even 16 stipulated protective orders require good cause showing
How later courts described this case
- even 16 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 STEPTOE LLP
STEPHEN J. NEWMAN (SBN 181570)
2 snewman@steptoe.com
CHAITRA G. BETAGERI (SBN 312760)
3
cbetageri@steptoe.com
4 2029 Century Park East, Suite 980
Los Angeles, California 90067
5 Telephone: (213) 439-9400
Facsimile: (213) 439-9599
6
Email: docketing@steptoe.com
7
Attorneys for Defendant
8 AMERICAN EXPRESS NATIONAL BANK
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA
11
12
KHARY LEWIS II, ) Case No. 2:25-cv-04238-SVW-MBK
13 )
Plaintiff, ) [Assigned to Hon. Stephen V. Wilson]
14 )
v. STIPULATION PROTECTIVE
)
15 ORDER
EXPERIAN INFORMATION )
16 SOLUTIONS, INC.; TRANS UNION, ) Complaint Filed: May 9, 2025
LLC; AMERICAN EXPRESS )
17
COMPANY; and CAPITAL ONE, N.A., )
18 )
Defendants. )
19 )
)
20
)
21 )
)
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)
23 )
)
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1 1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 2. GOOD CAUSE STATEMENT
12 This action is likely to involve trade secrets and other valuable research,
13 development, commercial, financial, technical and/or proprietary information for
14 which special protection from public disclosure and from use for any purpose other
15 than prosecution of this action is warranted. Such confidential and proprietary
16 materials and information consist of, among other things, confidential business or
17 financial information, information regarding confidential business practices, or other
18 confidential research, development, or commercial information (including
19 information implicating privacy rights of third parties), information otherwise
20 generally unavailable to the public, or which may be privileged or otherwise
21 protected from disclosure under state or federal statutes, court rules, case decisions,
22 or common law. Accordingly, to expedite the flow of information, to facilitate the
23 prompt resolution of disputes over confidentiality of discovery materials, to
24 adequately protect information the parties are entitled to keep confidential, to ensure
25 that the parties are permitted reasonable necessary uses of such material in
26 preparation for and in the conduct of trial, to address their handling at the end of the
27 litigation, and serve the ends of justice, a protective order for such information is
28 justified in this matter. It is the intent of the parties that information will not be
1 designated as confidential for tactical reasons and that nothing be so designated
2 without a good faith belief that it has been maintained in a confidential, non-public
3 manner, and there is good cause why it should not be part of the public record of this
4 case.
5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
6 The parties further acknowledge, as set forth in Section 14.3, below, that this
7 Stipulated Protective Order does not entitle them to file confidential information
8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
9 the standards that will be applied when a party seeks permission from the court to file
10 material under seal. There is a strong presumption that the public has a right of
11 access to judicial proceedings and records in civil cases. In connection with non-
12 dispositive motions, good cause must be shown to support a filing under seal. See
13 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
14 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
15 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
16 stipulated protective orders require good cause showing), and a specific showing of
17 good cause or compelling reasons with proper evidentiary support and legal
18 justification, must be made with respect to Protected Material that a party seeks to
19 file under seal. The parties’ mere designation of Disclosure or Discovery Material as
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 Further, if a party requests sealing related to a dispositive motion or trial, then
24 compelling reasons, not only good cause, for the sealing must be shown, and the
25 relief sought shall be narrowly tailored to serve the specific interest to be protected.
26 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For
27 each item or type of information, document, or thing sought to be filed or introduced
28 under seal, the party seeking protection must articulate compelling reasons,
1 supported by specific facts and legal justification, for the requested sealing order.
2 Again, competent evidence supporting the application to file documents under seal
3 must be provided by declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in
5 its entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting only
7 the confidential, privileged, or otherwise protectable portions of the document, shall
8 be filed. Any application that seeks to file documents under seal in their entirety
9 should include an explanation of why redaction is not feasible.
10 4. DEFINITIONS
11 4.1 Action: this pending federal lawsuit, titled Khary Lewis II v. Experian
12 Information Solutions, Inc., et al., C.D. Cal., Case No. 2:25-cv-04238-SVW-MBK.
13 4.2 Challenging Party: a Party or Non-Party that challenges the designation
14 of information or items under this Order.
