The opinion
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9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11 WESTERN DIVISION
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ASCENT INVESTOR RELATIONS, Case No. 2:25-cv-11107-SB (AJRx)
14 INC., a New York corporation, [PROPOSED] STIPULATED
15 Plaintiff, PROTECTIVE ORDER
16 v .
VISIONARY HOLDINGS INC., a
17
Canadian corporation; FARVISION
18 CAREER EDUCATION GROUP,
INC., a Canadian corporation; 3888
19 INVESTMENT GROUP LIMITED, a
Canadian corporation; and FAN
20
ZHOU, an individual,
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Defendant.
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1. GENERAL
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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 prosecuting
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this litigation may be warranted. Accordingly, the parties hereby stipulate to and
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2 petition the Court to enter the following Stipulated Protective Order. The parties
3 acknowledge that this Order does not confer blanket protections on all disclosures or
4 responses to discovery and that the protection it affords from public disclosure and
5 use extends only to the limited information or items that are entitled to confidential
6 treatment under the applicable legal principles. The parties further acknowledge, as
7 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
8 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the
9 procedures that must be followed and the standards that will be applied when a party
10 seeks permission from the court to file material under seal.
11 1.2 Good Cause Statement.
12 This action is likely to involve commercial, financial, and/or proprietary
13 information for which special protection from public disclosure and from use for any
14 purpose other than prosecution of this action is warranted. Such confidential and
15 proprietary materials and information consist of, among other things, confidential
16 business or financial information, information regarding confidential business
17 practices, or other confidential research, development, or commercial information
18 (including information implicating privacy rights of third parties), information
19 otherwise generally unavailable to the public, or which may be privileged or otherwise
20 protected from disclosure under state or federal statutes, court rules, case decisions,
21 or common law. Accordingly, to expedite the flow of information, to facilitate the
22 prompt resolution of disputes over confidentiality of discovery materials, to
23 adequately protect information the parties are entitled to keep confidential, to ensure
24 that the parties are permitted reasonable necessary uses of such material in preparation
25 for and in the conduct of trial, to address their handling at the end of the litigation,
26 and serve the ends of justice, a protective order for such information is justified in this
27 matter. It is the intent of the parties that information will not be designated as
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2 confidential for tactical reasons and that nothing be so designated without a good faith
3 belief that it has been maintained in a confidential, non-public manner, and there is
4 good cause why it should not be part of the public record of this case.
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6 2. DEFINITIONS
7 2.1 Action: the above-captioned matter, Ascent Investor Relations, Inc. v.
8 Visionary Holdings Inc. et. al., Case No. 2:25-cv-11107-SB-AJR, pending in the
9 United States District Court for the Central District of California.
10 2.2 Challenging Party: a Party or Non-Party that challenges the designation
11 of information or items under this Order.
12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
13 how it is generated, stored or maintained) or tangible things that qualify for protection
14 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
15 Cause Statement.
16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
17 support staff).
18 2.5 Designating Party: a Party or Non-Party that designates information or
19 items that it produces in disclosures or in responses to discovery as
20 “CONFIDENTIAL.”
21 2.6 Disclosure or Discovery Material: all items or information, regardless
22 of the medium or manner in which it is generated, stored, or maintained (including,
23 among other things, testimony, transcripts, and tangible things), that are produced or
24 generated in disclosures or responses to discovery in this matter.
25 2.7 Expert: a person with specialized knowledge or experience in a matter
26 pertinent to the litigation who has been retained by a Party or its counsel to serve as
27 an expert witness or as a consultant in this Action.
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2 2.8 House Counsel: attorneys who are employees of a party to this Action.
3 House Counsel does not include Outside Counsel of Record or any other outside
4 counsel.
5 2.9 Non-Party: any natural person, partnership, corporation, association, or
6 other legal entity not named as a Party to this action.
7 2.10 Outside Counsel of Record: attorneys who are not employees of a party
8 to this Action but are retained to represent or advise a party to this Action and have
9 appeared in this Action on behalf of that party or are affiliated with a law firm that
10 has appeared on behalf of that party, including support staff.
11 2.11 Party: any party to this Action, including all of its officers, directors,
12 employees, consultants, retained experts, and Outside Counsel of Record (and their
13 support staffs).
