1 | TROUTMAN PEPPER HAMILTON SANDERS LLP Ronald I. Raether, Bar No. 303118 2 || [email protected] Jessica R. Lohr, Bar No. 302348 3 || [email protected] 5 Park Plaza, Suite 1400 4 || Irvine, CA 92614-2545 Telephone: 949.622.2700 5 || Facsimile: 949.622.2739 6 Attorneys for Plaintiff ACCURATE BACKGROUND, LLC 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 | MARIA MAGDALENA MARTINEZ, | Case No. 8:20-CV-00870-DOC-DFM » 12 Plaintiff, STIPULATION AND PROPOSED PROTECTIVE ORDER : 13 || v. 14 || ACCURATE BACKGROUND, LLC, 15 Defendant. 16 17 18 IT IS HEREBY STIPULATED by and between Plaintiff Maria Martinez 19 || (‘Plaintiff’) and Defendant Accurate Background, LLC, (“Defendant’” and 20 || collectively, the “parties’”), through their respective attorneys of record, as follows: 21 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 23 || proprietary or private information for which special protection from public disclosure 24 || and from use for any purpose other than pursuing this litigation may be warranted. 95 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 96 || following Stipulated Protective Order. The parties acknowledge that this Order does 97 || not confer blanket protections on all disclosures or responses to discovery and that 9g || the protection it affords from public disclosure and use extends only to the limited

1 || information or items that are entitled to confidential treatment under the applicable 2 || legal principles. 3 2. GOOD CAUSE STATEMENT 4 Fed. R. Civ. P. 26(c)(1) requires a showing of good cause for the entry of a 5 || protective order by the Court to prevent public disclosure of material such as trade 6 || secrets or other confidential research, development, or commercial information. 7 In this action, documents and information have been and may be sought, 8 || produced or exhibited by and among the parties to this action relating to trade secrets, 9 || confidential research, business practices, commercial information, development, 10 || technology or other proprietary information belonging to Defendant (including, but 11 || not limited to, its computer systems, software and processes used for preparing 3 12 || consumer reports, and information derived therefrom), for which special protection : 13 || from public disclosure and from use for any purpose other than prosecution of this : 14 || action is warranted, or which may be privileged or otherwise protected from 15 || disclosure under state or federal statutes, court rules, case decisions, or common law. 16 Accordingly, to expedite the flow of information, to facilitate the prompt 17 || resolution of disputes over confidentiality of discovery materials, to adequately 18 || protect information the parties are entitled to keep confidential, to ensure that the 19 || parties are permitted reasonable necessary uses of such material in preparation for 20 || and in the conduct of trial, to address their handling at the end of the litigation, and 21 || serve the ends of justice, a protective order for such information is justified in this 22 || matter. 23 It is the intent of the parties that information will not be designated as 24 || confidential for tactical reasons and that nothing be so designated without a good 25 || faith belief that it has been maintained in a confidential, non-public manner, and there 26 || 1s good cause why it should not be part of the public record of this case. 27 38 3. BN ELEN LOE LANDER SEAL FILING 109274262v1 -2- STIPULATION AND PROTECTIVE ORDER

1 The parties further acknowledge, as set forth in Section 14.3, below, that this 2 || Stipulated Protective Order does not entitle them to file confidential information 3 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 4 || the standards that will be applied when a party seeks permission from the court to 5 || file material under seal. There is a strong presumption that the public has a right of 6 || access to judicial proceedings and records in civil cases. In connection with non- 7 || dispositive motions, good cause must be shown to support a filing under seal. See 8 || Kamakana v. City and County of Honolulu,

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

, 1210-11 (9th Cir. 2002), Makar- 10 || Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 1999) (even 11 || stipulated protective orders require good cause showing), and a specific showing of ¢ 12 || good cause or compelling reasons with proper evidentiary support and legal : 13 || justification, must be made with respect to Protected Material that a party seeks to : 14 || file under seal. The parties’ mere designation of Disclosure or Discovery Material as 15 | CONFIDENTIAL does not— without the submission of competent evidence by 16 || declaration, establishing that the material sought to be filed under seal qualifies as 17 || confidential, privileged, or otherwise protectable—constitute good cause. 18 || Further, if a party requests sealing related to a dispositive motion or trial, then 19 || compelling reasons, not only good cause, for the sealing must be shown, and the 20 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 21 || See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each 22 || item or type of information, document, or thing sought to be filed or introduced under 23 || seal, the party seeking protection must articulate compelling reasons, supported by 24 || specific facts and legal justification, for the requested sealing order. Again, 25 || competent evidence supporting the application to file documents under seal must be 26 || provided by declaration. 27 Any document that is not confidential, privileged, or otherwise protectable in 28 || its entirety will not be filed under seal if the confidential portions can be redacted. If 109274262v1 -3- STIPULATION AND PROTECTIVE ORDER

