CLARKSON LAW FIRM, P.C. 1 Ryan J. Clarkson (SBN 257074) 2 [email protected] Zachary T. Chrzan (SBN 329159) 3 [email protected] 4 9255 Sunset Blvd., Suite 804 Los Angeles, CA 90069 5 Tel: (213) 788-4050 6 Fax: (213) 788-4070

7 Attorneys for Plaintiff 8

9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12

13 ELENA COLEMAN, individually and on Case No. 2:20-cv-8100-FMO-AFM 14 behalf of all others similarly situated, [PROPOSED] ORDER 15 Plaintiff, APPROVING STIPULATED 16 PROTECTIVE ORDER1 vs. 17

18 MONDELEZ INTERNATIONAL INC., a Virginia Corporation, 19

20 Defendant. 21 22

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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 disclosure 4 ||and from use for any purpose other than prosecuting this litigation may be warranted. 5 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 || following Stipulated Protective Order. The parties acknowledge that this Order does 7 ||not confer blanket protections on all disclosures or responses to discovery and that the 8 || protection it affords from public disclosure and use extends only to the limited 9 ||information or items that are entitled to confidential treatment under the applicable 10 || legal principles. 11 B. GOOD CAUSE STATEMENT g 12 Defendant contends that this action is likely to involve the disclosure of 13 |}commercially sensitive and confidential information relating to the Swedish Fish 14 || products manufactured by Defendant Mondeléz International Inc. (““MDLZ”), for 15 || which special protection from public disclosure and from use for any purpose other 16 |/than prosecution of this action is warranted. Such confidential and proprietary 17 materials and information consist of, among other things, highly confidential 18 |/information relating to the machinery and filling specifications for the Swedish Fish 19 || products at issue, confidential financial information related to sales of the Swedish 20 || Fish products, and confidential consumer research and other information relating to 21 ||}consumers’ expectations of the fill level of the Swedish Fish products at issue. This 22 ||information is otherwise generally unavailable to the public, and it may be privileged 23 or otherwise protected from disclosure under state or federal statutes, court rules, case 24 || decisions, or common law. 25 Accordingly, to expedite the flow of information, to facilitate the prompt 26 ||resolution of disputes over confidentiality of discovery materials, to adequately 27 || protect information the parties are entitled to keep confidential, to ensure that the 28 parties are permitted reasonable necessary uses of such material in preparation for and 9d

1 in the conduct of trial, to address their handling at the end of the litigation, and serve 2 the ends of justice, a protective order for such information is justified in this matter. It 3 is the intent of the parties that information will not be designated as confidential for 4 tactical reasons and that nothing be so designated without a good faith belief that it 5 has been maintained in a confidential, non-public manner, and there is good cause 6 why it should not be part of the public record of this case. 7 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING 8 UNDER SEAL 9 The parties further acknowledge, as set forth in Section 12.3, below, that this 10 Stipulated Protective Order does not entitle them to file confidential information under 11 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 12 standards that will be applied when a party seeks permission from the court to file 13 material under seal. 14 There is a strong presumption that the public has a right of access to judicial 15 proceedings and records in civil cases. In connection with non-dispositive motions, 16 good cause must be shown to support a filing under seal. See Kamakana v. City and 17 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 18 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 19

(E.D. Wis. 1999) (even stipulated protective orders require good 20 cause showing), and a specific showing of good cause or compelling reasons with 21 proper evidentiary support and legal justification, must be made with respect to 22 Protected Material that a party seeks to file under seal. The parties’ mere designation 23 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 24 submission of competent evidence by declaration, establishing that the material sought 25 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 26 constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, then 1 ||sought shall be narrowly tailored to serve the specific interest to be protected. See 2 || Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each 3 |/item or type of information, document, or thing sought to be filed or introduced under 4 ||seal in connection with a dispositive motion or trial, the party seeking protection must 5 || articulate compelling reasons, supported by specific facts and legal justification, for 6 □□□ requested sealing order. Again, competent evidence supporting the application to 7 || file documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in its 9 |/entirety will not be filed under seal if the confidential portions can be redacted. If 10 documents can be redacted, then a redacted version for public viewing, omitting only 11 the confidential, privileged, or otherwise protectable portions of the document, shall be filed. Any application that seeks to file documents under seal in their entirety 13 should include an explanation of why redaction is not feasible. 14 2. DEFINITIONS 15 2.1. Action: this pending federal lawsuit. 16 2.2. Challenging Party: a Party or Non-Party that challenges the 17 || designation of information or items under this Order. 18 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 19 || how it is generated, stored or maintained) or tangible things that qualify for protection 20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 21 ||Cause Statement. 22 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 23 || support staff). 24 2.5. Designating Party: a Party or Non-Party that designates information or 25 ||items that it produces in disclosures or in responses to discovery as 26 ||“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 27 2.6. Disclosure or Discovery Material: all items or information, regardless of 28 ||the medium or manner in which it is generated, stored, or maintained (including,

