Opinion

1 Cheryl L. Schreck (SBN 130083)

E-Mail: cschreck@fisherphillips.com

2 Kassandra L. Sopko (SBN 364476)

E-Mail: klsopko@fisherphillips.com

3 FISHER & PHILLIPS LLP

444 South Flower Street

4 Suite 1500

Los Angeles, California 90071

5 Telephone: (213) 330-4500

Facsimile: (213) 330-4501

6

Attorneys for Defendant

7 TEXTECH ENGINEERED COMPOSITES, LLC

8 SAM RYAN HEIDARI, ESQ. SBN: 302555

MICHAEL ZAMAN, ESQ. SBN: 341237

9 LARISSA TAVEIRA, ESQ. SBN: 361014

HEIDARI LAW GROUP, PC

10 3530 Wilshire Blvd., Suite 710

Los Angeles, California 90010

11 Telephone: (213) 786-1023

Facsimile: (213) 884-4588

12 Email: eservice@heidarilawgroup.com

13 Attorneys for Plaintiff, IGNACIO T. LARA

14

[Counsel of Record Listed on Next Page]

15

16 IN THE UNITED STATES DISTRICT COURT

17 FOR THE CENTRAL DISTRICT OF CALIFORNIA

18

19 IGNACIO T. LARA, an individual, CASE NO.: 2:25-cv-06605-JLS-JC

20 Plaintiff, STIPULATED PROTECTIVE

ORDER

21 v.

[CHANGES MADE BY COURT TO

22 T C E O X M -T PO EC SI H T E E S N , G L I L N C E , E a R D E e D la ware PARAGRAPHS 3, 8, 9.3 & 13]

23 corporation company; SGL

COMPOSITES, INC, a Delaware

24 corporation company; JERRY PATINI,

an individual; and DOES 1 through 20,

25 inclusive,

26 Defendants.

27

28

111 MCGUIREWOODS LLP

222 Sabrina A. Beldner (SBN 221918)

Email: sbeldner@mcguirewoods.com

333 Peter J. Choi (SBN 306763)

444 Email: pchoi@mcguirewoods.com

Sutton T. McCann (SBN 365593)

555 Email: smccann@mcguirewoods.com

666 1800 Century Park East, 8th Floor

Los Angeles, CA 90067-1501

777 Telephone: 310.315.8200 / Facsimile:

888 310.315.8210

999 Attorneys for Defendant SGL Composites Inc.

111000

111111

111222

111333

111444

111555

111666

111777

111888

111999

222000

222111

222222

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222444

222555

222666

222777

222888

111 1. INTRODUCTION

222 1.1. Purposes and Limitations. Discovery in this action is likely to involve

333 production of confidential, proprietary, or private information for which special

444 protection from public disclosure and from use for any purpose other than prosecuting

555 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition

666 the court to enter the following Stipulated Protective Order. The parties acknowledge that

777 this Order does not confer blanket protections on all disclosures or responses to discovery

888 and that the protection it affords from public disclosure and use extends only to the

999 limited information or items that are entitled to confidential treatment under the

111000 applicable legal principles.

111111 1.2. Good Cause Statement. This action is likely to involve trade secrets,

111222 customer and pricing lists and other valuable research, development, commercial,

111333 financial, technical and/or proprietary information for which special protection from

111444 public disclosure and from use for any purpose other than prosecution of this action is

111555 warranted. Such confidential and proprietary materials and information consist of,

111666 among other things, confidential business or financial information, information regarding

111777 confidential business practices, or other confidential research, development, or

111888 commercial information (including information implicating privacy rights of third

111999 parties), information otherwise generally unavailable to the public, or which may be

222000 privileged or otherwise protected from disclosure under state or federal statutes, court

222111 rules, case decisions, or common law. Accordingly, to expedite the flow of information,

222222 to facilitate the prompt resolution of disputes over confidentiality of discovery materials,

222333 to adequately protect information the parties are entitled to keep confidential, to ensure

222444 that the parties are permitted reasonable necessary uses of such material in preparation

222555 for and in the conduct of trial, to address their handling at the end of the litigation, and

222666 serve the ends of justice, a protective order for such information is justified in this matter.