1 || documents can be redacted, then a redacted version for public viewing, omitting only 2 || the confidential, privileged, or otherwise protectable portions of the document, shall 3 || be filed. Any application that seeks to file documents under seal in their entirety 4 || should include an explanation of why redaction is not feasible. 5 4. DEFINITIONS 6 4.1. Action: Maria Martinez v. Accurate Background, LLC, Case No. 8:20- 7 || cv-00870-DOC-DFM (C.D. Cal.). 8 4.2 Challenging Party: a Party or Non-Party that challenges the designation 9 || of information or items under this Order. 10 4.3. “CONFIDENTIAL” Information or Items: information (regardless of 11 || how itis generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good : 13 || Cause Statement. 14 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 || their support staff). 16 4.5 Designating Party: a Party or Non-Party that designates information or 17 || items that it produces in disclosures or in responses to discovery as 18 || “CONFIDENTIAL.” 19 4.6 Disclosure or Discovery Material: all items or information, regardless 20 || of the medium or manner in which it is generated, stored, or maintained (including, 21 || among other things, testimony, transcripts, and tangible things), that are produced or 22 || generated in disclosures or responses to discovery. 23 4.7 Expert: a person with specialized knowledge or experience in a matter 24 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 || an expert witness or as a consultant in this Action. 26 4.8 House Counsel: attorneys who are employees of a party to this Action. 27 || House Counsel does not include Outside Counsel of Record or any other outside 28 || counsel. 109274262v1 -4- STIPULATION AND PROTECTIVE ORDER

1 4.9 Non-Party: any natural person, partnership, corporation, association or 2 || other legal entity not named as a Party to this action. 3 4.10 Outside Counsel of Record: attorneys who are not employees of a party 4 || to this Action but are retained to represent a party to this Action and have appeared 5 || in this Action on behalf of that party or are affiliated with a law firm that has appeared 6 || on behalf of that party, and includes support staff.’ 7 4.11 Party: any party to this Action, including all of its officers, directors, 8 || employees, consultants, retained experts, and Outside Counsel of Record (and their 9 || support staffs). 10 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 || Discovery Material in this Action. 12 4.13 Professional Vendors: persons or entities that provide litigation support : 13 || services (e.g., photocopying, videotaping, translating, preparing exhibits or : 14 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 || and their employees and subcontractors. 16 4.14 Protected Material: any Disclosure or Discovery Material that is 17 || designated as “CONFIDENTIAL.” 18 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 || from a Producing Party. 20 5. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 || Protected Material (as defined above), but also (1) any information copied or 23 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 || compilations of Protected Material; and (3) any testimony, conversations, or 25 || presentations by Parties or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 || trial judge and other applicable authorities. This Order does not govern the use of 28 || Protected Material at trial. 109274262v1 -5- STIPULATION AND PROTECTIVE ORDER

1 6. DURATION 2 Once a case proceeds to trial, information that was designated as 3 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 || as an exhibit at trial becomes public and will be presumptively available to all 5 || members of the public, including the press, unless compelling reasons supported by 6 || specific factual findings to proceed otherwise are made to the trial judge in advance 7 || of the trial. See Kamakana,

(distinguishing “good cause” g || showing for sealing documents produced in discovery from “compelling reasons” g || standard when merits-related documents are part of court record). Accordingly, the 10 || terms of this protective order do not extend beyond the commencement of the trial. 11 7. DESIGNATING PROTECTED MATERIAL 2 12 7.1 Exercise of Restraint and Care in Designating Material for Protection. 13 || Each Party or Non-Party that designates information or items for protection under 14 || this Order must take care to limit any such designation to specific material that 15 || qualifies under the appropriate standards. The Designating Party must designate for 16 || protection only those parts of material, documents, items or oral or written 17 || communications that qualify so that other portions of the material, documents, items 18 || or communications for which protection is not warranted are not swept unjustifiably 19 || within the ambit of this Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations 91 || that are shown to be clearly unjustified or that have been made for an improper 92 || purpose (e.g., to unnecessarily encumber the case development process or to impose 23 || unnecessary expenses and burdens on other parties) may expose the Designating 34 || Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 96 || designated for protection do not qualify for protection, that Designating Party must 97 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 109274262v1 -6- STIPULATION AND PROTECTIVE ORDER

