1 Richard S. Busch (SBN 319881) E-Mail: [email protected] 2 D. Keith Kelly II (SBN 323469) E-Mail: [email protected] 3 KING & BALLOW 1999 Avenue of the Stars, Suite 1100 4 Los Angeles, CA 90067 Telephone: (424) 253-1255 5 Facsimile: (888) 688-0482 Attorneys for Plaintiffs 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9

10 OLIVIER BASSIL, an individual, Case No. 2:20-cv-05099-SB-PD _____________________ 11 BENJAMIN LASNIER, an individual, and LUKAS BENJAMIN LETH, an Honorable Stanley Blumenfeld, Jr. 12 individual, Honorable Patricia Donahue

13 Plaintiffs, [DISCOVERY MATTER]

14 vs. STIPULATED PROTECTIVE ORDER 15 JACQUES WEBSTER p/k/a Travis 16 Scott, an individual; OZAN Complaint Filed: June 9, 2020 YILDIRIM p/k/a OZ, an individual; NIK DEJAN FRASCONA p/k/a Nik 17 D, an individual; MICHAEL GEORGE DEAN p/k/a Mike Dean, an individual; 18 JAMIE LEPR p/k/a Cash Passion, an individual; SEAN SOLYMAR, an 19 individual; CACTUS JACK RECORDS, LLC, a Texas limited 20 liability company; GRAND HUSTLE, LLC, a Georgia limited liability 21 company; SONY MUSIC ENTERTAINMENT, INC., a Delaware 22 corporation; SONY/ATV MUSIC PUBLISHING, LLC, a Delaware 23 corporation; PAPA GEORGE MUSIC, a California company; THESE ARE 24 SONGS OF PULSE, a California company; and DOES 1 through 50, 25 inclusive,

26 Defendants.

27 1 Plaintiffs OLIVIER BASSIL, BENJAMIN LASNIER, and LUKAS 2 BENJAMIN LETH (collectively “Plaintiffs”) and defendants JACQUES 3 WEBSTER; OZAN YILDIRIM; NIK DEJAN FRASCONA; MICHAEL GEORGE 4 DEAN; JAIME LEPE (sued as JAMIE LEPR); CACTUS JACK RECORDS, LLC; 5 SONY MUSIC ENTERTAINMENT (sued as SONY MUSIC ENTERTAINMENT, 6 INC.); SONY/ATV MUSIC PUBLISHING, LLC; PAPA GEORGE MUSIC; and 7 CYPMP, LLC (sued as THESE ARE SONGS OF PULSE) (collectively, 8 “Defendants”) (each a “Party” and together the “Parties”) hereby stipulate to the 9 following Stipulated Protective Order (“Protective Order” or “Order”) limiting the 10 disclosure and use of certain information, as set forth herein. 11 1. A. PURPOSES AND LIMITATIONS 12 Discovery in this action is likely to involve production of confidential, 13 proprietary, or private information for which special protection from public 14 disclosure and from use for any purpose other than prosecuting this litigation may 15 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 16 enter the following Stipulated Protective Order. The parties acknowledge that this 17 Order does not confer blanket protections on all disclosures or responses to 18 discovery and that the protection it affords from public disclosure and use extends 19 only to the limited information or items that are entitled to confidential treatment 20 under the applicable legal principles. The parties further acknowledge, as set forth 21 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 22 to file confidential information under seal; Civil Local Rule 79-5 sets forth the 23 procedures that must be followed and the standards that will be applied when a party 24 seeks permission from the court to file material under seal. 25 B. GOOD CAUSE STATEMENT 26 This action is likely to involve trade secrets, customer and pricing lists 27 another valuable research, development, commercial, financial, technical and/or 1 from use for any purpose other than prosecution of this action is warranted. Such 2 confidential and proprietary materials and information consist of, among other 3 things, confidential business or financial information, information regarding 4 confidential business practices, or other confidential research, development, or 5 commercial information (including information implicating privacy rights of third 6 parties), information otherwise generally unavailable to the public, or which may 7 be privileged or otherwise protected from disclosure under state or federal statutes, 8 court rules, case decisions, or common law. Accordingly, to expedite the flow of 9 information, to facilitate the prompt resolution of disputes over confidentiality of 10 discovery materials, to adequately protect information the parties are entitled to 11 keep confidential, to ensure that the parties are permitted reasonable necessary uses 12 of such material in preparation for and in the conduct of trial, to address their 13 handling at the end of the litigation, and serve the ends of justice, a protective order 14 for such information is justified in this matter. It is the intent of the parties that 15 information will not be designated as confidential for tactical reasons and that 16 nothing be so designated without a good faith belief that it has been maintained in 17 a confidential, non-public manner, and there is good cause why it should not be part 18 of the public record of this case. 19 2. DEFINITIONS 20 2.1 Action: the above-captioned lawsuit. 21 2.2 Challenging Party: a Party that challenges the designation of 22 information or items as confidential under this Order. 23 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 24 how it is generated, stored, or maintained) or tangible things that qualify for 25 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 26 the Good Cause Statement. 27 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced 7 or generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association, 15 or other legal entity not named as a Party to this Action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a 17 Party to this Action, but are retained to represent or advise a Party and have 18 appeared in this Action on behalf of that Party or are affiliated with a law firm which 19 has appeared on behalf of that Party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery 4 Material from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 Protected Material (as defined above), but also (1) any information copied or 8 extracted from Protected Material; (2) all copies, excerpts, summaries, or 9 compilations of Protected Material; and (3) any testimony, conversations, or 10 presentations by Parties or their Counsel that might reveal Protected Material. Any 11 use of Protected Material at trial shall be governed by the orders of the trial judge. 12 This Order does not govern the use of Protected Material at trial. 13 4. DURATION 14 Once a case proceeds to trial, all of the information that was designated as 15 confidential or maintained pursuant to this protective order becomes public and will 16 be presumptively available to all members of the public, including the press, unless 17 compelling reasons supported by specific factual findings to proceed otherwise are 18 made to the trial judge in advance of the trial. See Kamakana v. City and County of 19 Honolulu,

