Disney’s Dirty Secrets EXPOSED: Gina Carano Lawsuit Unleashes Confidential Bombshells!

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In their lawsuit, Gina Carano and The Walt Disney Company have reached an agreement about the disclosure of certain documents. A protective order has been issued by the court to protect sensitive information related to ‘The Mandalorian’ series, as well as potential future films like ‘The Mandalorian and Grogu’. While it seems Carano wants to disclose as much information as possible, Disney retains the right to contest keeping documents confidential even with a “good faith” provision for transparency. It remains uncertain whether this will delay the case, but there’s a good chance it could.

Here’s the Protective Order:

Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 1 of 17 Page ID #:1038 1 DONALD M. FALK (Cal. Bar #150256) DANIEL M. PETROCELLI SCHAERR | JAFFE LLP (Cal. Bar #97802) 2 Four Embarcadero Center, Suite 1400 MOLLY M. LENS 3 San Francisco, CA 94111 (Cal. Bar #283867) Tel: (415) 562-4942 KRISTIN MACDONNELL 4 Fax: (202) 776-0136 (Cal. Bar #307124) [email protected] O’MELVENY & MYERS LLP 5  $YHQXH RI WKH 6WDUV ஍‫) ހ‬ORRU EUGENE VOLOKH (Cal. Bar #194464) Los Angeles, CA 90067-6035 6 SCHAERR | JAFFE LLP Tel: (310) 553-6700 7 385 Charles East Young Dr. East Fax: (310) 246-6779 Los Angeles, CA 90095 [email protected] 8 Tel: (310) 206-3926 [email protected] [email protected] [email protected] 9 GENE C. SCHAERR* 10 H. CHRISTOPHER BARTOLOMUCCI* JONATHAN D. HACKER* EDWARD H. TRENT* JOSHUA REVESZ* 11 SCHAERR | JAFFE LLP O’MELVENY & MYERS LLP 12 1717 K Street NW, Suite 900 1625 Eye Street, NW Washington, DC 20006 Washington, DC 20006 13 Tel: (202) 787-1060 Tel: (202) 383-5300 [email protected] Fax: (202) 383-5414 14 [email protected] [email protected] 15 [email protected] [email protected] 16 Counsel for Plaintiff Counsel for Defendants 17 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 21 GINA CARANO, Case No. 2:24-cv-01009-SPG-SK 22 23 Plaintiff, AMENDED STIPULATED 24 v. PROTECTIVE ORDER 25 THE WALT DISNEY COMPANY, LUCASFILM LTD, LLC, and 26 HUCKLEBERRY INDUSTRIES (US), INC., 27 Defendant. 28 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 2 of 17 Page ID #:1039 1 1. A. 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 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Amended Stipulated Protective Order. The parties acknowledge 7 that this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential or Attorneys 10 Eyes Only treatment under the applicable legal principles. The parties further 11 acknowledge, as set forth in Section 12(c) (Filing Protected Material), below, that 12 this Amended Stipulated Protective Order does not entitle them to file confidential 13 or Attorneys Eyes Only information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve trade secrets and other valuable commercial, 19 financial, technical and/or proprietary information, including, for example, non- 20 public information about the creation of The Mandalorian, for which special 21 protection from public disclosure and from use for any purpose other than 22 prosecution of this action is warranted. Such confidential and proprietary materials 23 and information consist of, among other things, confidential business or financial 24 information, information regarding confidential business practices, commercial 25 information (including information implicating privacy rights of third parties), 26 information otherwise generally unavailable to the public, or which may be 27 privileged or otherwise protected from disclosure under state or federal statutes, 28 court rules, case decisions, or common law. Indeed, designating certain information 2 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 3 of 17 Page ID #:1040 1 on an attorney’s-eyes-only basis is provided for under this Court’s April 3, 2025 2 Order. Dkt. 69. Accordingly, to expedite the flow of information, to facilitate the 3 prompt resolution of disputes over confidentiality of discovery materials, to 4 adequately protect information the parties are entitled to keep confidential or 5 Attorneys Eyes Only, to ensure that the parties are permitted reasonable necessary 6 uses of such material in preparation for and in the conduct of trial, to address their 7 handling at the end of the litigation, and serve the ends of justice, a protective order 8 for such information is justified in this matter. It is the intent of the parties that 9 information will not be designated as confidential or Attorneys Eyes Only for 10 tactical reasons and that nothing be so designated without a good faith belief that it 11 has been maintained in a confidential, non-public manner, and there is good cause 12 why it should not be part of the public record of this case. 13 14 2. DEFINITIONS 15 a. Action: Gina Carano v. Walt Disney Co., No. 2:24-cv-01009-SPG-SK. 16 b. Challenging Party: a Party or Non-Party that challenges the designation of 17 information or items under this Order. 