The opinion
1 Jordan Ashley Duncan-Smith, Esq. (SBN 354658)
DOWNTOWN L.A. LAW GROUP
2 612 S Broadway
Los Angeles, CA 90014
3 Tel: (213) 389-3765
Fax: (877) 389-2775
4 jordan@downtownlalaw.com
5 Attorneys for Plaintiff, SHAWN MCSPADDEN
6 ***************************
7 ZACHARY S. TOLSON, ESQUIRE - State Bar #242824
GANETTE M. GENETTI - State Bar #256707
8 GOODMAN NEUMAN HAMILTON LLP
100 Bush Street, Suite 1800
9 San Francisco, California 94104
Telephone: (415) 705-0400
10 Facsimile: (415) 705-0411
ztolson@gnhllp.com; ggenetti@gnhllp.com
11
Attorneys for Defendant, HOME DEPOT U.S.A., INC.
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13 UNITED STATES DISTRICT COURT
14 EASTERN DISTRICT OF CALIFORNIA
15
16 SHAWN MCSPADDEN, an Case No. 1:25-cv-01021-BAM
individual,
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[PROPOSED] STIPULATED
Plaintiff,
18 PROTECTIVE ORDER
vs.
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HOME DEPOT U.S.A., INC., a
20 Delaware corporation; DOE 1 (STORE
MANAGER); DOES 2-50, inclusive,
21
Defendants.
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23
24
25 1. PURPOSES AND LIMITATIONS
26 Disclosure and discovery activity in this action are likely to involve production of
27 confidential, proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation may be
1 warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the
2 following Stipulated Protective Order. The parties acknowledge that this Order does not
3 confer blanket protections on all disclosures or responses to discovery and that the
4 protection it affords from public disclosure and use extends only to the limited
5 information or items that are entitled to confidential treatment under the applicable legal
6 principles. The parties further acknowledge, as set forth in Section 12.3, below, that this
7 Stipulated Protective Order does not entitle them to file confidential information under
8 seal; Civil Local Rules 140, 141 and 141.1 set forth the procedures that must be followed
9 and the standards that will be applied when a party seeks permission from the court to file
10 material under seal.
11 2. DEFINITIONS
12 2.1 Challenging Party: a Party or Non-Party that challenges the designation of
13 information or items under this Order.
14 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it
15 is generated, stored or maintained) or tangible things that qualify for protection under
16 Federal Rule of Civil Procedure 26(c).
17 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel
18 (as well as their support staff).
19 2.4 Designating Party: a Party or Non-Party that designates information or
20 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
21 2.5 Disclosure or Discovery Material: all items or information, regardless of the
22 medium or manner in which it is generated, stored, or maintained (including, among other
23 things, testimony, transcripts, and tangible things), that are produced or generated in
24 disclosures or responses to discovery in this matter.
25 2.6 Expert: a person with specialized knowledge or experience in a matter
26 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
27 expert witness or as a consultant in this action.
2.7 House Counsel: attorneys who are employees of a party to this action.
1 House Counsel does not include Outside Counsel of Record or any other outside counsel.
2 2.8 Non-Party: any natural person, partnership, corporation, association, or
3 other legal entity not named as a Party to this action.
4 2.9 Outside Counsel of Record: attorneys who are not employees of a party to
5 this action but are retained to represent or advise a party to this action and have appeared
6 in this action on behalf of that party or are affiliated with a law firm which has appeared
7 on behalf of that party.
8 2.10 Party: any party to this action, including all of its officers, directors,
9 employees, consultants, retained experts, and Outside Counsel of Record (and their
10 support staffs).
11 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
12 Discovery Material in this action.
13 2.12 Professional Vendors: persons or entities that provide litigation support
14 services (e.g., photocopying, videotaping, translating, preparing exhibits or
15 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
16 their employees and subcontractors.
17 2.13 Protected Material: any Disclosure or Discovery Material that is designated
18 as “CONFIDENTIAL.”
19 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
20 from a Producing Party.