1 ||among other things, testimony, transcripts, and tangible things), that are produced or 2 || generated in disclosures or responses to discovery in this matter. 3 2.7. Expert: a person with specialized knowledge or experience in a matter 4 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 5 expert witness or as a consultant in this Action. 6 2.8 HIGHLY CONFIDENTIAL” Information or Items: extremely sensitive 7 ||“CONFIDENTIAL Information or Items,” disclosure of which to another Party or Non- 8 Party would create a substantial risk of serious harm that could not be avoided by less 9 || restrictive means. 10 2.9. House Counsel: attorneys who are employees of a party to this Action. 11 ||House Counsel does not include Outside Counsel of Record or any other outside counsel. 13 2.10. Non-Party: any natural person, partnership, corporation, association or 14 || other legal entity not named as a Party to this action. 15 2.11. Outside Counsel of Record: attorneys who are not employees of a party 16 to this Action but are retained to represent or advise a party to this Action and have 17 || appeared in this Action on behalf of that party or are affiliated with a law firm that has 18 || appeared on behalf of that party, and includes support staff. 19 2.12. Party: any party to this Action, including all of its officers, directors, 20 ||employees, consultants, retained experts, and Outside Counsel of Record (and their 21 || support staffs). 22 2.13. Producing Party: a Party or Non-Party that produces Disclosure or 23 || Discovery Material in this Action. 24 2.14. Professional Vendors: persons or entities that provide litigation support 25 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 ||demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 ||and their employees and subcontractors. 28

1 2.15. Protected Material: any Disclosure or Discovery Material that is 2 || designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 3 2.16. Receiving Party: a Party that receives Disclosure or Discovery Material 4 || 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 extracted 8 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of 9 Protected Material; and (3) any testimony, conversations, or presentations by Parties 10 || or their Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern the use of Protected Material at trial. 13 4. DURATION 14 Once a case proceeds to trial, information that was designated as 15 ||} CONFIDENTIAL or HIGHLY CONFIDENTIAL or maintained pursuant to this 16 || protective order used or introduced as an exhibit at trial becomes public and will be 17 || presumptively available to all members of the public, including the press, unless 18 compelling reasons supported by specific factual findings to proceed otherwise are 19 made to the trial judge in advance of the trial. See Kamakana,

-81 20 (distinguishing “good cause” showing for sealing documents produced in discovery 21 from “compelling reasons” standard when merits-related documents are part of court 22 ||record). Accordingly, the terms of this protective order do not extend beyond the 23 ||commencement of the trial. 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 27 ||under this Order must take care to limit any such designation to specific material that 28 || qualifies under the appropriate standards. The Designating Party must designate for

1 || protection only those parts of material, documents, items or oral or written 2 ||communications that qualify so that other portions of the material, documents, items 3 ||or communications for which protection is not warranted are not swept unjustifiably 4 || within the ambit of this Order. 5 Mass, indiscriminate or routinized designations are prohibited. Designations 6 ||that are shown to be clearly unjustified or that have been made for an improper 7 || purpose (e.g., to unnecessarily encumber the case development process or to impose 8 unnecessary expenses and burdens on other parties) may expose the Designating Party 9 to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 || designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 || under this Order must be clearly so designated before the material is disclosed or 17 || produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic documents, 20 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the 21 || Producing Party affix at a minimum, the legend “CONFIDENTIAL” or “HIGHLY 22 || CONFIDENTIAL” to each page that contains protected material. If only a portion of 23 ||the material on a page qualifies for protection, the Producing Party also must clearly 24 |/identify the protected portion(s) (e.g., by making appropriate markings in the 25 margins). 26 A Party or Non-Party that makes original documents available for inspection 27 ||need not designate them for protection until after the inspecting Party has indicated 28 || which documents it would like copied and produced. During the inspection and before

