1 M(adicmaiht tSed. Aprdok ihnasc, Eviscqe. ) 2 THE ADKINS FIRM, P.C 1025 Westhaven Blvd., Suite 220 3 Franklin, Tennessee 37064 T: (615) 370.9659 4 F: (205) 208.9632 E: [email protected] 5 William A. Baird, Esq. 6 (Bar # 192675) Baird Law Firm 7 2625 Townsgate Road, 330 Westlake Village, Ca. 91361 8 (805)-267-1209 Phone [email protected] 9 COUNSEL FOR PLAINTIFF SUSAN TELLEM 10 Steven M. Dailey #163857 11 Rebecca L. Wilson #257613 KUTAK ROCK LLP 12 5 Park Plaza, Suite 1500 Irvine, CA 92614-8595 Telephone: (949) 417-0999 13 Facsimile: (949) 417-5394 Email: [email protected] 14 [email protected] COUNSEL FOR DEFENDANT 15 SELECT PORTFOLIO SERVICING, INC.

16 Jennifer Bergh 17 [email protected] Quilling, Selander, Lownds, 18 Winslett & Moser, P.C. 6900 N. Dallas Parkway, Suite 800 19 Plano, TX 75024 (214) 560-5460 20 (214) 871-2111 Fax COUNSEL FOR DEFENDANT 21 TRANS UNION, LLC

22 UNITED STATES DISTRICT COURT 23 CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 24 25 26 27 28 1 2

3 SUSAN TELLEM, an individual,

4 Plaintiff, Civil Action No. 2:20−cv−01907 AB 5 (RAOx) vs. 6 STIPULATED PROTECTIVE ORDER1 SELECT PORTFOLIO 7 SERVICING, INC. AND TRANS UNION, LLC, 8

9 Defendants.

10 1. A. PURPOSES AND LIMITATIONS 11 12 Discovery in this action is likely to involve production of confidential, 13 proprietary or private information for which special protection from public disclosure 14 and from use for any purpose other than prosecuting this litigation may be warranted. 15 16 Accordingly, the parties hereby stipulate to and petition the Court to enter the 17 following Stipulated Protective Order. The parties acknowledge that this Order does 18 not confer blanket protections on all disclosures or responses to discovery and that 19 20 the protection it affords from public disclosure and use extends only to the limited 21 information or items that are entitled to confidential treatment under the applicable 22 legal principles. 23 24 B. GOOD CAUSE STATEMENT 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided 28 under Magistrate Judge Rozella A. Oliver’s Procedures. 1 This action is likely to involve trade secrets, financial, technical and/or 2 proprietary information for which special protection from public disclosure and from 3 use for any purpose other than prosecution of this action is warranted. Such 4 5 confidential and proprietary materials and information consist of, among other 6 things, Plaintiff’s confidential financial and credit report information, confidential 7 8 business or financial information, information regarding confidential business 9 practices, or other confidential research, development, or commercial information 10 (including information implicating privacy rights of third parties), information 11 12 otherwise generally unavailable to the public, or which may be privileged or 13 otherwise generally unavailable to the public, or which may be privileged or 14 otherwise protected from disclosure under state or federal statutes, court rules, case 15 16 decisions, or common law. Accordingly, to expedite the flow of information, to 17 facilitate the prompt resolution of disputes over confidentiality or discovery 18 materials, to adequately protect information the parties are entitled to keep 19 20 confidential, to ensure that the parties are permitted reasonable necessary uses of such 21 material in preparation for and in the conduct of trial, to address their handling at the 22 end of the litigation, and serve the ends of justice, a protective order for such 23 24 information is justified in this matter. It is the intent of the parties that information 25 will not be designated as confidential for tactical reasons and that nothing be so 26 designated without a good faith belief that it has been maintained in a confidential, 27 28 1 non-public manner, and there is good cause why it should not be part of the public 2 record of this case. 3 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 4 5 The parties further acknowledge, as set forth in Section 12.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information 7 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 9 the standards that will be applied when a party seeks permission from the court to 10 file material under seal. 11 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive motions, 14 good cause must be shown to support a filing under seal. See Kamakana v. City and 15 16 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 17 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electronics, 18 Inc., 187 F.R.D. 576m 577 (E.D. Wis. 1999) (even stipulated protective orders 19 20 require good cause showing), and a specific showing of good cause or compelling 21 reasons with proper evidentiary support and legal justification, must be made with 22 respect to Protected Material that party seeks to file under seal. The parties’ mere 23 24 designation of Disclosure or Discovery Material as CONFIDENTIAL does not – 25 without the submission of competent evidence by declaration, establishing that the 26 material sought to be filed under seal qualifies as confidential, privileged, or 27 28 otherwise protectable – constitutes good cause. 1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the 3 relief sought shall be narrowly tailored to serve the specific interest to be protected. 4 5 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 6 item or type of information, document, or thing sought to be filed or introduced under 7 8 seal in connection with a dispositive motion or trial, the party seeking protection must 9 articulate compelling reasons, supported by specific facts and legal justification, for 10 the requested sealing order. Again, competent evidence supporting the application to 11 12 file documents under seal must be provided by declaration. 13 Any document that is not confidential, privileged, or otherwise protectable in 14 its entirety will not be filed under seal if the confidential portions can be redacted. If 15 16 documents can be redacted, than a redacted version for public viewing, omitting only 17 the confidential, privileged, or otherwise protectable portions of the document, shall 18 be filed. Any application that seeks to file documents under seal in their entirety 19 20 should include an explanation of why redaction is not feasible. 21 2. DEFINITIONS 22 2.1 Action: Susan Tellem v. Select Portfolio Serving Inc. and Trans Union, 23 24 LLC. 25 2.2 Challenging Party: a Party or Non-Party that challenges the designation 26 of information or items under this Order. 27 28 1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 2 how it is generated, stored or maintained) or tangible things that qualify for protection 3 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 4 5 Cause Statement. 6 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 7 8 their support staff). 9 2.5 Designating Party: a Party or Non-Party that designates information or 10 items that it produces in disclosures or in responses to discovery as 11 12 “CONFIDENTIAL.” 13 2.6 Disclosure or Discovery Material: all items or information, regardless 14 of the medium or manner in which it is generated, stored, or maintained (including, 15 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys or paralegals who are employees of a party to 23 24 this Action or contract counsel or contract paralegals. House Counsel does not 25 include Outside Counsel of Record or any other outside counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association or 27 28 other legal entity not named as a Party to this action. 1 2.10 Outside Counsel or Record: attorneys who are not employees of a party 2 to this Action but are retained to represent or advise a party to this Action and have 3 appeared in this Action on behalf of that party or are affiliated with a law firm that 4 5 has appeared on behalf of that party, and includes support staff. 6 2.11 Party: any party to this Action, including all of its officers, directors, 7 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 12 Discovery Material in this Action. 13 2.13 Professional Vendors: persons or entities that provide litigation support 14 services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 16 demonstrations, and organizing, storing, or retrieving data in any form or medium) 17 and their employees and subcontractors. 18 2.14 Protected Material: any Disclosure or Discovery Material that is 19 20 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 5 trial judge. This Order does not govern the use of Protected Material at trial. 6 4. DURATION 7 8 Once a case proceeds to trial, information that was designated as 9 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 10 as an exhibit at trial becomes public and will be presumptively available to all 11 12 members of the public, including the press, unless compelling reasons supported by 13 specific factual findings to proceed otherwise are made to the trial judge in advance 14 of the trial. See Kamakana,