21 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only Protected
23 Material (as defined above), but also (1) any information copied or extracted from
24 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
25 Material; and (3) any testimony, conversations, or presentations by Parties or their
26 Counsel that might reveal Protected Material. However, the protections conferred by this
27 Stipulation and Order do not cover the following information: (a) any information that is
in the public domain at the time of disclosure to a Receiving Party or becomes part of the
1 public domain after its disclosure to a Receiving Party as a result of publication not
2 involving a violation of this Order, including becoming part of the public record through
3 trial or otherwise; and (b) any information known to the Receiving Party prior to the
4 disclosure or obtained by the Receiving Party after the disclosure from a source who
5 obtained the information lawfully and under no obligation of confidentiality to the
6 Designating Party. Any use of Protected Material at trial shall be governed by a separate
7 agreement or order.
8 4. DURATION
9 Even after final disposition of this litigation, the confidentiality obligations
10 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in
11 writing or a court order otherwise directs. Final disposition shall be deemed to be the later
12 of (1) dismissal of all claims and defenses in this action, with or without prejudice; and (2)
13 final judgment herein after the completion and exhaustion of all appeals, rehearings,
14 remands, trials, or reviews of this action, including the time limits for filing any motions
15 or applications for extension of time pursuant to applicable law.
16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
18 Party or Non-Party that designates information or items for protection under this Order
19 must take care to limit any such designation to specific material that qualifies under the
20 appropriate standards. The Designating Party must designate for protection only those
21 parts of material, documents, items, or oral or written communications that qualify – so
22 that other portions of the material, documents, items, or communications for which
23 protection is not warranted are not swept unjustifiably within the ambit of this Order.
24 Mass, indiscriminate, or routinized designations are prohibited. Designations that
25 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
26 to unnecessarily encumber or delay the case development process or to impose
27 unnecessary expenses and burdens on other parties) expose the Designating Party to
sanctions.
1 If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the mistaken designation.
4 5.2 Manner and Timing of Designations. Except as otherwise provided in this
5 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
6 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
7 must be clearly so designated before the material is disclosed or produced.
8 Designation in conformity with this Order requires:
9 (a) for information in documentary form (e.g., paper or electronic documents, but
10 excluding transcripts of depositions or other pretrial or trial proceedings), that the
11 Producing Party affix the legend “CONFIDENTIAL” to each page that contains protected
12 material. If only a portion or portions of the material on a page qualifies for protection, the
13 Producing Party also must clearly identify the protected portion(s) (e.g., by making
14 appropriate markings in the margins). A Party or Non-Party that makes original
15 documents or materials available for inspection need not designate them for protection
16 until after the inspecting Party has indicated which material it would like copied and
17 produced. During the inspection and before the designation, all of the material made
18 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party
19 has identified the documents it wants copied and produced, the Producing Party must
20 determine which documents, or portions thereof, qualify for protection under this 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 Party
24 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
25 in the margins).
26 (b) for testimony given in deposition or in other pretrial or trial proceedings, that
27 the Designating Party identify on the record, before the close of the deposition, hearing, or
other proceeding, all protected testimony.
1 (c) for information produced in some form other than documentary and for any
2 other tangible items, that the Producing Party affix in a prominent place on the exterior of
3 the container or containers in which the information or item is stored the legend
4 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant
5 protection, the Producing Party, to the extent practicable, shall identify the protected
6 portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
8 to designate qualified information or items does not, standing alone, waive the
9 Designating Party’s right to secure protection under this Order for such material. Upon
10 timely correction of a designation, the Receiving Party must make reasonable efforts to
11 assure that the material is treated in accordance with the provisions of this Order.
12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
14 of confidentiality at any time. Unless a prompt challenge to a Designating Party’s
15 confidentiality designation is necessary to avoid foreseeable, substantial unfairness,
16 unnecessary economic burdens, or a significant disruption or delay of the litigation, a
17 Party does not waive its right to challenge a confidentiality designation by electing not to
18 mount a challenge promptly after the original designation is disclosed.
