1 || KATHLEEN STRICKLAND (SBN 64816) STEPHAN CHOO (SBN 284395) 2 || ROPERS MAJESKI PC 150 Spear Street, Suite 850 3 || San Francisco, CA 94105 Telephone: 415.543.4800 4 || Facsimile: 415.972.6301 Email: [email protected] 5 [email protected] 6 || Attorneys for Defendant 7 WAL-MART STORES, INC.

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 5 10 11 || DARNELL HENLEY, Case No. 2:20-cv-02902 GW (ASx) 12 Plaintiff, STIPULATED PROTECTIVE ORDER 13 Vv. || WAL-MART STORES, INC.; DOES 1 judge: Hon. George H. Wu to 20, Trial Date: October 13, 2020 15 Defendants. 19) 16

17] 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 19 || proprietary, or private information for which special protection from public 20 || disclosure and from use for any purpose other than prosecuting this litigation 21 || may be warranted. Accordingly, the parties hereby stipulate to and petition the 22 || Court to enter the following Stipulated Protective Order. The parties 23 || acknowledge that this Order does not confer blanket protections on all disclosures 24 || or responses to discovery and that the protection it affords from public disclosure 25 || and use extends only to the limited information or items that are entitled to 26 || confidential treatment under the applicable legal principles. The parties further 27 || acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 28 || Order does not entitle them to file confidential information under seal; Civil Local 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

1 || Rule 79-5 sets forth the procedures that must be followed and the standards that 2 || will be applied when a party seeks permission from the court to file material under 3 || seal. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets, customer and pricing lists 6 || and other valuable research, development, commercial, financial, technical and/or 7 || proprietary information for which special protection from public disclosure and 8 || from use for any purpose other than prosecution of this action is warranted. Such 9 || confidential and proprietary materials and information consist of, among other 10 || things, confidential business or financial information, information regarding 8 11 || confidential business practices, or other confidential research, development, or 12 || commercial information (including information implicating privacy rights of 13 || third parties), information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal 15 || statutes, court rules, case decisions, or common law. Accordingly, to expedite the 16 || flow of information, to facilitate the prompt resolution of disputes over 17 || confidentiality of discovery materials, to adequately protect information the parties || are entitled tokeep confidential, to ensure that the parties are permitted 19 || reasonable necessary uses of such material in preparation for and in the conduct of 20 || trial, to address their handling at the end of the litigation, and serve the ends of 21 || justice, a protective order for such information is justified in this matter. It is the 22 || intent of the parties that information will not be designated as confidential for 23 || tactical reasons and that nothing be so designated without a good faith belief that 24 || it has been maintained in a confidential, non-public manner, and there is good 25 || cause why it should not be part of the public record of this case. 26 || 2. DEFINITIONS 27 2.1 Action: This pending federal law suit identified with its caption and 28 || case number. 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

1 2.2 Challenging Party: a Party or Non-Party that challenges the 2 || designation of information or items under this Order. 3 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 4 || how it is generated, stored or maintained) or tangible things that qualify for 5 || protection under Federal Rule of Civil Procedure 26(c), and as specified above 6 || in the Good Cause Statement. 7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 8 || their support staff). 9 2.5 Designating Party: a Party or Non-Party that designates information 10 || or items that it produces in disclosures or in responses to discovery as 2 11 | “CONFIDENTIAL.” 12 2.6 Disclosure or Discovery Material: all items or information, regardless ° 13 || of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced 15 || or generated in disclosures or responses to discovery in this matter. 16 2.7 Expert: a person with specialized knowledge or experience in a matter 17 | pertinent to the litigation who has been retained by a Party or its counsel to serve as || an expert witness or as a consultant in this Action. 19 2.8 House Counsel: attorneys who are employees of a party to this 20 || Action. House Counsel does not include Outside Counsel of Record or any 21 || other outside counsel. 22 2.9 Non-Party: any natural person, partnership, corporation, association, 23 || or other legal entity not named as a Party to this action. 24 2.10 Outside Counsel of Record: attorneys who are not employees ofa 25 || party to this Action but are retained to represent or advise a party to this Action and 26 || have appeared in this Action on behalf of that party or are affiliated with a law firm 27 || which has appeared on behalf of that party, and includes support staff. This also 28 || encompasses counsel that act as consultants for an attorney or law firm. 4832-4842-5670.2 5 STIPULATED PROTECTIVE ORDER

