The opinion
1 CGUarMretMt MIN. SF a&hy W, PH.CI.T (EB,a Lr NLPo. 267103)
2 E-mail: gfahy@cwlawyers.com
Eric M. Khodadian (Bar No. 288146)
3 E-mail: ekhodadian@cwlawyers.com
Joshua Park (Bar No. 299572)
4 E-mail: jpark@cwlawyers.com
2424 S.E. Bristol Street, Suite 300
5 Newport Beach, CA 92660-0764
Telephone: (949) 852-1800
6 Facsimile: (949) 852-8510
7 Attorneys for Defendant
HILLSTONE RESTAURANT
8 GROUP, INC., doing business as
SOUTH BEVERLY GRILL
9
UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
11
12 MERCEDEH KHALEGHIAN, an ) CASE NO.: 2:25-cv-11558-SSC
individual, )
13 ) ASSIGNED TO THE HONORABLE
Plaintiff, ) MAGISTRATE JUDGE STEPHANIE S.
14 ) CHRISTENSEN
)
15 vs. ) STIPULATED PROTECTIVE
) ORDER
16 SOUTH BEVERLY GRILL; )
HILLSTONE RESTAURANT GROUP; ) Complaint Filed: October 30, 2025
17 DOE RESTAURANT MANAGER; and )
Trial Date: February 9, 2027
DOES 1 to 100, inclusive )
18 )
Defendants. )
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1 1. PURPOSES AND LIMITATIONS:
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that
8 the protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
11 2. GOOD CAUSE STATEMENT:
12 This action is likely to involve trade secrets, customer and pricing lists and
13 other valuable research, development, commercial, financial, technical and/or
14 proprietary information for which special protection from public disclosure and from
15 use for any purpose other than prosecution of this action is warranted. Such
16 confidential and proprietary materials and information consist of, among other things,
17 confidential business or financial information, information regarding confidential
18 business practices, or other confidential research, development, or commercial
19 information (including information implicating privacy rights of third parties),
20 information otherwise generally unavailable to the public, or which may be privileged
21 or otherwise protected from disclosure under state or federal statutes, court rules, case
22 decisions, or common law. Accordingly, to expedite the flow of information, to
23 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
24 to adequately protect information the parties are entitled to keep confidential, to
25 ensure that the parties are permitted reasonable necessary uses of such material in
26 preparation for and in the conduct of trial, to address their handling at the end of the
27 litigation, and serve the ends of justice, a protective order for such information is
28 justified in this matter. It is the intent of the parties that information will not be
1 designated as confidential for tactical reasons and that nothing be so designated
2 without a good faith belief that it has been maintained in a confidential, non-public
3 manner, and there is good cause why it should not be part of the public record of this
4 case.
5 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE:
6 The parties further acknowledge, as set forth in Section 14.3, below, that this
7 Stipulated Protective Order does not entitle them to file confidential information
8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
9 the standards that will be applied when a party seeks permission from the court to file
10 material under seal. There is a strong presumption that the public has a right of access
11 to judicial proceedings and records in civil cases. In connection with non-dispositive
12 motions, good cause must be shown to support a filing under seal. See Kamakana v.
13 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
14 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
15 Electrics, 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, establishing
21 that the material sought to be filed under seal qualifies as confidential, privileged, or
22 otherwise protectable—constitute good cause. Further, if a party requests sealing
23 related to a dispositive motion or trial, then compelling reasons, not only good cause,
24 for the sealing must be shown, and the relief sought shall be narrowly tailored to serve
25 the specific interest to be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d
26 665, 677-79 (9th Cir. 2010). For each item or type of information, document, or thing
27 sought to be filed or introduced under seal, the party seeking protection must articulate
28 compelling reasons, supported by specific facts and legal justification, for the
1 requested sealing order. Again, competent evidence supporting the application to file
2 documents under seal must be provided by declaration. Any document that is not
3 confidential, privileged, or otherwise protectable in its entirety will not be filed under
4 seal if the confidential portions can be redacted. If documents can be redacted, then a
5 redacted version for public viewing, omitting only the confidential, privileged, or
6 otherwise protectable portions of the document, shall be filed. Any application that
7 seeks to file documents under seal in their entirety should include an explanation of
8 why redaction is not feasible.
