1

2

3

4

5

6

7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 GOLD VALUE INTERNATIONAL Case No. 2:20-cv-01423-JWH-GJS TEXTILE, INC. d/b/a “FIESTA 12 FABRIC”, STIPULATED PROTECTIVE 13 Plaintiff, ORDER1

14 v.

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

(9th Cir. 2006), Phillips v. Gen. Motors 11 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 12 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 13 require good cause showing), and a specific showing of good cause or compelling 14 reasons with proper evidentiary support and legal justification, must be made with 15 respect to Protected Material that a party seeks to file under seal. The parties’ mere 16 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 17 without the submission of competent evidence by declaration, establishing that the 18 material sought to be filed under seal qualifies as confidential, privileged, or 19 otherwise protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 compelling reasons, not only good cause, for the sealing must be shown, and the 22 relief sought shall be narrowly tailored to serve the specific interest to be protected. 23 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 24 each item or type of information, document, or thing sought to be filed or introduced 25 under seal in connection with a dispositive motion or trial, the party seeking 26 protection must articulate compelling reasons, supported by specific facts and legal 27 justification, for the requested sealing order. Again, competent evidence supporting 1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. 3 If documents can be redacted, then a redacted version for public viewing, omitting 4 only the confidential, privileged, or otherwise protectable portions of the document, 5 shall be filed. Any application that seeks to file documents under seal in their 6 entirety should include an explanation of why redaction is not feasible. 7 8 2. DEFINITIONS 9 2.1 Action: this pending federal lawsuit. 10 2.2 Challenging Party: a Party or Non-Party that challenges the 11 designation of information or items under this Order. 12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 13 how it is generated, stored or maintained) or tangible things that qualify for 14 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 15 the Good Cause Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL” or “CONFIDENTIAL OUTSIDE COUNSEL ONLY.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless 22 of the medium or manner in which it is generated, stored, or maintained (including, 23 among other things, testimony, transcripts, and tangible things), that are produced or 24 generated in disclosures or responses to discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as 27 an expert witness or as a consultant in this Action. 1 House Counsel does not include Outside Counsel of Record or any other outside 2 counsel. 3 2.9 Non-Party: any natural person, partnership, corporation, association or 4 other legal entity not named as a Party to this action. 5 2.10 Outside Counsel of Record: attorneys who are not employees of a 6 party to this Action but are retained to represent or advise a party to this Action and 7 have appeared in this Action on behalf of that party or are affiliated with a law firm 8 that has appeared on behalf of that party, and includes support staff. 9 2.11 Party: any party to this Action, including all of its officers, directors, 10 employees, consultants, retained experts, and Outside Counsel of Record (and their 11 support staffs). 12 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 13 Discovery Material in this Action. 14 2.13 Professional Vendors: persons or entities that provide litigation 15 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 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 designated as “CONFIDENTIAL” or “CONFIDENTIAL OUTSIDE COUNSEL 20 ONLY.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery 22 Material from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or 26 extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 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 trial judge. This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 FINAL DISPOSITION of the action is defined as the conclusion of any appellate 8 proceedings, or, if no appeal is taken, when the time for filing of an appeal has run. 9 Except as set forth below, the terms of this protective order apply through FINAL 10 DISPOSITION of the action. The parties may stipulate that the they will be 11 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 12 but will have to file a separate action for enforcement of the agreement once all 13 proceedings in this case are complete. 14 Once a case proceeds to trial, information that was designated as CONFIDENTIAL 15 or maintained pursuant to this protective order used or introduced as an exhibit at 16 trial becomes public and will be presumptively available to all members of the 17 public, including the press, unless compelling reasons supported by specific factual 18 findings to proceed otherwise are made to the trial judge in advance of the trial. See 19 Kamakana,