1 2.11 Party: any party to this Action, including all of its officers, directors, 2 || employees, consultants, retained experts, and Outside Counsel of Record (and their 3 || support staffs). 4 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 5 || Discovery Material in this Action. 6 2.13 Professional Vendors: persons or entities that provide litigation 7 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 9 || and their employees and subcontractors. 10 2.14 Protected Material: any Disclosure or Discovery Material that is 8 11 || designated as “CONFIDENTIAL.” All pages impacted by this designation must be 12 || marked with this designation in clear language so this designation is as conspicuous 13 || as possible. 2.15 Receiving Party: a Party that receives Disclosure or Discovery 15 || Material from a Producing Party. m 16/3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only || Protected Material (as defined above), but also (1) any information copied or 19 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 20 || compilations of Protected Material; and (3) any testimony, conversations, or 21 || presentations by Parties or their Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of 23 || the trial judge. This Order does not govern the use of Protected Material at trial. 24 | 4. DURATION 25 Once a case proceeds to trial, all of the information that was designated as 26 || confidential or maintained pursuant to this protective order becomes public and will 27 || be presumptively available to all members of the public, including the press, 28 || unless compelling reasons supported by specific factual findings to proceed 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

| || otherwise are made to the trial judge in advance of the trial. See Kamakana v. 2 || City and County of Honolulu,

(9th Cir. 2006) 3 || (distinguishing “good cause” showing for sealing documents produced in discovery 4 || from “compelling reasons” standard when merits-related documents are part of 5 || court record). Accordingly, the terms of this protective order do not extend beyond 6 || the commencement of the trial. 7 Even after final disposition of this litigation, the confidentiality obligations 8 || imposed by this Order shall remain in effect until a Designating Party agrees 9 || otherwise in writing or a court order otherwise directs. Final disposition shall be 10 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, 8 11 || with or without prejudice; and (2) final judgment herein after the completion and 12 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 || including the time limits for filing any motions or applications for extension of time pursuant to applicable law. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 || Each Party or Non-Party that designates information or items for protection || under this Order must take care to limit any such designation to specific material 19 || that qualifies under the appropriate standards. The Designating Party must 20 || designate for protection only those parts of material, documents, items, or oral or 21 || written communications that qualify so that other portions of the material, 22 || documents, items, or communications for which protection is not warranted are not 23 || swept unjustifiably within the ambit of this Order. 24 Mass, indiscriminate, or routinized designations are prohibited. Designations 25 || that are shown to be clearly unjustified or that have been made for an 26 || improper purpose (e.g., to unnecessarily encumber the case development process or 27 || to impose unnecessary expenses and burdens on other parties) may expose the 28 || Designating Party to sanctions. 4832-4842-5670.2 - STIPULATED PROTECTIVE ORDER

1 If it comes to a Designating Party’s attention that information or items that it 2 || designated for protection do not qualify for protection, that Designating Party must 3 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2. Manner and Timing of Designations. Except as otherwise provided in 5 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as 6 || otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 7 || protection under this Order must be clearly so designated before the material is 8 || disclosed or produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 8 11 || documents, but excluding transcripts of depositions or other pretrial or trial 12 || proceedings), that the Producing Partyaffix at a minimum, the legend 13 |) “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that || contains protected material. If only a portion or portions of the material on a 15 || page qualifies for protection, the Producing Party also must clearly identify the 16 || protected portion(s) (e.g., by making appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection || need not designate them for protection until after the inspecting Party has indicated 19 || which documents it would like copied and produced. During the inspection 20 || and before the designation, all of the material made available for inspection 21 || shall be deemed “CONFIDENTIAL.” Afterthe inspecting Party has identified the 22 || documents it wants copied and produced, the Producing Party must determine 23 || which documents, or portions thereof, qualify for protection under this Order. 24 || Then, before producing the specified documents, the Producing Party must affix the 25 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 26 || portion or portions of the material on a page qualifies for protection, the Producing 27 || Party also must clearly identify the protected portion(s) (e.g., by making 28 || appropriate markings in the margins). 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