(9th Cir. 2006) (distinguishing “good cause” 20 showing for sealing documents produced in discovery from “compelling reasons” 21 standard when merits-related documents are part of court record). Accordingly, the 22 terms of this protective order do not extend beyond the commencement of the trial. 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under 26 this Order must take care to limit any such designation to specific material that 27 qualifies under the appropriate standards. The Designating Party must designate for 1 communications that qualify so that other portions of the material, documents, items, 2 or communications for which protection is not warranted are not swept unjustifiably 3 within the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations 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 unnecessary expenses and burdens on other parties) may expose the Designating 8 Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 under this Order must be clearly so designated before the material is disclosed or 16 produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix at a minimum, the legend 21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 22 contains protected material. If only a portion or portions of the material on a page 23 qualifies for protection, the Producing Party also must clearly identify the protected 24 portion(s) (e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and 1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must determine 3 which documents, or portions thereof, qualify for protection under this Order. Then, 4 before producing the specified documents, the Producing Party must affix the 5 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identify the 10 Disclosure or Discovery Material on the record, before the close of the deposition 11 all protected testimony. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive 20 the Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. 3 6.3 The burden of persuasion in any such challenge proceeding shall be on 4 the Designating Party. Frivolous challenges, and those made for an improper 5 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 6 parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall 8 continue to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules on the 10 challenge. 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending, or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under the 16 conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 13 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 27 as employees of said Outside Counsel of Record to whom it is reasonably necessary 1 (b) the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 16 will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 deposition testimony or exhibits to depositions that reveal Protected Material may 20 be separately bound by the court reporter and may not be disclosed to anyone except 21 as permitted under this Stipulated Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 PRODUCED IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 1 (a) promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order to 4 issue in the other litigation that some or all of the material covered by the subpoena 5 or order is subject to this Protective Order. Such notification shall include a copy of 6 this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued 8 by the Designating Party whose Protected Material may be affected. If the 9 Designating Party timely seeks a protective order, the Party served with the 10 subpoena or court order shall not produce any information designated in this action 11 as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action 16 to disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a Non- 20 Party in this Action and designated as “CONFIDENTIAL.” Such information 21 produced by Non-Parties in connection with this litigation is protected by the 22 remedies and relief provided by this Order. Nothing in these provisions should be 23 construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 1 that some or all of the information requested is subject to a confidentiality 2 agreement with a Non-Party; 3 (2) promptly provide the Non-Party with a copy of the Stipulated 4 Protective Order in this Action, the relevant discovery request(s), and a reasonably 5 specific description of the information requested; and 6 (3) make the information requested available for inspection by the 7 Non-Party, if requested. 8 (c) If the Non-Party fails to seek a protective order from this court within 14 9 days of receiving the notice and accompanying information, the Receiving Party 10 may produce the Non-Party’s confidential information responsive to the discovery 11 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 12 not produce any information in its possession or control that is subject to the 13 confidentiality agreement with the Non-Party before a determination by the court. 14 Absent a court order to the contrary, the Non-Party shall bear the burden and 15 expense of seeking protection in this court of its Protected Material. 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 18 Protected Material to any person or in any circumstance not authorized under this 19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 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 22 or persons to whom unauthorized disclosures were made of all the terms of this 23 Order, and (d) request such person or persons to execute the “Acknowledgment and 24 Agreement to Be Bound” that is attached hereto as Exhibit A. 