18 c. “CONFIDENTIAL” Information or Items: information (regardless of how 19 it is generated, stored, or maintained) or tangible things that qualify for protection 20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 21 Cause Statement. 22 d. Counsel: Outside Counsel of Record and House Counsel (as well as their 23 support staff). 24 e. 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” or “ATTORNEYS EYES ONLY.” 27 f. Disclosure or Discovery Material: all items or information, regardless of 28 the medium or manner in which it is generated, stored, or maintained (including, 3 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 4 of 17 Page ID #:1041 1 among other things, testimony, transcripts, and tangible things), that are produced 2 or generated in disclosures or responses to discovery in this matter. 3 g. 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 h. “ATTORNEYS EYES ONLY” Information or Items: information 7 (regardless of how it is generated, stored or maintained) or tangible things which 8 belong to a Designating Party who believes in good faith that the Disclosure of such 9 information to another Party or non-Party would create a substantial risk of serious 10 commercial, personal or financial injury and/or invasion of privacy that cannot be 11 avoided by less restrictive means. 12 i. House Counsel: attorneys who are employees of a party to this Action. 13 House Counsel does not include Outside Counsel of Record or any other outside 14 counsel. 15 j. Non-Party: any natural person, partnership, corporation, association, or 16 other legal entity not named as a Party to this action. 17 k. Outside Counsel of Record: attorneys who are not employees of a party to 18 this Action but are retained to represent or advise a party to this Action and have 19 appeared in this Action on behalf of that party or are affiliated with a law firm which 20 has appeared on behalf of that party, including support staff. 21 l. Party: any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and their 23 support staffs). 24 m. Producing Party: a Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 n. Professional Vendors: persons or entities that provide litigation support 27 services (e.g., photocopying, videotaping, translating, preparing exhibits or 28 demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 5 of 17 Page ID #:1042 1 and their employees and subcontractors. 2 o. Protected Material: any Disclosure or Discovery Material that is designated 3 as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY.” 4 p. Receiving Party: a Party that receives Disclosure or Discovery Material 5 from a Producing Party. 6 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or 10 extracted from Protected Material; (2) all copies, excerpts, summaries, or 11 compilations of Protected Material; and (3) any testimony, conversations, or 12 presentations by Parties or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 trial judge. This Order does not govern the use of Protected Material at trial. 15 16 4. DURATION 17 Even after final disposition of this litigation, the confidentiality obligations 18 imposed by this Order shall remain in effect until a Designating Party agrees 19 otherwise in writing or a court order otherwise directs. Final disposition shall be 20 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 21 or without prejudice; and (2) final judgment herein after the completion and 22 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 23 including the time limits for filing any motions or applications for extension of time 24 pursuant to applicable law. 25 26 5. DESIGNATING PROTECTED MATERIAL 27 a. Exercise of Restraint and Care in Designating Material for Protection. 28 Each Party or Non-Party that designates information or items for protection 5 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 6 of 17 Page ID #:1043 1 under this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items, or oral or written 4 communications that qualify so that other portions of the material, documents, items, 5 or communications for which protection is not warranted are not swept unjustifiably 6 within the ambit of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 b. Manner and Timing of Designations. Except as otherwise provided in this 16 Order (see, e.g., second paragraph of Section 5(b)(1) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (1) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” or “ATTORNEYS EYES ONLY” (hereinafter 25 “CONFIDENTIAL legend”), to each page that contains protected material. If 26 only a portion or portions of the material on a page qualifies for protection, the 27 Producing Party also must clearly identify the protected portion(s) (e.g., by 28 making appropriate markings in the margins). 6 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 7 of 17 Page ID #:1044 1 A Party or Non-Party that makes original documents available for 2 inspection need not designate them for protection until after the inspecting 3 Party has indicated which documents it would like copied and produced. 