1 Manner and Timing of Designations. Except as otherwise provided in 2 || this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 3 || that qualifies for protection under this Order must be clearly so designated before the 4 || material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic 7 || documents, but excluding transcripts of depositions or other pretrial or trial 8 || proceedings), that the Producing Party affix at a minimum, the legend 9 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 10 || contains protected material. If only a portion of the material on a page qualifies for 11 || protection, the Producing Party also must clearly identify the protected portion(s) ¢ 12 | (e.g., by making appropriate markings in the margins). : 13 A Party or Non-Party that makes original documents available for inspection : 14 || need not designate them for protection until after the inspecting Party has indicated 15 || which documents it would like copied and produced. During the inspection and 16 || before the designation, all of the material made available for inspection shall be 17 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 18 || 1t wants copied and produced, the Producing Party must determine which documents, 19 || or portions thereof, qualify for protection under this Order. Then, before producing 20 || the specified documents, the Producing Party must affix the “CONFIDENTIAL 21 || legend” to each page that contains Protected Material. If only a portion of the material 22 || on a page qualifies for protection, the Producing Party also must clearly identify the 23 || protected portion(s) (e.g., by making appropriate markings in the margins). 24 (b) for testimony given in depositions, a party may identify portions 25 || of depositions as containing CONFIDENTIAL information after transcription of the 26 || proceedings. A party will have until thirty (30) days after receipt of the finalized 27 || deposition transcript to inform the other party or parties to the action of the portions 28 || of the transcript to be designated as “CONFIDENTIAL,” which period may be 109274262v1 -7- STIPULATION AND PROTECTIVE ORDER

1 || extended by agreement of the parties. Deposition transcripts should be treated as 2 | CONFIDENTIAL in their entirety during the pendency of this thirty (30) day period. 3 (c) for information produced in some form other than documentary 4 || and for any other tangible items, that the Producing Party affix in a prominent place 5 || on the exterior of the container or containers in which the information is stored the 6 || legend “CONFIDENTIAL.” I[f only a portion or portions of the information warrants 7 || protection, the Producing Party, to the extent practicable, shall identify the protected 8 || portion(s). 9 7.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 10 || failure to designate qualified information or items does not, standing alone, waive 11 || the Designating Party’s right to secure protection under this Order for such material. ¢ 12 || Upon timely correction of a designation, the Receiving Party must make reasonable : 13 || efforts to assure that the material 1s treated in accordance with the provisions of this 14 || Order. 15 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 8.1 Timing of Challenges. Any Party or Non-Party may challenge a 17 || designation of confidentiality at any time that is consistent with the Court’s 18 || Scheduling Order. 19 8.2 Meet _and Confer. The Challenging Party shall initiate the dispute 20 || resolution process under Local Rule 37-1 et seq. 21 8.3. Joint Stipulation. Any challenge submitted to the Court shall be via a 22 || joint stipulation pursuant to Local Rule 37-2. 23 8.4 The burden of persuasion in any such challenge proceeding shall be on 24 || the Designating Party. Frivolous challenges, and those made for an improper purpose 25 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 26 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 27 || or withdrawn the confidentiality designation, all parties shall continue to afford the 28 109274262v1 -8- STIPULATION AND PROTECTIVE ORDER

1 || material in question the level of protection to which it is entitled under the Producing 2 || Party’s designation until the Court rules on the challenge. 3 9. ACCESS TO AND USE OF PROTECTED MATERIAL 4 9.1 Basic Principles. A Receiving Party may use Protected Material that is 5 || disclosed or produced by another Party or by a Non-Party in connection with this 6 || Action only for prosecuting, defending or attempting to settle this Action. Such 7 || Protected Material may be disclosed only to the categories of persons and under the 8 || conditions described in this Order. When the Action has been terminated, a Receiving 9 || Party must comply with the provisions of section 15 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 || location and in a secure manner that ensures that access is limited to the persons ¢ 12 || authorized under this Order. : 13 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless : 14 || otherwise ordered by the court or permitted in writing by the Designating Party, a 15 || Receiving Party may disclose any information or item designated 16 || “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, 18 || as well as employees of said Outside Counsel of Record to whom it is reasonably 19 || necessary to disclose the information for this Action; 20 21 22 (b) the officers, directors, and employees (including House Counsel) 23 || of the Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 || disclosure is reasonably necessary for this Action and who have signed the 26 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 (e) court reporters and their staff; 109274262v1 -9- STIPULATION AND PROTECTIVE ORDER