(distinguishing “good cause” 15 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record). Accordingly, the 18 terms of this protective order do not extend beyond the commencement of the trial. 19 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under 23 24 this Order must take care to limit any such designation to specific material that 25 qualifies under the appropriate standards. The Designating Party must designate for 26 protection only those parts of material, documents, items or oral or written 27 28 communications that qualify so that other portions of the material, documents, items 1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. Designations 4 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to impose 7 8 unnecessary expenses and burdens on other parties) may expose the Designating 9 Party to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 12 designated for protection do not qualify for protection, that Designating Party must 13 promptly notify all other Parties that it is withdrawing the inapplicable designation. 14 5.2 Manner and Timing of Designations. Except as otherwise provided in 15 16 this Order (see, e.g., second paragraph of section 5.2(a) 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 20 produced. 21 Designation in conformity with this Order requires: 22 (a) for information in documentary form (e.g., paper or electronic 23 24 documents, but excluding transcripts or depositions or other pretrial or trial 25 proceedings), that the Producing Party affix at a minimum, the legend 26 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”). To each page that 27 28 contains protected material. If only a portion of the material on a page qualifies for 1 protection, the Producing Party also must clearly identify the protected portion(s) 2 (e.g., by making appropriate markings in the margins). 3 A party or Non-Party that makes original documents available for inspection 4 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 8 before the designation, all of the material made available for inspection shall be 9 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 10 it wants copied and produced, the Producing Party must determine which documents, 11 12 or portions thereof, qualify for protection under this Order. Then, before producing 13 the specified documents, the Producing Party must affix the “CONFIDENTIAL 14 legend” to each page that contains Protected Material. If only a portion of the material 15 16 on a page qualifies for protection, the Producing Party also must clearly identify the 17 protected portion(s) (e.g., by making appropriate markings in the margins). 18 (b) for testimony given in depositions that the Designating Party 19 20 identifies the Disclosure or Discovery Material on the record, before the close of the 21 deposition all protected testimony. 22 (c) for information produced in some form other than documentary 23 24 and for any other tangible items, that the Producing Party affix in a prominent place 25 on the exterior of the container or containers in which the information is stored the 26 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 28 1 protection, the Producing Party, to the extent practicable, shall identify the protected 2 portion(s). 3 5.3 Inadvertent Failures to Designate: If timely corrected, an inadvertent 4 5 failure to designate qualified information or items does not, standing alone, waive 6 the Designating Party’s right to secure protection under this Order for such material. 7 8 Upon timely correction of a designation, the Receiving Party must make reasonable 9 efforts to assure that the material is treated in accordance with the provisions of this 10 Order. 11 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 16 Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37.1 et seq. 19 20 6.3 The burden of persuasion in any such challenge proceeding shall be on 21 the Designating Party. Frivolous challenges, and those made for an improper purpose 22 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 23 24 expose the Challenging Party to sanctions. Unless the Designating Party has waived 25 or withdrawn the confidentiality designation, all parties shall continue to afford the 26 material in question the level of protection to which it is entitled under the Producing 27 28 Party’s designation until the Court rules on the challenge. 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 5 Action only for prosecuting, defending or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 8 conditions described in this Order. When the Action has been terminated, a Receiving 9 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 12 location and in a secure manner that ensures that access is limited to the persons 13 authorized under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 15 16 otherwise ordered by the court or permitted in writing by the Designating Party, a 17 Receiving Party may disclose any information or item designated 18 “CONFIDENTIAL” only to: 19 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, 21 as well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 24 (b) the officers, directors, and employees (including House Counsel) 25 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 26 27 28 1 (c) experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 5 (d) the court and its personnel; 6 (e) court reporters and their staff; 7 8 (f) professional jury or trial consultants, mock jurors, and 9 Professional Vendors to whom disclosure is reasonably necessary for this Action and 10 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 12 (g) the author or recipient of a document containing the information 13 or a custodian or other person who otherwise possessed or knew the information; 14 (h) during their depositions, witnesses, and attorneys for witnesses, 15 16 in the Action to whom disclosure is reasonably necessary to provided: (1) the 17 deposing party requests that the witness sign the form attached as Exhibit 1 hereto; 18 and (2) they will not be permitted to keep any confidential information unless they 19 20 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 21 otherwise agreed by the Designating Party or ordered by the court. Pages of 22 transcribed deposition testimony or exhibits to depositions that reveal Protected 23 24 Material may be separately bound by the court reporter and may not be disclosed to 25 anyone except as permitted under this Stipulated Protective Order; and 26 27 28 1 (i) any mediator or settlement officer, and their supporting 2 personnel, mutually agreed upon by any of the parties engaged in settlement 3 discussions. 