# Opinion

> District Court, C.D. California · April 23, 2026

URL: https://www.frixlaw.com/law-library/cases/11374530

## Case

- **Full name:** Jane Doe v. Venus Concept USA Inc.; Joseph Brown; and Doe 1 to 10 inclusive
- **Court:** District Court, C.D. California
- **Decided:** April 23, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 BRIAN L. WILLIAMS, State Bar No. 227948
BWilliams@GGTrialLaw.com
2 JEMMA E. DUNN, State Bar No. 258454
JDunn@GGTrialLaw.com
3 PHILIP A. HORLACHER, State Bar No. 318837
PHorlacher@GGTrialLaw.com
4 GREENBERG GROSS LLP
601 S. Figueroa Street, 30th Floor
5 Los Angeles, California 90017
Telephone: (213) 334-7000
6 Facsimile: (213) 334-7001

7 Attorneys for Plaintiff, Jane Doe

8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 JANE DOE, an individual, Case No. 2:25-cv-11096 FMO (PDx)

12 Plaintiff, STIPULATED PROTECTIVE
ORDER
13 v.

14 VENUS CONCEPT USA INC.; a
Delaware corporation; JOSEPH
15 BROWN, an individual; and DOE 1 to
10 inclusive,
16
Defendants.
17 Judge: Hon. Fernando M. Olguin
Trial Date: January 26, 2027
18

