Opinion

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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10 JANE DOE, an individual, ) ) Case No. 8:26-cv-00854-JDE

Plaintiff, )

11 v. ) STIPULATED PROTECTIVE

12 DHANUBA HOSPITALITY, INC.; ) ) ORDER

PRAVIN R. AHIR, an individual; )

13 )

SURESHBHAI R. AHIR, an

)

14 individual, and DOES 1 through 100, )

inclusive, )

15 )

)

16 Defendants. )

)

17 )

18 Plaintiff Jane Doe, Defendant Dhanuba Hospitality, INC.; Defendant

19 Pravin R. Ahir, and Defendant Sureshbhai R. Ahir (collectively the “Parties”)

20 agree that discovery in this action is likely to involve production of

21 confidential, proprietary, or private information for which special protection

22 may be warranted.

23 Accordingly, the Parties stipulate and agree, subject to approval of the

24 Court, to enter the following Protective Order. The Parties acknowledge that

25 this Order is consistent with Fed. R. Civ. P. 26 and LCR 26(c). That Parties

26 acknowledge and agree that it does not confer blanket protection on all

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1 disclosures or responses to discovery; and the protection it affords from public

2 disclosure and use extends only to the limited information or items that are

3 entitled to confidential treatment under the applicable legal principles, and it

4 does not presumptively entitle parties to file confidential information under

5 seal.

6 1. PURPOSES AND LIMITATIONS

7 Discovery in this action is likely to involve production of confidential,

8 proprietary or private information for which special protection from public

9 disclosure and from use for any purpose other than pursuing this litigation may

10 be warranted. Accordingly, the parties hereby stipulate to and petition the

11 Court to enter the following Stipulated Protective Order. The parties

12 acknowledge that this Order does not confer blanket protections on all

13 disclosures or responses to discovery and that the protection it affords from

14 public disclosure and use extends only to the limited information or items that

15 are entitled to confidential treatment under the applicable legal principles.

16 2. GOOD CAUSE STATEMENT

17 This action is likely to involve trade secrets, customer and pricing lists

18 and other valuable research, development, commercial, financial, technical

19 and/or proprietary information for which special protection from public

20 disclosure and from use for any purpose other than prosecution of this action is

21 warranted. Such confidential and proprietary materials and information

22 consist of, among other things, confidential business or financial information,

23 information regarding confidential business practices, or other confidential

24 research, development, or commercial information (including information

25 implicating privacy rights of third parties), information otherwise generally

26 unavailable to the public, or which may be privileged or otherwise protected

27 from disclosure under state or federal statutes, court rules, case decisions, or

1 prompt resolution of disputes over confidentiality of discovery materials, to

2 adequately protect information the parties are entitled to keep confidential, to

3 ensure that the parties are permitted reasonable necessary uses of such material

4 in preparation for and in the conduct of trial, to address their handling at the

5 end of the litigation, and serve the ends of justice, a protective order for such

6 information is justified in this matter. It is the intent of the parties that

7 information will not be designated as confidential for tactical reasons and that

8 nothing be so designated without a good faith belief that it has been

9 maintained in a confidential, non-public manner, and there is good cause why

10 it should not be part of the public record of this case.

11 3. ACKNOWLEDGMENT OF UNDER SEAL FILING

12 PROCEDURE

13 The parties further acknowledge, as set forth in Section 14.3, below, that

14 this Stipulated Protective Order does not entitle them to file confidential

15 information under seal; Local Civil Rule 79-5 sets forth the standards and

16 procedures that must be followed and the standards that will be applied when a

17 party seeks permission from the court to file material under seal.

18 Further, if a party requests sealing related to a dispositive motion or trial,

19 then compelling reasons, not only good cause, for the sealing must be shown,

20 and the relief sought shall be narrowly tailored to serve the specific interest to

21 be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th

22 Cir. 2010).

23 Any document that is not confidential, privileged, or otherwise

24 protectable in its entirety will not be filed under seal if the confidential portions

25 can be redacted. If documents can be redacted, then a redacted version for

26 public viewing, omitting only the confidential, privileged, or otherwise

27 protectable portions of the document, shall be filed. Any application that seeks

1 why redaction is not feasible.

