The opinion
1 || Karen Liao (State Bar No. 256072)
karen. ligo@manningkass. com
2 || Niko B, Zhou (State Bar No. 353688)
riko <tou@ man mingkass.com
3 || MANNING & KAS
ELLROD, RAMIREZ, TRESTER LLP
4 ||695 Town Center Dr., Ste 400
Costa Mesa, California 92626
5 || Telephone: Dy 440-6690
Facsimile: (949) 474-6991
6
Attorneys for Defendant HOME DEPOT
7 || U.S.A., INC. (erroneously sued as The
Home Depot U.S.A., Inc.)
9
UNITED STATES DISTRICT COURT
10
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
< 11
1
oOo 3 ANA SINGH, an Individual, Case No. 2:26-cv-03769-AJR
z 1
Plaintiff, {PROPOSED} STIPULATED
z 14 PROTECTIVE ORDER
<x V.
= 15 Magistrate Judge A. Joel Richlin
THE HOME DEPOT, INC., a
16 || Corporation; DOES 1 TO 20,
17 Defendants.
18
19 1. A. PURPOSE AND LIMITATIONS
20 Discovery in this action is likely to involve production of confidential,
21 || proprietary, or private information for which special protection from public
22 || disclosure and from use for any purpose other than prosecuting this litigation may
23 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
24 || enter the following Stipulated Protective Order. The parties acknowledge that this
25 || Order does not confer blanket protections on all disclosures or responses to
26 || discovery and that the protection it affords from public disclosure and use extends
27 || only to the limited information or items that are entitled to confidential treatment
28 || under the applicable legal principles. The parties further acknowledge, as set forth in
1 || Section 12.3, below, that this Stipulated Protective Order does not entitle them to
2 || only to the limited information or items that are entitled to confidential treatment
3 || under the applicable legal principles. The parties further acknowledge, as set forth in
4 || Section 13.3, below, that this Stipulated Protective Order does not entitle them to
5 || file confidential information under seal; Civil Local Rule 79-5 sets forth the
6 || procedures that must be followed and the standards that will be applied when a party
7 □□ seeks permission from the court to file material under seal.
8 B. GOOD CAUSE STATEMENT
9 This action is likely to involve sensitive and confidential inter-agency
n 10 || documents related to the incident that should be protected from public
2 11 || dissemination. The mending discovery requests, as well as any future requests,
12 || would require production of information Home Depot considers confidential,
> 13 || proprietary, and private, business interests. Home Depot is the leading home
s 14 || improvement retailer and maintains its competitive advantage, in part, by being at
15 || the forefront of innovative business ideas, practices, and operations. Home Depot
16 || has been able to attain and maintain its position in the industry by taking advantage
17 || of the collective experience and knowledge of its associates and by investing
18 || resources to develop sound operating practices and a unique manner of doing
19 || business, all of which are embodied, in part, in the Company’s policies. This
20 || advantage would be greatly diminished if Home Depot’s policies were publicly
21 || disclosed making them available to the competitors.
22 Accordingly, to expedite the flow of information, to facilitate the prompt
23 || resolution of disputes over confidentiality of discovery materials, to adequately
24 || protect information the parties are entitled to keep confidential, to ensure that the
25 || parties are permitted reasonable necessary uses of such material in preparation for
26 || and in the conduct of trial, to address their handling at the end of the litigation, and
27 || serve the ends of justice, a protective order for such information is justified in this
28 || matter. It is the intent of the parties that information will not be designated as
1 || confidential for tactical reasons and that nothing be so designated without a good
2 || faith belief that it has been maintained in a confidential, non-public manner, and
3 || there is good cause why it should not be part of the public record of this case.
4|)2. DEFINITIONS
5 2.1 Action: This pending federal lawsuit in ANA SINGH V. THE HOME
6 || DEPOT, INC., Case No. 2:26-cv-03769-AJR.
7 2.2 Challenging Party: a Party or Non-Party that challenges the designation
8 || of information or items under this Order.
9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
10 || it is generated, stored, or maintained) or tangible things that qualify for protection
2 11 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
x 12 || Cause Statement.