9 4. DEFINITIONS
10 4.1 Action: Mercedeh Khaleghian v. South Beverly Grill, et al. (USDC Case
11 No. 2:25-cv-11558-SSC).
12 4.2 Challenging Party: a Party or Non-Party that challenges the designation
13 of information or items under this Order.
14 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
15 how it is generated, stored or maintained) or tangible things that qualify for protection
16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
17 Cause Statement.
18 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
19 support staff), including Vaziri Law Group, 1901 Avenue of the Stars, 20th Floor, Los
20 Angeles, California 90067, Counsel for Plaintiff Mercedeh Khaleghian (“Plaintiff”);
21 Cummins & White, LLP, 2424 S.E. Bristol Street, Suite 300, Newport Beach, CA
22 92660, Counsel for Defendant Hillstone Restaurant Group, Inc. dba South Beverly
23 Grill (“Defendant”).
24 4.5 Designating Party: a Party or Non-Party that designates information or
25 items that it produces in disclosures or in responses to discovery as
26 “CONFIDENTIAL.”
27 4.6 Disclosure or Discovery Material: all items or information, regardless of
28 the medium or manner in which it is generated, stored, or maintained (including,
1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery.
3 4.7 Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6 4.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9 4.9 Non-Party: any natural person, partnership, corporation, association or
10 other legal entity not named as a Party to this action.
11 4.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent a party to this Action and have appeared in
13 this Action on behalf of that party or are affiliated with a law firm that has appeared
14 on behalf of that party, and includes support staff.
15 4.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 4.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 4.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
28 ///
1 5. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 Protected Material (as defined above), but also (1) any information copied or
4 extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the
8 trial judge and other applicable authorities. This Order does not govern the use of
9 Protected Material at trial.
10 6. DURATION
11 Even after final disposition of this litigation, the confidentiality obligations
12 imposed by this Order shall remain in effect until a Designating Party agrees
13 otherwise in writing or a court order otherwise directs. Final disposition shall be
14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
15 or without prejudice; and (2) final judgment herein after the completion and
16 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
17 including the time limits for filing any motions or applications for extension of time
18 pursuant to applicable law.
19 7. DESIGNATING PROTECTED MATERIAL
20 7.1 Exercise of Restraint and Care in Designating Material for Protection.
21 Each Party or Non-Party that designates information or items for protection under this
22 Order must take care to limit any such designation to specific material that qualifies
23 under the appropriate standards. The Designating Party must designate for protection
24 only those parts of material, documents, items or oral or written communications that
25 qualify so that other portions of the material, documents, items or communications
26 for which protection is not warranted are not swept unjustifiably within the ambit of
27 this Order.
28 Mass, indiscriminate or routinized designations are prohibited. Designations
1 that are shown to be clearly unjustified or that have been made for an improper
2 purpose (e.g., to unnecessarily encumber the case development process or to impose
3 unnecessary expenses and burdens on other parties) may expose the Designating Party
4 to sanctions.
5 If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8 7.2 Manner and Timing of Designations. Except as otherwise provided in
9 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
10 that qualifies for protection under this Order must be clearly so designated before the
11 material is disclosed or produced.
12 Designation in conformity with this Order requires:
13 (a) for information in documentary form (e.g., paper or electronic
14 documents, but excluding transcripts of depositions or other pretrial or trial
15 proceedings), that the Producing Party affix at a minimum, the legend
16 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
17 contains protected material. If only a portion of the material on a page qualifies for
18 protection, the Producing Party also must clearly identify the protected portion(s)
19 (e.g., by making appropriate markings in the margins).
