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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SARA DEROSA, Individually, and 11 On Behalf of others similarly situated, Case No. 2:20-cv-02965-MCS (GJSx)

12 Plaintiff, CLASS ACTION 13 v. STIPULATED [PROPOSED] 14 VIACOMCBS INC.; CBS STUDIOS, PROTECTIVE ORDER1 INC.; SESSIONS PAYROLL 15 MANAGEMENT, INC.; FIRSTHAND PRODUCTIONS, 16 INC.; EAST END PRODUCTIONS, INC.; SNAPSHOT PRODUCTIONS, 17 INC.; GAIL LEVINE; GREGG LEVINE; BOARD OF TRUSTEES 18 OF THE AFTRA RETIREMENT FUND; BOARD OF TRUSTEES OF 19 THE SAG PRODUCERS PENSION PLAN; BOARD OF TRUSTEES OF 20 THE SAG-AFTRA HEALTH PLAN; and DOES 1-50, 21 22 Defendants.

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26 27 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to proposed terms for 6 confidential treatment of certain discovery, and petition the Court to enter the 7 following Stipulated Protective Order. The parties acknowledge that this Order does 8 not confer blanket protections on all disclosures or responses to discovery and that 9 the protection it affords from public disclosure and use extends only to the limited 10 information or items that are entitled to confidential treatment under the applicable 11 legal principles. 12 B. GOOD CAUSE STATEMENT 13 Discovery in this action may involve production of confidential, proprietary 14 or private information for which special protection from public disclosure may be 15 warranted. Specifically, Plaintiff brings this putative class action on behalf of 16 current and former non-exempt, hourly paid employees who worked for Sessions 17 Payroll Management Inc., Firsthand Productions, Inc., East End Productions, Inc., 18 Snapshot Productions, Inc., Gail Levine, Gregg Levine, ViacomCBS Inc., and CBS 19 Studios Inc., and DOES 1–50 (“Employer Defendants”) as “background actors” or 20 “stand-ins” whose rights Plaintiff asserts the Defendants violated and continue to 21 violate under the New York Labor Law (“NYLL”), New York Common Law, and 22