222777 It is the intent of the parties that information will not be designated as confidential for

222888 tactical reasons and that nothing be so designated without a good faith belief that it has

111 been maintained in a confidential, non-public manner, and there is good cause why it

222 should not be part of the public record of this case.

333 1.3. Acknowledgement of Procedure for Filing Under Seal. The parties further

444 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order

555 does not entitle them to file confidential information under seal; Local Rule 79-5 sets

666 forth the procedures that must be followed and the standards that will be applied when a

777 party seeks permission from the court to file material under seal.

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

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

111000 cause must be shown to support a filing under seal. See Kamakana v. City and Cnty. of

111111 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen.

111222 Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs.,

111333 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require

111444 good cause showing), and a specific showing of good cause or compelling reasons with

111555 proper evidentiary support and legal justification, must be made with respect to Protected

111666 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure

111777 or Discovery Material as CONFIDENTIAL does not— without the submission of

111888 competent evidence by declaration, establishing that the material sought to be filed under

111999 seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause.

222000 Further, if a party requests sealing related to a dispositive motion or trial, then

222111 compelling reasons, not only good cause, for the sealing must be shown, and the relief

222222 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

222333 v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

222444 information, document, or thing sought to be filed or introduced under seal in connection

222555 with a dispositive motion or trial, the party seeking protection must articulate compelling

222666 reasons, supported by specific facts and legal justification, for the requested sealing

222777 order. Again, competent evidence supporting the application to file documents under seal

222888 must be provided by declaration.

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

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

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

444 confidential, privileged, or otherwise protectable portions of the document, shall be filed.

555 Any application that seeks to file documents under seal in their entirety should include an

666 explanation of why redaction is not feasible

777 2. DEFINITIONS

888 2.1. Action: IGNACIO T. LARA v. TEX-TECH ENGINEERED COMPOSITIES,

999 LLC., and SGL COMPOSITES, INC. CASE NO.: 2:25-cv-06605-JLS-JC.

111000 2.2. Challenging Party: a Party or Non-Party that challenges the designation of

111111 information or items under this Order.

111222 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how it

111333 is generated, stored or maintained) or tangible things that qualify for protection under

111444 Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in the Good

111555 Cause Statement.

111666 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their

111777 support staff).

111888 2.5. Designating Party: a Party or Non-Party that designates information or items

111999 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

222000 2.6. Disclosure or Discovery Material: all items or information, regardless of the

222111 medium or manner in which it is generated, stored, or maintained (including, among

222222 other things, testimony, transcripts, and tangible things), that are produced or generated in

222333 disclosures or responses to discovery in this matter.

222444 2.7. Expert: a person with specialized knowledge or experience in a matter

222555 pertinent to the litigation who has been retained by a Party or its counsel to serve as an

222666 expert witness or as a consultant in this Action.

222777 2.8. Final Disposition: the later of (1) dismissal of all claims and defenses in this

222888 Action, with or without prejudice; and (2) final judgment herein after the completion and

111 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, including

222 the time limits for filing any motions or applications for extension of time pursuant to

333 applicable law.

444 2.9. In-House Counsel: attorneys who are employees of a party to this Action. In-

555 House Counsel does not include Outside Counsel of Record or any other outside counsel.

666 2.10. Non-Party: any natural person, partnership, corporation, association, or other

777 legal entity not named as a Party to this action.

888 2.11. Outside Counsel of Record: attorneys who are not employees of a party to

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

111000 in this Action on behalf of that party or are affiliated with a law firm which has appeared

111111 on behalf of that party, and includes support staff.

111222 2.12. Party: any party to this Action, including all of its officers, directors,

111333 employees, consultants, retained experts, and Outside Counsel of Record (and their

111444 support staffs).

