Extract to table

("NovaPay"), AMA's payroll processor and electronic timekeeping system provider, including system configuration data, time punch records, pay calculation algorithms, rounding rules, meal and rest period waiver records, and related system audit logs; WHEREAS, the parties agree that a protective order is necessary and appropriate to protect the confidentiality of such information, to safeguard the privacy interests of current and former employees and putative class members, and to preserve the trade secret and proprietary status of certain business information, while at the same time allowing the parties to conduct discovery fully, efficiently, and in accordance with the California Code of Civil Procedure and applicable rules; WHEREAS, this Stipulated Protective Order is consistent with the model protective order published by the Los Angeles Superior Court and is intended to balance the legitimate confidentiality interests of the parties and non-parties against the public's right of access to court proceedings and records; WHEREAS, the parties agree to be bound by the terms and conditions set forth herein, and respectfully request that the Court enter this Stipulated Protective Order as an order of the Court; NOW, THEREFORE, the parties stipulate and agree, and upon approval by the Court, IT IS HEREBY ORDERED as follows: SECTION 1: DEFINITIONS As used in this Protective Order, the following terms shall have the meanings set forth below: 1

All designations under this Order must be made in good faith and on a reasonable basis

The Designating Party shall use commercially reasonable efforts to ensure that the designation is clearly legible and conspicuously placed on each designated document or item

The court reporter shall mark the corresponding pages and lines of the transcript with the appropriate designation legend

Such notice shall be provided to all parties simultaneously and shall identify the designated material with reasonable specificity

Until the expiration of the twenty-one (21) calendar day designation period following receipt of the final certified transcript, all deposition transcripts and video recordings in this Action shall be treated as CONFIDENTIAL