limit any such designation to specific material that

6 qualifies under the appropriate standards. The Designating Party must designate for

7 protection only those parts of material, documents, items or oral or written

8 communications that qualify so that other portions of the material, documents, items

9 or communications for which protection is not warranted are not swept unjustifiably

10 within the ambit of this Order.

11 Mass, indiscriminate or routinized designations are prohibited. Designations

12 that are shown to be clearly unjustified or that have been made for an improper

13 purpose (e.g., to unnecessarily encumber the case development process or to impose

14 unnecessary expenses and burdens on other parties) may expose the Designating Party

15 to sanctions.

16 If it comes to a Designating Party’s attention that information or items that it

17 designated for protection do not qualify for protection at that level, that Designating

18 Party must promptly notify all other Parties that it is withdrawing the inapplicable

19 designation.

20 5.2 Manner and Timing of Designations. Except as otherwise provided in

21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

23 under this Order must be clearly so designated before the material is disclosed or

24 produced.

25 Designation in conformity with this Order requires:

26 (a) for information in documentary form (e.g., paper or electronic

27 documents, but excluding transcripts of depositions or other pretrial or trial

1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-AEO” (hereinafter

2 “CONFIDENTIAL legend” or “AEO legend”, respectively), to each page that

3 contains protected material. If only a portion of the material on a page qualifies for

4 protection, the Producing Party also must clearly identify the protected portion(s)

5 (e.g., by making appropriate markings in the margins).

6 A Party or Non-Party that makes original documents available for inspection

7 need not designate them for protection until after the inspecting Party has indicated

8 which documents it would like copied and produced. During the inspection and

9 before the designation, all of the material made available for inspection shall be

10 deemed “HIGHLY CONFIDENTIAL-AEO.” After the inspecting Party has

11 identified the documents it wants copied and produced, the Producing Party must

12 determine which documents, or portions thereof, qualify for protection under this

13 Order. Then, before producing the specified documents, the Producing Party must

14 affix the “CONFIDENTIAL legend” or “AEO legend” legend to each page that

15 contains Protected Material. If only a portion of the material on a page qualifies for

16 protection, the Producing Party also must clearly identify the protected portion(s)

17 (e.g., by making appropriate markings in the margins).

18 (b) for testimony given in depositions that the Designating Party identifies

19 the Disclosure or Discovery Material on the record, before the close of the deposition

20 all protected testimony and specifies the level of protection being asserted

21 (CONFIDENTIAL or HIGHLY CONFIDENTIAL-AEO).

22 (c) for information produced in some form other than documentary and for

23 any other tangible items, that the Producing Party affix in a prominent place on the

24 exterior of the container or containers in which the information is stored the legend

25 “CONFIDENTIAL” or “AEO legend.” If only a portion or portions of the

26 information warrants protection, the Producing Party, to the extent practicable, shall

27 identify the protected portion(s) and level.

1 failure to designate qualified information or items does not, standing alone, waive the

2 Designating Party’s right to secure protection under this Order for such material.

3 Upon timely correction of a designation, the Receiving Party must make reasonable

4 efforts to assure that the material is treated in accordance with the provisions of this

5 Order.

6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

7 6.1 Timing of Challenges. Any Party may challenge a designation of

8 confidentiality at any time that is consistent with the Court’s Scheduling Order.

9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

10 resolution process under Local Rule 37.1 et seq.

11 6.3 The burden of persuasion in any such challenge proceeding shall be on

12 the Designating Party. Frivolous challenges, and those made for an improper purpose

13 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

14 expose the Challenging Party to sanctions. Unless the Designating Party has waived

15 or withdrawn the confidentiality designation, all parties shall continue to afford the

16 material in question the level of protection to which it is entitled under the Producing

17 Party’s designation until the Court rules on the challenge.

18 7. ACCESS TO AND USE OF PROTECTED MATERIAL

19 7.1 Basic Principles. A Receiving Party may use Protected Material that is

20 disclosed or produced by another Party or by a Non-Party in connection with this

21 Action only for prosecuting, defending or attempting to settle this Action. Such

22 Protected Material may be disclosed only to the categories of persons and under the

23 conditions described in this Order. When the Action has been terminated, a Receiving

24 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

25 Protected Material must be stored and maintained by a Receiving Party at a

26 location and in a secure manner that ensures that access is limited to the persons

27 authorized under this Order.

