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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 Case No. LA CV19-06306 JAK Valentino S.p.A., (GJSx) 12

Plaintiff,

13 STIPULATED PROTECTIVE v. ORDER1 14 Mario Valentino S.p.A.; Yarch 15 Capital, LLC, 16 Defendants.

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18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 23 enter the following Stipulated Protective Order. The parties acknowledge that this 24 Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 27 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, product design documentation, 5 marketing and business plans and other valuable research, development, 6 commercial, financial, technical and/or proprietary information for which special 7 protection from public disclosure and from use for any purpose other than 8 prosecution of this action is warranted. Such confidential and proprietary materials 9 and information consist of, among other things, confidential business or financial 10 information, information regarding confidential business practices, or other 11 confidential research, development, or commercial information (including 12 information implicating privacy rights of third parties), information otherwise 13 generally unavailable to the public, or which may be privileged or otherwise 14 protected from disclosure under state or federal statutes, court rules, case decisions, 15 or common law. Accordingly, to expedite the flow of information, to facilitate the 16 prompt resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in 19 preparation for and in the conduct of trial, to address their handling at the end of the 20 litigation, and serve the ends of justice, a protective order for such information is 21 justified in this matter. It is the intent of the parties that information will not be 22 designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of this 25 case. 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 2 and the standards that will be applied when a party seeks permission from the court 3 to file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 proceedings and records in civil cases. In connection with non-dispositive motions, 6 good cause must be shown to support a filing under seal. See Kamakana v. City and 7 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 8 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 9 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 10 require good cause showing), and a specific showing of good cause or compelling 11 reasons with proper evidentiary support and legal justification, must be made with 12 respect to Protected Material that a party seeks to file under seal. The parties’ mere 13 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 14 without the submission of competent evidence by declaration, establishing that the 15 material sought to be filed under seal qualifies as confidential, privileged, or 16 otherwise protectable—constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, then 18 compelling reasons, not only good cause, for the sealing must be shown, and the 19 relief sought shall be narrowly tailored to serve the specific interest to be protected. 20 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 21 each item or type of information, document, or thing sought to be filed or introduced 22 under seal in connection with a dispositive motion or trial, the party seeking 23 protection must articulate compelling reasons, supported by specific facts and legal 24 justification, for the requested sealing order. Again, competent evidence supporting 25 the application to file documents under seal must be provided by declaration. 26 Any document that is not confidential, privileged, or otherwise protectable in 27 its entirety will not be filed under seal if the confidential portions can be redacted. 1 only the confidential, privileged, or otherwise protectable portions of the document, 2 shall be filed. Any application that seeks to file documents under seal in their 3 entirety should include an explanation of why redaction is not feasible. 4 2. DEFINITIONS 5 2.1 Action: this pending federal lawsuit. 6 2.2 Challenging Party: a Party or Non-Party that challenges the 7 designation of information or items under this Order. 8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 9 how it is generated, stored or maintained) or tangible things that qualify for 10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 the Good Cause Statement. 12 2.4 “CONFIDENTIAL ATTORNEYS EYES ONLY” Information or 13 Items: CONFIDENTIAL Information or Items that may for any business or 14 competitive purpose need to be protected from disclosure, trade secrets, and/or 15 information in which the Party or Non-party has an interest that such materials 16 should be protected from disclosure to other parties, and should be strictly viewable 17 only by Outside Counsel of Record or others described in Section 7.3. 18 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.6 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL” or CONFIDENTIAL ATTORNEYS EYES ONLY.” 23 2.7 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 2.8 Expert: a person with specialized knowledge or experience in a matter 1 an expert witness or as a consultant in this Action. 2 2.9 House Counsel: attorneys who are employees of a party to this Action. 3 House Counsel does not include Outside Counsel of Record or any other outside 4 counsel. 5 2.10 Non-Party: any natural person, partnership, corporation, association or 6 other legal entity not named as a Party to this action. 7 2.11 Outside Counsel of Record: attorneys who are not employees of a 8 party to this Action but are retained to represent or advise a party to this Action and 9 have appeared in this Action on behalf of that party or are affiliated with a law firm 10 that has appeared on behalf of that party, and includes support staff. In addition, 11 Outside Counsel of Record for Valentino, S.p.A. includes the firm of Bonelli Erede 12 Lombardi Pappalardo, including support staff. Outside Counsel of Record for 13 Mario Valentino S.p.A. includes the law firm of Spheriens Avvocati, including 14 support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.14 Professional Vendors: persons or entities that provide litigation 21 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 and their employees and subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES 26 ONLY.” 27 2.16 Receiving Party: a Party that receives Disclosure or Discovery 3. SCOPE 1 The protections conferred by this Stipulation and Order cover not only 2 Protected Material (as defined above), but also (1) any information copied or 3 extracted from Protected Material; (2) all copies, excerpts, summaries, or 4 compilations of Protected Material; and (3) any testimony, conversations, or 5 presentations by Parties or their Counsel that might reveal Protected Material. 6 Any use of Protected Material at trial shall be governed by the orders of the 7 trial judge. This Order does not govern the use of Protected Material at trial. 8 4. DURATION 9 FINAL DISPOSITION of the action is defined as the conclusion of any 10 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 11 has run. Except as set forth below, the terms of this protective order apply through 12 FINAL DISPOSITION of the action. The parties may stipulate that they will be 13 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 14 but will have to file a separate action for enforcement of the agreement once all 15 proceedings in this case are complete. 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 18 as an exhibit at trial becomes public and will be presumptively available to all 19 members of the public, including the press, unless compelling reasons supported by 20 specific factual findings to proceed otherwise are made to the trial judge in advance 21 of the trial. See Kamakana,

(distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record). Accordingly, for 24 such materials, the terms of this protective order do not extend beyond the 25 commencement of the trial. 26

27 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate for 6 protection only those parts of material, documents, items or oral or written 7 communications that qualify so that other portions of the material, documents, items 8 or communications for which protection is not warranted are not swept unjustifiably 9 within the ambit of this Order. 10 Mass, indiscriminate or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES ONLY” 1 material. If only a portion of the material on a page qualifies for protection, the 2 Producing Party also must clearly identify the protected portion(s) (e.g., by making 3 appropriate markings in the margins). 4 A Party or Non-Party that makes original documents available for inspection 5 need not designate them for protection until after the inspecting Party has indicated 6 which documents it would like copied and produced. During the inspection and 7 before the designation, all of the material made available for inspection shall be 8 deemed “CONFIDENTIAL ATTORNEYS EYES ONLY.” After the inspecting 9 Party has identified the documents it wants copied and produced, the Producing 10 Party must determine which documents, or portions thereof, qualify for protection 11 under this Order. Then, before producing the specified documents, the Producing 12 Party must affix the “CONFIDENTIALITY legend” to each page that contains 13 Protected Material. If only a portion of the material on a page qualifies for 14 protection, the Producing Party also must clearly identify the protected portion(s) 15 (e.g., by making appropriate markings in the margins). 16 (b) a Party or Nonparty may, if appropriate, designate specific portions of 17 the transcript “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES 18 ONLY” at the deposition or within thirty (30) days of completion of the final 19 transcript, and any portions so designated shall thereafter be treated in accordance 20 with the terms of this Order. Any portions not designated within the thirty (30) day 21 timeframe shall thereafter be treated as non-Protected Material. Until the expiration 22 of the thirty (30) day timeframe, deposition transcripts shall be treated as 23 CONFIDENTIAL ATTORNEYS EYES ONLY.. 24 (c) for information produced in some form other than documentary and 25 for any other tangible items, that the Producing Party affix in a prominent place on 26 the exterior of the container or containers in which the information is stored the 27 legend “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES ONLY.” 1 Party, to the extent practicable, shall identify the protected portion(s). 2 (d) for information produced in non-tangible form, that the Producing 3 Party apply the legend “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS 4 EYES ONLY” in the filename, subject line, or in some other manner reasonably 5 calculated to apprise a person of the designation. 6 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 failure to designate qualified information or items does not, standing alone, waive 8 the Designating Party’s right to secure protection under this Order for such material. 9 Upon timely correction of a designation, the Receiving Party must make reasonable 10 efforts to assure that the material is treated in accordance with the provisions of this 11 Order. 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 The burden of persuasion in any such challenge proceeding shall be on 19 the Designating Party. Frivolous challenges, and those made for an improper 20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 21 parties) may expose the Challenging Party to sanctions. Unless the Designating 22 Party has waived or withdrawn the confidentiality designation, all parties shall 23 continue to afford the material in question the level of protection to which it is 24 entitled under the Producing Party’s designation until the Court rules on the 25 challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 14 well as employees of said Outside Counsel of Record to whom it is reasonably 15 necessary to disclose the information for this Action; 16 (b) the officers, directors, and employees (including House Counsel) of 17 the Receiving Party to whom disclosure is reasonably necessary for this Action and 18 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), provided, however, 22 the signed Acknowledgment and Agreement to Be Bound: 23 (1) is delivered to counsel for all other Parties within two 24 business days of execution; or, 25 (2) if, not delivered to counsel for all other Parties within two 26 business days of execution, is delivered to counsel for all other 27 Parties prior to disclosure of CONFIDENTIAL or 1 items; 2 (d) the court and its personnel; 3 (e) court reporters and their staff; 4 (f) professional jury or trial consultants, mock jurors, and Professional 5 Vendors to whom disclosure is reasonably necessary for this Action and who have 6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (g) the author or recipient of a document containing the information or a 8 custodian or other person who otherwise possessed or knew the information who has 9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (h) during their depositions, witnesses, and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 13 will not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 15 agreed by the Designating Party or ordered by the court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal Protected Material may 17 be separately bound by the court reporter and may not be disclosed to anyone except 18 as permitted under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 7.3 Disclosure of Confidential Attorneys Eyes Only Information or Items. 