2 4. DEFINITIONS

3 4.1 Action: Jane Doe v. DHANUBA HOSPITALITY, INC., et al.

4 4.2 Party: any party named in this Action that has not been dismissed.

5 4.3 “CONFIDENTIAL” Information or Items: information

6 (regardless of how it is generated, stored or maintained) or tangible things that

7 qualify for protection under Federal Rule of Civil Procedure 26(c), and as

8 specified above in the Good Cause Statement.

9 Discovery Materials (regardless of how it is generated, stored or

10 maintained) or tangible things reflecting: [1] potentially sensitive personal

11 identifying numbers and financial information, including but not limited to

12 social security numbers, credit card information, bank account information,

13 and financial account numbers and amounts; [2] any trade secret or other

14 confidential research, development, proprietary or competitively sensitive

15 information; [4] medical records including but not limited to psychiatric or

16 psychological medical records; and [5] any material prohibited from disclosure

17 by statute, caselaw or Court Order that is nonetheless discoverable.

18 “Confidential Information” does not include “Plaintiff’s Identity” which is

19 separately addressed in Sections 4.4 and IV.

20 4.4 Plaintiff’s Identity: means Plaintiff’s personally identifiable

21 information, including: [1] names and aliases used by Plaintiff at any time; [2]

22 Plaintiff’s date of birth; [3] Plaintiff’s Social Security Number; [4] Plaintiff’s

23 current and prior residential address; [5] Plaintiff’s personal and home phone

24 numbers and social media or online user accounts; [6] Plaintiff’s physical

25 description, including weight, hair color, eye color, ethnicity, tattoos,

26 piercings; [7] Videos, photographs, or other depictions of Plaintiff; and [8] the

27 names of Plaintiff’s parents, siblings, children, and spouse, if any.

1 4.6 Designating Party: a Party or Non-Party that designates

2 information or items that it produces in disclosures or in responses to discovery

3 as “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY.”

4 4.7 Disclosure or Discovery Material: all items or information,

5 regardless of the medium or manner in which it is generated, stored, or

6 maintained (including, among other things, testimony, transcripts, and tangible

7 things), that are produced or generated in disclosures or responses to discovery.

8 4.8 Expert: a person with specialized knowledge or experience in a

9 matter pertinent to the litigation who has been retained by a Party or its

10 counsel to serve as an expert witness or as a consultant in this Action.

11 4.9 House Counsel: attorneys who are employees of a party to this

12 Action. House Counsel does not include Outside Counsel of Record or any

13 other outside counsel.

14 4.10 Non-Party: any natural person, partnership, corporation,

15 association or other legal entity not named as a Party to this action.

16 4.11 Outside Counsel of Record: attorneys who are not employees of a

17 party to this Action but are retained to represent a party to this Action and

18 have appeared in this Action on behalf of that party or are affiliated with a law

19 firm that has appeared on behalf of that party, and includes support staff.

20 4.12 Party: any party to this Action, including all of its officers,

21 directors, employees, consultants, retained experts, and Outside Counsel of

22 Record (and their support staffs).

23 4.13 Producing Party: a Party or Non-Party that produces Disclosure or

24 Discovery Material in this Action.

25 4.14 Professional Vendors: persons or entities that provide litigation

26 support services (e.g., photocopying, videotaping, translating, preparing

27 exhibits or demonstrations, and organizing, storing, or retrieving data in any

1 4.15 Protected Material: any Disclosure or Discovery Material that is

2 designated as “CONFIDENTIAL” or “PLAINTIFF’S IDENTITY.” as

3 provided for in this Stipulated Protective Order.

4 4.16 Receiving Party: refers to a Party or Non-Party to which

5 information or items containing Confidential Information or Plaintiff’s Identity

6 that has been produced by a Designating Party.