2 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
S 14 || support staff).
15 2.5 Designating Party: a Party or Non-Party that designates information or
16 || items that it produces in disclosures or in responses to discovery as
17 || “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: all items or information, regardless of
19 || the medium or manner in which it is generated, stored, or maintained (including,
20 || among other things, testimony, transcripts, and tangible things), that are produced or
21 || generated in disclosures or responses to discovery in this matter,
22 2.7 Expert: a person with specialized knowledge or experience in a matter
23 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
24 || an expert witness or as a consultant in this Action.
25 2.8 House Counsel: attorneys who are employees of a party to this Action.
26 || House Counsel does not include Outside Counsel of Record or any other outside
27 || counsel.
28 2.9 Non-Party: any natural person, partnership, corporation, association, or
1 || other legal entity not named as a Party to this action.
2 2.10 Outside Counsel of Record: attorneys who are not employees of a party
3 || to this Action but are retained to represent or advise a party to this Action and have
4 || appeared in this Action on behalf of that party or are affiliated with a law firm that
5 || has appeared on behalf of that party, and includes support staff.
6 2.11 Party: any party to this Action, including all of its officers, directors,
7 ||employees, consultants, retained experts, and Outside Counsel of Record (and their
8 || support staff).
9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
n 10 || Discovery Material in this Action.
2 11 2.13 Professional Vendors: persons or entities that provide litigation support
12 || services (e.g., photocopying, videotaping, translating, preparing exhibits or
> 13 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
14 || and their employees and subcontractors.
15 2.14 Protected Material: any Disclosure or Discovery Material that is
16 || designated as “CONFIDENTIAL.”
17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
18 || from a Producing Party.
19 3. SCOPE
20 The protections conferred by this Stipulation and Order cover not only
21 || Protected Material (as defined above), but also (1) any information copied or
22 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
23 || compilations of Protected Material; and (3) any testimony, conversations, or
24 || presentations by Parties or their Counsel that might reveal Protected Material.
25 Any use of Protected Material at trial shall be governed by the orders of the
26 || trial judge. This Order does not govern the use of Protected Material at trial.
27 4. DURATION
28 Once a case proceeds to trial, all of the court-filed information to be
1 |] introduced that was previously designated as confidential or maintained pursuant to
2 this protective order becomes public and will be presumptively available to all
3 ||members of the public, including the press, unless compelling reasons supported by
4 || specific factual findings to proceed otherwise are made to the trial judge in advance
5 || of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81
6 || (9th Cir_2006) (distinguishing “good cause” showing for sealing documents
7 || produced in discovery from “compelling reasons” standard when merits-related
8 || documents are part of court record). Accordingly, the terms of this protective order
9 || do not extend beyond the commencement of the trial.
wn 10 5. DESIGNATING PROTECTED MATERIAL
2 11 5.1 Exercise of Restraint and Care in Designating Material for Protection.
12 || Each Party or Non-Party that designates information or items for protection under
2 13 || this Order must take care to limit any such designation to specific material that
S 14 || qualifies under the appropriate standards. The Designating Party must designate for
15 || protection only those parts of material, documents, items, or oral or written
16 || communications that qualify so that other portions of the material, documents,
17 || items, or communications for which protection is not warranted are not swept
18 || unjustifiably within the ambit of this Order.
19 Mass, indiscriminate, or routinized designations are prohibited. Designations
20 || that are shown to be clearly unjustified or that have been made for an improper
21 || purpose (e.g., to unnecessarily encumber the case development process or to impose
22 || unnecessary expenses and burdens on other parties) may expose the designated
23 || party to sanctions.
24 If it comes to a Designating Party’s attention that information or items that it
25 || designated for protection do not qualify for protection, that Designating Party must
26 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
27 5.2 Manner and Timing of Designations. Except as otherwise provided in this
28 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
1 || stipulated or ordered, Disclosure or Discovery of Material that qualifies for
2 || protection under this Order must be clearly so designated before the material is
3 || disclosed or produced. Designation in conformity with this Order requires:
4 (a) for information in documentary form (e.g., paper or electronic documents,
5 || but excluding transcripts of depositions or other pretrial or trial proceedings), that
6 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
7||“CONFIDENTIAL legend’), to each page that contains protected material. If only a
8 || portion or portions of the material on a page qualify for protection, the Producing
9 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate
10 || markings in the margins).