22 Unless otherwise ordered by the court or permitted in writing by the Designating 23 Party, a Receiving Party may disclose any information or item designated 24 “CONFIDENTIAL ATTORNEYS EYES ONLY” only to those persons listed in 25 Sections 7.2 (a), (c), (d), (e), (f), (g), and (i). 26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 27 IN OTHER LITIGATION 1 that compels disclosure of any information or items designated in this Action as 2 “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES ONLY,” that 3 Party must: 4 (a) promptly notify in writing the Designating Party. Such notification 5 shall include a copy of the subpoena or court order; 6 (b) promptly notify in writing the party who caused the subpoena or order 7 to issue in the other litigation that some or all of the material covered by the 8 subpoena or order is subject to this Protective Order. Such notification shall include 9 a copy of this Stipulated Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to be 11 pursued by the Designating Party whose Protected Material may be affected. 12 If the Designating Party timely seeks a protective order, the Party served with 13 the subpoena or court order shall not produce any information designated in this 14 action as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS EYES ONLY” 15 before a determination by the court from which the subpoena or order issued, unless 16 the Party has obtained the Designating Party’s permission. The Designating Party 17 shall bear the burden and expense of seeking protection in that court of its 18 confidential material and nothing in these provisions should be construed as 19 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 20 directive from another court. 21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 PRODUCED IN THIS LITIGATION 23 (a) The terms of this Order are applicable to information produced by a 24 Non-Party in this Action and designated as “CONFIDENTIAL” or 25 “CONFIDENTIAL ATTORNEYS EYES ONLY.” Such information produced by 26 Non-Parties in connection with this litigation is protected by the remedies and relief 27 provided by this Order. Nothing in these provisions should be construed as 1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s 4 confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party 15 may produce the Non-Party’s confidential information responsive to the discovery 16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 17 not produce any information in its possession or control that is subject to the 18 confidentiality agreement with the Non-Party before a determination by the court. 19 Absent a court order to the contrary, the Non-Party shall bear the burden and 20 expense of seeking protection in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 1 Agreement to Be Bound” that is attached hereto as Exhibit A. 2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 11.1 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. Pursuant to Federal Rule of Evidence 502(d) and 10 (e), insofar as the parties reach an agreement on the effect of disclosure of a 11 communication or information covered by the attorney-client privilege or work 12 product protection, the parties may incorporate their agreement in the stipulated 13 protective order submitted to the court. 14 11.2 Procedure for Return. If information subject to a claim of privilege or 15 work product protection is inadvertently produced, such production shall in no way 16 prejudice or otherwise constitute a waiver of, or estoppel as to, any claim of 17 privilege or work-product protection for such information. If a Producing Party has 18 inadvertently produced information subject to a claim of privilege or protection, 19 upon written request made by the Producing Party of such inadvertent production, 20 the information for which a claim of inadvertent production is made, including all 21 copies, shall be returned within two (2) court days of such request unless the 22 receiving party intends to challenge the producing party’s assertion of privilege or 23 protection. All copies of inadvertently produced documents shall be destroyed, and 24 any document or material information reflecting the contents of the inadvertently 25 produced information shall be expunged. If a Receiving Party objects to the return 26 of such information within the two (2) court day period described above, the 27 Receiving Party may move the Court for an order determining the status of the 1 Receiving Party may retain the inadvertently produced documents in a sealed 2 envelope and shall not make any use of such information. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Civil Rule 79-5. Protected Material 13 may only be filed under seal pursuant to a court order authorizing the sealing of the 14 specific Protected Material at issue. If a Party’s request to file Protected Material 15 under seal is denied by the court, then the Receiving Party may file the information 16 in the public record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in 21 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if not the same 25 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 26 (by category, where appropriate) all the Protected Material that was returned or 27 destroyed and (2) affirms that the Receiving Party has not retained any copies, 1 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 2 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 reports, attorney work product, and consultant and expert work product, even if such 5 materials contain Protected Material. Any such archival copies that contain or 6 constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4 (DURATION). 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 7 Dated: February 26, 2020 ARNOLD & PORTER KAYE SCHOLER LLP 8