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25
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27
1 1. PURPOSE AND LIMITATIONS
2 Discovery in this action will require the production and exchange of highly
3 sensitive and private information. The parties have already propounded written
4 discovery, including requests for production of documents, that specifically seek
5 such materials.
6 For instance, Defendants seek Plaintiff’s therapy and mental health records,
7 including, but not limited to,records reflecting diagnoses, treatment, and
8 communications with providers. These records contain intensely personal
9 information, including disclosures concerning alleged sexual assault and other
10 sensitive life events, as well as information relating to third parties who are not
11 parties to this litigation.
12 Plaintiff, in turn, seeks Defendants’ personnel records, including disciplinary
13 records. sensitive communications and other employment records for percipient
14 witnesses involved in the events at issue, including the individual accused of assault,
15 as well as documents reflecting Defendants’ receipt, investigation, and response to
16 allegations of sexual assault, discrimination, harassment, and retaliation made by
17 Plaintiff and other employees. These materials necessarily include internal
18 complaints, witness statements, investigative findings, and related communications,
19 that Defendants contend contain private and sensitive information concerning
20 current and former employees and other non-parties.
21 The disclosure of these categories of information implicates significant
22 privacy rights under California law, including the constitutional right to privacy.
23 Absent appropriate safeguards, production of such materials would result in an
24 unwarranted invasion of privacy and create a substantial risk of misuse of sensitive
25 personal information.
26 Because the parties have already sought this information through formal
27 discovery, its production is not hypothetical but inevitable. A protective order is
1 while ensuring that therapy records, personnel records, and other confidential
2 materials are used solely for purposes of this litigation and are not subject to public
3 disclosure.
4 The parties acknowledge that this Order does not confer blanket protection on
5 all discovery and that its protections apply only to information entitled to
6 confidential treatment under applicable law.
7 Accordingly, the parties hereby stipulate to and petition the Court to enter the
8 following Stipulated Protective Order. The parties acknowledge that this Order does
9 not confer blanket protections on all disclosures or responses to discovery and that
10 the protection it affords from public disclosure and use extends only to the limited
11 information or items that are entitled to confidential treatment under the applicable
12 legal principles.
13 2. GOOD CAUSE STATEMENT
14 This action arises from claims of sexual harassment, sexual battery, gender
15 violence, discrimination, retaliation, and negligent supervision and retention under
16 the Fair Employment and Housing Act ("FEHA") and California common law.
17 Discovery in this action is likely to involve sensitive materials warranting special
18 protection from public disclosure, including: (1) Plaintiff's medical, psychiatric, and
19 mental health records—including records relating to diagnoses of Post Traumatic
20 Stress Disorder, Major Depressive Disorder, and related conditions—reflecting
21 highly personal and private information about a survivor of sexual assault; (2)
22 Plaintiff's identity, which Plaintiff has filed a motion seeking to protect the
23 disclosure of to preserve her legitimate privacy interests as a victim of sexual assault
24 and to prevent embarrassment, harassment, injury, re-traumatization, and further
25 harm to her professional reputation; (3) personnel records of Plaintiff, Defendant
26 Joseph Brown, and potentially other current and former Venus Concept USA Inc.
27 employees, including records of complaints, discipline, performance evaluations,
1 pertaining to complaints, investigations, and findings relating to allegations of
2 sexual harassment or misconduct at Venus Concept USA Inc.; (5) private text
3 messages, emails, and other personal communications between parties and
4 witnesses; (6) confidential business records of Defendant Venus Concept USA Inc.,
5 including internal policies, procedures, corporate communications, and information
6 regarding other employees who have not consented to the disclosure of their
7 personal information; and (7) information produced by or concerning non-party
8 witnesses, including potential third-party victims of discrimination, harassment, or
9 retaliation who have privacy interests in their identities and personal circumstances.
10 Disclosure of such materials beyond the confines of this litigation could cause
11 serious harm to Plaintiff as a survivor of sexual assault, expose non-party employees
12 to reputational and personal harm, prejudice the parties' ability to conduct necessary
13 discovery. Accordingly, to expedite the flow of information, to facilitate the prompt
14 resolution of disputes over confidentiality of discovery materials, to adequately
15 protect information the parties are entitled to keep confidential, to ensure that the
16 parties are permitted reasonable necessary uses of such material in preparation for
17 and in the conduct of trial, to address their handling at the end of the litigation, and
18 to serve the ends of justice, a protective order for such information is justified in this
19 matter. It is the intent of the parties that information will not be designated as
20 confidential for tactical reasons and that nothing be so designated without a good
21 faith belief that it has been maintained in a confidential, non-public manner, and
22 there is good cause why it should not be part of the public record of this case.
23 3. ACKNOWLEDGMENT OF UNDER SEAL FILING
24 PROCEDURE
25 The parties further acknowledge, as set forth in Section 14.3, below, that this
26 Stipulated Protective Order does not entitle them to file confidential information
27 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
1 to file material under seal. There is a strong presumption that the public has a right
2 of access to judicial proceedings and records in civil cases. In connection with non-
3 dispositive motions, good cause must be shown to support a filing under seal. See
4 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
5 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-
6 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
7 stipulated protective orders require good cause showing), and a specific showing of
8 good cause or compelling reasons with proper evidentiary support and legal
