The opinion
1 ECtOhaZnE CNh eOrn’CinO (SNBNNO 2R7 3 906)
2 401 Wilshire Boulevard, Suite 850
Santa Monica, California 90401
3 Telephone: 310.393.4000
Facsimile: 310.394.4700
4 Email: echernin@cozen.com
5 Attorneys for Defendants
TAYLOR ENTERPRISE SOLUTIONS, INC.,
6 JOHN M. BULLOCK and TAYLOR CORPORATION
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11
Linda Hartoonian, an Individual, Case No. 2:25-cv-08515 JLS (BFMx)
12
Plaintiff, STIPULATED PROTECTIVE
13 ORDER
v.
14 Date: February 18, 2026
TAYLOR ENTERPRISE SOLUTIONS, Judge: Hon. Josephine L. Staton
15 INC., a Minnesota corporation; and Dept.: 8A
JOHN M. BULLOCK, an Individual;
16 DOE 1 as TAYLOR CORPORATION; Compl. Filed: Aug. 5, 2025
and DOES 2 through 10, Amd. Compl. Filed: Sept. 23, 2025
17 Trial: Not set
Defendants.
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19
1. INTRODUCTION
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1.1 Purposes and Limitations. Discovery in this action is likely to involve
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production of confidential, proprietary, or private information for which special
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protection from public disclosure and from use for any purpose other than
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prosecuting this litigation may be warranted. Accordingly, the parties hereby
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stipulate to and petition the court to enter the following Stipulated Protective Order.
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The parties acknowledge that this Order does not confer blanket protections on all
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disclosures or responses to discovery and that the protection it affords from public
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disclosure and use extends only to the limited information or items that are entitled
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1 to confidential treatment under the applicable legal principles.
2 1.2 Good Cause Statement.
3 This action is likely to involve valuable commercial, financial, technical
4 and/or proprietary information for which special protection from public disclosure
5 and from use for any purpose other than prosecution of this action is warranted. Such
6 confidential and proprietary materials and information consist of, among other
7 things, confidential business or financial information, information regarding
8 confidential business practices, or commercial information (including information
9 implicating privacy rights of third parties), information otherwise generally
10 unavailable to the public, or which may be privileged or otherwise protected from
11 disclosure under state or federal statutes, court rules, case decisions, or common law.
12 Specifically, such valuable information includes information to pertaining to and
13 consisting of Defendant Taylor Enterprise Solutions, Inc.’s (“TESI”) internal
14 business practices and documents, highly sensitive and proprietary documents
15 pertaining to TESI’s business structure, highly sensitive information and documents
16 pertaining to TESI’s decision to implement a reduction in force, TESI’s employment
17 policies and procedures, and other business practices and information that is
18 unknown to the public. Such information also includes highly sensitive information
19 of Plaintiff Linda Hartoonian (“Plaintiff”), including Plaintiff’s personnel file,
20 Plaintiff’s highly sensitive financial documents and information, and Plaintiff’s
21 disciplinary record, all of which is confidential and unknown to the public.
22 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
23 of disputes over confidentiality of discovery materials, to adequately protect
24 information the parties are entitled to keep confidential, to ensure that the parties are
25 permitted reasonable necessary uses of such material in preparation for and in the
26 conduct of trial, to address their handling at the end of the litigation, and serve the
27 ends of justice, a protective order for such information is justified in this matter. It
28 is the intent of the parties that information will not be designated as confidential for
1 tactical reasons and that nothing be so designated without a good faith belief that it
2 has been maintained in a confidential, non-public manner, and there is good cause
3 why it should not be part of the public record of this case.
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
5 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
6 Protective Order does not entitle them to file confidential information under seal;
7 Local Rule 79-5 sets forth the procedures that must be followed and the standards
8 that will be applied when a party seeks permission from the court to file material
9 under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd
14 v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v.