15 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
18 Good Cause Statement.
19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 4.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
24 ONLY.”
25 4.6 Disclosure or Discovery Material: all items or information, regardless of
26 the medium or manner in which it is generated, stored, or maintained (including,
27 among other things, testimony, transcripts, and tangible things), that are produced or
28 generated in disclosures or responses to discovery.
1 4.7 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as
3 an expert witness or as a consultant in this Action.
4 4.8 “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”
5 Information or Items: extremely sensitive and/or proprietary “CONFIDENTIAL”
6 Information or Items, the disclosure of which to another Party or Non-Party would
7 create a substantial risk of serious harm that could not be avoided by less restrictive
8 means.
9 4.9 House Counsel: attorneys who are employees of a party to this Action.
10 House Counsel does not include Outside Counsel of Record or any other outside
11 counsel.
12 4.10 Non-Party: any natural person, partnership, corporation, association or
13 other legal entity not named as a Party to this action.
14 4.11 Outside Counsel of Record: attorneys who are not employees of a party
15 to this Action but are retained to represent a party to this Action and have appeared
16 in this Action on behalf of that party or are affiliated with a law firm that has
17 appeared on behalf of that party, and includes support staff.
18 4.12 Party: any party to this Action, including all of its officers, directors,
19 employees, consultants, retained experts, and Outside Counsel of Record (and their
20 support staffs).
21 4.13 Producing Party: a Party or Non-Party that produces Disclosure or
22 Discovery Material in this Action.
23 4.14 Professional Vendors: persons or entities that provide litigation support
24 services (e.g., photocopying, videotaping, translating, preparing exhibits or
25 demonstrations, and organizing, storing, or retrieving data in any form or medium)
26 and their employees and subcontractors.
27
28
1 4.15 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --
3 ATTORNEYS’ EYES ONLY.”
4 4.16 Receiving Party: a Party that receives Disclosure or Discovery Material
5 from a Producing Party.
6 5. SCOPE
7 The protections conferred by this Stipulation and Order cover not only
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 presentations by Parties or their Counsel that might reveal Protected Material.
12 Any use of Protected Material at trial shall be governed by the orders of the
13 trial judge and other applicable authorities. This Order does not govern the use of
14 Protected Material at trial.
15 6. DURATION
16 Once a case proceeds to trial, information that was designated as
17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
18 as an exhibit at trial becomes public and will be presumptively available to all
19 members of the public, including the press, unless compelling reasons supported by
20 specific factual findings to proceed otherwise are made to the trial judge in advance
21 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
22 showing for sealing documents produced in discovery from “compelling reasons”
23 standard when merits-related documents are part of court record). Accordingly, the
24 terms of this protective order do not extend beyond the commencement of the trial.
25 7. DESIGNATING PROTECTED MATERIAL
26 7.1 Exercise of Restraint and Care in Designating Material for Protection.
27 Each Party or Non-Party that designates information or items for protection under
28 this Order must take care to limit any such designation to specific material that
1 qualifies under the appropriate standards. The Designating Party must designate for
2 protection only those parts of material, documents, items or oral or written
3 communications that qualify so that other portions of the material, documents, items
4 or communications for which protection is not warranted are not swept unjustifiably
5 within the ambit of this Order.
6 Mass, indiscriminate or routinized designations are prohibited. Designations
7 that are shown to be clearly unjustified or that have been made for an improper
8 purpose (e.g., to unnecessarily encumber the case development process or to impose
9 unnecessary expenses and burdens on other parties) may expose the Designating
10 Party to sanctions.
11 If it comes to a Designating Party’s attention that information or items that it
12 designated for protection do not qualify for protection, that Designating Party must
13 promptly notify all other Parties that it is withdrawing the inapplicable designation.
14 7.2 Manner and Timing of Designations. Except as otherwise provided in
15 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
16 that qualifies for protection under this Order must be clearly so designated before the
17 material is disclosed or produced.
18 Designation in conformity with this Order requires:
19 (a) for information in documentary form (e.g., paper or electronic
20 documents, but excluding transcripts of depositions or other pretrial or trial
21 proceedings), that the Producing Party affix at a minimum, the legend
22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY
23 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (the “HIGHLY
24 CONFIDENTIAL legend”), to each page that contains protected material. If only a
25 portion of the material on a page qualifies for protection, the Producing Party also
26 must clearly identify the protected portion(s) (e.g., by making appropriate markings
27 in the margins).