111555 2.13. Producing Party: a Party or Non-Party that produces Disclosure or

111666 Discovery Material in this Action.

111777 2.14. Professional Vendors: persons or entities that provide litigation- support

111888 services (e.g., photocopying, videotaping, translating, preparing exhibits or

111999 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

222000 their employees and subcontractors.

222111 2.15. Protected Material: any Disclosure or Discovery Material that is designated

222222 as “CONFIDENTIAL.”

222333 2.16. Receiving Party: a Party that receives Disclosure or Discovery Material from

222444 a Producing Party.

222555 3. SCOPE

222666 The protections conferred by this Stipulation and Order cover not only Protected

222777 Material (as defined above), but also (1) any information copied or extracted from

222888 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

111 Material; and (3) any testimony, conversations, or presentations by Parties or their

222 Counsel that might reveal Protected Material other than during a court hearing or trial.

333 Any use of Protected Material during a court hearing/at trial shall be governed

444 by the orders of the presiding judge. This Stipulated Protective Order does not govern

555 the use of Protected Material during court hearings/at trial.

666 4. TRIAL AND DURATION

777

The terms of this Stipulated Protective Order apply through Final Disposition of

888

the Action.

999

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

111000

CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used

111111

or introduced as an exhibit at trial becomes public and will be presumptively available

111222

to all members of the public, including the press, unless compelling reasons supported

111333

by specific factual findings to proceed otherwise are made to the trial judge in advance

111444

of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing

111555

for sealing documents produced in discovery from “compelling reasons” standard when

111666

merits-related documents are part of court record). Accordingly, for such materials, the

111777

terms of this Stipulated Protective Order do not extend beyond the commencement of

111888

the trial.

111999

Even after Final Disposition of this litigation, the confidentiality obligations

222000

imposed by this Stipulated Protective Order shall remain in effect until a Designating

222111

Party agrees otherwise in writing or a court order otherwise directs.

222222

5. DESIGNATING PROTECTED MATERIAL

222333

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

222444

Party or Non-Party that designates information or items for protection under this Order

222555

must take care to limit any such designation to specific material that qualifies under the

222666

appropriate standards. The Designating Party must designate for protection only those

222777

parts of material, documents, items, or oral or written communications that qualify so

222888

111 that other portions of the material, documents, items, or communications for which

222 protection is not warranted are not swept unjustifiably within the ambit of this Order.

333 Mass, indiscriminate, or routinized designations are prohibited. Designations that

444 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

555 to unnecessarily encumber the case development process or to impose unnecessary

666 expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

888 designated for protection do not qualify for protection, that Designating Party must

999 promptly notify all other Parties that it is withdrawing the inapplicable designation.

111000 5.2. Manner and Timing of Designations. Except as otherwise provided in this

111111 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as

111222 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for

111333 protection under this Stipulated Protective Order must be clearly so designated before the

111444 material is disclosed or produced.

111555 Designation in conformity with this Stipulated Protective Order requires:

111666 (a) for information in documentary form (e.g., paper or electronic documents, but

111777 excluding transcripts of depositions or other pretrial or trial proceedings), that the

111888 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that

111999 contains protected material. If only a portion or portions of the material on a page

222000 qualifies for protection, the Producing Party also must clearly identify the protected

222111 portion(s) (e.g., by making appropriate markings in the margins).

222222 A Party or Non-Party that makes original documents available for inspection need

222333 not designate them for protection until after the inspecting Party has indicated which

222444 documents it would like copied and produced. During the inspection and before the

222555 designation, all of the material made available for inspection shall be deemed

222666 CONFIDENTIAL. After the inspecting Party has identified the documents it wants

222777 copied and produced, the Producing Party must determine which documents, or portions

222888 thereof, qualify for protection under this Stipulated Protective Order. Then, before

111 producing the specified documents, the Producing Party must affix the

222 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a

333 portion or portions of the material on a page qualifies for protection, the Producing Party

444 also must clearly identify the protected portion(s) (e.g., by making appropriate markings

555 in the margins).