15 Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
16 orders require good cause showing), and a specific showing of good cause or
17 compelling reasons with proper evidentiary support and legal justification, must be
18 made with respect to Protected Material that a party seeks to file under seal. The
19 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
20 does not—without the submission of competent evidence by declaration,
21 establishing that the material sought to be filed under seal qualifies as confidential,
22 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. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each
27 item or type of information, document, or thing sought to be filed or introduced
28 under seal in connection with a dispositive motion or trial, the party seeking
1 protection must articulate compelling reasons, supported by specific facts and legal
2 justification, for the requested sealing order. Again, competent evidence supporting
3 the application to file documents under seal 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 2. DEFINITIONS
11 2.1 Action: the above captioned litigation, United States District Court for
12 the Central District of California, Case No. 2:25-cv-08515 JLS (BFMx).
13 2.2 Challenging Party: a Party or Non-Party that challenges the designation
14 of information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored or maintained) or tangible things that qualify for
17 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified
18 above in the Good Cause Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 2.5 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.”
24 2.6 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced or
27 generated in disclosures or responses to discovery in this matter.
28 2.7 Expert: a person with specialized knowledge or experience in a matter
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as
2 an expert witness or as a consultant in this Action.
3 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses
4 in this Action, with or without prejudice; and (2) final judgment herein after the
5 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
6 this Action, including the time limits for filing any motions or applications for
7 extension of time pursuant to applicable law.
8 2.9 In-House Counsel: attorneys who are employees of a party to this
9 Action. In-House Counsel does not include Outside Counsel of Record or any other
10 outside counsel.
11 2.10 Non-Party: any natural person, partnership, corporation, association, or
12 other legal entity not named as a Party to this action.
13 2.11 Outside Counsel of Record: attorneys who are not employees of a party
14 to this Action but are retained to represent or advise a party to this Action and have
15 appeared in this Action on behalf of that party or are affiliated with a law firm which
16 has appeared on behalf of that party, and includes support staff.
17 2.12 Party: any party to this Action, including all of its officers, directors,
18 employees, consultants, retained experts, and Outside Counsel of Record (and their
19 support staffs).
20 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this Action.
22 2.14 Professional Vendors: persons or entities that provide litigation-
23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
24 demonstrations, and organizing, storing, or retrieving data in any form or medium)
25 and their employees and subcontractors.
26 2.15 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL.”
28 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
1 from a Producing Party.
2 3. SCOPE
3 The protections conferred by this Stipulation and Order cover not only
4 Protected Material (as defined above), but also (1) any information copied or
5 extracted from Protected Material; (2) all copies, excerpts, summaries, or
6 compilations of Protected Material; and (3) any testimony, conversations, or
7 presentations by Parties or their Counsel that might reveal Protected Material.
8 Any use of Protected Material at trial shall be governed by the orders of the
9 trial judge. This Stipulated Protective Order does not govern the use of Protected
10 Material at trial.
11 4. TRIAL AND DURATION
12 The terms of this Stipulated Protective Order apply through Final Disposition
13 of the Action.
14 Once a case proceeds to trial, information that was designated as
15 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
16 used or introduced as an exhibit at trial becomes public and will be presumptively
17 available to all members of the public, including the press, unless compelling reasons
18 supported by specific factual findings to proceed otherwise are made to the trial
19 judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing
20 “good cause” showing for sealing documents produced in discovery from
21 “compelling reasons” standard when merits-related documents are part of court
22 record). Accordingly, for such materials, the terms of this Stipulated Protective
23 Order do not extend beyond the commencement of the trial.
24 Even after Final Disposition of this litigation, the confidentiality obligations
25 imposed by this Stipulated Protective Order shall remain in effect until a Designating
26 Party agrees otherwise in writing or a court order otherwise directs.
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1 5. DESIGNATING PROTECTED MATERIAL
2 5.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or items for protection under
4 this Order must take care to limit any such designation to specific material that
5 qualifies under the appropriate standards. The Designating Party must designate for
6 protection only those parts of material, documents, items, or oral or written
7 communications that qualify so that other portions of the material, documents, items,
8 or communications for which protection is not warranted are not swept unjustifiably
9 within the ambit of this Order.