28
1 A Party or Non-Party that makes original documents available for inspection
2 need not designate them for protection until after the inspecting Party has indicated
3 which documents it would like copied and produced. During the inspection and
4 before the designation, all of the material made available for inspection shall be
5 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
6 it wants copied and produced, the Producing Party must determine which documents,
7 or portions thereof, qualify for protection under this Order. Then, before producing
8 the specified documents, the Producing Party must affix the “CONFIDENTIAL
9 legend” or the “HIGHLY CONFIDENTIAL legend” to each page that contains
10 Protected Material. If only a portion of the material on a page qualifies for
11 protection, the Producing Party also must clearly identify the protected portion(s)
12 (e.g., by making appropriate markings in the margins).
13 (b) for testimony given in depositions that the Designating Party
14 identifies the Disclosure or Discovery Material on the record, before the close of the
15 deposition all protected testimony.
16 (c) for information produced in some form other than documentary
17 and for any other tangible items, that the Producing Party affix in a prominent place
18 on the exterior of the container or containers in which the information is stored the
19 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
20 EYES ONLY.” If only a portion or portions of the information warrants protection,
21 the Producing Party, to the extent practicable, shall identify the protected portion(s).
22 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
23 failure to designate qualified information or items does not, standing alone, waive the
24 Designating Party’s right to secure protection under this Order for such material.
25 Upon timely correction of a designation, the Receiving Party must make reasonable
26 efforts to assure that the material is treated in accordance with the provisions of this
27 Order.
28
1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1 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 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37-1 et seq.
7 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
8 joint stipulation pursuant to Local Rule 37-2.
9 8.4 The burden of persuasion in any such challenge proceeding shall be on
10 the Designating Party. Frivolous challenges, and those made for an improper purpose
11 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
12 expose the Challenging Party to sanctions. Unless the Designating Party has waived
13 or withdrawn the confidentiality designation, all parties shall continue to afford the
14 material in question the level of protection to which it is entitled under the Producing
15 Party’s designation until the Court rules on the challenge.
16 9. ACCESS TO AND USE OF PROTECTED MATERIAL
17 9.1 Basic Principles. A Receiving Party may use Protected Material that is
18 disclosed or produced by another Party or by a Non-Party in connection with this
19 Action only for prosecuting, defending or attempting to settle this Action. Such
20 Protected Material may be disclosed only to the categories of persons and under the
21 conditions described in this Order. When the Action has been terminated, a
22 Receiving Party must comply with the provisions of section 15 below (FINAL
23 DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
27 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
28 otherwise ordered by the court or permitted in writing by the Designating Party, a
1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
3 (a) the Receiving Party’s Outside Counsel of Record in this Action,
4 as well as employees of said Outside Counsel of Record to whom it is reasonably
5 necessary to disclose the information for this Action;
6 (b) the officers, directors, and employees (including House Counsel)
7 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
8 (c) Experts (as defined in this Order) of the Receiving Party to whom
9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (d) the court and its personnel;
12 (e) court reporters and their staff;
13 (f) professional jury or trial consultants, mock jurors, and
14 Professional Vendors to whom disclosure is reasonably necessary for this Action and
15 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (g) the author or recipient of a document containing the information
17 or a custodian or other person who otherwise possessed or knew the information;
18 (h) during their depositions, witnesses, and attorneys for witnesses, in
19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
20 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
21 they will not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may be
25 separately bound by the court reporter and may not be disclosed to anyone except as
26 permitted under this Stipulated Protective Order; and
27
28
1 (i) any mediators or settlement officers and their supporting
2 personnel, mutually agreed upon by any of the parties engaged in settlement
3 discussions.