1 || () professional jury or trial consultants, mock jurors, and Professional Vendors to 2 || whom disclosure is reasonably necessary for this Action and who have signed the 3 || “Acknowledgment and Agreement to Be Bound’ (Exhibit = A); 4 (g) the author or recipient of a document containing the information 5 || or a custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, 7 || in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 8 || party requests that the witness sign the form attached as Exhibit A hereto; and 9 || (2) they will not be permitted to keep any confidential information unless they sign 10 || the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 || agreed by the Designating Party or ordered by the court. Pages of transcribed ¢ 12 || deposition testimony or exhibits to depositions that reveal Protected Material may be : 13 || separately bound by the court reporter and may not be disclosed to anyone except as : 14 || permitted under this Stipulated Protective Order; 15 (i) any mediators or settlement officers and their supporting 16 || personnel, mutually agreed upon by any of the parties engaged in settlement 17 || discussions; and 18 (j) Plaintiff. 19 20 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 21 TT 22 If a Party is served with a subpoena or a court order issued in other litigation 23 || that compels disclosure of any information or items designated in this Action as 24 || “CONFIDENTIAL,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification 26 || shall include a copy of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or 28 || order to issue in the other litigation that some or all of the material covered by the 109274262v1 - 10- STIPULATION AND PROTECTIVE ORDER

1 || subpoena or order is subject to this Protective Order. Such notification shall include 2 || acopy of this Stipulated Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be 4 || pursued by the Designating Party whose Protected Material may be affected. If the 5 || Designating Party timely seeks a protective order, the Party served with the subpoena 6 || or court order shall not produce any information designated in this action as 7 || “CONFIDENTIAL” before a determination by the court from which the subpoena or 8 || order issued, unless the Party has obtained the Designating Party’s permission. The 9 || Designating Party shall bear the burden and expense of seeking protection in that 10 || court of its confidential material and nothing in these provisions should be construed 11 || as authorizing or encouraging a Receiving Party in this Action to disobey a lawful ¢ 12 || directive from another court. 13 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE {4 | PRODUCEDIN THIS LITIGATION ©

15 (a) The terms of this Order are applicable to information produced 16 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 17 || information produced by Non-Parties in connection with this litigation is protected 18 || by the remedies and relief provided by this Order. Nothing in these provisions should 19 || be construed as prohibiting a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, 21 || to produce a Non-Party’s confidential information in its possession, and the Party is 22 || subject to an agreement with the Non-Party not to produce the Non-Party’s 23 || confidential information, then the Party shall: 24 (1) promptly notify in writing the Requesting Party and the 25 || Non-Party that some or all of the information requested is subject to a confidentiality 26 || agreement with a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the 28 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a 109274262v1 -ll- STIPULATION AND PROTECTIVE ORDER

] || reasonably specific description of the information requested; and 2 (3) make the information requested available for inspection by 3 || the Non-Party, if requested. 4 (c) If the Non-Party fails to seek a protective order from this court 5 || within 14 days of receiving the notice and accompanying information, the Receiving 6 || Party may produce the Non-Party’s confidential information responsive to the 7 || discovery request. If the Non-Party timely seeks a protective order, the Receiving 8 || Party shall not produce any information in its possession or control that is subject to 9 || the confidentiality agreement with the Non-Party before a determination by the court. 10 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 11 || of seeking protection in this court of its Protected Material. 12 12. UNAUTHORIZED DISCLOSURE OF PROTECTED ne 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 || Protected Material to any person or in any circumstance not authorized under this 16 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 19 || persons to whom unauthorized disclosures were made of all the terms of this Order, 20 || and (d) request such person or persons to execute the “Acknowledgment an 21 || Agreement to Be Bound” attached hereto as Exhibit A. 22 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 23 Te 24 When a Producing Party gives notice to Receiving Parties that certain 25 || inadvertently produced material is subject to a claim of privilege or other protection, 26 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 || may be established in an e-discovery order that provides for production without prior 109274262v1 -12- STIPULATION AND PROTECTIVE ORDER