10 Mass, indiscriminate, or routinized designations are prohibited. Designations
11 that are shown to be clearly unjustified or that have been made for an improper
12 purpose (e.g., to unnecessarily encumber the case development process or to impose
13 unnecessary expenses and burdens on other parties) may expose the Designating
14 Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
16 designated for protection do not qualify for protection, that Designating Party must
17 promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 5.2 Manner and Timing of Designations. Except as otherwise provided
19 in this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
20 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
21 qualifies for protection under this Stipulated Protective Order must be clearly so
22 designated before the material is disclosed or produced.
23 Designation in conformity with this Stipulated Protective Order requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or trial
26 proceedings), that the Producing Party affix at a minimum, the legend
27 “CONFIDENTIAL” to each page that contains protected material. If only a portion
28 or portions of the material on a page qualifies for protection, the Producing Party
1 also must clearly identify the protected portion(s) (e.g., by making appropriate
2 markings in the margins).
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and
6 before the designation, all of the material made available for inspection shall be
7 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
8 it wants copied and produced, the Producing Party must determine which
9 documents, or portions thereof, qualify for protection under this Stipulated
10 Protective Order. Then, before producing the specified documents, the Producing
11 Party must affix the “CONFIDENTIAL” legend to each page that contains
12 Protected Material. If only a portion or portions of the material on a page qualifies
13 for protection, the Producing Party also must clearly identify the protected
14 portion(s) (e.g., by making appropriate markings in the margins).
15 (b) for testimony given in depositions that the Designating Party
16 identify the Disclosure or Discovery Material on the record, before the close of the
17 deposition all protected testimony.
18 (c) for information produced in some form other than documentary and
19 for any other tangible items, that the Producing Party affix in a prominent place on
20 the exterior of the container or containers in which the information is stored the
21 “CONFIDENTIAL” legend. If only a portion or portions of the information
22 warrants protection, the Producing Party, to the extent practicable, shall identify
23 the protected portion(s).
24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
25 failure to designate qualified information or items does not, standing alone, waive
26 the Designating Party’s right to secure protection under this Order for such material.
27 Upon timely correction of a designation, the Receiving Party must make reasonable
28 efforts to assure that the material is treated in accordance with the provisions of this
1 Stipulated Protective Order.
2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
3 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
4 designation of confidentiality at any time that is consistent with the court’s
5 Scheduling Order.
6 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
7 resolution process under Local Rule 37.1 et seq. and with Section 12 of Judge
8 Staton’s Civil Procedures titled “Discovery Motions in a Civil Case.”1
9 6.3. The burden of persuasion in any such challenge proceeding shall be on
10 the Designating Party. Frivolous challenges, and those made for an improper
11 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
12 parties) may expose the Challenging Party to sanctions. Unless the Designating Party
13 has waived or withdrawn the confidentiality designation, all parties shall continue to
14 afford the material in question the level of protection to which it is entitled under the
15 Producing Party’s designation until the court rules on the challenge.
16 7. ACCESS TO AND USE OF PROTECTED MATERIAL
17 7.1 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 reaches a Final Disposition, a
22 Receiving Party must comply with the provisions of section 13 below.
23 Protected Material must be stored and maintained by a Receiving Party at a
24 location and in a secure manner that ensures that access is limited to the persons
25 authorized under this Stipulated Protective Order.