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 26 OTHERWISE PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 3 may be established in an e-discovery order that provides for production without 4 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 5 as the parties reach an agreement on the effect of disclosure of a communication or 6 information covered by the attorney-client privilege or work product protection, the 7 parties may incorporate their agreement in the stipulated protective order submitted 8 to the court. 9 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 11 person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Protective Order no Party waives any right it otherwise would have to object to 14 disclosing or producing any information or item on any ground not addressed in this 15 Stipulated Protective Order. Similarly, no Party waives any right to object on any 16 ground to use in evidence of any of the material covered by this Protective Order. 17 12.3 Filing Protected Material. A Party that seeks to file under seal any 18 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 19 only be filed under seal pursuant to a court order authorizing the sealing of the 20 specific Protected Material at issue. If a Party's request to file Protected Material 21 under seal is denied by the court, then the Receiving Party may file the information 22 in the public record unless otherwise instructed by the court. 23 12.4 Protection of Deposition Transcripts and Video-Taped Depositions. 24 With respect to depositions, all Parties and Non-Parties that have agreed to be bound 25 by this Stipulation agree that no portions of any transcript or videotape of any 26 deposition, whether or not designated as confidential, shall be posted at any time 27 (including during or after the pendency of this lawsuit), in any form or manner on 1 Instagram, or Twitter accounts. Additionally, all Parties and Non-Parties that have 2 agreed to be bound by this Stipulation further agree not to provide any portions of 3 any transcript or videotape of any deposition, whether or not designated as 4 confidential, to any third-parties who have not agreed to be bound by this 5 Stipulation, for the purposes of being posted at any time (including during or after 6 the pendency of this lawsuit), in any form or manner on or to the Internet, including, 7 but not limited to YouTube, Facebook, Instagram, or Twitter. 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 4, within 60 10 days of a written request by the Designating Party, each Receiving Party must return 11 all Protected Material to the Producing Party or destroy such material. As used in 12 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 summaries, and any other format reproducing or capturing any of the Protected 14 Material. Whether the Protected Material is returned or destroyed, the Receiving 15 Party must submit a written certification to the Producing Party (and, if not the same 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 abstracts, compilations, summaries or any other format reproducing or capturing 20 any of the Protected Material. Notwithstanding this provision, Counsel are entitled 21 to retain an archival copy of all pleadings, motion papers, trial, deposition, and 22 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 23 expert reports, attorney work product, and consultant and expert work product, even 24 if such materials contain Protected Material. Any such archival copies that contain 25 or constitute Protected Material remain subject to this Protective Order as set forth 26 in Section 4 (DURATION). 27 /// 1 VIOLATIONS 2 Any violation of this Order may be punished by any and all appropriate 3 ||measures including, without limitation, contempt proceedings and/or monetary 4 ||sanctions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 Dated: December 10, 2020 /s/Richard S. Busch 7 Richard S. Busch D. Keith Kelly II 8 KING & BALLOW. Attorneys for Plaintiffs 9 10 Dated: December 10, 2020 /s/Edwin F. McPherson Edwin F. McPherson 11 Pierre B. Pine McPHERSON LLP 12 Attorneys for Defendants Sony Music Entertainment, 13 Sony/ATV Music Publishing, LLC, Cactus Jack Records, LLC, J acques Webster, Michael George Dean, 14 and Papa George Music 15 Dated: December 10, 2020 /s/Allen B. Grodsk 16 Allen B. Grodsky GRODSKY OLECKI & PURITSKY LLP 17 Attorneys for Defendants | Ozan Yildirim and Nik Dejan Franscona 18 19 Dated: December 10, 2020 /s/Peter Anderson Peter Anderson 20 DAVIS WRIGHT TREMAINE LLP Attorneys for Defendant 1 CYPMP, LLC 22 73 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 4, 25 || Dated: December 11, 2020 alice Lona 26 Honorable Patricia Donahue United States Magistrate Judge 27 28

1 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 Order 6 that was issued by the United States District Court for the Central District of 7 California on _________________ [date] in the case of Olivier Bassil et al., v. 8 Jacques Webster, etc., et al., Case No. 2:20-cv-05099-SB-PD. I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 11 and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 1 LOCAL RULE 5-4.3.4(a)(2)(i) CERTIFICATION 2 The filer of this document attests that all other signatories listed above on 3 whose behalf this filing is submitted concur in the filing’s content and have 4 authorized the filing. 5

6 Dated: December 10, 2020 /s/Richard S. Busch Richard S. Busch 7 D. Keith Kelly II KING & BALLOW 8 Attorneys for Plaintiffs 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27