7 5. ACCESSING AND USE OF PLAINTIFFS IDENTITY

8 5.1 During pre-trial proceedings in this Action and in any public

9 filings, subject to further order, the Parties must either redact Plaintiff’s

10 Identity or use the pseudonym “Jane Doe” in place of Plaintiff’s Identity.

11 5.2 After the filing of this Order by the Court, Plaintiff shall provide

12 Defendants, through their Counsel, with Plaintiff’s full name, maiden name,

13 alias names used at any time, birthday, address, trafficker(s)’ names,

14 trafficker(s)’ associate(s)’ names, and any known identifying information about

15 their trafficker(s) and associate(s). Nothing in this Order shall prevent any

16 Party from seeking further protections or modification of this Order for the

17 trial or litigation of this Action. Nothing in this Order shall prevent a Party

18 from requesting from Plaintiff during the course of discovery any other

19 information that is linked or linkable to the true identity of Plaintiff or her

20 trafficker(s) and associates. Relatedly, nothing in this Order relieves Plaintiff of

21 the obligation to produce any discoverable documents or information that

22 Plaintiff intends to rely upon at trial

23 5.3 Access to Plaintiff’s Identity shall be limited to, and only to, the

24 following:

25 (a) The Parties, as defined in Section 1.2(b), who are bound by this

26 Order, including current owners, current officers, current directors, and current

27 employees of the Parties (including In-House Counsel), and agents and/or

1 defenses (but only to the extent that such individuals are not alleged to be

2 traffickers);

3 (b) Any Counsel of Record for the Parties who are bound by this Order

4 and retained specifically for this Action, and employees, agents, and

5 representatives of Counsel of Record as needed to litigate any claims or

6 defenses;

7 (c) Law enforcement agencies and agency personnel;

8 (d) Former employees (including In-House Counsel), officers,

9 contractors, and representatives of the Parties will have access to Plaintiff’s

10 name and photographs only, who Counsel of Record for a Party in good faith

11 believes may be called to testify at trial or deposition in this Action and who

12 execute Exhibit A;

13 (e) Any witness, except Non-Party traffickers of Plaintiff and the Non-

14 Party traffickers’ associates, who Counsel of Record for a Party in good faith

15 believes may be called to testify at trial or deposition in this Action and who

16 signs Exhibit A will have access to Plaintiff’s name and photographs only. If a

17 witness refuses to sign Exhibit A, the witness will have access to Plaintiff’s

18 name and photographs only, provided they are made aware of this Protective

19 Order and their obligations under it, and that Counsel executes the Attorney

20 Certification Regarding Disclosure of Plaintiff’s Identity or Confidential

21 Information and Admonishment as to the Court’s Protective Order attached as

22 Exhibit B;

23 (f) Any mediator appointed by the Court or jointly selected by the Parties

24 who executes Exhibit A;

25 (g) Insurers for any of the Parties, third-party administrators for the

26 Insurers or Parties, or indemnitors for any of the Parties, including coverage

27 counsel for the insurers, who have or may provide indemnity or other coverage

1 (h) The Court and Court personnel;

2 (i) Court reporters, recorders, and videographers engaged for

3 depositions;

4 (j) Any custodian of records whom a Party reasonably believes has

5 records related to Plaintiff that are likely to be relevant and admissible in this

6 Action, so long as the request for records does not create a public record

7 identifying Plaintiff as the Plaintiff in this Action;

8 (k) Any Expert, consultant, or investigator retained by the Parties, their

9 Counsel of Record, or Outside Counsel specifically in connection with this

10 Action and who have executed Exhibit A;

11 (l) Professional Vendors retained by the Parties, their Counsel of Record,

12 or Outside Counsel, provided that the Professional Vendor executes Exhibit A.