1 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 || parties reach an agreement on the effect of disclosure of a communication or 3 || information covered by the attorney-client privilege or work product protection, the 4 || parties may incorporate their agreement in the stipulated protective order submitted 5 || to the court. 6 14. MISCELLANEOUS 7 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 || person to seek its modification by the Court in the future. 9 14.2 Right to Assert Other Objections. By stipulating to the entry of this 10 || Protective Order, no Party waives any right it otherwise would have to object to 11 || disclosing or producing any information or item on any ground not addressed in this ¢ 12 || Stipulated Protective Order. Similarly, no Party waives any right to object on any : 13 || ground to use in evidence of any of the material covered by this Protective Order. : 14 14.3. Filing Protected Material. A Party that seeks to file under seal any 15 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may 16 || only be filed under seal pursuant to a court order authorizing the sealing of the 17 || specific Protected Material. If a Party’s request to file Protected Material under seal 18 || 1s denied by the court, then the Receiving Party may file the information in the public 19 || record unless otherwise instructed by the court. 20 15. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 6, within 60 22 || days of a written request by the Designating Party, each Receiving Party must return 23 || all Protected Material to the Producing Party or destroy such material. As used in this 24 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 || summaries, and any other format reproducing or capturing any of the Protected 26 || Material. Whether the Protected Material is returned or destroyed, the Receiving 27 || Party must submit a written certification to the Producing Party (and, if not the same 28 || person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 109274262v1 - 13 - STIPULATION AND PROTECTIVE ORDER

1 || (by category, where appropriate) all the Protected Material that was returned or 2 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 3 || abstracts, compilations, summaries or any other format reproducing or capturing any 4 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 5 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 6 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 7 || reports, attorney work product, and consultant and expert work product, even if such 8 || materials contain Protected Material. Any such archival copies that contain or 9 || constitute Protected Material remain subject to this Protective Order as set forth in 10 || 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 sanctions. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 109274262v1 -14- STIPULATION AND PROTECTIVE ORDER

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 Dated: August 5, 2020 LOKER LAW, APC 3 4 By: /s/ Matthew Loker 5 Matthew Loker Attorneys for Plaintiff 6 MARIA MAGDALENA 5 MARTINEZ 8 || Dated: August , 2020 TROUTMAN PEPPER HAMILTON 9 SANDERS LLP

10 By. eee 11 Ronald I. Raether Attomeys for Plaintiff 12 ACCURATE BACKGROUND, LLC 3 ‘ 14 Signature Certification 15 || Pursuant to Local Rule 5-4.3.4(a)(2), I hereby certify that all other signatories 16 || listed, on whose behalf this filing is submitted, concur with the contents of this 17 || filing and have authorized the filing. 18 /s/ Jessica R. Lohr 19 Jessica R. Lohr 20 21 22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 DATED: August 5, 2020 25 DOUGLAS F. McCORMICK 26 United States Magistrate Judge 27 28 109274262v1 -15- STIPULATION AND PROTECTIVE ORDER

1 EXHIBIT A 2 DECLARATION OF COMPLIANCE 3 Maria Magdalena Martinez v. Accurate Background, LLC. 4 United States District Court, Central District of California Case No. 8:20-cv-00870-DOC-DFM 5 6 I, , declare as follows: 7 1. My address is 8 2. My present employer is 9 3. My present occupation or job description is 10 4 I have received a copy of the Stipulated Protective Order entered in this 1] |} action on , 2020. 2 12 5. I have carefully read and understand the provisions of this Stipulated 13 || Protective Order. 14 6. I will comply with all provisions of this Stipulated Protective Order. 15 7. I will hold in confidence, and will not disclose to anyone not qualified 16 || under the Stipulated Protective Order, any information, documents or other materials 17 || produced subject to this Stipulated Protective Order. 18 8. I will use such information, documents or other materials produced 19 || subject to this Stipulated Protective Order only for purposes of this present action. 20 9. Upon termination of this action, or upon request, I will return and deliver 21 || all information, documents or other materials produced subject to this Stipulated 22 || Protective Order, and all documents or things which I have prepared relating to the 93 || information, documents or other materials that are subject to the Stipulated Protective 24 || Order, to my counsel in this action, or to counsel for the party by whom I am 95 || employed or retained or from whom I received the documents. 26 10. I hereby submit to the jurisdiction of this Court for the purposes of 97 || enforcing the Stipulated Protective Order in this action. 28 109274262v1 - 16 - STIPULATION AND PROTECTIVE ORDER

1 I declare under penalty of perjury under the laws of the United States that the 2 || following is true and correct. 3 Executed this ___— day _—of , 2020 at . 4 5 8 9 10 11 12

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