(distinguishing “good cause” showing for sealing 20 documents produced in discovery from “compelling reasons” standard when merits- 21 related documents are part of court record). Accordingly, for such materials, the 22 terms of this protective order do not extend beyond the commencement of the trial. 23 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under 27 this Order must take care to limit any such designation to specific material that 1 Disclosure or Discovery Material “CONFIDENTIAL OUTSIDE COUNSEL 2 ONLY” only if it, in concurrence with its counsel, in good faith deems that 3 disclosure of such material to a party would be injurious to the commercial interests 4 of the Designating Party under the standards of Rule 26 of the Federal Rules of Civil 5 Procedure or Local Rules. The Designating Party must designate for protection only 6 those parts of material, documents, items or oral or written communications that 7 qualify so that other portions of the material, documents, items or communications 8 for which protection is not warranted are not swept unjustifiably within the ambit of 9 this Order. 10 Mass, indiscriminate or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” or “CONFIDENTIAL OUTSIDE COUNSEL ONLY” 1 material or, in the case of electronically stored information produced in native 2 format, to the medium conveying the information (e.g., contained in the e-mail, to 3 which the ESI is attached). If only a portion of the material on a page qualifies for 4 protection, the Producing Party also must clearly identify the protected portion(s) 5 (e.g., by making appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 need not designate them for protection until after the inspecting Party has indicated 8 which documents it would like copied and produced. During the inspection and 9 before the designation, all of the material made available for inspection shall be 10 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 11 documents it wants copied and produced, the Producing Party must determine which 12 documents, or portions thereof, qualify for protection under this Order. Then, 13 before producing the specified documents, the Producing Party must affix the 14 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 15 portion of the material on a page qualifies for protection, the Producing Party also 16 must clearly identify the protected portion(s) (e.g., by making appropriate markings 17 in the margins). 18 (b) for testimony given in depositions that the Designating Party identifies 19 the Disclosure or Discovery Material on the record, before the close of the 20 deposition all protected testimony, or, within thirty (30) days after receipt of the 21 deposition transcript, advise opposing counsel of the specific pages to be maintained 22 in confidence and affix the appropriate “CONFIDENTIAL legend” to each page of 23 the transcript that contains Protected Material. The Designating Party shall send a 24 list and/or copy of such designated Protected Material to the Receiving Party and the 25 Court Reporter who shall conform all copies of the transcript in their possession to 26 reflect such confidentiality designation and shall re-bind separately those portions of 27 the testimony designated as Protected Material and shall mark the face of the 1 “CONFIDENTIAL PURSUANT TO COURT ORDER” or “CONFIDENTIAL 2 PURSUANT TO COURT ORDER – AVAILABLE TO COUNSEL ONLY” as 3 appropriate. Deposition transcripts shall be treated by the Parties as 4 “CONFIDENTIAL OUTSIDE COUNSEL ONLY” until such designations are made 5 or until the lapse of the thirty (30) day period. 6 (c) for information produced in some form other than documentary and 7 for any other tangible items, that the Producing Party affix in a prominent place on 8 the exterior of the container or containers in which the information is stored the 9 appropriate “CONFIDENTIAL legend.” If only a portion or portions of the 10 information warrants protection, the Producing Party, to the extent practicable, shall 11 identify the protected portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive 14 the Designating Party’s right to secure protection under this Order for such material. 15 Upon timely correction of a designation, the Receiving Party must make reasonable 16 efforts to assure that the material is treated in accordance with the provisions of this 17 Order. 18 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 24 resolution process under Local Rule 37.1 et seq. 25 6.3 The burden of persuasion in any such challenge proceeding shall be on 26 the Designating Party. Frivolous challenges, and those made for an improper 27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 1 Party has waived or withdrawn the confidentiality designation, all parties shall 2 continue to afford the material in question the level of protection to which it is 3 entitled under the Producing Party’s designation until the Court rules on the 4 challenge. 5 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this 9 Action only for prosecuting, defending or attempting to settle this Action. Such 10 Protected Material may be disclosed only to the categories of persons and under the 11 conditions described in this Order. When the Action has been terminated, a 12 Receiving Party must comply with the provisions of section 13 below (FINAL 13 DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” and “CONFIDENTIAL OUTSIDE 18 COUNSEL ONLY” Information or Items. Unless otherwise ordered by the court or 19 permitted in writing by the Designating Party, a Receiving Party may disclose any 20 information or item designated “CONFIDENTIAL” or “CONFIDENTIAL 21 OUTSIDE COUNSEL ONLY” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action, 27 except for Information or Items designated “CONFIDENTIAL OUTSIDE 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 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or a 10 custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in the 12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 13 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 14 not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL” or “CONFIDENTIAL OUTSIDE COUNSEL ONLY,” that 1 (a) promptly notify in writing the Designating Party. Such notification 2 shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order 4 to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall include 6 a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” or “CONFIDENTIAL OUTSIDE COUNSEL 12 ONLY” before a determination by the court from which the subpoena or order 13 issued, unless the Party has obtained the Designating Party’s permission. The 14 Designating Party shall bear the burden and expense of seeking protection in that 15 court of its confidential material and nothing in these provisions should be construed 16 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 17 directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 PRODUCED IN THIS LITIGATION 21 (a) The terms of this Order are applicable to information produced by a 22 Non-Party in this Action and designated as “CONFIDENTIAL” or 23 “CONFIDENTIAL OUTSIDE COUNSEL ONLY.” Such information produced by 24 Non-Parties in connection with this litigation is protected by the remedies and relief 25 provided by this Order. Nothing in these provisions should be construed as 26 prohibiting a Non-Party from seeking additional protections. 27 (b) In the event that a Party is required, by a valid discovery request, to 1 subject to an agreement with the Non-Party not to produce the Non-Party’s 2 confidential information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and the Non-Party 4 that some or all of the information requested is subject to a confidentiality 5 agreement with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the 10 Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court within 12 14 days of receiving the notice and accompanying information, the Receiving Party 13 may produce the Non-Party’s confidential information responsive to the discovery 14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 15 not produce any information in its possession or control that is subject to the 16 confidentiality agreement with the Non-Party before a determination by the court. 17 Absent a court order to the contrary, the Non-Party shall bear the burden and 18 expense of seeking protection in this court of its Protected Material. 19 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 Protected Material to any person or in any circumstance not authorized under this 23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 26 persons to whom unauthorized disclosures were made of all the terms of this Order, 27 and (d) request such person or persons to execute the “Acknowledgment and 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 7 procedure may be established in an e-discovery order that provides for production 8 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 9 (e), insofar as the parties reach an agreement on the effect of disclosure of a 10 communication or information covered by the attorney-client privilege or work 11 product protection, the parties may incorporate their agreement in the stipulated 12 protective order submitted to the court. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Local Civil Rule 79-5. Protected Material 24 may only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party’s request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 in the public record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 [CONTINUED ON NEXT PAGE]