19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
20 process by providing written notice of each designation it is challenging and describing
21 the basis for each challenge. To avoid ambiguity as to whether a challenge has been made,
22 the written notice must recite that the challenge to confidentiality is being made in
23 accordance with this specific paragraph of the Protective Order. The parties shall attempt
24 to resolve each challenge in good faith and must begin the process by conferring directly
25 (in voice-to-voice dialogue; other forms of communication are not sufficient) within 14
26 days of the date of service of notice. In conferring, the Challenging Party must explain the
27 basis for its belief that the confidentiality designation was not proper and must give the
Designating Party an opportunity to review the designated material, to reconsider the
1 circumstances, and, if no change in designation is offered, to explain the basis for the
2 chosen designation. A Challenging Party may proceed to the next stage of the challenge
3 process only if it has engaged in this meet and confer process first or establishes that the
4 Designating Party is unwilling to participate in the meet and confer process in a timely
5 manner.
6 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
7 intervention, the Designating Party shall file and serve a motion to retain confidentiality
8 under Civil Local Rules 140, 141, and 141.1 (and in compliance with Civil Local Rule
9 230, if applicable) within 21 days of the initial notice of challenge or within 14 days of the
10 parties agreeing that the meet and confer process will not resolve their dispute, whichever
11 is earlier. Each such motion must be accompanied by a competent declaration affirming
12 that the movant has complied with the meet and confer requirements imposed in the
13 preceding paragraph. Failure by the Designating Party to make such a motion including
14 the required declaration within 21 days (or 14 days, if applicable) shall automatically
15 waive the confidentiality designation for each challenged designation. In addition, the
16 Challenging Party may file a motion challenging a confidentiality designation at any time
17 if there is good cause for doing so, including a challenge to the designation of a deposition
18 transcript or any portions thereof. Any motion brought pursuant to this provision must be
19 accompanied by a competent declaration affirming that the movant has complied with the
20 meet and confer requirements imposed by the preceding paragraph.
21 The burden of persuasion in any such challenge proceeding shall be on the
22 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to
23 harass or impose unnecessary expenses and burdens on other parties) may expose the
24 Challenging Party to sanctions. Unless the Designating Party has waived the
25 confidentiality designation by failing to file a motion to retain confidentiality as described
26 above, all parties shall continue to afford the material in question the level of protection to
27 which it is entitled under the Producing Party’s designation until the court rules on the
challenge.
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this case
4 only for prosecuting, defending, or attempting to settle this litigation. Such Protected
5 Material may be disclosed only to the categories of persons and under the conditions
6 described in this Order. When the litigation has been terminated, a Receiving Party must
7 comply with the provisions of section 13 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a location and
9 in a secure manner that ensures that access is limited to the persons authorized under this
10 Order.
11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
12 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
13 may disclose any information or item designated “CONFIDENTIAL” only to:
14 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
15 employees of said Outside Counsel of Record to whom it is reasonably necessary to
16 disclose the information for this litigation and who have signed the “Acknowledgment and
17 Agreement to Be Bound” that is attached hereto as Exhibit A;
18 (b) the officers, directors, and employees (including House Counsel) of the
19 Receiving Party to whom disclosure is reasonably necessary for this litigation and who
20 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
22 reasonably necessary for this litigation and who have signed the “Acknowledgment and
23 Agreement to Be Bound” (Exhibit A);
24 (d) the court and its personnel;
25 (e) court reporters and their staff, professional jury or trial consultants, mock
26 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
27 litigation and who have signed the “Acknowledgment and Agreement to Be Bound”
(Exhibit A);
1 (f) during their depositions, witnesses in the action to whom disclosure is
2 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be
3 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the
4 court. Pages of transcribed deposition testimony or exhibits to depositions that reveal
5 Protected Material must be separately bound by the court reporter and may not be
6 disclosed to anyone except as permitted under this Stipulated Protective Order.
7 (g) the author or recipient of a document containing the information or a custodian
8 or other person who otherwise possessed or knew the information.