14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
15 Discovery Material in this Action.
16 2.13 Professional Vendors: persons or entities that provide litigation support
17 services (e.g., photocopying, videotaping, translating, preparing exhibits or
18 demonstrations, and organizing, storing, or retrieving data in any form or medium)
19 and their employees and subcontractors.
20 2.14 Protected Material: any Disclosure or Discovery Material that is
21 designated as “CONFIDENTIAL.”
22 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
23 from a Producing Party.
24
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or extracted
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2 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
3 Protected Material; and (3) any testimony, conversations, or presentations by Parties
4 or their Counsel that might reveal Protected Material.
5 Any use of Protected Material at trial shall be governed by section 12.3 and/or
6 the orders of the trial judge. This Order does not govern the use of Protected Material
7 at trial.
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9 4. DURATION
10 Once a case proceeds to trial, all of the court-filed information to be introduced
11 that was previously designated as confidential or maintained pursuant to this
12 protective order becomes public and will be presumptively available to all members
13 of the public, including the press, unless compelling reasons supported by specific
14 factual findings to proceed otherwise are made to the trial judge in advance of the
15 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
16 2006) (distinguishing “good cause” showing for sealing documents produced in
17 discovery from “compelling reasons” standard when merits-related documents are
18 part of court record). Accordingly, the terms of this protective order do not extend
19 beyond the commencement of the trial.
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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 this
24 Order must take care to limit any such designation to specific material that qualifies
25 under the appropriate standards. The Designating Party must designate for protection
26 only those parts of material, documents, items, or oral or written communications that
27 qualify so that other portions of the material, documents, items, or communications
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2 for which protection is not warranted are not swept unjustifiably within the ambit of
3 this Order.
4 Mass, indiscriminate, or routinized designations are prohibited. Designations
5 that are shown by court order, to be clearly unjustified or that have been made for an
6 improper purpose (e.g., to unnecessarily encumber the case development process or
7 to impose unnecessary expenses and burdens on other parties) may expose the
8 Designating Party to sanctions imposed by the court, and only after attempts to resolve
9 the issue during the meet and confer process before asking for court intervention.
10 If it comes to a Designating Party’s attention that information or items that it
11 designated for protection do not qualify for protection, that Designating Party must
12 promptly notify all other Parties that it is withdrawing the inapplicable designation.
13 5.2 Manner and Timing of Designations. Except as otherwise provided in
14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
16 under this Order must be clearly so designated before the material is disclosed or
17 produced.
18 Designation in conformity with this Order requires:
19 (a) for information in documentary form (e.g., paper or electronic
20 documents, but excluding transcripts of depositions or other pretrial or trial
21 proceedings), that the Producing Party affix, at a minimum, the legend
22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
23 contains protected material. If only a portion or portions of the material on a page
24 qualifies for protection, the Producing Party also must clearly identify the protected
25 portion(s) (e.g., by making appropriate markings in the margins).
26 A Party or Non-Party that makes original documents available for inspection
27 need not designate them for protection until after the inspecting Party has indicated
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2 which documents it would like copied and produced. During the inspection and
3 before the designation, all of the material made available for inspection shall be
4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
5 it wants copied and produced, the Producing Party must determine which documents,
6 or portions thereof, qualify for protection under this Order. Then, before producing
7 the specified documents, the Producing Party must affix the “CONFIDENTIAL
8 legend” to each page that contains Protected Material. If only a portion or portions
9 of the material on a page qualifies for protection, the Producing Party also must clearly
10 identify the protected portion(s) (e.g., by making appropriate markings in the
11 margins).
12 (b) for testimony given in depositions that the Designating Party identify
13 the Disclosure or Discovery Material on the record, before the close of the deposition.
14 (c) for information produced in some form other than documentary and
15 for any other tangible items, that the Producing Party affix in a prominent place on
16 the exterior of the container or containers in which the information is stored the legend
17 “CONFIDENTIAL.” If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
20 5.3 Inadvertent Failures to Designate. If timely corrected within 30 days, an
21 inadvertent failure to designate qualified information or items does not, standing
22 alone, waive the Designating Party’s right to secure protection under this Order for
23 such material. Upon timely correction of a designation, the Receiving Party must
24 make reasonable efforts to assure that the material is treated in accordance with the
25 provisions of this Order.
