The opinion
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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ALICE ROSENBLUM, Case No. 2:25-cv-08457-JLS-PDx
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Plaintiff, PROTECTIVE ORDER
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v.
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PASSES, INC., a Delaware corporation,
15 NOFHOTOS GROUP LLC, a
California limited liability company,
16 WLM MANAGEMENT LLC, a
California limited liability company,
17 LUCY GUO, an individual ALEC
CELESTIN, an individual, and LANI
18 GINOZA, an individual,
19 Defendants.
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1 1. STIPULATED PROTECTIVE ORDER
2 A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve the production of confidential,
4 proprietary, or private information for which protection from public disclosure and
5 from use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the Parties hereby stipulate to and petition the Court to enter the
7 following Stipulated Protective Order. The Parties acknowledge that this Order does
8 not confer blanket protections on all disclosures or responses to discovery and that
9 the protection it affords extends only to the limited information or items that are
10 entitled to confidential treatment under the applicable legal principles.
11 B. GOOD CAUSE STATEMENT
12 This action is likely to involve information regarding personal medical history,
13 as well as financial and proprietary business information for which special protection
14 from public disclosure and from use for any purpose other than prosecution of this
15 action is warranted. Such confidential information consists of, among other things,
16 confidential information implicating the privacy rights of Parties and Non-Parties,
17 information regarding personal medical history, financial information, commercial
18 information, and/or information otherwise generally unavailable to the public or
19 which may be privileged or otherwise protected from disclosure under state or
20 federal statutes, court rules, case decisions, or common law. Accordingly, to
21 expedite the flow of information, to facilitate the prompt resolution of disputes over
22 confidentiality of discovery materials, to adequately protect information the Parties
23 are entitled to keep confidential, to ensure that the Parties are permitted reasonable
24 necessary uses of such material in preparation for and in the conduct of trial, to
25 address their handling at the end of the litigation, and serve the ends of justice, a
26 protective order for such information is justified in this matter. It is the intent of the
27 Parties that information will not be designated as confidential for tactical reasons
1 maintained in a confidential, non-public manner, and there is good cause why it
2 should not be part of the public record of this case.
3 C. PROCEDURE FOR FILING UNDER SEAL
4 The Parties further acknowledge that this Stipulated Protective Order alone
5 does not entitle them to file confidential information under seal; Local Civil Rule 79-
6 5 sets forth the procedures that must be followed and the standards that will be
7 applied when a Party seeks permission from the Court to file material under seal.
8 There is a strong presumption that the public has a right of access to judicial
9 proceedings and records in civil cases. In connection with non-dispositive motions,
10 good cause must be shown to support a filing under seal. See Kamakana v. City and
11 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
12 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
13 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
14 good cause showing), and a specific showing of good cause or compelling reasons
15 with proper evidentiary support and legal justification, must be made with respect to
16 Protected Material that a party seeks to file under seal. The mere designation of
17 Disclosure or Discovery Material as CONFIDENTIAL does not—without the
18 submission of competent evidence by declaration, establishing that the material
19 sought to be filed under seal qualifies as confidential, privileged, or otherwise
20 protectable—constitute good cause.
21 Further, if a Party requests sealing related to a dispositive motion or trial, then
22 compelling reasons, not only good cause, for the sealing must be shown, and the
23 relief sought shall be narrowly tailored to serve the specific interest to be protected.
24 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
25 each item or type of information, document, or thing sought to be filed or introduced
26 under seal in connection with a dispositive motion or trial, the Party seeking
27 protection must articulate compelling reasons, supported by specific facts and legal
1 the application to file documents under seal must be provided by declaration.
2 Any document that is not confidential, privileged, or otherwise protectable in
3 its entirety will not be filed under seal if the confidential portions can be redacted.
4 If documents can be redacted, then a redacted version for public viewing, omitting
5 only the confidential, privileged, or otherwise protectable portions of the document,
6 shall be filed. Any application that seeks to file documents under seal in their entirety
7 should include an explanation of why redaction is not feasible.