4 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 6 IN OTHER LITIGATION 7 8 If a Party is served with a subpoena or a court order issued in other litigation 9 that compels disclosure of any information or items designated in this Action as 10 “CONFIDENTIAL,” that Party must: 11 12 (a) promptly notify in writing the Designating Party. Such 13 notification shall include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or 15 16 order to issue in the other litigation that some or all of the material covered by the 17 subpoena or order is subject to this Protective Order. Such notification shall include 18 a copy of this Stipulated Protective Order; and 19 20 (c) cooperate with respect to all reasonable procedures sought to be 21 pursued by the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with 23 24 the subpoena or court order shall not produce any information designated in this 25 action as “CONFIDENTIAL” before a determination by the court from which the 26 subpoena or order issued, unless the Party has obtained the Designating Party’s 27 28 permission. The Designating Party shall bear the burden and expense of seeking 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED IN THIS LITIGATION 7 8 (a) The terms of this Order are applicable to information produced 9 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 10 information produced by Non-Parties in connection with this litigation is protected 11 12 by the remedies and relief provided by this Order. Nothing in these provisions should 13 be construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, 15 16 to produce a Non-Party’s confidential information in its possession, and the Party is 17 subject to an agreement with the Non-Party not to produce the Non-Party’s 18 confidential information, then the Party shall: 19 20 (1) promptly notify in writing the Requesting Party and the 21 Non-Party that some or all of the information requested is subject to a confidentiality 22 agreement with a Non-Party; 23 24 (2) promptly provide the Non-Party with a copy of the 25 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 26 reasonably specific description of the information requested; and 27 28 1 (3) make the information requested available for inspection by 2 the Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court 4 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 8 discovery request. If the Non-Party timely seeks a protective order, the Receiving 9 Party shall not produce any information in its possession or control that is subject to 10 the confidentiality agreement with Non-Party before a determination by the court. 11 12 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 13 of seeking protection in this court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 20 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 21 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 22 persons to whom unauthorized disclosures were mode of all the terms of this Order, 23 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. 26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 27 28 PROTECTED MATERIAL 1 When a Producing Party gives notice to Receiving Parties that certain 2 inadvertently produced material is subject to a claim of privilege or other protection, 3 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 4 5 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 6 may be established in an e-discovery order that provides for production without prior 7 8 privilege review Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 12 parties may incorporate their agreement in the stipulated protective order submitted 13 to the court. 14 12. MISCELLANEOUS 15 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 20 Protective Order, no Party waives any right it otherwise would have to object to 21 disclosing or producing any information or item on any ground not addressed in this 22 Stipulated Protective Order. Similarly, no Party waives any right to object on any 23 24 ground to use in evidence of any of the material covered by this Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 27 28 only be filed under seal pursuant to a court order authorizing the sealing of the 1 specific Protected Material at issue. If a Party’s request to file Protected Material 2 under seal is denied by the court, then the Receiving Party may file the information 3 in the public record unless otherwise instructed by the court. 4 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 60 7 8 days of written request by the Designating Party, each Receiving Party must return 9 all Protected Material to the Producing Party or destroy such material. As used in this 10 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving 14 Party must submit a written certification to the Producing Party (and, if not the same 15 16 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 17 (by category, where appropriate) all the Protected Material that was returned or 18 destroyed and (2) affirms that the Receiving Party has not retained any copies, 19 20 abstracts, compilations, summaries or any other format reproducing or capturing any 21 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 22 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 25 reports, attorney work product, and consultant and expert work product, even if such 26 materials contain Protected Material. Any such archival copies that contain or 27 28 ! | constitute Protected Material remain subject to this Protective Order as set forth in 2 Section 4 (DURATION). 3 4 | 14. VIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 including, without limitation, contempt proceedings and/or monetary sanctions. 7 g | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 DATED: August 12,2020. /s/ Micah_S. Adkins 10 Micah S. Adkins THE ADKINS FIRM, P.C. 11 1025 Westhaven Blvd., Suite 220 Franklin, Tennessee 37064 12 William A. Baird, Esq. (SBN 192675) 13 BAIRD LAW FIRM 2625 Townsgate Road, Suite 330 14 Westlake Vi age, CA 91361 COUNSEL FOR PLAINTIFF SUSAN TELLEM 15 DATED: August 12,2020 = /s/ Steven M. Dailey Qe consent) 16 teven M. Dailey Rebecca L. Wilson #257613 17 KUTAK ROCK LLP 5 Park Plaza, Suite 1500 Irvine, CA 92614-8595 18 Telephone: (949) 417-0999 COUNSEL FOR SELECT PORTFOLIO 19 SERVICING, INC. 20 | DATED: _ August 12,2020 = /s/ Jennifer Bergh (with consent) ennifer org 21 Quilling, Selander, Lownds, Winslett & Moser, P.C. 22 6900 N. Dallas Parkway, Suite 800 Plano, TX 75024 23 COUNSEL FOR TRANS UNION, LLC 24 | DATED: _ August 13, 2020 2 ° “Rapedea Qj, Ce. 26 pe HON. ROZELLA A. OLIVER 27 United States Magistrate Judge 28 -19-