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1 Judge Staton’s Procedures are available at https://apps.cacd.uscourts.gov/Jps/honorable-
28 josephine-l-staton
1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
2 otherwise ordered by the court or permitted in writing by the Designating Party, a
3 Receiving Party may disclose any information or item designated
4 “CONFIDENTIAL” only:
5 (a) to the Receiving Party’s Outside Counsel of Record in this Action,
6 as well as employees of said Outside Counsel of Record to whom it is reasonably
7 necessary to disclose the information for this Action;
8 (b) to the officers, directors, and employees (including House Counsel)
9 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
10 (c) to Experts (as defined in this Order) of the Receiving Party to whom
11 disclosure is reasonably necessary for this Action and who have signed the
12 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
13 (d) to the court and its personnel;
14 (e) to court reporters and their staff;
15 (f) to professional jury or trial consultants, mock jurors, and
16 Professional Vendors to whom disclosure is reasonably necessary for this Action
17 and who have signed the “Acknowledgment and Agreement to Be Bound”
18 (Exhibit A);
19 (g) to the author or recipient of a document containing the information
20 or a custodian or other person who otherwise possessed or knew the information;
21 (h) during their depositions, to witnesses, and attorneys for witnesses,
22 in the Action to whom disclosure is reasonably necessary, provided: (1) the
23 deposing party requests that the witness sign the “Acknowledgment and
24 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to
25 keep any confidential information unless they sign the “Acknowledgment and
26 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
27 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits
28 to depositions that reveal Protected Material may be separately bound by the court
1 reporter and may not be disclosed to anyone except as permitted under this
2 Stipulated Protective Order; and
3 (i) to any mediator or settlement officer, and their supporting
4 personnel, mutually agreed upon by any of the parties engaged in settlement
5 discussions.
6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
7 PRODUCED IN OTHER LITIGATION
8 If a Party is served with a subpoena or a court order issued in other
9 litigation that compels disclosure of any information or items designated in this
10 Action as “CONFIDENTIAL,” that Party must:
11 (a) promptly notify in writing the Designating Party. Such
12 notification shall include a copy of the subpoena or court order;
13 (b) promptly notify in writing the party who caused the subpoena or
14 order to issue in the other litigation that some or all of the material covered by
15 the subpoena or order is subject to this Protective Order. Such notification shall
16 include a copy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be
18 pursued by the Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served with
20 the subpoena or court order shall not produce any information designated in this
21 action as “CONFIDENTIAL” before a determination by the court from which the
22 subpoena or order issued, unless the Party has obtained the Designating Party’s
23 permission. The Designating Party shall bear the burden and expense of seeking
24 protection in that court of its confidential material and nothing in these provisions
25 should be construed as authorizing or encouraging a Receiving Party in this Action
26 to disobey a lawful directive from another court.
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1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 9.1. Application. The terms of this Stipulated Protective Order are
4 applicable to information produced by a Non-Party in this Action and designated
5 as “CONFIDENTIAL.” Such information produced by Non-Parties in connection
6 with this litigation is protected by the remedies and relief provided by this Order.
7 Nothing in these provisions should be construed as prohibiting a Non-Party from
8 seeking additional protections.
9 9.2. Notification. In the event that a Party is required, by a valid discovery
10 request, to produce a Non-Party’s confidential information in its possession, and
11 the Party is subject to an agreement with the Non-Party not to produce the Non-
12 Party’s confidential information, then the Party shall:
13 (a) Promptly notify in writing the Requesting Party and the Non-Party
14 that some or all of the information requested is subject to a confidentiality
15 agreement with a Non-Party:
16 (b) make the information requested available for inspection by the Non-
17 Party, if requested.
18 9.3. Conditions of Production. If the Non-Party fails to seek a protective
19 order from this court within 14 days of receiving the notice and accompanying
20 information, the Receiving Party may produce the Non-Party’s confidential
21 information responsive to the discovery request. If the Non-Party timely seeks a
22 protective order, the Receiving Party shall not produce any information in its
23 possession or control that is subject to the confidentiality agreement with the Non-
24 Party before a determination by the court. Absent a court order to the contrary, the
25 Non-Party shall bear the burden and expense of seeking protection in this court of
26 its Protected Material.
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1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
2 MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 Protected Material to any person or in any circumstance not authorized under this
5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
6 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
7 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
8 or persons to whom unauthorized disclosures were made of all the terms of this
9 Order, and (d) request such person or persons to execute the “Acknowledgment and
10 Agreement to Be Bound” (Exhibit A).
11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
12 OTHERWISE PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the
16 Federal Rules of Civil Procedure. This provision is not intended to modify whatever
17 procedure may be established in an e-discovery order that provides for production
18 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules
19 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of
20 a communication or information covered by the attorney-client privilege or work
21 product protection, the parties may incorporate their agreement in the stipulated
22 protective order submitted to the court.