4 During the inspection and before the designation, all of the material made 5 available for inspection shall be deemed “CONFIDENTIAL.” After the 6 inspecting Party has identified the documents it wants copied and produced, the 7 Producing Party must determine which documents, or portions thereof, qualify 8 for protection under this Order. Then, before producing the specified 9 documents, the Producing Party must affix the appropriate “CONFIDENTIAL 10 legend” to each page that contains Protected Material. If only a portion or 11 portions of the material on a page qualifies for protection, the Producing Party 12 also must clearly identify the protected portion(s) (e.g., by making appropriate 13 markings in the margins). 14 (2) for testimony given in depositions, the Designating Party may 15 provisionally designate the entirety of deposition testimony as 16 “CONFIDENTIAL,” with the obligation to identify more specific portions of 17 the testimony as to which protection is sought within 30 days following receipt 18 of the deposition transcript (or within the time otherwise agreed by the Parties). 19 (3) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on 21 the exterior of the container or containers in which the information is stored the 22 appropriate “CONFIDENTIAL” legend. If only a portion or portions of the 23 information warrants protection, the Producing Party, to the extent practicable, 24 shall identify the protected portion(s). 25 c. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 26 to designate qualified information or items does not, standing alone, waive the 27 Designating Party’s right to secure protection under this Order for such material. 28 Upon timely correction of a designation, the Receiving Party must make reasonable 7 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 8 of 17 Page ID #:1045 1 efforts to assure that the material is treated in accordance with the provisions of this 2 Order. 3 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 a. Timing of Challenges. Any Party or Non-Party may challenge a designation 6 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 7 b. Meet and Confer. The Challenging Party shall initiate the dispute resolution 8 process under Civil Local Rule 37-1 et seq. 9 c. The burden of persuasion in any such challenge proceeding shall be on the 10 Designating Party. Frivolous challenges, and those made for an improper purpose 11 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may 12 expose the Challenging Party to sanctions. Unless the Designating Party has waived 13 or withdrawn the confidentiality designation, all parties shall continue to afford the 14 material in question the level of protection to which it is entitled under the 15 Producing Party’s designation until the Court rules on the challenge. 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 a. Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending, or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a 23 Receiving Party must comply with the provisions of Section 13 below (FINAL 24 DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 28 b. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 8 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 9 of 17 Page ID #:1046 1 ordered by the Court or permitted in writing by the Designating Party, a Receiving 2 Party may disclose any information or item designated “CONFIDENTIAL” only to: 3 (1) the Receiving Party’s Outside Counsel of Record in this Action, as well 4 as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 (2) the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 (3) Experts (as defined in this Order) of the Receiving Party to whom 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (4) the Court and its personnel; 12 (5) court reporters and their staff; 13 (6) professional jury or trial consultants, mock jurors, and Professional 14 Vendors to whom disclosure is reasonably necessary for this Action and who 15 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (7) the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (8) any deposition or non-trial hearing witness in the Action (including, for 19 the avoidance of doubt, in preparation for such testimony) who previously did 20 not have access to the Confidential Materials (including any counsel for such 21 individuals); provided, (1) the witness signs the form attached as Exhibit A 22 hereto; and (2) the witness will not be permitted to keep any confidential 23 information unless they sign the “Acknowledgment and Agreement to Be 24 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 25 ordered by the Court; and 26 (9) any mediator or settlement officer, and their supporting personnel, 27 mutually agreed upon by any of the parties engaged in settlement discussions. 28 c. Disclosure of “ATTORNEYS EYES ONLY” Information or Items. 