# Opinion > District Court, C.D. California · June 10, 2026 URL: https://www.frixlaw.com/law-library/cases/11383306 ## Case - **Full name:** Ana Singh v. The Home Depot, Inc., a Corporation; DOES 1 TO 20 - **Court:** District Court, C.D. California - **Decided:** June 10, 2026 - **Opinion:** 100trialcourt - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11383306 ## Opinion text 1 || Karen Liao (State Bar No. 256072) karen. ligo@manningkass. com 2 || Niko B, Zhou (State Bar No. 353688) riko 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 27 28 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