8 2. DEFINITIONS
9 2.1 Action: this pending lawsuit, Rosenblum v. Passes, Inc., et al., 2:25-cv-
10 08457-JLS-PD (C.D. Cal.).
11 2.2 Challenging Party: the Party or Non-Party who challenges the
12 designation of information or items under this Order.
13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
14 how it is generated, stored or maintained) or tangible things that qualify for
15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
16 Good Cause Statement.
17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
18 their support staff).
19 2.5 Designating Party: a Party or Non-Party that designates information or
20 items that it produces in disclosures or in responses to discovery as
21 “CONFIDENTIAL.”
22 2.6 Disclosure or Discovery Material: all items or information, regardless
23 of the medium or manner in which it is generated, stored, or maintained (including,
24 among other things, testimony, transcripts, and tangible things), that are produced or
25 generated in disclosures or responses to discovery in this matter.
26 2.7 Expert: a person with specialized knowledge or experience in a matter
27 pertinent to the litigation who has been retained by a Party or its counsel to serve as
1 2.8 House Counsel: attorneys who are employees of a party to this Action.
2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4 2.9 Non-Party: any natural person, partnership, corporation, association, or
5 other legal entity not named as a Party to this action.
6 2.10 Outside Counsel of Record: attorneys who are not employees of a party
7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm which
9 has appeared on behalf of that party, and includes support staff.
10 2.11 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.12 Producing Party: a Party or Non-Party who produces Disclosure or
14 Discovery Material in this Action.
15 2.13 Professional Vendors: persons or entities that provide litigation support
16 services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.14 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.15 Receiving Party: a Party who receives Disclosure or Discovery
22 Material from a Producing Party.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only
25 Protected Material (as defined above), but also (1) any information copied or
26 extracted from Protected Material; (2) all copies, excerpts, summaries, or
27 compilations of Protected Material; and (3) any testimony, conversations, or
1 Any use of Protected Material at trial shall be governed by the orders of the
2 trial judge. This Order does not govern the use of Protected Material at trial.
3 4. DURATION
4 FINAL DISPOSITION of the action is defined as the conclusion of any
5 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
6 has run. Except as set forth below, the terms of this protective order apply through
7 FINAL DISPOSITION of the action. The Parties may stipulate that they will be
8 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
9 but will have to file a separate action for enforcement of the agreement once all
10 proceedings in this case are complete.
11 Once a case proceeds to trial, information that was designated as
12 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
13 as an exhibit at trial becomes public and will be presumptively available to all
14 members of the public, including the press, unless compelling reasons supported by
15 specific factual findings to proceed otherwise are made to the trial judge in advance
16 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
17 showing for sealing documents produced in discovery from “compelling reasons”
18 standard when merits-related documents are part of court record). Accordingly, for
19 such materials, the terms of this protective order do not extend beyond the
20 commencement of the trial.
21 5. DESIGNATING PROTECTED MATERIAL
22 5.1 Exercise of Restraint and Care in Designating Material for Protection.
23 Each Party or Non-Party that designates information or items for protection under
24 this Order must take care to limit any such designation to specific material that
25 qualifies under the appropriate standards. The Designating Party must designate for
26 protection only those parts of material, documents, items, or oral or written
27 communications that qualify so that other portions of the material, documents, items,
1 within the ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited. Designations
3 that are shown to be clearly unjustified or that have been made for an improper
4 purpose (e.g., to unnecessarily encumber the case development process or to impose
5 unnecessary expenses and burdens on other Parties) may expose the Designating
6 Party to sanctions.
7 If it comes to a Designating Party’s attention that information or items that it
8 designated for protection do not qualify for protection, that Designating Party must
9 promptly notify all other Parties that it is withdrawing the inapplicable designation.
10 5.2 Manner and Timing of Designations. Except as otherwise provided in
11 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
12 that qualifies for protection under this Order must be clearly so designated before the
13 material is disclosed or produced.