4 9.3 Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
5 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
6 writing by the Designating Party, a Receiving Party may disclose any information or
7 item designated “HIGHLY CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
9 employees of said Outside Counsel of Record to whom it is reasonably necessary to
10 disclose the information for this Action;
11 (b) Experts (as defined in this Order) of the Receiving Party to whom
12 disclosure is reasonably necessary for this Action and who have signed the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (c) the court and its personnel;
15 (d) private court reporters and their staff to whom disclosure is reasonably
16 necessary for this Action and who have signed the “Acknowledgment and
17 Agreement to Be Bound” (Exhibit A);
18 (e) professional jury or trial consultants, mock jurors, and Professional
19 Vendors to whom disclosure is reasonably necessary for this Action and who have
20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (f) the author or recipient of a document containing the information or a
22 custodian or other person who otherwise possessed or knew the information; and
23 (g) any mediator or settlement officer, and their supporting personnel,
24 mutually agreed upon by any of the parties engaged in settlement discussions.
25 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
26 OTHER LITIGATION
27 If a Party is served with a subpoena or a court order issued in other litigation
28 that compels disclosure of any information or items designated in this Action as
1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
2 ONLY,”that Party must:
3 (a) promptly notify in writing the Designating Party. Such
4 notification shall include a copy of the subpoena or court order;
5 (b) promptly notify in writing the party who caused the subpoena or
6 order to issue in the other litigation that some or all of the material covered by the
7 subpoena or order is subject to this Protective Order. Such notification shall include a
8 copy of this Stipulated Protective Order; and
9 (c) cooperate with respect to all reasonable procedures sought to be
10 pursued by the Designating Party whose Protected Material may be affected. If the
11 Designating Party timely seeks a protective order, the Party served with the subpoena
12 or court order shall not produce any information designated in this action as
13 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
14 ONLY” before a determination by the court from which the subpoena or order
15 issued, unless the Party has obtained the Designating Party’s permission. The
16 Designating Party shall bear the burden and expense of seeking protection in that
17 court of its confidential material and nothing in these provisions should be construed
18 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
19 directive from another court.
20 11. 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
23 a Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
24 CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such information produced by
25 Non-Parties in connection with this litigation is protected by the remedies and relief
26 provided by this Order. Nothing in these provisions should be construed as
27 prohibiting a Non-Party from seeking additional protections.
28
1 (b) In the event that a Party is required, by a valid discovery request,
2 to produce a Non-Party’s confidential information in its possession, and the Party is
3 subject to an agreement with the Non-Party not to produce the Non-Party’s
4 confidential information, then the Party shall:
5 (1) promptly notify in writing the Requesting Party and the
6 Non-Party that some or all of the information requested is subject to a confidentiality
7 agreement with a Non-Party;
8 (2) promptly provide the Non-Party with a copy of the
9 Stipulated Protective Order in this Action, the relevant discovery request(s), and a
10 reasonably specific description of the information requested; and
11 (3) make the information requested available for inspection by
12 the Non-Party, if requested.
13 (c) If the Non-Party fails to seek a protective order from this court
14 within 14 days of receiving the notice and accompanying information, the Receiving
15 Party may produce the Non-Party’s confidential information responsive to the
16 discovery request. If the Non-Party timely seeks a protective order, the Receiving
17 Party shall not produce any information in its possession or control that is subject to
18 the confidentiality agreement with the Non-Party before a determination by the court.
19 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
20 of seeking protection in this court of its Protected Material.
21 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
23 Protected Material to any person or in any circumstance not authorized under this
24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
27 persons to whom unauthorized disclosures were made of all the terms of this Order,
28
1 and (d) request such person or persons to execute the “Acknowledgment an
2 Agreement to Be Bound” attached hereto as Exhibit A.
3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
4 PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that certain
6 inadvertently produced material is subject to a claim of privilege or other protection,
7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
9 may be established in an e-discovery order that provides for production without prior
10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
11 parties reach an agreement on the effect of disclosure of a communication or
12 information covered by the attorney-client privilege or work product protection, the
13 parties may incorporate their agreement in the stipulated protective order submitted
14 to the court.
15 14. MISCELLANEOUS
16 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
17 person to seek its modification by the Court in the future.
18 14.2 Right to Assert Other Objections. By stipulating to the entry of this
19 Protective Order, no Party waives any right it otherwise would have to object to
20 disclosing or producing any information or item on any ground not addressed in this
21 Stipulated Protective Order. Similarly, no Party waives any right to object on any
22 ground to use in evidence of any of the material covered by this Protective Order.