(a) during the applicable statutory period (collectively “Class 23 Members” and “Class Period”). Defendants each deny these allegations. 24 The parties anticipate that discovery in this case may involve some disclosure 25 of private employee information as well as sensitive business information for which 26 special protection from public disclosure may be warranted. Such confidential 27 materials and information may consist of, among other things, trade secrets, 1 privacy rights of third parties), information regarding confidential business 2 practices, or information implicating privacy rights, information otherwise generally 3 unavailable to the public, or which may be privileged or otherwise protected from 4 disclosure under state or federal statutes, court rules, case decisions, or common 5 law. 6 Accordingly, to expedite the flow of information, to facilitate the prompt 7 resolution of disputes over confidentiality of discovery materials, to adequately 8 protect information the parties are entitled to keep confidential, to ensure that the 9 parties are permitted reasonable necessary uses of such material in preparation for 10 and in the conduct of trial, to address their handling at the end of the litigation, and 11 serve the ends of justice, a protective order for such information is justified in this 12 matter. 13 It is the intent of the parties that information will not be designated as 14 confidential for tactical reasons and that nothing be so designated without a good 15 faith belief that it has been maintained in a confidential, non-public manner, and 16 there is good cause why it should not be part of the public record of this case. 17 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 18 The parties further acknowledge, as set forth in Section 12.3, below, that this 19 Stipulated Protective Order does not entitle them to file confidential information 20 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 21 and the standards that will be applied when a party seeks permission from the Court 22 to file material under seal. 23 There is a strong presumption that the public has a right of access to judicial 24 proceedings and records in civil cases. In connection with non-dispositive motions, 25 good cause must be shown to support a filing under seal. See Kamakana v. City and 26 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 27 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 1 require good cause showing), and a specific showing of good cause or compelling 2 reasons with proper evidentiary support and legal justification, must be made with 3 respect to Protected Material that a party seeks to file under seal. The parties’ mere 4 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 5 without the submission of competent evidence by declaration, establishing that the 6 material sought to be filed under seal qualifies as confidential, privileged, or 7 otherwise protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the 10 relief sought shall be narrowly tailored to serve the specific interest to be protected. 11 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 12 each item or type of information, document, or thing sought to be filed or introduced 13 under seal in connection with a dispositive motion or trial, the party seeking 14 protection must articulate compelling reasons, supported by specific facts and legal 15 justification, for the requested sealing order. Again, competent evidence supporting 16 the application to file documents under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in 18 its entirety will not be filed under seal if the confidential portions can be redacted. 19 If documents can be redacted, then a redacted version for public viewing, omitting 20 only the confidential, privileged, or otherwise protectable portions of the document, 21 shall be filed. Any application that seeks to file documents under seal in their 22 entirety should include an explanation of why redaction is not feasible. 23 2. DEFINITIONS 24 2.1 Action: the above-captioned lawsuit entitled DeRosa v. ViacomCBS 25 Inc., et al., Case No. 2:20-cv-02965-MCS (GJSx).. 26 2.2 Challenging Party: a Party or Non-Party that challenges the 27 designation of information or items under this Order. 1 how it is generated, stored or maintained) or tangible things that qualify for 2 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 3 the Good Cause Statement. 4 2.4 Counsel: Outside Counsel of Record and House Counsel,as well as 5 their support staff. 6 2.5 Designating Party: a Party or Non-Party that designates information or 7 items that it produces in disclosures or in responses to discovery as 8 “CONFIDENTIAL.” 9 2.6 Disclosure or Discovery Material: all items or information, regardless 10 of the medium or manner in which it is generated, stored, or maintained (including, 11 among other things, testimony, transcripts, and tangible things), that are produced or 12 generated in disclosures or responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in a matter 14 pertinent to the litigation who has been retained by a Party or its counsel to serve as 15 an expert witness or as a consultant in this Action. 16 2.8 House Counsel: attorneys who are employees of a party to this Action. 17 House Counsel does not include Outside Counsel of Record or any other outside 18 counsel. 19 2.9 Non-Party: any natural person, partnership, corporation, association or 20 other legal entity not named as a Party to this action. 21 2.10 Outside Counsel of Record: attorneys who are not employees of a 22 party to this Action but are retained to represent or advise a party to this Action and 23 have appeared in this Action on behalf of that party or are affiliated with a law firm 24 that has appeared on behalf of that party, and includes support staff. 25 2.11 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their 27 support staffs). 1 Discovery Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation 3 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 2.14 Protected Material: any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 8 2.15 Receiving Party: a Party that receives Disclosure or Discovery 9 Material from a Producing Party. 3. SCOPE 10 The protections conferred by this Stipulation and Order cover not only 11 Protected Material (as defined above), but also (1) any information copied or 12 extracted from Protected Material; (2) all copies, excerpts, summaries, or 13 compilations of Protected Material; and (3) any testimony, conversations, or 14 presentations by Parties or their Counsel that might reveal Protected Material. 15 Any use of Protected Material at trial shall be governed by the orders of the 16 trial judge. This Order does not govern the use of Protected Material at trial. 17 4. DURATION 18 FINAL DISPOSITION of the action is defined as the conclusion of any 19 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 20 has run. Except as set forth below, the terms of this protective order apply through 21 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 22 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 23 but will have to file a separate action for enforcement of the agreement once all 24 proceedings in this case are complete. 25 Once a case proceeds to trial, information that was designated as 26 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 27 1 members of the public, including the press, unless compelling reasons supported by 2 specific factual findings to proceed otherwise are made to the trial judge in advance 3 of the trial. See Kamakana,