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27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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2 6.1 Timing of Challenges. Any Party or Non-Party may challenge, via letter
3 and/or electronic mail stating the reasons why according to Local Rule 37-1 et seq., 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. Any discovery motion must strictly
8 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
9 6.3 Burden. The burden of persuasion in any such challenge proceeding
10 shall be on the Designating Party. Frivolous challenges, and those made for an
11 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
12 other parties) may expose the Challenging Party to sanctions. Unless the Designating
13 Party has waived or withdrawn the confidentiality designation, all parties shall
14 continue to afford the material in question the level of protection to which it is entitled
15 under the Producing Party’s designation until the Court rules on the challenge.
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17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1 Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this
20 Action only for prosecuting, defending, or attempting to settle this Action. Such
21 Protected Material may be disclosed only to the categories of persons and under the
22 conditions described in this Order. When the Action has been terminated, a Receiving
23 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
24 Protected Material must be stored and maintained by a Receiving Party at a
25 location and in a secure manner that ensures that access is limited to the persons
26 authorized under this Order.
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2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
3 otherwise ordered by the Court or permitted in writing by the Designating Party, a
4 Receiving Party may disclose any information or item designated
5 “CONFIDENTIAL” only to:
6 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
7 well as employees of said Outside Counsel of Record to whom it is reasonably
8 necessary to disclose the information for this Action;
9 (b) the officers, directors, and employees (including House Counsel) of
10 the Receiving Party to whom disclosure is reasonably necessary for this Action;
11 (c) Experts (as defined in this Order) of the Receiving Party to whom
12 disclosure is reasonably necessary for this Action and who have signed the
13 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (d) the Court and its personnel;
15 (e) court reporters and their staff;
16 (f) professional jury or trial consultants, mock jurors, and Professional
17 Vendors to whom disclosure is reasonably necessary for this Action and who have
18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (g) the author or recipient of a document containing the information or
20 a custodian or other person who otherwise possessed or knew the information;
21 (h) during their depositions, witnesses, and attorneys for witnesses, in
22 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
23 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
24 will not be permitted to keep any confidential information unless they sign the
25 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
26 agreed by the Designating Party or ordered by the Court. Pages of transcribed
27 deposition testimony or exhibits to depositions that reveal Protected Material may be
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2 separately bound by the court reporter and may not be disclosed to anyone except as
3 permitted under this Stipulated Protective Order; and
4 (i) any mediator or settlement officer, and their supporting personnel,
5 mutually agreed upon by any of the parties engaged in settlement discussions.
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7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
8 PRODUCED IN OTHER LITIGATION
9 If a Party is served with a subpoena or a court order issued in other litigation
10 that compels disclosure of any information or items designated in this Action as
11 “CONFIDENTIAL,” that Party must:
12 (a) promptly notify in writing the Designating Party. Such notification shall
13 include a copy of the subpoena or court order;
14 (b) promptly notify in writing the party who caused the subpoena or order to
15 issue in the other litigation that some or all of the material covered by the subpoena
16 or order is subject to this Protective Order. Such notification shall include a copy of
17 this Stipulated Protective Order; and
18 (c) cooperate with respect to all reasonable procedures sought to be pursued
19 by the Designating Party whose Protected Material may be affected.
20 If the Designating Party timely seeks a protective order, the Party served with
21 the subpoena or court order shall not produce any information designated in this action
22 as “CONFIDENTIAL” before a determination by the court from which the subpoena
23 or order issued, unless the Party has obtained the Designating Party’s permission. The
24 Designating Party shall bear the burden and expense of seeking protection in that court
25 of its confidential material and nothing in these provisions should be construed as
26 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
27 directive from another court.
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2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
3 PRODUCED IN THIS LITIGATION
4 (a) The terms of this Order are applicable to information produced by a Non-
5 Party in this Action and designated as “CONFIDENTIAL.” Such information
6 produced by Non-Parties in connection with this litigation is protected by the
7 remedies and relief provided by this Order. Nothing in these provisions should be
8 construed as prohibiting a Non-Party from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request, to produce
10 a Non-Party’s confidential information in its possession, and the Party is subject to an
11 agreement with the Non-Party not to produce the Non-Party’s confidential
12 information, then the Party shall:
13 (1) 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 agreement
15 with a Non-Party;
16 (2) promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s), and a reasonably
18 specific description of the information requested; and
19 (3) make the information requested available for inspection by the Non-
20 Party, if requested.
21 (c) If the Non-Party fails to seek a protective order from this Court within 14
22 days of receiving the notice and accompanying information, the Receiving Party may
23 produce the Non-Party’s confidential information responsive to the discovery request.