13 (m) Government agencies and agency personnel, but only after such

14 agency is made aware of this Order and to the extent that the disclosure of

15 Plaintiff’s Identity is necessary to litigate any claims or defenses or to comply

16 with any obligations or requirements, and so long as the disclosure does not

17 create a public record that identifies Plaintiff as the Plaintiff in this lawsuit; and

18 (n) Such other persons as hereafter may be designated by written

19 agreement of Plaintiff in this Action or by order of the Court and who execute

20 Exhibit A.

21 5.4 As used herein, “traffickers” does not include Defendants’

22 employees and agents whose actions may meet the definition of trafficking.

23 Only Plaintiff’s identifying name(s) and/or photographs of Plaintiff may be

24 disclosed to Plaintiff’s alleged trafficker(s) and his or her counsel, and only to

25 the extent it is necessary, i.e., that Plaintiff’s Identity will assist the alleged

26 trafficker(s) in recalling, relating, or explaining facts or in testifying. Such

27 disclosure shall only take place if the procedures herein are followed and the

1 below (Section 5.5).

2 5.5 Defendants may not disclose Plaintiff’s Identity to the alleged

3 traffickers and their associates without prior Court approval. To obtain Court

4 approval, Defendants must comply with the Local Rules to seek to file a sealed

5 application, serving Plaintiff with a copy, in which Defendants: (1) describe

6 with reasonable specificity the nature of the information sought from the

7 alleged trafficker(s) or their associate(s); (2) provide the identity of the

8 trafficker(s) or their associate(s) from whom information is sought; (3) explain

9 why the information is sought from the alleged trafficker(s) or their associate(s)

10 as opposed to some other source; (4) identify any alternative means available

11 to get the information; (5) identify any and all attempts to get the information

12 from other sources; and (6) explain the necessity of disclosing Plaintiff’s

13 Identity to the alleged trafficker(s) or their associate(s). Within seven (7) days

14 after Defendants file and serve their application, Plaintiff may file a response

15 and if Plaintiff seeks to have the response sealed, Plaintiff must comply with

16 the Local Rules, and Plaintiff must serve Defendants with a copy of her

17 response that identifies: (1) any specific concerns with or objections to

18 Defendants’ request; and (2) facts demonstrating how and why Defendants’

19 proposed disclosure of Plaintiff’s Identity poses a risk of harm to Plaintiff

20 and/or her family; and (3) any reasonable restrictions the Court should place

21 on the disclosure of Plaintiff’s Identity. The Court will then evaluate the

22 application and provide its ruling. Should the Court grant Defendants’

23 application, Defendants shall provide Plaintiff with at least fourteen (14) days

24 advance notice of the contact and where and how the contact will occur.

25 6. SCOPE

26 A. The protections conferred by this Stipulation and Order cover not

27 only Protected Material (as defined above), but also (1) any information copied

1 compilations of Protected Material; and (3) any testimony, conversations, or

2 presentations by Parties or their Counsel that might reveal Protected Material.

3 B. Any use of Protected Material at trial shall be governed by the

4 orders of the trial judge and other applicable authorities. This Order does not

5 govern the use of Protected Material at trial.

6 C. Except for Plaintiff’s Identity, the protections conferred by this

7 Protective Order do not cover information that is in the public domain or

8 becomes part of the public domain through trial or otherwise.

9 D. All provisions of this Protective Order and the protections

10 conferred herein extend to any Non-Party asked or compelled to produce

11 Protected Material.

12 E. This Protective Order is without prejudice to the right of any Party

13 to seek further or additional or less restrictive protection of any Discovery

14 Material or to modify this Protective Order in any way, including, without

15 limitation, an order that certain matter not be produced at all.

16 F. To the extent a Designating Party provides Protected Material

17 under the terms of this Protective Order to the Receiving Party, the Receiving

18 Party shall not share that material with any Non-Party, absent express written

19 permission from the Designating Party, unless in conformance with this

20 Protective Order.

21 G. If a Party independently learns, obtains, or acquires Confidential

22 Information or information regarding Plaintiff’s identity, absent contrary

23 order, such information is subject to this Protective Order, and the Party shall

24 not share that material with any Non-Party, absent express written permission

25 from the subject Party, unless in conformance with this Protective Order.