9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
10 OTHER LITIGATION
11 If a Party is served with a subpoena or a court order issued in other litigation that
12 compels disclosure of any information or items designated in this action as
13 “CONFIDENTIAL,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification shall
15 include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or order to issue
17 in the other litigation that some or all of the material covered by the subpoena or order is
18 subject to this Protective Order. Such notification shall include a copy of this Stipulated
19 Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
21 Designating Party whose Protected Material may be affected.
22 If the Designating Party timely seeks a protective order, the Party served with the
23 subpoena or court order shall not produce any information designated in this action as
24 “CONFIDENTIAL” before a determination by the court from which the subpoena or
25 order issued, unless the Party has obtained the Designating Party’s permission. The
26 Designating Party shall bear the burden and expense of seeking protection in that court of
27 its confidential material – and nothing in these provisions should be construed as
authorizing or encouraging a Receiving Party in this action to disobey a lawful directive
1 from another court.
2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
3 PRODUCED IN THIS LITIGATION
4 (a) The terms of this Order are applicable to information produced by a Non-Party
5 in this action and designated as “CONFIDENTIAL.” Such information produced by Non-
6 Parties in connection with this litigation is protected by the remedies and relief provided
7 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party
8 from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request, to produce a
10 Non-Party’s confidential information in its possession, and the Party is subject to an
11 agreement with the Non-Party not to produce the Non-Party’s confidential information,
12 then the Party shall:
13 (1) promptly notify in writing the Requesting Party and the Non-Party that some or
14 all of the information requested is subject to a confidentiality agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order
16 in this litigation, the relevant discovery request(s), and a reasonably specific description of
17 the information requested; and
18 (3) make the information requested available for inspection by the Non-Party.
19 (c) If the Non-Party fails to object or seek a protective order from this court within
20 14 days of receiving the notice and accompanying information, the Receiving Party may
21 produce the Non-Party’s confidential information responsive to the discovery request. If
22 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
23 information in its possession or control that is subject to the confidentiality agreement
24 with the Non-Party before a determination by the court. Absent a court order to the
25 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
26 court of its Protected Material.
27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
1 Protected Material to any person or in any circumstance not authorized under this
2 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
3 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
4 unauthorized copies of the Protected Material, (c) inform the person or persons to whom
5 unauthorized disclosures were made of all the terms of this Order, and (d) request such
6 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is
7 attached hereto as Exhibit A.
8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
9 PROTECTED MATERIAL
10 When a Producing Party gives notice to Receiving Parties that certain inadvertently
11 produced material is subject to a claim of privilege or other protection, the obligations of
12 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
13 This provision is not intended to modify whatever procedure may be established in an e-
14 discovery order that provides for production without prior privilege review. Pursuant to
15 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
16 effect of disclosure of a communication or information covered by the attorney-client
17 privilege or work product protection, the parties may incorporate their agreement in the
18 stipulated protective order submitted to the court.
19 12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
21 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 Protective Order no Party waives any right it otherwise would have to object to disclosing
24 or producing any information or item on any ground not addressed in this Stipulated
25 Protective Order. Similarly, no Party waives any right to object on any ground to use in
26 evidence of any of the material covered by this Protective Order.
27 12.3 Filing Protected Material. Without a court order a Party may not file in the
public record in this action any Protected Material. A Party that seeks to file under seal
1 any Protected Material must comply with Civil Local Rules 140, 141 and 141.1.
2 Protected Material may only be filed under seal pursuant to a court order authorizing the
3 sealing of the specific Protected Material at issue. If a Receiving Party’s request to file
4 Protected Material under seal pursuant to Civil Local Rules 140, 141 and 141.1 is denied
5 by the court, then the Receiving Party may file the information in the public record
6 pursuant to Civil Local Rules 140, 141 and 141.1, unless otherwise instructed by the court.
7 13. FINAL DISPOSITION
8 Within 60 days after the final disposition of this action, as defined in paragraph 4,
9 each Receiving Party must return all Protected Material to the Producing Party or destroy
10 such material. As used in this subdivision, “all Protected Material” includes all copies,
11 abstracts, compilations, summaries, and any other format reproducing or capturing any of
12 the Protected Material. Whether the Protected Material is returned or destroyed, the
13 Receiving Party must submit a written certification to the Producing Party (and, if not the
14 same person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
15 (by category, where appropriate) all the Protected Material that was returned or destroyed
16 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
17 compilations, summaries or any other format reproducing or capturing any of the
18 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
19 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
20 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
21 work product, and consultant and expert work product, even if such materials contain
22 Protected Material. Any such archival copies that contain or constitute Protected Material
23 remain subject to this Protective Order as set forth in Section 4 (DURATION).