666 (b) for testimony given in depositions that the Designating Party identify the

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

888 protected testimony.

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

111000 other tangible items, that the Producing Party affix in a prominent place on the exterior of

111111 the container or containers in which the information is stored the “CONFIDENTIAL”

111222 legend. If only a portion or portions of the information warrants protection, the

111333 Producing Party, to the extent practicable, shall identify the protected portion(s).

111444 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

111555 to designate qualified information or items does not, standing alone, waive the

111666 Designating Party’s right to secure protection under this Order for such material. Upon

111777 timely correction of a designation, the Receiving Party must make reasonable efforts to

111888 assure that the material is treated in accordance with the provisions of this Stipulated

111999 Protective Order.

222000 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

222111 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation

222222 of confidentiality at any time that is consistent with the court’s Scheduling Order.

222333 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution

222444 process under Local Rule 37.1 et seq.

222555 6.3. The burden of persuasion in any such challenge proceeding shall be on the

222666 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

222777 to harass or impose unnecessary expenses and burdens on other parties) may expose the

222888 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

111 the confidentiality designation, all parties shall continue to afford the material in question

222 the level of protection to which it is entitled under the Producing Party’s designation until

333 the court rules on the challenge.

444 7. ACCESS TO AND USE OF PROTECTED MATERIAL

555 7.1. Basic Principles. A Receiving Party may use Protected Material that is

666 disclosed or produced by another Party or by a NonParty in connection with this Action

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

888 Material may be disclosed only to the categories of persons and under the conditions

999 described in this Order. When the Action reaches a Final Disposition, a Receiving Party

111000 must comply with the provisions of section 13 below.

111111 Protected Material must be stored and maintained by a Receiving Party at a

111222 location and in a secure manner that ensures that access is limited to the persons

111333 authorized under this Stipulated Protective Order.

111444 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

111555 ordered by the court or permitted in writing by the Designating Party, a Receiving Party

111666 may disclose any information or item designated “CONFIDENTIAL” only:

111777 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well as

111888 employees of said Outside Counsel of Record to whom it is reasonably necessary to

111999 disclose the information for this Action;

222000 (b) to the officers, directors, and employees (including House Counsel) of the

222111 Receiving Party to whom disclosure is reasonably necessary for this Action;

222222 (c) to Experts (as defined in this Order) of the Receiving Party to whom disclosure

222333 is reasonably necessary for this Action and who have signed the “Acknowledgment and

222444 Agreement to Be Bound” (Exhibit A);

222555 (d) to the court and its personnel;

222666 (e) to court reporters and their staff;

222777 (f) to professional jury or trial consultants, mock jurors, and Professional Vendors

222888 to whom disclosure is reasonably necessary for this Action and who have signed the

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

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

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

444 (h) during their depositions, to witnesses, and attorneys for witnesses, in the Action

555 to whom disclosure is reasonably necessary, provided: (1) the deposing party requests

666 that the witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

777 and (2) the witness will not be permitted to keep any confidential information unless they

888 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

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

111000 testimony or exhibits to depositions that reveal Protected Material may be separately

111111 bound by the court reporter and may not be disclosed to anyone except as permitted

111222 under this Stipulated Protective Order; and

111333 (i) to any mediator or settlement officer, and their supporting personnel, mutually

111444 agreed upon by any of the parties engaged in settlement discussions.

111555 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

111666 OTHER LITIGATION

111777 If a Party is served with a subpoena or a court order issued in other litigation that

111888 compels disclosure of any information or items designated in this Action as

111999 “CONFIDENTIAL,” that Party must:

222000 (a) promptly notify in writing the Designating Party. Such notification shall

222111 include a copy of the subpoena or court order;

222222 (b) promptly notify in writing the party who caused the subpoena or order to issue

222333 in the other litigation that some or all of the material covered by the subpoena or order is

222444 subject to this Protective Order. Such notification shall include a copy of this Stipulated

222555 Protective Order; and

222666 (c) cooperate with respect to all reasonable procedures sought to be pursued by the