(distinguishing “good cause” 4 showing for sealing documents produced in discovery from “compelling reasons” 5 standard when merits-related documents are part of court record). Accordingly, for 6 such materials, the terms of this protective order do not extend beyond the 7 commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection under 11 this Order must take care to limit any such designation to specific material that 12 qualifies under the appropriate standards. The Designating Party must designate for 13 protection only those parts of material, documents, items or oral or written 14 communications that qualify so that other portions of the material, documents, items 15 or communications for which protection is not warranted are not swept unjustifiably 16 within the ambit of this Order. 17 Mass, indiscriminate or routinized designations are prohibited. Designations 18 that are shown to be clearly unjustified or that have been made for an improper 19 purpose (e.g., to unnecessarily encumber the case development process or to impose 20 unnecessary expenses and burdens on other parties) may expose the Designating 21 Party to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 designated for protection do not qualify for protection, and the Designating Party 24 agrees or the Court orders otherwise, that Designating Party must promptly notify 25 all other Parties that it is withdrawing the inapplicable designation. 26 5.2 Manner and Timing of Designations. Except as otherwise provided in 27 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 1 under this Order must be clearly so designated before the material is disclosed or 2 produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic 5 documents, but excluding transcripts of depositions or other pretrial or trial 6 proceedings), that the Producing Party affix at a minimum, the legend 7 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 8 contains protected material. If only a portion of the material on a page qualifies for 9 protection, the Producing Party also must clearly identify the protected portion(s) 10 (e.g., by making appropriate markings in the margins) to the extent possible. 11 A Party or Non-Party that makes original documents available for inspection 12 need not designate them for protection until after the inspecting Party has indicated 13 which documents it would like copied and produced. During the inspection and 14 before the designation, all of the material made available for inspection shall be 15 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 16 documents it wants copied and produced, the Producing Party must determine which 17 documents, or portions thereof, qualify for protection under this Order. Then, 18 before producing the specified documents, the Producing Party must affix the 19 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 20 portion of the material on a page qualifies for protection, the Producing Party also 21 must clearly identify the protected portion(s) (e.g., by making appropriate markings 22 in the margins). 23 (b) for testimony given in depositions that the Designating Party identifies 24 the Disclosure or Discovery Material on the record, before the close of the 25 deposition all protected testimony. In the alternative, the Designating Party may 26 designate the entirety of the testimony given at the deposition, as well as exhibits, as 27 “CONFIDENTIAL” prior to conclusion of the deposition with the right to identify 1 days following receipt of the deposition transcript. Where portions of the testimony 2 are designated for protection, the transcript pages containing Disclosure or 3 Discovery Material may be separately bound by the court reporter with the legend 4 “CONFIDENTIAL” at the top of each such page. 5 (c) for information produced in some form other than documentary and 6 for any other tangible items, that the Producing Party affix in a prominent place on 7 the exterior of the container or containers in which the information is stored the 8 legend “CONFIDENTIAL.” If only a portion or portions of the information 9 warrants protection, the Producing Party, to the extent practicable, shall identify the 10 protected portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 12 failure to designate qualified information or items does not, standing alone, waive 13 the Designating Party’s right to secure protection under this Order for such material. 14 Upon timely correction of a designation, the Receiving Party must make reasonable 15 efforts to assure that the material is treated in accordance with the provisions of this 16 Order. 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 designation of confidentiality at any time that is consistent with the Court’s 20 Scheduling Order. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37.1 et seq. 23 6.3 The burden of persuasion in any such challenge proceeding shall be on 24 the Designating Party. Frivolous challenges, and those made for an improper 25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 26 parties) may expose the Challenging Party to sanctions. Unless the Designating 27 Party has waived or withdrawn the confidentiality designation, all parties shall 1 entitled under the Producing Party’s designation until the Court rules on the 2 challenge. 3 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a 10 Receiving Party must comply with the provisions of section 13 below (FINAL 11 DISPOSITION). 12 Protected Material must be stored and maintained by a Receiving Party at a 13 location and in a secure manner that ensures that access is limited to the persons 14 authorized under this Order. 15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 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 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 (b) the Receiving Party, if an individual, and the officers, directors, and 23 employees (including House Counsel) of the Receiving Party, if an entity, to whom 24 disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (e) court reporters and their staff; 2 (f) professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary for this Action and who have 4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 (g) the author or recipient of a document containing the information or a 6 custodian or other person who otherwise possessed or knew the information; 7 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 9 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 10 not be permitted to keep any confidential information unless they sign the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 12 agreed by the Designating Party or ordered by the Court. Pages of transcribed 13 deposition testimony or exhibits to depositions that reveal Protected Material may 14 be separately bound by the court reporter and may not be disclosed to anyone except 15 as permitted under this Stipulated Protective Order; and 16 (i) any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions. 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 19 IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification 24 shall include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order 26 to issue in the other litigation that some or all of the material covered by the 27 subpoena or order is subject to this Protective Order. Such notification shall include 1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with 4 the subpoena or court order shall not produce any information designated in this 5 action as “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these provisions 9 should be construed as authorizing or encouraging a Receiving Party in this Action 10 to disobey a lawful directive from another court. 11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a 14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to 19 produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the Non-Party 23 that some or all of the information requested is subject to a confidentiality 24 agreement with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated 26 Protective Order in this Action, the relevant discovery request(s), and a reasonably 27 specific description of the information requested; and 1 Non-Party, if requested. 2 (c) If the Non-Party fails to seek a protective order from this Court within 3 14 days of receiving the notice and accompanying information, the Receiving Party 4 may produce the Non-Party’s confidential information responsive to the discovery 5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 6 not produce any information in its possession or control that is subject to the 7 confidentiality agreement with the Non-Party before a determination by the Court. 8 Absent a court order to the contrary, the Non-Party shall bear the burden and 9 expense of seeking protection in this court of its Protected Material. 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all of the terms of this 17 Order, and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit 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 protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 25 procedure may be established in an e-discovery order that provides for production 26 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 27 (e), insofar as the parties reach an agreement on the effect of disclosure of a 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 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 of 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 including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 || DATED November 23. 2020 7 || BOUCHER LLP 8 /s/ Mallory Whitelaw RAYMOND P. BOUCHER 9 || SHEHNAZ M. BHUJSWALA MARIA L. WEITZ 10 |) MALLORY WHITELAW Attorneys for Plaintiff and the Putative Class