23 14.3 Filing Protected Material. A Party that seeks to file under seal any
24 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
25 only be filed under seal pursuant to a court order authorizing the sealing of the
26 specific Protected Material. If a Party’s request to file Protected Material under seal
27 is denied by the court, then the Receiving Party may file the information in the public
28 record unless otherwise instructed by the court.
1 15. FINAL DISPOSITION
2 After the final disposition of this Action, as defined in paragraph 6, within 60
3 days of a written request by the Designating Party, each Receiving Party must return
4 all Protected Material to the Producing Party or destroy such material. As used in this
5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected
7 Material. Whether the Protected Material is returned or destroyed, the Receiving
8 Party must submit a written certification to the Producing Party (and, if not the same
9 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
10 (by category, where appropriate) all the Protected Material that was returned or
11 destroyed and (2) affirms that the Receiving Party has not retained any copies,
12 abstracts, compilations, summaries or any other format reproducing or capturing any
13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
16 reports, attorney work product, and consultant and expert work product, even if such
17 materials contain Protected Material. Any such archival copies that contain or
18 constitute Protected Material remain subject to this Protective Order as set forth in
19 Section 6 (DURATION).
20 16. VIOLATION
21 Any violation of this Order may be punished by appropriate measures
22 including, without limitation, contempt proceedings and/or monetary sanctions.
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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 Dated: December 10, 2025 LOS ANGELES LEGAL SOLUTIONS
F. JAY RAHIMI
4
5
By: /s/ F. Jay Rahimi
6 F. Jay Rahimi
7
Attorneys for Plaintiff
8 KHARY LEWIS II
9
10 Dated: December 10, 2025 STEPTOE LLP
STEPHEN J. NEWMAN
11 CHAITRA G. BETAGERI
12
13 By: /s/ Chaitra G. Betageri
Chaitra G. Betageri
14
15 Attorneys for Defendant
AMERICAN EXPRESS NATIONAL
16 BANK
17
Quilling, Selander, Lownds,
18 Winslett & Moser, P.C.
19
Dated: December 10, 2025 By: /s/Jason S. Roberts
20
Jason S. Roberts
21 Attorneys for Defendant
TRANS UNION LLC
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| || Dated: December 10, 2025 DOLL AMIR & ELEY LLP
HUNTER R. ELEY
3
4 By: _/s/ Hunter R. Eley
5 HUNTER R. ELEY
6
Attorneys for Defendant
7 CAPITAL ONE, N.A.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
12 ;
13 || DATED: — 12/11/2025 Je-CL Kid
MICHAEL B. FMAN
14 United States Magistrate Judge
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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 that I have read in its
6 entirety and understand the Stipulated Protective Order that was issued by the United
7 States District Court for the Central District of California in the case of Khary Lewis
8 II v. Experian Information Solutions, Inc., et al., Case No. 2:25-cv-04238-SVW-
9 MBK. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly
12 promise that I will not disclose in any manner any information or item that is subject
13 to this Stipulated Protective Order to any person or entity except in strict compliance
14 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 or type
19 full name] of _____________________________________________________
20 [print or type full address and telephone number] as my California agent for service
21 of process in connection with this action or any proceedings related to enforcement
22 of this Stipulated Protective Order.
23 Date: _________________________
24 City and State where sworn and signed: ___________________________________
25 Printed name: _____________________________
26 Signature: ________________________________
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1 SIGNATURE CERTIFICATION
2 Pursuant to L.R. 5-4.3.4(a)(2), I, Chaitra G. Betageri, hereby certify that the
3 content of this Stipulation and Proposed Protective Order is acceptable to all parties
4 who are required to sign this stipulation. All parties have authorized me to affix the
5 CM/ECF signatures to this document.
6
7 /s/ Chaitra G. Betageri
Chaitra G. Betageri
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1 CERTIFICATE OF SERVICE
2 I hereby certify that on December 10, 2025, a copy of the foregoing
3 STIPULATION AND PROPOSED PROTECTIVE ORDER was filed
4 electronically and served by U.S. Mail on anyone unable to accept electronic filing.
5 Notice of this filing will be sent by e-mail to all parties by operation of the court’s
6 electronic filing system or by mail to anyone unable to accept electronic filing as
7 indicated on the Notice of Electronic Filing. Parties may access this filing through
8 the court’s CM/ECF System.
9
10 /s/ Chaitra G. Betageri
Chaitra G. Betageri
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