20 A Party or Non-Party that makes original documents available for inspection
21 need not designate them for protection until after the inspecting Party has indicated
22 which documents it would like copied and produced. During the inspection and
23 before the designation, all of the material made available for inspection shall be
24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
25 it wants copied and produced, the Producing Party must determine which documents,
26 or portions thereof, qualify for protection under this Order. Then, before producing
27 the specified documents, the Producing Party must affix the “CONFIDENTIAL
28 legend” to each page that contains Protected Material. If only a portion of the material
1 on a page qualifies for protection, the Producing Party also must clearly identify the
2 protected portion(s) (e.g., by making appropriate markings in the margins).
3 (b) for testimony given in depositions that the Designating Party identifies
4 the Disclosure or Discovery Material on the record, before the close of the deposition
5 all protected testimony.
6 (c) for information produced in some form other than documentary and for
7 any other tangible items, that the Producing Party affix in a prominent place on the
8 exterior of the container or containers in which the information is stored the legend
9 “CONFIDENTIAL.” If only a portion or portions of the information warrants
10 protection, the Producing Party, to the extent practicable, shall identify the protected
11 portion(s).
12 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13 failure to designate qualified information or items does not, standing alone, waive the
14 Designating Party’s right to secure protection under this Order for such material.
15 Upon timely correction of a designation, the Receiving Party must make reasonable
16 efforts to assure that the material is treated in accordance with the provisions of this
17 Order.
18 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
23 resolution process under Local Rule 37-1 et seq.
24 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
25 joint stipulation pursuant to Local Rule 37-2.
26 8.4 The burden of persuasion in any such challenge proceeding shall
27 be on the Designating Party. Frivolous challenges, and those made for an improper
28 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
1 may expose the Challenging Party to sanctions. Unless the Designating Party has
2 waived or withdrawn the confidentiality designation, all parties shall continue to
3 afford the material in question the level of protection to which it is entitled under the
4 Producing Party’s designation until the Court rules on the challenge.
5 9. ACCESS TO AND USE OF PROTECTED MATERIAL
6 9.1 Basic Principles. A Receiving Party may use Protected Material that is
7 disclosed or produced by another Party or by a Non-Party in connection with this
8 Action only for prosecuting, defending or attempting to settle this Action. Such
9 Protected Material may be disclosed only to the categories of persons and under the
10 conditions described in this Order. When the Action has been terminated, a Receiving
11 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
12 Protected Material must be stored and maintained by a Receiving Party at a
13 location and in a secure manner that ensures that access is limited to the persons
14 authorized under this Order.
15 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
16 otherwise ordered by the court or permitted in writing by the Designating Party, a
17 Receiving Party may disclose any information or item designated
18 “CONFIDENTIAL” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
20 employees of said Outside Counsel of Record to whom it is reasonably necessary to
21 disclose the information for this Action;
22 (b) the officers, directors, and employees (including House Counsel) of the
23 Receiving Party to whom disclosure is reasonably necessary for this Action;
24 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure
25 is reasonably necessary for this Action and who have signed the “Acknowledgment
26 and Agreement to Be Bound” (Exhibit A)
27 (d) the court and its personnel;
28 (e) court reporters and their staff;
1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
2 to whom disclosure is reasonably necessary for this Action and who have signed the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in the
7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
8 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
9 not be permitted to keep any confidential information unless they sign the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
11 agreed by the Designating Party or ordered by the court. Pages of transcribed
12 deposition testimony or exhibits to depositions that reveal Protected Material may be
13 separately bound by the court reporter and may not be disclosed to anyone except as
14 permitted under this Stipulated Protective Order; and
15 (i) any mediators or settlement officers and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
18 PRODUCED IN OTHER LITIGATION.
19 If a Party is served with a subpoena or a court order issued in other litigation
20 that compels disclosure of any information or items designated in this Action as
21 “CONFIDENTIAL,” that Party must:
22 (a) promptly notify in writing the Designating Party. Such notification shall
23 include a copy of the subpoena or court order;
24 (b) promptly notify in writing the party who caused the subpoena or order to
25 issue in the other litigation that some or all of the material covered by the subpoena
26 or order is subject to this Protective Order. Such notification shall include a copy of
27 this Stipulated Protective Order; and
28 (c) cooperate with respect to all reasonable procedures sought to be pursued by
1 the Designating Party whose Protected Material may be affected.