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10 By: /s/ James S. Blackburn James S. Blackburn (SBN 169134) 11 [email protected] 777 S. Figueroa Street, 44th Floor 12 Los Angeles, CA 90017-5844 Telephone: (213) 243-4000 13 Facsimile: (213) 243-4199

14 Attorneys for Valentino S.p.A. 15 GIOCONDA LAW GROUP PLLC 16 Dated: February 26, 2020 FISHER BROYLES LLP 17

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19 By: /s/ Joseph C. Giocanda Joseph C. Gioconda (pro hac vice) 20 [email protected] THE GIOCONDA LAW GROUP PLLC 21 100 Park Avenue, 16th Floor New York, NY 10017 22 Phone: (212) 235-1220 Fax: (888) 697-9665 23 Daniel D. Harshman (SBN 177139) 24 [email protected] FISHERBROYLES LLP 25 2110 Artesia Boulevard, Suite 606 Los Angeles, CA 90036 26 Phone: (310) 400-5668 Fax: (310) 400-5669 27 Attorneys for Mario Valentino S.p.A. 1 RITHOLZ LEVY FIELDS LLP 2 Dated: February 26, 2020 3 By: /s/ David Boren 4 David Boren (SBN 186316) dboren @rlfllp.com 5 Ritholz Levy Fields LLP 10940 Wilshire Blvd., Suite 1600 6 Los Angeles, CA 90024 Phone: (310) 443-4176 7 Fax: (310) 443-4220 8 9 Attorneys for Yarch Capital, LLC.

10 LOCAL RULE 5-4 ATTESTATION 11 I, James S. Blackburn, attest that all other signatories listed, and on whose

3 behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 14 6 15 |) Dated: February 26, 2020 By: /s/ James S. Blackburn 16 James S. Blackburn 17 18 19 20 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 || DATED: March 2, 2020 23 24 pat 25 GAIL J. STANDISH 26 || UNITED STATES MAGISTRATE JUDGE 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date]_____________________ in the case of Valentino S.p.A. v. Mario 9 Valentino S.p.A., et al., No. LA CV19-06306 (GJSx). I agree to comply with and to 10 be bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27