222777 Designating Party whose Protected Material may be affected.

222888 ///

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

222 subpoena or court order shall not produce any information designated in this action as

333 “CONFIDENTIAL” before a determination by the court from which the subpoena or

444 order issued, unless the Party has obtained the Designating Party’s permission or unless

555 otherwise required by the law or court order. The Designating Party shall bear the

666 burden and expense of seeking protection in that court of its confidential material and

777 nothing in these provisions should be construed as authorizing or encouraging a

888 Receiving Party in this Action to disobey a lawful directive from another court.

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

111000 PRODUCED IN THIS LITIGATION

111111 9.1. Application. The terms of this Stipulated Protective Order are applicable to

111222 information produced by a Non-Party in this Action and designated as

111333 “CONFIDENTIAL.” Such information produced by NonParties in connection with this

111444 litigation is protected by the remedies and relief provided by this Order. Nothing in these

111555 provisions should be construed as prohibiting a Non-Party from seeking additional

111666 protections.

111777 9.2. Notification. In the event that a Party is required, by a valid discovery

111888 request, to produce a Non-Party’s confidential information in its possession, and the Party

111999 is subject to an agreement with the NonParty not to produce the Non-Party’s confidential

222000 information, then the Party shall:

222111 (a) promptly notify in writing the Requesting Party and the Non-Party that some or

222222 all of the information requested is subject to a confidentiality agreement with a Non-

222333 Party;

222444 (b) make the information requested available for inspection by the Non-Party, if

222555 requested.

222666 9.3. Conditions of Production. If the Non-Party fails to seek a protective order

222777 from this court within 14 days of receiving the notice and accompanying information, the

222888 Receiving Party may produce the Non-Party’s confidential information responsive to the

111 shall not produce any information in its possession or control that is subject to the

222

confidentiality agreement with the Non-Party before a determination by the court

333

unless otherwise required by the law or court order. Absent a court order to the

444

contrary, the Non-Party shall bear the burden and expense of seeking protection in this

555

court of its Protected Material.

666 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

111000 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

111111 all unauthorized copies of the Protected Material, (c) inform the person or persons to

111222 whom unauthorized disclosures were made of all the terms of this Order, and (d) request

111333 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

111444 (Exhibit A).

111555 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

111666 PROTECTED MATERIAL

111777 When a Producing Party gives notice to Receiving Parties that certain inadvertently

111888 produced material is subject to a claim of privilege or other protection, the obligations of

111999 the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the Federal Rules of Civil

222000 Procedure. This provision is not intended to modify whatever procedure may be

222111 established in an e-discovery order that provides for production without prior privilege

222222 review. Pursuant to Rules 502(d) and (e) of the Federal Rules of Evidence, insofar as the

222333 parties reach an agreement on the effect of disclosure of a communication or information

222444 covered by the attorney-client privilege or work product protection, the parties may

222555 incorporate their agreement in the stipulated protective order submitted to the court.

222666 12. MISCELLANEOUS

222777 12.1. Right to Further Relief. Nothing in this Stipulated Protective Order abridges

222888 the right of any person to seek its modification by the court in the future.

111 12.2. Right to Assert Other Objections. By stipulating to the entry of this

222 Stipulated Protective Order no Party waives any right it otherwise would have to object to

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

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

555 to use in evidence of any of the material covered by this Stipulated Protective Order.

666 12.3. Filing Protected Material. A Party that seeks to file under seal any Protected

777 Material must comply with Local Rule 79-5. Protected Material may only be filed under

888 seal pursuant to a court order authorizing the sealing of the specific Protected Material at

999 issue. If a Party's request to file Protected Material under seal is denied by the court, then

111000 the Receiving Party may file the information in the public record unless otherwise

111111 instructed by the court.

111222 13. FINAL DISPOSITION

111333 After the Final Disposition of this Action, as defined in paragraphs 2.8 & 4, within 60

111444 days of a written request by the Designating Party, each Receiving Party must return all

111555 Protected Material to the Producing Party or destroy such material. As used in this

111666 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

111777 summaries, and any other format reproducing or capturing any of the Protected Material.