2 If the Designating Party timely seeks a protective order, the Party served with
3 the subpoena or court order shall not produce any information designated in this action
4 as “CONFIDENTIAL” before a determination by the court from which the subpoena
5 or order issued, unless the Party has obtained the Designating Party’s permission. The
6 Designating Party shall bear the burden and expense of seeking protection in that court
7 of its confidential material and nothing in these provisions should be construed as
8 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
9 directive from another court.
10 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
11 PRODUCED IN THIS LITIGATION
12 (a) The terms of this Order are applicable to information produced by a Non-
13 Party in this Action and designated as “CONFIDENTIAL.” Such information
14 produced by Non-Parties in connection with this litigation is protected by the
15 remedies and relief provided by this Order. Nothing in these provisions should be
16 construed as prohibiting a Non-Party from seeking additional protections.
17 (b) In the event that a Party is required, by a valid discovery request, to
18 produce a Non-Party’s confidential information in its possession, and the Party is
19 subject to an agreement with the Non-Party not to produce the Non-Party’s
20 confidential information, then the Party shall:
21 (1) promptly notify in writing the Requesting Party and the NonParty that some
22 or all of the information requested is subject to a confidentiality agreement with a
23 Non-Party;
24 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
25 Order in this Action, the relevant discovery request(s), and a reasonably specific
26 description of the information requested; and
27 (3) make the information requested available for inspection by the Non-Party,
28 if requested.
1 (c) If the Non-Party fails to seek a protective order from this court within 14
2 days of receiving the notice and accompanying information, the Receiving Party may
3 produce the Non-Party’s confidential information responsive to the discovery request.
4 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
5 any information in its possession or control that is subject to the confidentiality
6 agreement with the Non-Party before a determination by the court. Absent a court
7 order to the contrary, the Non-Party shall bear the burden and expense of seeking
8 protection in this court of its Protected Material.
9 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
10 MATERIAL
11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
12 Protected Material to any person or in any circumstance not authorized under this
13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
16 persons to whom unauthorized disclosures were made of all the terms of this Order,
17 and (d) request such person or persons to execute the “Acknowledgment an
18 Agreement to Be Bound” attached hereto as Exhibit A.
19 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
20 OTHERWISE 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), insofar as the
27 parties reach an agreement on the effect of disclosure of a communication or
28 information covered by the attorney-client privilege or work product protection, the
1 parties may incorporate their agreement in the stipulated protective order submitted
2 to the cour
3 14. MISCELLANEOUS
4 14.1 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 14.2 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 14.3 Filing Protected Material. A Party that seeks to file under seal any
12 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
13 only be filed under seal pursuant to a court order authorizing the sealing of the specific
14 Protected Material. If a Party’s request to file Protected Material under seal is denied
15 by the court, then the Receiving Party may file the information in the public record
16 unless otherwise instructed by the court.
17 15. FINAL DISPOSITION
18 After the final disposition of this Action, as defined in paragraph 6, within 60
19 days of a written request by the Designating Party, each Receiving Party must return
20 all Protected Material to the Producing Party or destroy such material. As used in this
21 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
22 summaries, and any other format reproducing or capturing any of the Protected
23 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
24 must submit a written certification to the Producing Party (and, if not the same person
25 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by
26 category, where appropriate) all the Protected Material that was returned or destroyed
27 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
28 compilations, summaries or any other format reproducing or capturing any of the
1 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
2 | archival copy of all pleadings, motion papers, trial, deposition, and hearing
3 | transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
4 || reports, attorney work product, and consultant and expert work product, even if such
5 || materials contain Protected Material. Any such archival copies that contain or
6 || constitute Protected Material remain subject to this Protective Order as set forth in
7 || Section 6 (DURATION).