9 justification must be made with respect to Protected Material that a party seeks to
10 file under seal. The parties' mere designation of Disclosure or Discovery Material as
11 CONFIDENTIAL does not—without the submission of competent evidence by
12 declaration, establishing that the material sought to be filed under seal qualifies as
13 confidential, privileged, or otherwise protectable—constitute good cause.
14 Further, if a party requests sealing related to a dispositive motion or trial, then
15 compelling reasons, not only good cause, for the sealing must be shown, and the
16 relief sought shall be narrowly tailored to serve the specific interest to be protected.
17 See Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For
18 each item or type of information, document, or thing sought to be filed or introduced
19 under seal, the party seeking protection must articulate compelling reasons,
20 supported by specific facts and legal justification, for the requested sealing order.
21 Again, competent evidence supporting the application to file documents under seal
22 must be provided by declaration.
23 Any document that is not confidential, privileged, or otherwise protectable in
24 its entirety will not be filed under seal if the confidential portions can be redacted. If
25 documents can be redacted, then a redacted version for public viewing, omitting
26 only the confidential, privileged, or otherwise protectable portions of the document,
27 shall be filed. Any application that seeks to file documents under seal in their
1
2 4. DEFINITIONS
3 4.1 Action: This pending federal lawsuit, Jane Doe v. Venus Concept USA
4 Inc., et al., Case No. 2:25-cv-11096, pending in the United States District Court for
5 the Central District of California.
6 4.2 Challenging Party: a Party or Non-Party that challenges the designation
7 of information or items under this Order.
8 4.3 "CONFIDENTIAL" Information or Items: information (regardless of
9 how it is generated, stored or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), and/or as specified above in
11 the Good Cause Statement.
12 4.4 Counsel: Outside Counsel of Record (as well as their support staff) and
13 House Counsel (as well as their support staff).
14 4.5 Designating Party: a Party or Non-Party that designates information or
15 items that it produces in disclosures or in responses to discovery as
16 "CONFIDENTIAL."
17 4.6 Disclosure or Discovery Material: all items or information, regardless of
18 the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced or
20 generated in disclosures or responses to discovery in this matter.
21 4.7 Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24 4.8 House Counsel: attorneys who are employees of a party to this Action.
25 House Counsel does not include Outside Counsel of Record or any other outside
26 counsel.
27 4.9 Non-Party: any natural person, partnership, corporation, association or
1 4.10 Outside Counsel of Record: attorneys who are not employees of a party
2 to this Action but are retained to represent a party to this Action and have appeared
3 in this Action on behalf of that party or are affiliated with a law firm that has
4 appeared on behalf of that party, and includes support staff.
5 4.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 4.13 Professional Vendors: persons or entities that provide litigation support
11 services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 4.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as "CONFIDENTIAL."
16 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
17 from a Producing Party.
18 5. SCOPE
19 The protections conferred by this Stipulation and Order cover not only
20 Protected Material (as defined above), but also (1) any information copied or
21 extracted from Protected Material; (2) all copies, excerpts, summaries, or
22 compilations of Protected Material; and (3) any testimony, conversations, or
23 presentations by Parties or their Counsel that might reveal Protected Material.
24 Any use of Protected Material at trial shall be governed by the orders of the
25 trial judge and other applicable authorities. This Order does not govern the use of
26 Protected Material at trial.
27 6. DURATION
1 obligations imposed by this Order will remain in effect until a Designating
Party agrees otherwise in writing or a court order otherwise directs. Final
2 disposition will be deemed to be the later of (1) dismissal of all claims and
defenses in this Action, with or without prejudice; and (2) final judgment
3 herein after the completion and exhaustion of all appeals, rehearings, remands,
trials, or reviews of this Action, including the time limits for filing any motions
4 or applications for extension of time pursuant to applicable law.
DESIGNATING PROTECTED MATERIAL
5
7.1 Exercise of Restraint and Care in Designating Material for
6
Protection. Each Party or Non-Party that designates information or items for
7
protection under this Order must take care to limit any such designation to specific
8
material that qualifies under the appropriate standards. The Designating Party must
9
designate for protection only those parts of material, documents, items or oral or
10
written communications that qualify so that other portions of the material,
11
documents, items or communications for which protection is not warranted are not
12
swept unjustifiably within the ambit of this Order.
13
Mass, indiscriminate or routinized designations are prohibited. Designations
14
that are shown to be clearly unjustified or that have been made for an improper
15
purpose (e.g., to unnecessarily encumber the case development process or to impose
16
unnecessary expenses and burdens on other parties) may expose the Designating
17
Party to sanctions.
18
If it comes to a Designating Party's attention that information or items that it
19
designated for protection do not qualify for protection, that Designating Party must
20
promptly notify all other Parties that it is withdrawing the inapplicable designation.
21
7.2 Manner and Timing of Designations. Except as otherwise provided in
22
this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material
23
that qualifies for protection under this Order must be clearly so designated before
24
the material is disclosed or produced.
25
Designation in conformity with this Order requires:
26
(a) for information in documentary form (e.g., paper or electronic documents,
27
but excluding transcripts of depositions or other pretrial or trial proceedings), that
1 the Producing Party affix at a minimum the legend "CONFIDENTIAL" (hereinafter
2 "CONFIDENTIAL legend"), to each page that contains protected material. If only a
3 portion of the material on a page qualifies for protection, the Producing Party also
4 must clearly identify the protected portion(s) (e.g., by making appropriate markings
5 in the margins).