1 (b) for testimony given in depositions that the Designating Party 2 || identify the Disclosure or Discovery Material on the record, before the close of the 3 || deposition all protected testimony. 4 (c) for information produced in some form other than documentary 5 || and for any other tangible items, that the Producing Party affix in a prominent place 6 || on the exterior of the container or containers in which the information is stored 7 || the legend “CONFIDENTIAL.” If only a portion or portions of the information 8 || warrants protection, the Producing Party, to the extent practicable, shall identify the 9 || protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 11 }| failure to designate qualified information or items does not, standing alone, 12 || waive the Designating Party’s right to secure protection under this Order for such 13 || material. Upon timely correction of a designation, the Receiving Party must make |] reasonable efforts to assure that the material is treated in accordance with the 15 || provisions of this Order. 16 |] 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a || designation of confidentiality at any time that is consistent with the Court’s 19 || Scheduling Order. 20 6.2 Meet_and Confer. The Challenging Party shall initiate the dispute 21 || resolution process under Local Rule 37.1 et seq. 22 6.3. The burden of persuasion in any such challenge proceeding shall be 23 || on the Designating Party. Frivolous challenges, and those made for an improper 24 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 25 || parties) may expose the Challenging Party to sanctions. Unless the 26 || Designating Party has waived or withdrawn the confidentiality designation, all 27 || parties shall continue to afford the material in question the level of protection to 28 || which it is entitled under the Producing Party’s designation until the Court rules on 4832-4842-5670.2 a STIPULATED PROTECTIVE ORDER

1 || the challenge 2 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 7.1 Basic Principles. A Receiving Party may use Protected Material that 4 || is disclosed or produced by another Party or by a Non-Party in connection with 5 || this Action only for prosecuting, defending, or attempting to settle this Action. 6 || Such Protected Material may be disclosed only to the categories of persons and 7 || under the conditions described in this Order. When the Action has been terminated, 8 || a Receiving Party must comply with the provisions of section 13 below (FINAL 9 || DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at 8 11 || a location and in a secure manner that ensures that access is limited to the persons 12 || authorized under this Order. 13 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless |} otherwise ordered by the court or permitted in writing by the Designating Party, 15 || a Receiving Party may disclose any information or item designated M4 || “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this 618 || Action, as well as employees of said Outside Counsel of Record to whom it is 19 || reasonably necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) 21 || of the Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to 23 || whom disclosure is reasonably necessary for this Action and who have signed the 24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and 28 || Professional Vendors to whom disclosure is reasonably necessary for this Action 4832-4842-5670.2 6 STIPULATED PROTECTIVE ORDER

1 || and who have signed the “Acknowledgment and Agreement to Be Bound” 2 || (Exhibit A); 3 (g) the author or recipient of a document containing the information 4 || or a custodian or other person who otherwise possessed or knew the information; 5 (h) during their depositions, witnesses ,and attorneys for witnesses, in 6 || the Action to whom disclosure is reasonably necessary provided: (1) the deposing 7 || party requests that the witness sign the form attached as Exhibit 1 hereto; and 8 || (2) they will not be permitted to keep any confidential information unless they sign 9 || the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 10 || agreed by the Designating Party or ordered by the court. Pages of transcribed 8 11 || deposition testimony or exhibits to depositions that reveal Protected Material 12 || may be separately bound by the court reporter and may not be disclosed to anyone 13 || except as permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting 15 || personnel, mutually agreed upon by any of the parties engaged in settlement 16 || discussions. 17] 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED || INOTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 || that compels disclosure of any information or items designated in this Action 21 || as “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such 23 || notification shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or 25 || order to issue in the other litigation that some or all of the material covered by the 26 || subpoena or order is subject to this Protective Order. Such notification shall 27 || include a copy of this Stipulated Protective Order; and 28 (c) cooperate with respect to all reasonable procedures sought to be 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