9 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 10 of 17 Page ID #:1047 1 Unless otherwise ordered by the court or permitted in writing by the Designating 2 Party, information designated as “ATTORNEYS EYES ONLY” may be disclosed, 3 provided, and/or received only by: 4 (1) the Receiving Party’s Outside Counsel of Record in this Action, as well 5 as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action; 7 (2) Experts (as defined in this Order) of the Receiving Party to whom 8 disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (3) the Court and its personnel; and 11 (4) court reporters and their staff. 12 For the avoidance of doubt, the individuals permitted to receive ATTORNEYS EYES 13 ONLY information (identified in paragraphs 7(c)(1), 7(c)(2), 7(c)(3), and 7(c)(4) 14 above) are not permitted to disclose, provide, and/or share, in whole or in part, the 15 contents of any ATTORNEYS EYES ONLY information, with such prohibition 16 extending to any representation or characterization of the contents of any of the so- 17 designated information. The Receiving Party’s Outside Counsel of Record in this 18 Action may utilize ATTORNEYS EYES ONLY information during the deposition of 19 the Designating Party or current employee of the Designating Party with knowledge 20 of the ATTORNEYS EYES ONLY information, provided, however, that anyone not 21 permitted to receive ATTORNEYS EYES ONLY INFORMATION is not present. 22 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 23 IN OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation 25 that compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL” or “ATTORNEYS EYES ONLY,” that Party must: 27 (a) promptly notify in writing the Designating Party. Such notification shall 28 include a copy of the subpoena or court order; 10 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 11 of 17 Page ID #:1048 1 (b) promptly notify in writing the party who caused the subpoena or order 2 to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall 4 include a copy of this Amended Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued 6 by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY” before a 10 determination by the court from which the subpoena or order issued, unless the Party 11 has obtained the Designating Party’s permission. The Designating Party shall bear 12 the burden and expense of seeking protection in that court of its confidential 13 material, and nothing in these provisions should be construed as authorizing or 14 encouraging a Receiving Party in this Action to disobey a lawful directive from 15 another court. 16 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a Non- 20 Party in this Action and designated as “CONFIDENTIAL” or “ATTORNEYS 21 EYES ONLY.” Such information produced by Non-Parties in connection with 22 this litigation is protected by the remedies and relief provided by this Order. 23 Nothing in these provisions should be construed as prohibiting a Non-Party 24 from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a Non-Party’s confidential information in its possession, and the Party 27 is subject to an agreement with the Non-Party not to produce the Non-Party’s 28 confidential information, then the Party shall: 11 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 12 of 17 Page ID #:1049 1 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Amended 5 Stipulated Protective Order in this Action, the relevant discovery request(s), 6 and a reasonably specific description of the information requested; and 7 (3) make the information requested available for inspection by the Non- 8 Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this Court within 10 14 days of receiving the notice and accompanying information, the Receiving 11 Party may produce the Non-Party’s confidential information responsive to the 12 discovery request. If the Non-Party timely seeks a protective order, the 13 Receiving Party shall not produce any information in its possession or control 14 that is subject to the confidentiality agreement with the Non-Party before a 15 determination by the Court. Absent a court order to the contrary, with the court 16 having discretion to shift costs, the Non-Party shall bear the burden and 17 expense of seeking protection in this Court of its Protected Material. 18 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 21 Protected Material to any person or in any circumstance not authorized under this 22 Amended Stipulated Protective Order, the Receiving Party must immediately (a) 23 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 24 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 25 the person or persons to whom unauthorized disclosures were made of all the terms 26 of this Order, and (d) request such person or persons to execute the 27 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 28 A. 12 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 13 of 17 Page ID #:1050 1 2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 8 procedure may be established in an e-discovery order that provides for production 9 without prior privilege review. 10 11 12. MISCELLANEOUS 12 a. Right to Relief. Nothing in this Order abridges the right of any person to 13 seek its modification by the Court in the future. 