6 A Party or Non-Party that makes original documents available for inspection
7 need not designate them for protection until after the inspecting Party has indicated
8 which documents it would like copied and produced. During the inspection and
9 before the designation, all of the material made available for inspection shall be
10 deemed "CONFIDENTIAL." After the inspecting Party has identified the
11 documents it wants copied and produced, the Producing Party must determine which
12 documents, or portions thereof, qualify for protection under this Order. Then, before
13 producing the specified documents, the Producing Party must affix the
14 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a
15 portion of the material on a page qualifies for protection, the Producing Party also
16 must clearly identify the protected portion(s) (e.g., by making appropriate markings
17 in the margins).
18 (b) for testimony given in depositions, that the Designating Party identifies
19 the Disclosure or Discovery Material on the record, before the close of the
20 deposition, all protected testimony.
21 (c) for information produced in some form other than documentary and for
22 any other tangible items, that the Producing Party affix in a prominent place on the
23 exterior of the container or containers in which the information is stored the legend
24 "CONFIDENTIAL." If only a portion or portions of the information warrants
25 protection, the Producing Party, to the extent practicable, shall identify the protected
26 portion(s).
27 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
1 the Designating Party's right to secure protection under this Order for such material.
2 Upon timely correction of a designation, the Receiving Party must make reasonable
3 efforts to assure that the material is treated in accordance with the provisions of this
4 Order.
5 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6 8.1 Timing of Challenges. Any Party or Non-Party may challenge a
7 designation of confidentiality at any time that is consistent with the Court's
8 Scheduling Order.
9 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
10 resolution process under Local Rule 37-1 et seq.
11 8.3 The burden of persuasion in any such challenge proceeding shall be on the
12 Designating Party. Frivolous challenges, and those made for an improper purpose
13 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
14 expose the Challenging Party to sanctions. Unless the Designating Party has waived
15 or withdrawn the confidentiality designation, all parties shall continue to afford the
16 material in question the level of protection to which it is entitled under the
17 Producing Party's designation until the Court rules on the challenge.
18 9. ACCESS TO AND USE OF PROTECTED MATERIAL
19 9.1 Basic Principles. A Receiving Party may use Protected Material that is
20 disclosed or produced by another Party or by a Non-Party in connection with this
21 Action only for prosecuting, defending or attempting to settle this Action. Such
22 Protected Material may be disclosed only to the categories of persons and under the
23 conditions described in this Order. When the Action has been terminated, a
24 Receiving Party must comply with the provisions of Section 15 below (FINAL
25 DISPOSITION).
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
1 9.2 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 to:
5 (a) the Receiving Party's Outside Counsel of Record in this Action, as well as
6 employees of said Outside Counsel of Record to whom it is reasonably necessary to
7 disclose the information for this Action;
8 (b) the officers, directors, and employees (including House Counsel) of the
9 Receiving Party to whom disclosure is reasonably necessary for this Action;
10 (c) 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) the Court and its personnel;
14 (e) court reporters and their staff;
15 (f) professional jury or trial consultants, mock jurors, and Professional
16 Vendors to whom disclosure is reasonably necessary for this Action and who have
17 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);
18 (g) the author or recipient of a document containing the information or a
19 custodian or other person who otherwise possessed or knew the information;
20 (h) during their depositions, witnesses, and attorneys for witnesses, in the
21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
23 will not be permitted to keep any confidential information unless they sign the
24 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise
25 agreed by the Designating Party or ordered by the court. Pages of transcribed
26 deposition testimony or exhibits to depositions that reveal Protected Material may
27 be separately bound by the court reporter and may not be disclosed to anyone except
1 (i) any mediators or settlement officers and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions; and
3 (j) the Plaintiff and any individually named Defendant.
4 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
5 PRODUCED IN OTHER LITIGATION
6 If a Party is served with a subpoena or a court order issued in other litigation
7 that compels disclosure of any information or items designated in this Action as
8 "CONFIDENTIAL," that Party must:
9 (a) promptly notify in writing the Designating Party. Such notification shall
10 include a copy of the subpoena or court order;
11 (b) promptly notify in writing the party who caused the subpoena or order to
12 issue in the other litigation that some or all of the material covered by the subpoena
13 or order is subject to this Protective Order. Such notification shall include a copy of
14 this Stipulated Protective Order; and
15 (c) cooperate with respect to all reasonable procedures sought to be pursued
16 by the Designating Party whose Protected Material may be affected.
17 If the Designating Party timely seeks a protective order, the Party served with
18 the subpoena or court order shall not produce any information designated in this
19 action as "CONFIDENTIAL" before a determination by the court from which the
20 subpoena or order issued, unless the Party has obtained the Designating Party's
21 permission. The Designating Party shall bear the burden and expense of seeking
22 protection in that court of its confidential material and nothing in these provisions
23 should be construed as authorizing or encouraging a Receiving Party in this Action
24 to disobey a lawful directive from another court.
25 11. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
26 PRODUCED IN THIS LITIGATION
27 (a) The terms of this Order are applicable to information produced by a Non-
1 produced by Non-Parties in connection with this litigation is protected by the
2 remedies and relief provided by this Order. Nothing in these provisions should be
3 construed as prohibiting a Non-Party from seeking additional protections.