14 Designation in conformity with this Order requires:
15 (a) for information in documentary form (e.g., paper or electronic
16 documents, but excluding transcripts of depositions or other pretrial or trial
17 proceedings), that the Producing Party affix at a minimum, the legend
18 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
19 contains protected material. If only a portion or portions of the material on a page
20 qualifies for protection, the Producing Party also must clearly identify the protected
21 portion(s) (e.g., by making appropriate markings in the margins).
22 A Party or Non-Party who makes original documents available for inspection
23 need not designate them for protection until after the inspecting Party has indicated
24 which documents it would like copied and produced. During the inspection and
25 before the designation, all of the material made available for inspection shall be
26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
27 documents it wants copied and produced, the Producing Party must determine which
1 producing the specified documents, the Producing Party must affix the
2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
3 portion or portions of the material on a page qualifies for protection, the Producing
4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
5 markings in the margins).
6 (b) for testimony given in depositions that the Designating Party identify
7 the Disclosure or Discovery Material on the record, before the close of the deposition
8 all protected testimony.
9 (c) for information produced in some form other than documentary and for
10 any other tangible items, that the Producing Party affix in a prominent place on the
11 exterior of the container or containers in which the information is stored the legend
12 “CONFIDENTIAL.” If only a portion or portions of the information warrants
13 protection, the Producing Party, to the extent practicable, shall identify the protected
14 portion(s).
15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
16 failure to designate qualified information or items does not, standing alone, waive
17 the Designating Party’s right to secure protection under this Order for such material.
18 Upon timely correction of a designation, the Receiving Party must make reasonable
19 efforts to assure that the material is treated in accordance with the provisions of this
20 Order.
21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
23 designation of confidentiality at any time that is consistent with the Court’s
24 Scheduling Order.
25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
26 resolution process under Local Rule 37.1, et seq.
27 6.3 The burden of persuasion in any such challenge proceeding shall be on
1 (e.g., to harass or impose unnecessary expenses and burdens) may expose the
2 Challenging Party to sanctions. Unless the Designating Party has waived or
3 withdrawn the confidentiality designation, all Parties shall continue to afford the
4 material in question the level of protection to which it is entitled under the Producing
5 Party’s designation until the Court rules on the challenge.
6 7. ACCESS TO AND USE OF PROTECTED MATERIAL
7 7.1 Basic Principles. A Receiving Party may use Protected Material that is
8 disclosed or produced by another Party or by a Non-Party in connection with this
9 Action only for prosecuting, defending, or attempting to settle this Action. Such
10 Protected Material may be disclosed only to the categories of persons and under the
11 conditions described in this Order. When the Action has been terminated, a
12 Receiving Party must comply with the provisions of section 13 below (FINAL
13 DISPOSITION).
14 Protected Material must be stored and maintained by a Receiving Party at a
15 location and in a secure manner that ensures that access is limited to the persons
16 authorized under this Order.
17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
18 otherwise ordered by the Court or permitted in writing by the Designating Party, a
19 Receiving Party may disclose any information or item designated
20 “CONFIDENTIAL” only to:
21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
22 as employees of said Outside Counsel of Record to whom it is reasonably necessary
23 to disclose the information for this Action;
24 (b) any Receiving Party that is a natural person and the officers, directors,
25 and employees (including House Counsel) of the Receiving Party to whom
26 disclosure is reasonably necessary for this Action;
27 (c) Experts (as defined in this Order) of the Receiving Party to whom
1 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (d) the Court and its personnel;
3 (e) court reporters and their staff;
4 (f) professional jury or trial consultants, mock jurors, and Professional
5 Vendors to whom disclosure is reasonably necessary for this Action and who have
6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (g) the author or recipient of a document containing the information or a
8 custodian or other person who otherwise possessed or knew the information;
9 (h) during their depositions, witnesses, and attorneys for witnesses, in the
10 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
11 requests that the witness sign the “Acknowledgment and Agreement to Be Bound”
12 attached as Exhibit A hereto; and (2) they will not be permitted to keep any
13 confidential information unless they sign the “Acknowledgment and Agreement to
14 Be Bound,” unless otherwise agreed by the Designating Party or ordered by the
15 Court. Pages of transcribed deposition testimony or exhibits to depositions that
16 reveal Protected Material may be separately bound by the court reporter and may not
17 be disclosed to anyone except as permitted under this Stipulated Protective Order;
18 and
19 (i) a mediator or settlement officer, and their supporting personnel,
20 mutually agreed upon by any of the Parties engaged in settlement discussions.