24 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
25 any information in its possession or control that is subject to the confidentiality
26 agreement with the Non-Party before a determination by the Court. Absent a court
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2 order to the contrary, the Non-Party shall bear the burden and expense of seeking
3 protection in this Court of its Protected Material.
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5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
7 Protected Material to any person or in any circumstance not authorized under this
8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
11 persons to whom unauthorized disclosures were made of all the terms of this Order,
12 and (d) request such person or persons to execute the “Acknowledgment and
13 Agreement to Be Bound” that is attached hereto as Exhibit A.
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15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
16 PROTECTED MATERIAL
17 When a Producing Party gives notice to Receiving Parties that certain
18 inadvertently produced material is subject to a claim of privilege (e.g. attorney-client
19 or work-product) or other protection, the obligations of the Receiving Parties are those
20 set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not
21 intended to modify whatever procedure may be established in an e-discovery order
22 that provides for production without prior privilege review. Pursuant to Federal Rule
23 of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of
24 disclosure of a communication or information covered by the attorney-client privilege
25 or work product protection, the parties may incorporate their agreement in the
26 stipulated protective order submitted to the Court.
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2 12. MISCELLANEOUS
3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
4 person to seek its modification by the Court in the future.
5 12.2 Right to Assert Other Objections. By stipulating to the entry of this
6 Protective Order, no Party waives any right it otherwise would have to object to
7 disclosing or producing any information or item on any ground not addressed in this
8 Stipulated Protective Order. Similarly, no Party waives any right to object on any
9 ground to use in evidence of any of the material covered by this Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
12 only be filed under seal pursuant to a court order authorizing the sealing of the specific
13 Protected Material at issue; good cause must be shown in the request to file under
14 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
15 then the Receiving Party may file the information in the public record unless
16 otherwise instructed by the Court.
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18 13. FINAL DISPOSITION
19 After the final disposition of this Action, within 60 days of a written request by
20 the Designating Party, each Receiving Party must return all Protected Material to the
21 Producing Party or destroy such material. As used in this subdivision, “all Protected
22 Material” includes all copies, abstracts, compilations, summaries, and any other
23 format reproducing or capturing any of the Protected Material. Whether the Protected
24 Material is returned or destroyed, the Receiving Party must submit a written
25 certification to the Producing Party (and, if not the same person or entity, to the
26 Designating Party) by the 60 day deadline that (1) identifies (by category, where
27 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms
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2 || that the Receiving Party has not retained any copies, abstracts, compilations,
3 || summaries or any other format reproducing or capturing any of the Protected Material.
4 || Notwithstanding this provision, counsel are entitled to retain an archival copy of all
5 || pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
6 || correspondence, deposition and trial exhibits, expert reports, attorney work product,
7 || and consultant and expert work product, even if such materials contain Protected
g || Material. Any such archival copies that contain or constitute Protected Material
9 || remain subject to this Protective Order as set forth in Section 4 (DURATION).
10
11 || 14. VIOLATION OF ORDER
12 Any violation of this Order may be punished by any and all appropriate
13. || measures including, without limitation, and/or monetary sanctions.
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15 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16
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ig |) DATED: April 17,2026
19 ) A
0 Michael C. Landman
Attorneys for Plaintiff
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DATED: April 17, 2026
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%6 /s/ Ivan Pose
Ivan Posey
27 || Attorneys for Defendants
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2 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
4 || DATED: 4/23/2026
HON. A. JOEL RICHLIN
5 United States Magistrate Judge
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2 EXHIBIT A
3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
4
5 I, _____________________________ [full name], of _________________
6 [full address], declare under penalty of perjury that I have read in its entirety and
7 understand the Stipulated Protective Order that was issued by the United States
8 District Court for the Central District of California on ____________ [date] in the
9 case of ___________ [insert case name and number]. I agree to comply with and
10 to be bound 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 __________________________ [full
19 name] of _______________________________________ [full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23
24 Date: ______________________________________
25 City and State where signed: _________________________________
26 Printed name: _______________________________
27 Signature: __________________________________
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