1 || pursued by the Designating Party whose Protected Material may be affected. 2 If the Designating Party timely seeks a protective order, the Party served 3 || with the subpoena or court order shall not produce any information designated in 4 || this action as “CONFIDENTIAL” before a determination by the court from 5 || which the subpoena or order issued, unless the Party has obtained the 6 || Designating Party’s permission. The Designating Party shall bear the burden 7 || and expense of seeking protection in that court of its confidential material and 8 || nothing in these provisions should be construed as authorizing or encouraging a 9 || Receiving Party in this Action to disobey a lawful directive from another court. 10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 11 | PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 |} Non-Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the 15 || remedies and relief provided by this Order. Nothing in these provisions should 16 || be construed as prohibiting a Non-Party from seeking additional protections. 17 (b) Inthe event that a Party is required, by a valid discovery request, to || produce a Non-Party’s confidential information in its possession, and the Party is 19 || subject to an agreement with the Non-Party not to produce the Non-Party’s 20 || confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non- 22 || Party that some or all of the information requested is subject to a confidentiality 23 || agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 || specific description of the information requested; and 27 (3) make the information requested available for inspection by the 28 || Non-Party, if requested. 4832-4842-5670.2 TA STIPULATED PROTECTIVE ORDER

1 (c) Ifthe Non-Party fails to seek a protective order from this court within 2 || 14 days of receiving the notice and accompanying information, the Receiving Party 3 || may produce the Non-Party’s confidential information responsive to the discovery 4 || request. If the Non-Party timely seeks a protective order, the Receiving Party 5 || shall not produce any information in its possession or control that is subject to the 6 || confidentiality agreement with the Non-Party before a determination by the 7 || court. Absent a court order to the contrary, the Non-Party shall bear the burden and 8 || expense of seeking protection in this court of its Protected Material. 9} 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has 8 11 || disclosed Protected Material to any person or in any circumstance not authorized 12 || under this Stipulated Protective Order, the Receiving Party must immediately (a) 13 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its |] best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 15 || the person or persons to whom unauthorized disclosures were made of all the terms 16 || of this Order, and (d) request such person or persons to execute the Ey 17 | “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit m8 | A. 19} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 | PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 || inadvertently produced material is subject to a claim of privilege or other 23 || protection, the obligations of the Receiving Parties are those set forth in Federal 24 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 25 || whatever procedure may be established in an e-discovery order that provides for 26 || production without prior privilege review. Pursuant to Federal Rule of Evidence 27 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 28 || of a communication or information covered by the attorney-client privilege or work 4832-4842-5670.2 14 STIPULATED PROTECTIVE ORDER

1 || product protection, the parties may incorporate their agreement in the stipulated 2 || protective order submitted to the court. 3} 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of 5 || any 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 7 || this Protective Order no Party waives any right it otherwise would have to 8 || object to disclosing or producing any information or item on any ground not 9 || addressed in this Stipulated Protective Order. Similarly, no Party waives any 10 || right to object on any ground to use in evidence of any of the material covered by 8 11 || this Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the 15 || specific Protected Material at issue. If a Party’s request to file Protected Material 16 || under seal (via protective order motion or otherwise) is denied by the court, then the 17 || Receiving Party may file the information in the public record unless otherwise 618 || instructed by the court. 19 Defendant currently asserts that much of their document production from 20 || their Custodian of Records/employees/agents/contractors is/are sensitive and 21 || protected materials for one reason or another. The parties have met and conferred 22 || on this issue. It is understood that Plaintiff does not wish to bear the burden and 23 || expense of moving the court to seal documents that defendant designated as 24 || Protected Material. 25 The parties agree that plaintiff should provide a reasonable five (5) day 26 || notice to defendant, of the need to use, reference and file with the court, certain 27 || Protected Material when filing court documents. It is agreed to by the parties, that 28 || plaintiff may file motion papers or other court filings, including motion opposition 4832-4842-5670.2 1A STIPULATED PROTECTIVE ORDER