26 6. DURATION

27 Confidential Information that is subject to this Protective Order may be

1 conditions imposed by the Court upon application by any party. The

2 commencement of trial nor the termination of this case shall not relieve

3 counsel or other persons obligated hereunder from their responsibility to

4 maintain the confidentiality of Confidential Information pursuant to this

5 Protective Order.

6 7. DESIGNATING PROTECTED MATERIAL

7 7.1 Exercise of Restraint and Care in Designating Material for

8 Protection. Each Party or Non-Party that designates information or items for

9 protection under this Order must take care to limit any such designation to

10 material that qualifies under the appropriate standards. The Designating Party

11 must designate for protection only those parts of material, documents, items or

12 oral or written communications that qualify so that other portions of the

13 material, documents, items or communications for which protection is not

14 warranted are not swept unjustifiably within the ambit of this Order.

15 Mass, indiscriminate or routinized designations are prohibited.

16 Designations that are shown to be clearly unjustified or that have been made

17 for an improper purpose (e.g., to unnecessarily encumber the case development

18 process or to impose unnecessary expenses and burdens on other parties) may

19 expose the Designating Party to sanctions.

20 If it comes to a Designating Party’s attention that information or items

21 that it designated for protection do not qualify for protection, that Designating

22 Party must promptly notify all other Parties that it is withdrawing the

23 inapplicable designation.

24 7.2 Manner and Timing of Designations. Except as otherwise

25 provided in this Order, or as otherwise stipulated or ordered, Disclosure of

26 Discovery Material that qualifies for protection under this Order must be

27 clearly so designated before the material is disclosed or produced.

1 (a) for information in documentary form (e.g., paper or electronic

2 documents, but excluding transcripts of depositions or other pretrial or trial

3 proceedings), that the Producing Party affix at a minimum, the legend

4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page

5 that contains protected material. If only a portion of the material on a page

6 qualifies for protection, the Producing Party also must clearly identify the

7 protected portion(s) (e.g., by making appropriate markings in the margins).

8 A Party or Non-Party that makes original documents available for

9 inspection need not designate them for protection until after the inspecting

10 Party has indicated which documents it would like copied and produced.

11 During the inspection and before the designation, all of the material made

12 available for inspection shall be deemed “CONFIDENTIAL.” After the

13 inspecting Party has identified the documents it wants copied and produced,

14 the Producing Party must determine which documents, or portions thereof,

15 qualify for protection under this Order. Then, before producing the specified

16 documents, the Producing Party must affix the “CONFIDENTIAL legend” to

17 each page that contains Protected Material. If only a portion of the material on

18 a page qualifies for protection, the Producing Party also must clearly identify

19 the protected portion(s) (e.g., by making appropriate markings in the margins).

20 (b) for testimony given in depositions that the Designating Party

21 identifies the Disclosure or Discovery Material within 21 days after transcript

22 availability.

23 (c) for information produced in some form other than documentary and

24 for any other tangible items, that the Producing Party affix in a prominent

25 place on the exterior of the container or containers in which the information is

26 stored the legend “CONFIDENTIAL.” If only a portion or portions of the

27 information warrants protection, the Producing Party, to the extent

1 7.3 Inadvertent Failures to Designate. If timely corrected, an

2 inadvertent failure to designate qualified information or items does not,

3 standing alone, waive the Designating Party’s right to secure protection under

4 this Order for such material. Upon timely correction of a designation, the

5 Receiving Party must make reasonable efforts to assure that the material is

6 treated in accordance with the provisions of this Order.

7 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

8 8.1. Timing of Challenges. Any Party or Non-Party may challenge a

9 designation of confidentiality at any time that is consistent with the Court’s

10 Scheduling Order.

11 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

12 resolution process under Local Rule 37-1 et seq.