1 otherwise ordered by the court or permitted in writing by the Designating Party, a

2 Receiving Party may disclose any information or item designated

3 “CONFIDENTIAL” only to:

4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

5 as employees of said Outside Counsel of Record to whom it is reasonably necessary

6 to disclose the information for this Action;

7 (b) the officers, directors, and employees (including House Counsel) of the

8 Receiving Party to whom disclosure is reasonably necessary for this Action;

9 (c) Experts (as defined in this Order) of the Receiving Party to whom

10 disclosure is reasonably necessary for this Action and who have signed the

11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

12 (d) the court and its personnel;

13 (e) court reporters and their staff;

14 (f) professional jury or trial consultants, mock jurors, and Professional

15 Vendors to whom disclosure is reasonably necessary for this Action and who have

16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

17 (g) the author or recipient of a document containing the information or a

18 custodian or other person who otherwise possessed or knew the information;

19 (h) during their depositions, witnesses, and attorneys for witnesses, in the

20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

21 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

22 not be permitted to keep any confidential information unless they sign the

23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

24 agreed by the Designating Party or ordered by the court. Pages of transcribed

25 deposition testimony or exhibits to depositions that reveal Protected Material may be

26 separately bound by the court reporter and may not be disclosed to anyone except as

27 permitted under this Stipulated Protective Order; and

1 mutually agreed upon by any of the parties engaged in settlement discussions.

2 7.3 Disclosure of “HIGHLY CONFIDENTIAL-AEO” Information or Items.

3 Unless otherwise ordered by the court or permitted in writing by the Designating

4 Party, a Receiving Party may disclose any information or item designated “HIGHLY

5 CONFIDENTIAL-AEO” only to:

6 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

7 as employees of said Outside Counsel of Record to whom it is reasonably necessary

8 to disclose the information for this Action;

9 (b) Experts of the Receiving Party (1) to whom disclosure is reasonably

10 necessary for this Action, (2) who have signed the “Acknowledgment and Agreement

11 to Be Bound” (Exhibit A), and (3) as to whom the procedures set forth in paragraph

12 7.4, below, have been followed;

13 (c) the court and its personnel;

14 (d) court reporters and their staff;

15 (e) professional jury or trial consultants, mock jurors, and Professional

16 Vendors to whom disclosure is reasonably necessary for this Action and who have

17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); and

18 (f) the author or recipient of a document containing the information or a

19 custodian or other person who otherwise possessed or knew the information.

20 7.4 Procedures for Approving or Objecting to Disclosure of “HIGHLY

21 CONFIDENTIAL-AEO” Information or Items to Experts.

22 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-AEO” information or

23 items may be disclosed to an Expert without disclosure of the identity of the Expert

24 as long as the Expert is not a current officer, director, or employee of a competitor of

25 a Party or anticipated to become one.

26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

27 OTHER LITIGATION

1 that compels disclosure of any information or items designated in this Action as

2 “CONFIDENTIAL,” that Party must:

3 (a) promptly notify in writing the Designating Party. Such notification shall

4 include a copy of the subpoena or court order;

5 (b) promptly notify in writing the party who caused the subpoena or order

6 to issue in the other litigation that some or all of the material covered by the subpoena

7 or order is subject to this Protective Order. Such notification shall include a copy of

8 this Stipulated Protective Order; and

9 (c) cooperate with respect to all reasonable procedures sought to be pursued

10 by the Designating Party whose Protected Material may be affected.

11 If the Designating Party timely seeks a protective order, the Party served with

12 the subpoena or court order shall not produce any information designated in this action

13 as “CONFIDENTIAL” before a determination by the court from which the subpoena

14 or order issued, unless the Party has obtained the Designating Party’s permission. The

15 Designating Party shall bear the burden and expense of seeking protection in that court

16 of its confidential material and nothing in these provisions should be construed as

17 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

18 directive from another court.

19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

20 PRODUCED IN THIS LITIGATION

21 (a) The terms of this Order are applicable to information produced by a Non-

22 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY

23 CONFIDENTIAL-AEO.” Such information produced by Non-Parties in connection

24 with this litigation is protected by the remedies and relief provided by this Order.

25 Nothing in these provisions should be construed as prohibiting a Non-Party from

26 seeking additional protections.

27 (b) In the event that a Party is required, by a valid discovery request, to produce

1 agreement with the Non-Party not to produce the Non-Party’s confidential

2 information, then the Party shall:

3 (1) promptly notify in writing the Requesting Party and the Non-Party that

4 some or all of the information requested is subject to a confidentiality agreement with

5 a Non-Party;

6 (2) promptly provide the Non-Party with a copy of the Stipulated

7 Protective Order in this Action, the relevant discovery request(s), and a reasonably

8 specific description of the information requested; and

9 (3) make the information requested available for inspection by the Non-

10 Party, if requested.

11 (c) If the Non-Party fails to seek a protective order from this court within 14

12 days of receiving the notice and accompanying information, the Receiving Party may

13 produce the Non-Party’s confidential information responsive to the discovery request.

14 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

15 any information in its possession or control that is subject to the confidentiality

16 agreement with the Non-Party before a determination by the court. Absent a court

17 order to the contrary, the Non-Party shall bear the burden and expense of seeking

18 protection in this court of its Protected Material.