1 || papers, that reference the Protected Material by its stamped Bates Numbers with 2 || pre-fix “DEF_”. 3 The burden is then on defendant to move the court to seal the specific pages 4 || of the Protected Material, whether an exhibit or otherwise. Defendant must move 5 || the court within five (5) business days to seek an order to seal the Protected 6 || Material. If and when the court order permitting the filing of the Protected Material 7 || “under seal” is issued to moving party defendant, defendant shall, no later than 72 8 || hours, file the unredacted and complete identified sensitive material or document at 9 || issue with the court under seal. 10 The intent and goal is to not reduce plaintiff's time permitted to file or 8 11 || oppose motions or engage in other court filings that use and reference protected 12 || materials. The intent and goal is for plaintiff to file as complete papers as possible, 13 || which may include references to defendant’s protected material, and provide and instigate defendant to take steps to obtain an order to obtain an order that permits 15 || sealing, and then defendant immediately file the referenced protected materials 16 || under seal or not file them under seal, so the court may then review the alleged 17 || sensitive protected materials at issue, alongside plaintiffs filed papers. 18 This same procedure may also work in reverse as to the two parties in this 19 || case. However, plaintiff does not foresee any claim or need to assert the existence 20 || of protected materials, at this point in time. 21 |} 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 12 23 || months after the final disposition of the case, by way of a written request by the 24 || Designating Party, each Receiving Party must return all Protected Material to the 25 || Producing Party or destroy such material. Plaintiff shall have up to 12 months to 26 || destroy such materials from the date of request. As used in this subdivision, “all 27 || Protected Material” includes all copies, abstracts, compilations, summaries, and any 28 || other format reproducing or capturing any of the Protected Material. 4832-4842-5670.2 14 STIPULATED PROTECTIVE ORDER

1 Notwithstanding this provision, Counsel are entitled to retain an archival 2 || copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 3 || memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 4 | work product, and consultant and expert work product, even if such materials 5 || contain Protected Material. Any such archival copies that contain or constitute 6 || Protected Material remain subject to this Protective Order as set forth in Section 4 7 || and shall continue for as long as counsel preserve their files in due course at their 8 || law firm. 9 || 14. Any violation of this Order may be punished by any and all appropriate 10 || measures including, without limitation, contempt proceedings and/or monetary 8 11 || sanctions. 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: LAW OFFICES OF 14 GENE J. GOLDSMAN 15 16 By: _/s/ Evan A. Blair EVAN A. BLAIR GENE J. GOLDSMAN Attorneys for Plaintiff DARNELL HENLEY 19 20 > Dated: ROPERS MAJESKI PC

22 By: /s/ Stephan Choo 23 KATHLEEN N. STRICKLAND STEPHAN CHOO 24 Attorneys for Defendant WAL-MART STORES, INC. 26 27 28 4832-4842-5670.2 4 STIPULATED PROTECTIVE ORDER

l ATTESTATION

In compliance with Local Rule 5-1, the filing attorney attests that he has ; obtained concurrence regarding the filing and contents of this document with the other signatories thereto. 7 8 9 10 ul

16 17 (18 19 20 21 22 23 24 25 26 27 28 4832-4842-5670.2 STIPULATED PROTECTIVE ORDER

1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 , | DATED: 8/10/20 /S/ CHARLES F. EICK CHARLES F. EICK U.S. MAGISTRATE JUDGE 6 7 8 9 10 ul

16

(18 19 20 21 22 23 24 25 26 27 28 4832-4842-5670.2 1; STIPULATED PROTECTIVE ORDER

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of 5 || perjury that I have read in its entirety and understand the Stipulated Protective 6 || Order that was issued by the United States District Court for the Central District of 7 || California on , 2020, in the case of Darnell Henley v. Wal-Mart 8 || Stores, Inc., Case No. 2:20-cv-02902 GW (ASx). I agree to comply with and to be 9 || bound by all the terms of this Stipulated Protective Order and I understand 10 || and acknowledge that failure to so comply could expose me to sanctions and 8 11 || punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 || any manner any information or item that is subject to this Stipulated Protective 13 || Order to any person or entity except in strict compliance with the provisions of this |] Order. I further agree to submit to the jurisdiction of the United States District 15 || Court for the Central District of California for the purpose of enforcing the terms of 16 || this Stipulated Protective Order, even if such enforcement proceedings occur after 17 | termination of this action. I hereby appoint [print or 618 || type full name] of [print or type full address and 19 || telephone number] as my California agent for service of process in connection with 20 || this action or any proceedings related to enforcement of this Stipulated Protective 21 || Order. 22 || Date: 23 || City and State where sworn and signed: 24 || Printed name: 25 || Signature: 26 27 28 4832-4842-5670.2 14 STIPULATED PROTECTIVE ORDER