21 8. PROTECTED MATERIAL IN OTHER LITIGATION
22 If a Party is served with a subpoena or a court order issued in other litigation
23 that compels disclosure of any information or items designated in this Action as
24 “CONFIDENTIAL,” that Party must:
25 (a) promptly notify in writing the Designating Party. Such notification
26 shall include a copy of the subpoena or court order;
27 (b) promptly notify in writing the Party who caused the subpoena or order
1 or order is subject to this Protective Order. Such notification shall include a copy of
2 this Stipulated Protective Order; and
3 (c) cooperate with respect to all reasonable procedures sought to be pursued
4 by the Designating Party whose Protected Material may be affected.
5 If the Designating Party timely seeks a protective order, the Party served
6 with the subpoena or court order shall not produce any information designated in this
7 action as “CONFIDENTIAL” before a determination by the court from which the
8 subpoena or order issued, unless the Party has obtained the Designating Party’s
9 permission. The Designating Party shall bear the burden and expense of seeking
10 protection in that court of its confidential material and nothing in these provisions
11 should be construed as authorizing or encouraging a Receiving Party in this Action
12 to disobey a lawful directive from another court.
13 9. NON-PARTY’S PROTECTED MATERIAL
14 (a) The terms of this Order are applicable to information produced by a
15 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
16 produced by Non-Parties in connection with this litigation is protected by the
17 remedies and relief provided by this Order. Nothing in these provisions should be
18 construed as prohibiting a Non-Party from seeking additional protections.
19 (b) In the event that a Party is required, by a valid discovery request, to
20 produce a Non-Party’s confidential information in its possession, and the Party is
21 subject to an agreement with the Non-Party not to produce the Non-Party’s
22 confidential information, then the Party shall:
23 (1) promptly notify in writing the Requesting Party and the Non-Party
24 that some or all of the information requested is subject to a confidentiality agreement
25 with a Non-Party;
26 (2) promptly provide the Non-Party with a copy of the Stipulated
27 Protective Order in this Action, the relevant discovery request(s), and a reasonably
1 (3) make the information requested available for inspection by the
2 Non-Party, if requested.
3 (c) If the Non-Party fails to seek a protective order from this Court within
4 14 days of receiving the notice and accompanying information, the Receiving Party
5 may produce the Non-Party’s confidential information responsive to the discovery
6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
7 not produce any information in its possession or control that is subject to the
8 confidentiality agreement with the Non-Party before a determination by the Court.
9 Absent a Court order to the contrary, the Non-Party shall bear the burden and expense
10 of seeking protection in this Court of its Protected Material.
11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
17 persons to whom unauthorized disclosures were made of all the terms of this Order,
18 and (d) request such person or persons to execute the “Acknowledgment and
19 Agreement to Be Bound” that is attached hereto as Exhibit A.
20 11. INADVERTENT PRODUCTION OF PROTECTED MATERIAL
21 When a Producing Party gives notice to Receiving Parties that certain
22 inadvertently produced material is subject to a claim of privilege or other protection,
23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
25 may be established in an e-discovery order that provides for production without prior
26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), the Parties
27 agree that, with respect to material subject to a claim of privilege or other protection,
1 with the litigation pending before the Court—in which event the disclosure is also
2 not a waiver in any other federal or state proceeding.
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
5 person to seek its modification by the Court in the future.