12 DATED: November 23. 2020 13 MITCHELL SILBERBERG & KNUPP 14 /s/ Corey G. Singer 15 16 || Attorneys for Defendants ViacomCBS Inc. and CBS Studios Inc. 17 DATED: November 23. 2020 18 19 LAW OFFICES OF PAUL A. BECK tsi Paul A. Beck 20 || Attorneys for Defendants Sessions Payroll Management, Inc., Gail Levine, and Gregg Levine

22 23 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 || DATED: December 15, 2020 26 27 _ GAIL J. STANDISH 28 || UNITED STATES MAGISTRATE JUDGE

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 DeRosa v. ViacomCBS Inc., et al., Case No. 2:20-cv-02965- 9 MCS (GJSx). I agree to comply with and to be bound by all of the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 ATTESTATION 1 2 I, Mallory Whitelaw, am the registered CM/ECF User whose ID and 3 password are being used to file this document. Pursuant to Central District of 4 California Local Rule 5-4.3.4(A)(2)(ii), I hereby attest and certify that all other 5 signatories listed on this document, on whose behalf this filing is submitted to the 6 Court, concur in the filing’s content and authorized the filing. 7 DATED: Novemeber 23, 2020 Respectfully submitted, 8

9 BOUCHER LLP

10 By: /s/ Mallory Whitelaw 11 MALLORY WHITELAW Attorney for Plaintiff and the 12 Putative Class 13

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