13 8.3 Joint Stipulation. Any challenge submitted to the Court shall be

14 via a joint stipulation pursuant to Local Rule 37-2.

15 8.4 The burden of persuasion in any such challenge proceeding shall

16 be on the Designating Party. Frivolous challenges, and those made for an

17 improper purpose (e.g., to harass or impose unnecessary expenses and burdens

18 on other parties) may expose the Challenging Party to sanctions. Unless the

19 Designating Party has waived or withdrawn the confidentiality designation, all

20 parties shall continue to afford the material in question the level of protection

21 to which it is entitled under the Producing Party’s designation until the Court

22 rules on the challenge.

23 9. ACCESS TO AND USE OF PROTECTED MATERIAL, AND

24 FILING PROTECTED MATERIAL

25 9.1 Basic Principles. A Receiving Party may use Protected Material

26 that is disclosed or produced by another Party or by a Non-Party in connection

27 with this Action only for prosecuting, defending or attempting to settle this

1 persons and under the conditions described in this Order. When the Action has

2 been terminated, a Receiving Party must comply with the provisions of section

3 15 below (FINAL DISPOSITION).

4 Protected Material must be stored and maintained by a Receiving Party

5 at a location and in a secure manner that ensures that access is limited to the

6 persons authorized under this Order.

7 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

8 otherwise ordered by the court or permitted in writing by the Designating

9 Party, a Receiving Party may disclose any information or item designated

10 “CONFIDENTIAL” only to:

11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

12 well as employees of said Outside Counsel of Record to whom it is reasonably

13 necessary to disclose the information for this Action;

14 (b) the officers, directors, and employees (including House Counsel) of

15 the Receiving Party to whom disclosure is reasonably necessary for this

16 Action;

17 (c) Experts (as defined in this Order) of the Receiving Party to whom

18 disclosure is reasonably necessary for this Action and who have signed the

19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

20 (d) Any witness who counsel in good faith believes may have relevant

21 evidence or may be called to testify at trial who have signed the

22 'Acknowledgment and Agreement to Be Bound'" (Exhibit A);

23 (e) the court and its personnel;

24 (f) court reporters and their staff;

25 (g) professional jury or trial consultants, mock jurors, and

26 Professional Vendors to whom disclosure is reasonably necessary for this

27 Action and who have signed the “Acknowledgment and Agreement to Be

1 (h) the author or recipient of a document containing the information

2 or a custodian or other person who otherwise possessed or knew the

3 information;

4 (i) during their depositions, witnesses, and attorneys for witnesses, in

5 the Action to whom disclosure is reasonably necessary provided: (1) the

6 deposing party requests that the witness sign the form attached as Exhibit A

7 hereto; and (2) they will not be permitted to keep any confidential information

8 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit

9 A), unless otherwise agreed by the Designating Party or ordered by the court.

10 Pages of transcribed deposition testimony or exhibits to depositions that reveal

11 Protected Material may be separately bound by the court reporter and may not

12 be disclosed to anyone except as permitted under this Protective Order; and

13 (j) any mediators or settlement officers and their support staff,

14 mutually agreed upon by any of the parties engaged in settlement discussions.

15 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

16 PRODUCED IN OTHER LITIGATION

17 If a Party is served with a subpoena or a court order issued in other

18 litigation that compels disclosure of any information or items designated in this

19 Action as “CONFIDENTIAL,” that Party must:

20 (a) promptly notify in writing the Designating Party. Such notification

21 shall include a copy of the subpoena or court order;

22 (b) promptly notify in writing the party who caused the subpoena or

23 order to issue in the other litigation that some or all of the material covered by

24 the subpoena or order is subject to this Protective Order. Such notification

25 shall include a copy of this Stipulated Protective Order; and

26 (c) cooperate with respect to all reasonable procedures sought to be

27 pursued by the Designating Party whose Protected Material may be affected. If

1 subpoena or court order shall not produce any information designated in this

2 action as “CONFIDENTIAL” before a determination by the court from which

3 the subpoena or order issued, unless the Party has obtained the Designating

4 Party’s permission. The Designating Party shall bear the burden and expense

5 of seeking protection in that court of its confidential material and nothing in