1 EXHIB IT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 4 I, ______________________________ [print of type full name], of 5 _______________________ [print of type full address], declare under penalty of 6 perjury that I have read in its entirety and understand the Stipulated Protective 7 8 Order that was issued by the United States District Court for the Central District of 9 California on February 27, 2020 in the case of Susan Tellem v. Select Portfolio 10 Servicing, Inc. and Trans Union, LLC Case No. 2:20-cv-1907-AB-RAO. I agree to 11 12 comply with and to be bound by all the terms of this Stipulated Protective Order 13 and I understand and acknowledge that failure to so comply could expose me to 14 sanctions and punishment in the nature of contempt. I solemnly promise that I will 15 16 not disclose in any manner any information or item that is subject to this Stipulated 17 Protective Order to any person or entity except in strict compliance with the 18 provisions of this Order. I further agree to submit to the jurisdiction of the United 19 20 States District Court for the Central District of California for enforcing the terms of 21 this Stipulated Protective Order, even if such enforcement proceedings occur after 22 termination of this action. I hereby appoint ______________________________ 23 24 [print or type full name] of 25 __________________________________________________ [print or type full 26 address and telephone number] as my California agent for service of process in 27 28 1 connection with this action or any proceedings related to enforcement of this 2 Stipulated Protective Order. 3 Date: ___________________________ 4 5 City and State where sworn and signed: 6 _____________________________________________ 7 8 9 Printed named: ___________________________________ 10 Signature: _______________________________________ 11

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