2 11 A Party or Non-Party that makes original documents available for inspection
x 12 ||need not designate them for protection until after the inspecting Party has indicated
2 13 || which documents it would like copied and produced. During the inspection and
S$ 14 || before the designation, all of the material made available for inspection shall be
15 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the
16 || documents it wants copied and produced, the Producing Party must determine which
17 || documents, or portions thereof, qualify for protection under this Order. Then, before
18 || producing the specified documents, the Producing Party must affix the
19 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
20 || portion or portions of the material on a page qualify for protection, the Producing
21 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate
22 || markings in the margins).
23 (b) for testimony given in depositions that the Designating Party identifies the
24 || Disclosure or Discovery Material on the record, before the close of the deposition all
25 || protected testimony.
26 (c) for information produced in some form other than documentary and for
27 || any other tangible items, that the Producing Party affix in a prominent place on the
28 || exterior of the container or containers in which the information is stored the legend
1 || “CONFIDENTIAL.” If only a portion or portions of the information warrants
2 || protection, the Producing Party, to the extent practicable, shall identify the protected
3 || portion(s).
4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
5 || failure to designate qualified information or items does not, standing alone, waive
6 || the Designating Party’s right to secure protection under this Order for such material.
7 || Upon timely correction of a designation, the Receiving Party must make reasonable
8 || efforts to assure that the material is treated in accordance with the provisions of this
9 || Order.
10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
12 || designation of confidentiality at any time that is consistent with the Court’s
> 13 || Scheduling Order,
s 14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
15 || resolution process under Local Rule 37.1 et seq.
16 6.3 The burden of persuasion in any such challenge proceeding shall be on the
17 || Designating Party. Frivolous challenges, and those made for an improper purpose
18 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
19 || expose the Challenging Party to sanctions. Unless the Designating Party has waived
20 || or withdrawn the confidentiality designation, all parties shall continue to afford the
21 || material in question the level of protection to which it is entitled under the
22 || Producing Party’s designation until the Court rules on the challenge.
23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24 7.1 Basic Principles. A Receiving Party may use Protected Material that is
25 || disclosed or produced by another Party or by a Non-Party in connection with this
26 || Action only for prosecuting, defending, or attempting to settle this Action. Such
27 || Protected Material may be disclosed only to the categories of persons and under the
28 || conditions described in this Order. When the Action has been terminated, a
1 || Receiving Party must comply with the provisions of section 13 below (FINAL
2 || DISPOSITION). Protected Material must be stored and maintained by a Receiving
3 || Party at a location and in a secure manner that ensures that access is limited to the
4 || persons authorized under this Order.
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
6 || ordered by the court or permitted in writing by the Designating Party, a Receiving
7 || Party may disclose any information or item designated “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
9 || employees of said Outside Counsel of Record to whom it is reasonably necessary to
10 || disclose the information for this Action;
2 11 (b) the officers, directors, and employees (including House Counsel) of the
x 12 || Receiving Party to whom disclosure is reasonably necessary for this Action;
2 13 (c) Experts (as defined in this Order) of the Receiving Party to whom
S$ 14 || disclosure is reasonably necessary for this Action and who have signed the
15 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (d) the court and its personnel;
17 (e) court reporters and their staff;
18 (f) professional jury or trial consultants, mock jurors, and Professional
19 || Vendors to whom disclosure is reasonably necessary for this Action and who have
20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (g) the author or recipient of a document containing the information or a
22 || custodian or other person who otherwise possessed or knew the information;
23 (h) during their depositions, witnesses, and attorneys for witnesses, in the
24 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
25 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they
26 || will not be permitted to keep any confidential information unless they sign the
27 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
28 || agreed by the Designating Party or ordered by the court. Pages of transcribed
1 || deposition testimony or exhibits to depositions that reveal Protected Material may
2 || be separately bound by the court reporter and may not be disclosed to anyone except
3 ||as 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.