19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

21 Protected Material to any person or in any circumstance not authorized under this

22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

23 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

24 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

25 persons to whom unauthorized disclosures were made of all the terms of this Order,

26 and (d) request such person or persons to execute the “Acknowledgment and

27 Agreement to Be Bound” that is attached hereto as Exhibit A.

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

2 PROTECTED MATERIAL

3 When a Producing Party gives notice to Receiving Parties that certain

4 inadvertently produced material is subject to a claim of privilege or other protection,

5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

7 may be established in an e-discovery order that provides for production without prior

8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

9 parties reach an agreement on the effect of disclosure of a communication or

10 information covered by the attorney-client privilege or work product protection, the

11 parties may incorporate their agreement in the stipulated protective order submitted

12 to the court.

13 12. MISCELLANEOUS

14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

15 person to seek its modification by the Court in the future.

16 12.2 Right to Assert Other Objections. By stipulating to the entry of this

17 Protective Order, no Party waives any right it otherwise would have to object to

18 disclosing or producing any information or item on any ground not addressed in this

19 Stipulated Protective Order. Similarly, no Party waives any right to object on any

20 ground to use in evidence of any of the material covered by this Protective Order.

21 12.3 Filing Protected Material. A Party that seeks to file under seal any

22 Protected Material must comply with Local Civil Rule 79-5. Protected Material may

23 only be filed under seal pursuant to a court order authorizing the sealing of the specific

24 Protected Material at issue. If a Party’s request to file Protected Material under seal

25 is denied by the court, then the Receiving Party may file the information in the public

26 record unless otherwise instructed by the court.

27 13. FINAL DISPOSITION

1 days of a written request by the Designating Party, each Receiving Party must return

2 all Protected Material to the Producing Party or destroy such material. As used in this

3 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

4 summaries, and any other format reproducing or capturing any of the Protected

5 Material. Whether the Protected Material is returned or destroyed, the Receiving

6 Party must submit a written certification to the Producing Party (and, if not the same

7 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

8 (by category, where appropriate) all the Protected Material that was returned or

9 destroyed and (2) affirms that the Receiving Party has not retained any copies,

10 abstracts, compilations, summaries or any other format reproducing or capturing any

11 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

12 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

13 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

14 reports, attorney work product, and consultant and expert work product, even if such

15 materials contain Protected Material. Any such archival copies that contain or

16 constitute Protected Material remain subject to this Protective Order as set forth in

17 Section 4 (DURATION).

18 14. VIOLATION

19 Any violation of this Order may be punished by appropriate measures

20 including, without limitation, contempt proceedings and/or monetary sanctions.

21

22 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

23

24 DATED: December 2, 2025

25 __/_s_/ U__ye_n_ N__gu_y_e_n_ _______________________

Steven A. Heath

26 Uyen Nguyen

27 Attorneys for Plaintiff

1 || DATED: December 2, 2025

2 /s/ Stephen Farkas

Genevieve Walser-Jolly

3 Stephen P. Farkas

4 Andrew Yu-Chih

Attorneys for Defendants

5 || TIMELESS COSMETICS, LLC,

TIMELESS SKIN CARE LLC,

6 || VERONICA PEDERSEN, AND

ALEX PEDERSON

8 SIGNATURE CERTIFICATION

9 Pursuant to L.R. 5-4.3.4(a)(2)@), I certify that all other signatories listed, and

10 || on whose behalf the filing is submitted, concur in the filing’s content and have

11 || authorized the filing.

12

13 /s/ Stephen Farkas

4 Stephen P. Farkas

15

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

16

17

DATED: 12/4/2025

18

Raythn Oy, OC

20 || HON.SROZELLA A. OLIVER

5 United States Magistrate Judge

22

23

24

25

26

27

28

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [print or type full name], of

4 _________________ [print or type full address], declare under penalty of perjury that

5 I have read in its entirety and understand the Stipulated Protective Order that was

6 issued by the United States District Court for the Central District of California on

7 [date] in the case of BYOAPPS, LLC v. TIMELESS COSMETICS, LLC, et al; United

8 States District Court Central District of California Case No. 2:25-CV-1925-RAO. I

9 agree to comply with and to be bound by all the terms of this Stipulated Protective

10 Order and I understand and acknowledge that failure to so comply could expose me

11 to sanctions and punishment in the nature of contempt. I solemnly promise that I will

12 not disclose in any manner any information or item that is subject to this Stipulated

13 Protective Order to any person or entity except in strict compliance with the

14 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 enforcing the terms of this Stipulated

17 Protective Order, even if such enforcement proceedings occur after termination of this

18 action. I hereby appoint __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

20 telephone number] as my California agent for service of process in connection with

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25 Printed name: _______________________________

26

27 Signature: __________________________________