6 12.2 Right to Assert Other Objections. By stipulating to the entry of this
7 Protective Order no Party waives any right it otherwise would have to object to
8 disclosing or producing any information or item on any ground not addressed in this
9 Stipulated Protective Order. Similarly, no Party waives any right to object on any
10 ground to use in evidence of any of the material covered by this Protective Order.
11 12.3 Filing Protected Material. A Party that seeks to file under seal any
12 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
13 only be filed under seal pursuant to a Court order authorizing the sealing of the
14 specific Protected Material at issue. If a Party’s request to file Protected Material
15 under seal is denied by the Court, then the Receiving Party may file the information
16 in the public record unless otherwise instructed by the Court.
17 12.4 No Waiver of Constitutional Rights. Nothing in this Stipulated
18 Protective Order, nor any act taken in compliance with it, shall be construed as a
19 waiver of any Party’s constitutional rights, including, without limitation, their rights
20 under the Fifth Amendment to the United States Constitution. Without limiting the
21 foregoing, compliance with this Order shall not constitute a waiver of any protections
22 afforded by the Fifth Amendment, including under the “act of production” doctrine.
23 Nothing herein shall be deemed to compel any Party or person to provide testimony
24 or materials in violation of their Fifth Amendment rights. Notwithstanding the
25 foregoing, nothing in this Section 12.4 is intended to provide any Party with
26 protections above those provided by the United States Constitution nor prevent the
27 disclosure of testimony or documents not protected by the Fifth Amendment. In
1 been a waiver of another Party’s rights under the Fifth Amendment to the United
2 States Constitution for a reason other than the Party’s compliance with this Order.
3 13. FINAL DISPOSITION
4 After the final disposition of this Action, within 60 days of a written request
5 by the Designating Party, each Receiving Party must make reasonable efforts to
6 return all Protected Material to the Producing Party or destroy such material. As
7 used in this subdivision, “all Protected Material” includes all copies, abstracts,
8 compilations, summaries, and any other format reproducing or capturing any of the
9 Protected Material. Whether the Protected Material is returned or destroyed, the
10 Receiving Party must submit a written certification to the Producing Party (and, if
11 not the same person or entity, to the Designating Party) by the 60 day deadline that
12 (1) identifies (by category, where appropriate) all the Protected Material that was
13 returned or destroyed and (2) affirms that the Receiving Party has not retained any
14 copies, abstracts, compilations, summaries or any other format reproducing or
15 capturing any of the Protected Material. Notwithstanding this provision, Counsel
16 are entitled to retain an archival copy of all pleadings, motion papers, trial,
17 deposition, and hearing transcripts, legal memoranda, correspondence, deposition
18 and trial exhibits, expert reports, attorney work product, and consultant and expert
19 work product, even if such materials contain Protected Material. Any such archival
20 copies that contain or constitute Protected Material remain subject to this Protective
21 Order as set forth in Section 4 (DURATION).
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23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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25 DATED: April 16, 2026
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27 /s/ Adam George
Attorneys for Plaintiff Alice Rosenblum
2 || DATED: April 16, 2026
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4 |\|/s/ Nary Kim
5 Attorneys for Defendants Passes, Inc. and Lucy Guo
6 DATED: April 16, 2026
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8 /s/ Matthew Troccoli
9 || Attorneys for Defendant Lani Ginoza
10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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DATED: April 20, 2026
14 Palaces Oona hoe
= The Hon. PatriciaDonahue
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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
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of Rosenblum v. Passes Inc. et al., No. 2:25-cv-08457 (C.D.
8 Cal.). I agree to comply with and to be bound by all the terms of this Stipulated
9 Protective Order and I understand and acknowledge that failure to so comply could
10 expose me to sanctions and punishment in the nature of contempt. I solemnly
11 promise that I will not disclose in any manner any information or item that is subject
12 to this Stipulated Protective Order to any person or entity except in strict
13 compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint ________________________ [print or
18 type full name] of _________ [print or type full address and telephone number] as
19 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: _____________________________
24 Printed name: ____________________________________
25 Signature: ________________________________
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