6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
7 PRODUCED IN OTHER LITIGATION
8 If a Party is served with a subpoena or a court order issued in other litigation
9 || that compels disclosure of any information or items designated in this Action as
10 || “CONFIDENTIAL,” that Party must:
2 11 (a) promptly notify in writing the Designating Party. Such notification shall
12 || include a copy of the subpoena or court order;
2 13 (b) promptly notify in writing the party who caused the subpoena or order to
S 14 || be issued in the other litigation that some or all of the material covered by the
15 || subpoena or order is subject to this Protective Order. Such notification shall include
16 ||a copy of this Stipulated Protective Order; and
17 (c) cooperate with respect to all reasonable procedures sought to be pursued
18 || by the Designating Party whose Protected Material may be affected.
19 If the Designating Party timely seeks a protective order, the Party served with
20 || the subpoena or court order shall not produce any information designated in this
21 |} action as “CONFIDENTIAL” before a determination by the court from which the
22 || subpoena or order issued, unless the Party has obtained the Designating Party’s
23 || permission. The Designating Party shall bear the burden and expense of seeking
24 || protection in that court of its confidential material and nothing in these provisions
25 || should be construed as authorizing or encouraging a Receiving Party in this Action
26 || to disobey a lawful directive from another court.
27
28
1 9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a Non-
4 || Party in this Action and designated as “CONFIDENTIAL.” Such information
5 || produced by Non-Parties in connection with this litigation is protected by the
6 || remedies and relief provided by this Order. Nothing in these provisions should be
7 || construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 || produce a Non-Party’s confidential information in its possession, and the Party is
10 || subject to an agreement with the Non-Party not to produce the Non-Party’s
2 11 || confidential information, then the Party shall:
x 12 (1) promptly notify in writing the Requesting Party and the Non-Party
2 13 || that some or all of the information requested is subject to a confidentiality
S 14 || agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated
16 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
17 || specific description of the information requested; and
18 (3) make the information requested available for inspection by the Non-
19 || Party, if requested.
20 (c) If the Non-Party fails to seek a protective order from this court within 14
21 || days of receiving the notice and accompanying information, the Receiving Party
22 ||may produce the Non-Party’s confidential information responsive to the discovery
23 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall
24 || not produce any information in its possession or control that is subject to the
25 || confidentiality agreement with the Non-Party before a determination by the court.
26 || Absent a court order to the contrary, the Non-Party shall bear the burden and
27 || expense of seeking protection in this court of its Protected Material.
28
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
2 MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 || Protected Material to any person or in any circumstance not authorized under this
5 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
6 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
7 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
8 || persons to whom unauthorized disclosures were made of all the terms of this Order,
9 || and (d) request such person or persons to execute the “Acknowledgment and
10 || Agreement to Be Bound” that is attached hereto as Exhibit A.
2 11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
x 12 OTHERWISE PROTECTED MATERIAL
2 13 When a Producing Party gives notice to Receiving Parties that certain
14 || inadvertently produced material is subject to a claim of privilege or other protection,
= 15 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 || may be established in an e-discovery order that provides for production without
18 || prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
19 || as the parties reach an agreement on the effect of disclosure of a communication or
20 || information covered by the attorney-client privilege or work product protection, the
21 || parties may incorporate their agreement in the stipulated protective order submitted
22 || to the court.
23 12. MISCELLANEOUS
24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
25 || person to seek its modification by the Court in the future.
26 12.2 Right to Assert Other Objections. By stipulating to the entry of this
27 || Protective Order no Party waives any right it otherwise would have to object to
28 || disclosing or producing any information or item on any ground not addressed in this
1 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 || ground to use in evidence of any of the material covered by this Protective Order.
3 12.3 Filing Protected Material. A Party that seeks to file under seal any
4 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
5 || only be filed under seal pursuant to a court order authorizing the sealing of the
6 || specific Protected Material at issue. If a Party's request to file Protected Material
7 || under seal is denied by the court, then the Receiving Party may file the information
8 || in the public record unless otherwise instructed by the court.