24 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
25 ///
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27 ///
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1 ECF CERTIFICATION
2
I, Ganette M. Genetti, certify that the content of this document (Stipulated
3
Protective Order) is acceptable to the undersigned counsel of record to affix my
4
electronic signature hereto.
5
DATED: December 11, 2025 GOODMAN NEUMAN HAMILTON LLP
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By: /s/ Ganette M. Genetti
8 ZACHARY S. TOLSON
GANETTE M. GENETTI
9 Attorneys for Defendant
HOME DEPOT U.S.A., INC.
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11 ECF CERTIFICATION
12
I, Jordan Ashley Duncan-Smith, certify that the content of this document
13
(Stipulated Protective Order) is acceptable to the undersigned counsel of record to
14
affix my electronic signature hereto.
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DATED: December 11, 2025 DOWNTOWN LA LAW GROUP
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By: /s/ Jordan Ashley Duncan-Smith
18 JORDAN ASHLEY DUNCAN-SMITH
Attorneys for Plaintiff
19 SHAWN MCSPADDEN
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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 I have read in its entirety
5 and understand the Stipulated Protective Order that was issued by the United States District
6 Court for the Eastern District of California on [date] in the case of ___________ [insert
7 formal name of the case and the number and initials assigned to it by the court]. I agree to
8 comply with and to be bound by all the terms of this Stipulated Protective Order and I
9 understand and acknowledge that failure to so comply could expose me to sanctions and
10 punishment in the nature of contempt. I solemnly promise that I will not disclose in any
11 manner any information or item that is subject to this Stipulated Protective Order to any
12 person or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court for the
14 Eastern District of California for the purpose of enforcing the terms of this Stipulated
15 Protective Order, even if such enforcement proceedings occur after termination of this
16 action.
17 I hereby appoint __________________________ [print or type full name] of
18 _______________________________________ [print or type full address and telephone
19 number] as my California agent for service of process in connection with this action or any
20 proceedings related to enforcement of this Stipulated Protective Order.
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22 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
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25 Printed name: _______________________________
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27 Signature: __________________________________
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6 ORDER
7 The Court has reviewed the Stipulated Protective Order filed by Plaintiff Shawn
8 McSpadden (“Plaintiff”) and Defendant Home Depot USA, Inc. (“Defendant”),
9 through their counsel of record, requesting that the Court enter an Order.
10 Having considered the above stipulation, and finding good cause, the Court
11 adopts the signed Stipulated Protective Order, (Doc. 19), subject to the following:
12 Exhibit A, lines 13-16: “I further agree to submit to the jurisdiction of the United
13 States District Court for the Eastern District of California for the purpose of enforcing the
14 terms of this Stipulated Protective Order, even if such enforcement proceedings occur after
15 termination of this action” is hereby struck and replaced with “I further agree to submit to
16 the jurisdiction of the United States District Court for the Eastern District of California for
17 the purpose of enforcing the terms of this Stipulated Protective Order, up to and until the
18 termination of this action.”
19 The parties are advised that pursuant to the Local Rules of the United States
20 District Court, Eastern District of California, any documents subject to the protective
21 order to be filed under seal must be accompanied by a written request which complies
22 with Local Rule 141 prior to sealing. The party making a request to file documents
23 under seal shall be required to show good cause for documents attached to a non-
24 dispositive motion or compelling reasons for documents attached to a dispositive
25 motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009).
26 Within five (5) days of any approved document filed under seal, the party shall file a
27 redacted copy of the sealed document. The redactions shall be narrowly tailored to
protect only the information that is confidential or was deemed confidential.
1 Additionally, the parties shall consider resolving any dispute arising under the
2 protective order according to the Court’s informal discovery dispute procedure.
3
4 IT IS SO ORDERED.
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Dated: December 11, 2025 /s/ Barbara A. McAuliffe _
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UNITED STATES MAGISTRATE JUDGE
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