4 (b) In the event that a Party is required, by a valid discovery request, to
5 produce a Non-Party's confidential information in its possession, and the Party is
6 subject to an agreement with the Non-Party not to produce the Non-Party's
7 confidential information, then the Party shall:
8 (1) promptly notify in writing the Requesting Party and the Non-Party that
9 some or all of the information requested is subject to a confidentiality agreement
10 with a Non-Party;
11 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
12 Order in this Action, the relevant discovery request(s), and a reasonably specific
13 description of the information requested; and
14 (3) make the information requested available for inspection by the Non-Party,
15 if requested.
16 (c) If the Non-Party fails to seek a protective order from this court within 14
17 days of receiving the notice and accompanying information, the Receiving Party
18 may produce the Non-Party's confidential information responsive to the discovery
19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
20 not produce any information in its possession or control that is subject to the
21 confidentiality agreement with the Non-Party before a determination by the court.
22 Absent a court order to the contrary, the Non-Party shall bear the burden and
23 expense of seeking protection in this court of its Protected Material.
24 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
25 MATERIAL
26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27 Protected Material to any person or in any circumstance not authorized under this
1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
3 persons to whom unauthorized disclosures were made of all the terms of this Order,
4 and (d) request such person or persons to execute the "Acknowledgment and
5 Agreement to Be Bound" attached hereto as Exhibit A.
6 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
7 OTHERWISE PROTECTED MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain
9 inadvertently produced material is subject to a claim of privilege or other protection,
10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
12 may be established in an e-discovery order that provides for production without
13 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
14 as the parties reach an agreement on the effect of disclosure of a communication or
15 information covered by the attorney-client privilege or work product protection, the
16 parties may incorporate their agreement in the stipulated protective order submitted
17 to the court.
18 14. MISCELLANEOUS
19 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 14.2 Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order, no Party waives any right it otherwise would have to object to
23 disclosing or producing any information or item on any ground not addressed in this
24 Stipulated Protective Order. Similarly, no Party waives any right to object on any
25 ground to use in evidence of any of the material covered by this Protective Order.
26 14.3 Filing Protected Material. A Party that seeks to file under seal any
27 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
1 specific Protected Material. If a Party's request to file Protected Material under seal
2 is denied by the court, then the Receiving Party may file the information in the
3 public record unless otherwise instructed by the court.
4 15. FINAL DISPOSITION
5 After the final disposition of this Action, as defined in paragraph 6, within 60
6 days of a written request by the Designating Party, each Receiving Party must return
7 all Protected Material to the Producing Party or destroy such material. As used in
8 this subdivision, "all Protected Material" includes all copies, abstracts, compilations,
9 summaries, and any other format reproducing or capturing any of the Protected
10 Material. Whether the Protected Material is returned or destroyed, the Receiving
11 Party must submit a written certification to the Producing Party (and, if not the same
12 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
13 (by category, where appropriate) all the Protected Material that was returned or
14 destroyed and (2) affirms that the Receiving Party has not retained any copies,
15 abstracts, compilations, summaries or any other format reproducing or capturing any
16 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
17 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
18 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
19 reports, attorney work product, and consultant and expert work product, even if such
20 materials contain Protected Material. Any such archival copies that contain or
21 constitute Protected Material remain subject to this Protective Order as set forth in
22 Section 6 (DURATION).
23
24 16. VIOLATION
25 Any willful violation of this Order may be punished by appropriate measures
26 including, without limitation, contempt proceedings and/or evidentiary or monetary
27 sanctions, or other appropriate action at the discretion of the Court.
2||DATED: April 16, 2026 GREENBERG GROSS LLP
3
4
5 By: /s/Philip A. Horlacher
Brian L. Williams
6 Jemma E. Dunn
7 Philip A. Horlacher
Attorneys for Plaintiff, Jane Doe
8
9 DATED: April 16, 2026 FISHER & PHILLIPS LLP
10
11
By: /s/Talar Tavlian
12 Talar Tavlian
13 Attorneys for Defendants Venus Concept
14 USA Inc. and Joseph Brown

15 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
16
17\| DATED: 04/23/2026 Flier Mana
18 PATRICIA DONAHUE
19 United States Magistrate Judge
20
21
22
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24
25
26
27
28

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, ________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on ____________________ [date] in the case of Jane Doe v. Venus Concept USA
9 Inc., case no. 2:25-cv-11096 FMO (PDx). I agree to comply with and to be bound
10 by all the terms of this Stipulated Protective Order and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and punishment
12 in the nature of contempt. I solemnly promise that I will not disclose in any manner
13 any information or item that is subject to this Stipulated Protective Order to any
14 person or entity except in strict compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint ________________________ [print or
19 type full name] of ________________________________________________ [print
20 or type full address and telephone number] as my California agent for service of
21 process in connection with this action or any proceedings related to enforcement of
22 this Stipulated Protective Order.
23 Date: _______________________________
24 City and State where sworn and
25 Signed: _______________________________
26 Printed Name: _______________________________
27 Signature: _______________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11374530. Public record. Not legal advice.