9 13. FINAL DISPOSITION
10 After the final disposition of this Action, as defined in paragraph 4, within 60
2 11 || days of a written request by the Designating Party, each Receiving Party must return
]all Protected Material to the Producing Party or destroy such material. As used in
2 13 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
S || summaries, and any other format reproducing or capturing any of the Protected
= 15 || Material. Whether the Protected Material is returned or destroyed, the Receiving
16 || Party must submit a written certification to the Producing Party (and, if not the same
17 || person or entity, to the Designating Party) by the 60-day deadline that (1) identifies
18 || (by category, where appropriate) all the Protected Material that was returned or
19 || destroyed and (2)affirms that the Receiving Party has not retained any copies,
20 || abstracts, compilations, summaries or any other format reproducing or capturing any
21 || of the Protected Material. Notwithstanding this provision, Counsel is entitled to
22 ||retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
23 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
24 || reports, attorney work product, and consultant and expert work product, even if such
25 || materials contain Protected Material. Any such archival copies that contain or
26 || constitute Protected Material remain subject to this Protective Order as set forth in
27 || Section 4 (DURATION).
28 14. Any violation of this Order may be punished by any and all appropriate
1 || measures including, without limitation, contempt proceedings and/or monetary
2 || sanctions.
3 SO STIPULATED, THROUGH COUNSEL OF RECORD:
4||DATED: May 28, 2026 MANNING & KASS
5 ELLROD, RAMIREZ, TRESTER LLP
6
7
By: /s/KarenLiao
8 Karen Liao
9 Niko B. Zhou
Attorneys for Defendant HOME DEPOT
10 U:S.A., INC.
< 11
— 12||DATED: May 28, 2026 THE NOVAK LAW FIRM, P.C.
Oo
13
=
” |/[Fubeod Ceumtebu
< Gf Lan
= 15 By:
Sean M. Novak, Esq.
6 Farbod Youmtobian, Esq.
17 Ryan Naim, Esq.
12 Nathan Soleimani, Esq.
Attorneys for Plaintiff Ana Singh
19
20
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22||DATED: June 10, 2026
23
24 By: \oek Ref A
95 Magistrate Judge A. Joel Richlin
26
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2
3
4
5
EXHIBIT “A”
6
UNITED STATES DISTRICT COURT
7
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
9 □
ANA SINGH, an Individual, Case No. 2:26-cv-03769-AJR
10
Plaintiff, [PROPOSED] STIPULATED
2 il PROTECTIVE ORDER
V.
12 Magistrate Judge A. Joel Richlin
THE HOME DEPOT, INC., a
Zz 13 || Corporation; DOES 1| TO 20,
14 Defendants.
= 1
AGREEMENT CONCERNING INFORMATION COVERED BY
16 CONFIDENTIALITY STIPULATION AND PROTECTIVE ORDER
17 I have been designated by , aS a person who may
18 ||have access to CONFIDENTIAL INFORMATION as that term is defined in the
19
Confidentiality Stipulation and Protective Order (the “Order’’) entered in the above-
20
1 || entitled case. Having read the Stipulated Protective Order that was issued by The
22 || United States District Court for The Central District of California, I agree to comply
23
34 fully with it and to be bound by its terms with respect to all documents and information
75 || designated as “Confidential” under the Order. I agree not to copy any documents or
26 || information that has been designated as “Confidential” and disclosed to me and not
27
38 to disclose such documents or information to any person or entity not authorized under
1 || the Order to view CONFIDENTIAL INFORMATION.
2 I further agree to submit to the jurisdiction of the United States District Court
3
4 for the Central District of California for enforcing the terms of this Stipulated
5 || Protective Order, even if such enforcement proceeding occur after termination of this
6
action.
7
8 I hereby appoint [print or type full name]
9 || with [print or type full address
and telephone number] as my California agent for service of process in connection
11
<x
x 12 || With this action or any proceedings related to enforcement of this Stipulated Protective
©
= 131! Order.
S$ 14
<x I declare under penalty of perjury under the laws of the state of California that
= 15
the foregoing is true and correct. Executed this day of □
17 .
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19 Name
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Title
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22 Employer
23
Address
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