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 5 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. ° || DATED: — March 10, 2021 By: /s/ Trevor W. Barrett 8 || Stephen M. Doniger, Esq. 9 || Scott Alan Burroughs, Esq. Trevor W. Barrett, Esq. 10 |) Justin M. Gomes, Esq. 11 || DONIGER /BURROUGHS Attorneys for Plaintiff Gold Value International Textile, Inc. 12 13 || DATED: March 10, 2021 14 By: /s/Jessica S. Rutherford 15 || John F. Olsen, Esq. 16 || FERDINAND IP, LLP Jessica S. Rutherford, Esq. (pro hac vice) 17 || FERDINAND IP, LLC 1g. || Attorneys for Defendants Sundance Holdings Group, L.L.C. & Blue Tassel, Inc. 19 DATED: March 10, 2021 20 91 || By: /s/Todd M. Lander Todd M. Lander, Esq. 22 || FREEMAN, FREEEMAN & SMILEY, LLP 93 || Attorneys for Defendants Sundance Catalog Company, LLC & Nation Design Partners, LLC 24 25 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 26 || DATED: March 16, 2021 wat 27 GAIL J. STANDISH 28 UNITED STATES MAGISTRATE JUDGE

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 perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Gold Value International Textile, Inc. v. Sundance Catalog 8 Company, LLC, et al., Civil Action No. 2:20-cv-01423-JWH-GJS. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not 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 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