111888 Whether the Protected Material is returned or destroyed, the Receiving Party must submit

111999 a written certification to the Producing Party (and, if not the same person or entity, to the

222000 Designating Party) by the 60 day deadline that (1) identifies (by category, where

222111 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that

222222 the Receiving Party has not retained any copies, abstracts, compilations, summaries or

222333 any other format reproducing or capturing any of the Protected Material. Notwithstanding

222444 this provision, Counsel is entitled to retain an archival copy of all pleadings, motion

222555 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

222666 deposition and trial exhibits, expert reports, attorney work product, and consultant and

222777 expert work product, even if such materials contain Protected Material. Any such archival

222888 copies that contain or constitute Protected Material remain subject to this Protective

111 Order as set forth in Section 4.

222 14. VIOLATION

333 Any violation of this Stipulated Protective Order may be punished by any and all

444 appropriate measures including without limitation, contempt proceedings and/or

555 monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

666

Dated: January 22, 2026 FISHER & PHILLIPS LLP

777

888

999 By: /s/Cheryl L. Schreck

Cheryl L. Schreck

111000

Kassandra L. Sopko

111111 Attorneys for Defendant

TEXTECH ENGINEERED COMPOSITES, LLC

111222

111333

Dated: January 22, 2026 HEIDARI LAW GROUP, PC

111444

111555

By: /s/ Larissa Taveira

111666

Larissa Taveira

111777 Rashed Zayyat

Attorneys for Plaintiff

111888

IGNACIO T. LARA

111999

222000 Dated: January 22, 2026 MCGUIREWOODS LLP

222111

222222 By: /s/ Sabrina Beldner

222333 Sabrina Beldner

Peter J. Choi

222444 Sutton T. McCann

222555 Attorneys for Defendant

SGL COMPOSITES, INC

222666

222777

222888

111 ECF ATTESTATION

222 Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures, I attest under penalty of

333 perjury that all other signatories listed, and on whose behalf the filing is submitted,

444 concur in the filing’s content and have authorized the filing.

555

666 Dated: January 22, 2026 By: /s/Cheryl L. Schreck

Cheryl L. Schreck

777

888

999

111000

111111 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED.

111222

111333 DATED: January _ 2 _ 4 , 2026 _____________/s_/___________________

111444 Honorable Jacqueline Chooljian

United States Magistrate Judge

111555

111666

111777

111888

111999

222000

222111

222222

222333

222444

222555

222666

222777

222888

111 EXHIBIT A

222 ACKNOLWEDGEMENT AND AGREEMENT TO BE BOUND

333 I, ________________________ [print or type full name], of

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

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

666 by the United States District Court for the Central District of California on 1/24/26 in

777 the case of Ignacio T. Lara v. Tex-Tech Engineered Composities, LLC, et al., Case

888 No. 2:25-cv-06605-JLS-JC. I agree to comply with and to be bound by all the terms

999 of this Stipulated Protective Order and I understand and acknowledge that failure to so

111000 comply could expose me to sanctions and punishment in the nature of contempt. I

111111 solemnly promise that I will not disclose in any manner any information or item that is

111222 subject to this Stipulated Protective Order to any person or entity except in strict

111333 compliance with the provisions of this Order.

111444

I further agree to submit to the jurisdiction of the United States District Court for

111555

the Central District of California for the purpose of enforcing the terms of this

111666

Stipulated Protective Order, even if such enforcement proceedings occur after

111777

termination of this action. I hereby appoint ________________________ [print or

111888

type full name] of _________ [print or type full address and telephone number] as

111999

my California agent for service of process in connection with this action or any

222000

proceedings related to enforcement of this Stipulated Protective Order.

222111

222222

222333 Date: ___________________________

222444 City and State sworn and signed: ___________________________

222555

Printed name: ___________________________

222666

Signature: ___________________________

222777

222888