23 12. MISCELLANEOUS
24 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
25 abridges the right of any person to seek its modification by the court in the future.
26 12.2 Right to Assert Other Objections. By stipulating to the entry of this
27 Stipulated Protective Order no Party waives any right it otherwise would have to
28 object to disclosing or producing any information or item on any ground not
1 addressed in this Stipulated Protective Order. Similarly, no Party waives any right
2 to object on any ground to use in evidence of any of the material covered by this
3 Stipulated Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any
5 Protected Material must comply with Local Rule 79-5. Protected Material may only
6 be filed under seal pursuant to a court order authorizing the sealing of the specific
7 Protected Material at issue. If a Party’s request to file Protected Material under seal
8 is denied by the court, then the Receiving Party may file the information in the public
9 record unless otherwise instructed by the court.
10 13. FINAL DISPOSITION
11 After the Final Disposition of this Action, as defined in paragraph 4, within
12 60 days of a written request by the Designating Party, each Receiving Party must
13 return all Protected Material to the Producing Party or destroy such material. As used
14 in this subdivision, “all Protected Material” includes all copies, abstracts,
15 compilations, summaries, and any other format reproducing or capturing any of the
16 Protected Material. Whether the Protected Material is returned or destroyed, the
17 Receiving Party must submit a written certification to the Producing Party (and, if
18 not the same person or entity, to the Designating Party) by the 60 day deadline that
19 (1) identifies (by category, where appropriate) all the Protected Material that was
20 returned or destroyed and (2) affirms that the Receiving Party has not retained any
21 copies, abstracts, compilations, summaries or any other format reproducing or
22 capturing any of the Protected Material. Notwithstanding this provision, Counsel is
23 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
24 and hearing transcripts, legal memoranda, correspondence, deposition and trial
25 exhibits, expert reports, attorney work product, and consultant and expert work
26 product, even if such materials contain Protected Material. Any such archival copies
27 that contain or constitute Protected Material remain subject to this Protective Order
28 as set forth in Section 4.
1] 14. VIOLATION
2 Any violation of this Stipulated Protective Order may be punished by any and
all appropriate measures including, without limitation, contempt proceedings and/or
4|| monetary sanctions.
6|| IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7|| DATED: March 27, 2026 /s/ Ethan Chernin
g Ethan Chernin
Cozen O’Connor
9 Attorneys for Defendants, Taylor
10 Enterprise Solutions, Inc., John M.
Bullock, and Taylor Corporation
1]
12 |} DATED:_March 27, 2026 /s/ Nick Yasman
B Ronald L. Zambrano, Esq.
Nick Yasman, Esq.
14 West Coast Trial Lawyers, APLC
15 Attorneys for Plaintiff,
Linda Hartoonian
16
'’! FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
19 DATED: 3/30/2026 Teta
20 HONORABLE BRIANNA FULLER MIRCHEFF
1 United States Magistrate Judge
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STIPULATED PROTECTIVE ORDER
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
5 entirety and understand the Stipulated Protective Order that was issued by the
6 United States District Court for the Central District of California on [date] in the
7 case of Linda Hartoonian v. Taylor Enterprise Solutions, Inc., John M. Bullock,
8 Doe 1 as Taylor Corporation, and Does 2 through 10, Case No. 2:25-cv-08515
9 JLS (BFMX). I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item
13 that is subject to this Stipulated Protective Order to any person or entity except in
14 strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District
16 Court for the Central District of California for the purpose of enforcing the terms
17 of this Stipulated Protective Order, even if such enforcement proceedings occur
18 after termination of this action. I hereby appoint [print or
19 type full name] of [print or type full address
20 and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date:
24 City and State where sworn and signed:
25 Printed name:
26 Signature:
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