6 these provisions should be construed as authorizing or encouraging a

7 Receiving Party in this Action to disobey a lawful directive from another court.

8 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO

9 BE PRODUCED IN THIS LITIGATION

10 (a) The terms of this Order are applicable to information produced by a

11 Non-Party in this Action and designated as “CONFIDENTIAL.” Such

12 information produced by Non-Parties in connection with this litigation is

13 protected by the remedies and relief provided by this Order. Nothing in these

14 provisions should be construed as prohibiting a Non-Party from seeking

15 additional protections.

16 (b) In the event that a Party is required, by a valid discovery request, to

17 produce a Non-Party’s confidential information in its possession, and the Party

18 is subject to an agreement with the Non-Party not to produce the Non-Party’s

19 confidential information, then the Party shall:

20 (1) promptly notify in writing the Requesting Party and the Non-

21 Party that some or all of the information requested is subject to a

22 confidentiality agreement with a Non-Party;

23 (2) promptly provide the Non-Party with a copy of the Stipulated

24 Protective Order in this Action, the relevant discovery request(s), and a

25 reasonably specific description of the information requested; and

26 (3) make the information requested available for inspection by the

27 Non-Party, if requested.

1 14 days of receiving the notice and accompanying information, the Receiving

2 Party may produce the Non-Party’s confidential information responsive to the

3 discovery request. If the Non-Party timely seeks a protective order, the

4 Receiving Party shall not produce any information in its possession or control

5 that is subject to the confidentiality agreement with the Non-Party before a

6 determination by the court. Absent a court order to the contrary, the Non-

7 Party shall bear the burden and expense of seeking protection in this court of

8 its Protected Material.

9 12. UNAUTHORIZED DISCLOSURE OF PROTECTED

10 MATERIAL

11 If a Receiving Party learns that, by inadvertence or otherwise, it has

12 disclosed Protected Material to any person or in any circumstance not

13 authorized under this Stipulated Protective Order, the Receiving Party must

14 immediately (a) notify in writing the Designating Party of the unauthorized

15 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

16 Protected Material, (c) inform the person or persons to whom unauthorized

17 disclosures were made of all the terms of this Order, and (d) request such

18 person or persons to execute the “Acknowledgment an Agreement to Be

19 Bound” attached hereto as Exhibit A.

20 13. INADVERTENT PRODUCTION OF PRIVILEGED OR

21 OTHERWISE PROTECTED MATERIAL

22 When a Producing Party gives notice to Receiving Parties that certain

23 inadvertently produced material is subject to a claim of privilege or other

24 protection, the obligations of the Receiving Parties are those set forth in

25 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to

26 modify whatever procedure may be established in an e-discovery order that

27 provides for production without prior privilege review. Pursuant to Federal

1 of disclosure of a communication or information covered by the attorney-client

2 privilege or work product protection, the parties may incorporate their

3 agreement in the stipulated protective order submitted to the court.

4 14. MISCELLANEOUS

5 14.1 Right to Further Relief. Nothing in this Order abridges the right of

6 any person to seek its modification by the Court in the future.

7 14.2 Right to Assert Other Objections. By stipulating to the entry of this

8 Protective Order, no Party waives any right it otherwise would have to object

9 to disclosing or producing any information or item on any ground not

10 addressed in this Stipulated Protective Order. Similarly, no Party waives any

11 right to object on any ground to use in evidence of any of the material covered

12 by this Protective Order.

13 14.3 Filing Protected Material. A Party that seeks to file under seal any

14 Protected Material must comply with Local Civil Rule 79-5. Protected

15 Material may only be filed under seal pursuant to a court order authorizing the

16 sealing of the specific Protected Material. If a Party’s request to file Protected

17 Material under seal is denied by the court, then the Receiving Party may file

18 the information in the public record unless otherwise instructed by the court.