8 16. VIOLATION
9 Any violation of this Order may be punished by appropriate measures
10 || including, without limitation, contempt proceedings and/or monetary sanctions.
11 | ITTS SO STIPULATED, THROUGH COUNSEL OF RECORD.
12 Respectfully submitted,
13 || Dated: May 12, 2026 VAZIRI LAW GROUP
14 om
Id Mark Giannamore, &§q.
16 Kayvan Vaziri, Esq.
Attorneys for Plaintiff
17 MERCEDEH KHALEGHIAN
18
19 || Dated: May 12, 2026 CUMMINS & WHITE, LLP
20
By:
71 Garrett Mi. Fahy
Eric N¥ Khodadian
Joshva Park
73 Attomeys for Defendant HILLSTONE
RESTAURANT GROUP, INC., doing
4 business as SOUTH BEVERLY GRILL.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3 || DATED: May 13, 2026 Zo
4 United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name], of [print or type full address],
4 declare under penalty of perjury that I have read in its entirety and understand the
5 Stipulated Protective Order that was issued by the United States District Court for the
6 Central District of California on [date] in the case of Mercedeh Khaleghian v. South
7 Beverly Grill, et al. (USDC Case No. 2:25-cv-11558-SSC). I agree to comply with
8 and to be bound by all the terms of this Stipulated Protective Order and I understand
9 and acknowledge that failure to so comply could expose me to sanctions and
10 punishment in the nature of contempt. I solemnly promise that I will not disclose in
11 any manner any information or item that is subject to this Stipulated Protective Order
12 to any person or entity except in strict compliance with the provisions of this Order.
13 I further agree to submit to the jurisdiction of the United States District Court
14 for the Central District of California for the purpose of enforcing the terms of this
15 Stipulated Protective Order, even if such enforcement proceedings occur after
16 termination of this action. I hereby appoint [print or type full name] of
17 [print or type full address and telephone number] as my California agent for service of
18 process in connection with this action or any proceedings related to enforcement of
19 this Stipulated Protective Order.
20
I declare under penalty of perjury under the laws of the United States of America
21
that the foregoing is true and correct.
22
23 Date:
24 City and State where sworn and signed:
25 Printed name:
26 Signature:
27
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] CERTIFICATE OF SERVICE
2 || Khaleghian v. South Beverly Gril, et al.
3 | UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA —
WESTERN DIVISION
4 || Case No.: 2:25-cv-11558-SSC
5 I, the undersigned, declare:
6 I am employed in the County of Orange, State of California. I am over the age
of 18 and not a pay to the within action. business address is 2424 S.E. Bristol
7 || Street, Suite 300, Newport Beach, CA 92660-0764.
8 On May 12, 2026, I served the following document(s) STIPULATED
PROTECTIVE ORDER on the interested parties in this action by placing a true and
9 || correct copy of each document thereof, enclosed in a sealed envelope, addressed as
follows:
10
VAZIRI LAW GROUP
Mark Giannamore, Esq. (SBN 125550)
12 Nicholas Bryman, Esq. (SBN 322172)
teammg(@vazirilaw.com
13 nbryman@vazirilaw.com
1901 Avenue of the Stars, 20" Floor
14 Los Angeles, California 90067
15 Telephone: (310) 777-7540
Attorney for Plaintiff Mercedeh Khaleghian
16
By CM/ECF: I caused the above-referenced document(s) to be served to the
17 attached-named person(s) at his/her/their e-mail address(es) of record. The
ig transmission was reported as complete and without error.
19
20 Executed on May 12, 2026, at Newport Beach, California.
21 (F ederal) I declare that I am employed in the office of a member of the bar of
9 this Court at whose direction this service was made.
/s/ Kim N. Ho
4 Kim N. Ho
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