14 b. Right to Assert Other Objections. By stipulating to the entry of this 15 Protective Order, no Party waives any right it otherwise would have to object to 16 disclosing or producing any information or item on any ground not addressed in this 17 Amended Stipulated Protective Order. Similarly, no Party waives any right to object 18 on any ground to use in evidence of any of the material covered by this Protective 19 Order. And nothing in these provisions should be construed as prohibiting a Party 20 from seeking additional protections. 21 c. Filing Protected Material. A Party that seeks to file under seal any Protected 22 Material must comply with Civil Local Rule 79-5. Protected Material may only be 23 filed under seal pursuant to a court order authorizing the sealing of the specific 24 Protected Material at issue. If a Party’s request to file Protected Material under seal 25 is denied by the court, then the Receiving Party may file the information in the public 26 record unless otherwise instructed by the court. 27 28 13. FINAL DISPOSITION 13 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 14 of 17 Page ID #:1051 1 After the final disposition of this Action, as defined in Section 4 2 (DURATION), within 60 days of a written request by the Designating Party, each 3 Receiving Party must return all Protected Material to the Producing Party or destroy 4 such material. As used in this subdivision, “all Protected Material” includes all 5 copies, abstracts, compilations, summaries, and any other format reproducing or 6 capturing any of the Protected Material. Whether the Protected Material is returned 7 or destroyed, the Receiving Party must submit a written certification to the 8 Producing Party (and, if not the same person or entity, to the Designating Party) by 9 the 60 day deadline that (1) identifies (by category, where appropriate) all the 10 Protected Material that was returned or destroyed; and (2) affirms that the Receiving 11 Party has not retained any copies, abstracts, compilations, summaries, or any other 12 format reproducing or capturing any of the Protected Material. Notwithstanding this 13 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 14 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 15 deposition and trial exhibits, expert reports, attorney work product, and consultant 16 and expert work product, even if such materials contain Protected Material. Any 17 such archival copies that contain or constitute Protected Material remain subject to 18 this Protective Order as set forth in Section 4 (DURATION). 19 20 14. Any violation of this Order may be punished by any and all appropriate 21 measures including, without limitation, contempt proceedings and/or monetary 22 sanctions. 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 25 DATED: April 11, 2025 /s/ Gene C. Schaerr 26 Gene C. Schaerr Edward H. Trent 27 Counsel for Plaintiff 28 14 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 15 of 17 Page ID #:1052 1 2 3 DATED: April 11, 2025 /s/ Molly M. Lens 4 Daniel M. Petrocelli Molly M. Lens 5 Counsel for Defendants 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 16 of 17 Page ID #:1053 1 Attestation of E-Filed Signature 2 I, Molly M. Lens, am the ECF user whose ID and password are being used to 3 file this stipulation. Pursuant to C.D. Cal. L.R. 5-4.3.4, I attest that all other 4 signatories listed, and on whose behalf the present filing is submitted, concur in the 5 filing’s contents and have authorized the filing. 6 7 /s/ Molly M. Lens Molly M. Lens 8 Dated: April 11, 2025 9 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 12 April 11, 2025 DATED:________________________ 13 14 ____________________________________ 15 Honorable Steve Kim 16 United States Magistrate Judge 17 18 19 20 21 22 23 24 25 26 27 28 16 Case 2:24-cv-01009-SPG-SK Document 71 Filed 04/11/25 Page 17 of 17 Page ID #:1054 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________, of _________________, declare under 5 penalty of perjury that I have read in its entirety and understand the Amended 6 Stipulated Protective Order that was issued by the United States District Court for the 7 Central District of California on [date] in the case of Gina Carano v. Walt Disney Co., 8 No. 2:24-cv-01009-SPG-SK. I agree to comply with and to be bound by all the terms 9 of this Amended Stipulated Protective Order, and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Amended Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Amended Stipulated Protective Order, even if such enforcement proceedings occur 17 after termination of this action. I hereby appoint __________________________ 18 [print or type full name] of _______________________________________ [print 19 or type full address and telephone number] as my California agent for service of 20 process in connection with this action or any proceedings related to enforcement of 21 this Amended Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28

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