19 15. FINAL DISPOSITION

20 After the final disposition of this Action, as defined in paragraph 6,

21 within 60 days of a written request by the Designating Party, each Receiving

22 Party must return all Protected Material to the Producing Party or destroy such

23 material. As used in this subdivision, “all Protected Material” includes all

24 copies, abstracts, compilations, summaries, and any other format reproducing

25 or capturing any of the Protected Material. Whether the Protected Material is

26 returned or destroyed, the Receiving Party must submit a written certification

27 to the Producing Party (and, if not the same person or entity, to the

1 where appropriate) all the Protected Material that was returned or destroyed

2 and (2) affirms that the Receiving Party has not retained any copies, abstracts,

3 compilations, summaries or any other format reproducing or capturing any of

4 the Protected Material. Notwithstanding this provision, Counsel are entitled to

5 retain an archival copy of all pleadings, motion papers, trial, deposition, and

6 hearing transcripts, legal memoranda, correspondence, deposition and trial

7 exhibits, expert reports, attorney work product, and consultant and expert

8 work product, even if such materials contain Protected Material. Any such

9 archival copies that contain or constitute Protected Material remain subject to

10 this Protective Order as set forth in Section 6 (DURATION).

11 16. VIOLATION

12 Any violation of this Order may be punished by appropriate measures

13 including, without limitation, contempt proceedings and/or monetary

14 sanctions.

15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

16

Singleton Schreiber, LLP

17

DATED: _7-22-2026___________ _/s/ Meagan Verschueren ___________

18

Brett Schreiber, Esq.

19 Meagan Verschueren, Esq.

Katie Llamas, Esq.

20

Vanessa Trujillo, Esq.

21 591 Camino de la Reina, Ste. 1025

22 San Diego, California 92108

T: (619) 771-3473

23 E: bschreiber@singletonschreiber.com

24 E: mverschueren@singletonschreiber.com

E: kllamas@singletonschreiber.com

25 E: vtrujillo@singletonschreiber.com

26 Attorneys for Plaintiff

27

Freeman Mathis & Gary, LLP

1 DATED: 7-23-2026 /s/ Kimberly Wah

Kimberly Wah, SBN 265817

2 550 S. Hope Street, Suite 2200

3 Los Angeles, CA 90071

T: (213) 615-7000

4 E: Kimberly. Wah@fmglaw.com

5

DATED: _7-22-2026 /s/ Samantha L. Edwards

6 Samantha L. Edwards, SBN 323341

7 770 East Warm Springs Road, Suite 360

Las Vegas, NV 89119

8 T: 725-258-8401

9 E: Samantha.Edwards@fmglaw.com

10 Attorneys for Defendants DHANUBA

11 HOSPITALITY, INC., PRAVIN R. AHIR

and SURESHBHAI R. AHIR

13

4 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

15 | DATED: September 2, 2026 of

16 Lipa :

17 HN D. EARLY

18 United States Magistrate Judge

19

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28

an

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________, of

4 _____________________________, declare under penalty of perjury that I have

5 read in its entirety and understand the Stipulated Protective Order that was

6 issued by the United States District Court for the Central District of California

7 in the case of Jane Doe v DHANUBA HOSPITALITY, INC., et al., Case

8 No. 8:26-cv-00854-JDE. I agree to comply with and to be bound by all the

9 terms of this Stipulated Protective Order and I understand and acknowledge

10 that failure to so comply could expose me to sanctions and punishment in the

11 nature of contempt. I solemnly promise that I will not disclose in any manner

12 any information or item that is subject to this Stipulated Protective Order to

13 any person or entity except in strict compliance with the provisions of this

14 Order.

15 I further agree to submit to the jurisdiction of the United States District

16 Court for the Central District of California for the purpose of enforcing the

17 terms of this Stipulated Protective Order, even if such enforcement proceedings

18 occur after termination of this Action.

19

Date: ________________

20

Printed Name

21

22

Signature

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