1 || the designation, all of the material made available for inspection shall be deemed 2 ||“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” After the inspecting Party has 3 ||identified the documents it wants copied and produced, the Producing Party must 4 determine which documents, or portions thereof, qualify for protection under this 5 ||Order. Then, before producing the specified documents, the Producing Party must 6 || affix the “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” legend to each page 7 ||that contains Protected Material. If only a portion of the material on a page qualifies 8 || for protection, the Producing Party also must clearly identify the protected portion(s) 9 |I(e.g., by making appropriate markings in the margins). 10 (b) for testimony given in depositions that the Designating Party identifies 11 ||the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. 13 (c) for information produced in some form other than documentary and for 14 any other tangible items, that the Producing Party affix in a prominent place on the 15 exterior of the container or containers in which the information is stored the legend 16 ||“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion or portions 17 of the information warrants protection, the Producing Party, to the extent practicable, 18 shall identify the protected portion(s). 19 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 || failure to designate qualified information or items does not, standing alone, waive the 21 || Designating Party’s right to secure protection under this Order for such material. 22 ||Upon timely correction of a designation, the Receiving Party must make reasonable 23 || efforts to assure that the material is treated in accordance with the provisions of this 24 || Order. 25 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 6.1 Timing of Challenges. Any Part or Non-Party may challenge a 27 || designation of confidentiality at any time that is consistent with the Court’s 28 || 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 Joint Stipulation. Any challenge submitted to the Court shall be via a 4 ||joint stipulation pursuant to Local Rule 37-2. 5 6.4 The burden of persuasion in any such challenge proceeding shall be on 6 the Designating Party. Frivolous challenges, and those made for an improper purpose 7 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may 8 ||expose the Challenging Party to sanctions. Unless the Designating Party has waived 9 withdrawn the confidentiality designation, all parties shall continue to afford the 10 || material in question the level of protection to which it is entitled under the Producing 11 || Party’s designation until the Court rules on the challenge. S12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1. Basic Principles. A Receiving Party may use Protected Material that is 14 || disclosed or produced by another Party or by a Non-Party in connection with this 15 || Action only for prosecuting, defending or attempting to settle this Action. Such 16 || Protected Material may be disclosed only to the categories of persons and under the 17 ||conditions described in this Order. When the Action has been terminated, a Receiving 18 Party must comply with the provisions of section 13 below (FINAL 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 1s 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 “CONFIDENTIAL” 25 || only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 27 || well as employees of said Outside Counsel of Record to whom it is reasonably 28 ||necessary to disclose the information for this Action;

1 (b) the officers, directors, and employees (including House Counsel) of 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 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 will 16 |/not be permitted to keep any confidential information unless they sign the 17 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 18 || by the Designating Party or ordered by the court. Pages of transcribed deposition 19 || testimony or exhibits to depositions that reveal Protected Material may be separately 20 bound by the court reporter and may not be disclosed to anyone except as permitted 21 under this Stipulated Protective Order; and 22 (1) any mediator or settlement officer, and their supporting personnel, 23 ||mutually agreed upon by any of the parties engaged in settlement discussions. 24 7.3 Disclosure of “HIGHLY CONFIDENTIAL” Information or Items. Unless 25 ||otherwise ordered by the court or permitted in writing by the Designating Party, a 26 ||Receiving Party may disclose any information or item designated “HIGHLY 27 || CONFIDENTIAL” only to: 28 10

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 |}employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 || disclose the information for this Action; 4 (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure 5 reasonably necessary for this Action and who have signed the “Acknowledgment and 6 || Agreement to Be Bound” (Exhibit A); 7 (c) the court and its personnel; 8 (d) court reporters and their staff; 9 (e) professional jury or trial consultants, mock jurors, and Professional Vendors 10 ||to whom disclosure is reasonably necessary for this Action and who have signed the 11 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A); (f) the author or recipient of a document containing the information or a custodian 13 || or other person who otherwise possessed or knew the information; 14 (g) any mediator or settlement officer, and their supporting personnel, mutually 15 ||agreed upon by any of the parties engaged in settlement discussions. 16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in other litigation 19 that compels disclosure of any information or items designated in this Action as 20 ||“CONFIDENTIAL or HIGHLY CONFIDENTIAL,” that Party must: 21 (a) promptly notify in writing the Designating Party. Such notification shall 22 ||include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the subpoena or order to 24 ||issue in the other litigation that some or all of the material covered by the subpoena or 25 order is subject to this Protective Order. Such notification shall include a copy of this 26 || Stipulated Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to be pursued 28 || by the Designating Party whose Protected Material may be affected. 11

1 If the Designating Party timely seeks a protective order, the Party served with 2 subpoena or court order shall not produce any information designated in this 3 ||action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a 4 || determination by the court from which the subpoena or order issued, unless the Party 5 ||has obtained the Designating Party’s permission. The Designating Party shall bear the 6 || burden and expense of seeking protection in that court of its confidential material and 7 ||nothing in these provisions should be construed as authorizing or encouraging a 8 || Receiving Party in this Action to disobey a lawful directive from another court. 9 119. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 10 IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- g 12 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 13 ||} CONFIDENTIAL.” Such information produced by Non-Parties in connection with 14 this litigation is protected by the remedies and relief provided by this Order. Nothing 15 ||in these provisions should be construed as prohibiting a Non-Party from seeking 16 || additional protections. 17 (b) Inthe event that a Party is required, by a valid discovery request, to 18 || 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-Party 22 ||that some or all of the information requested is subject to a confidentiality agreement 23 || 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. 19

1 (c) Ifthe Non-Party fails to seek a protective order from this court within 14 2 || days of receiving the notice and accompanying information, the Receiving Party may 3 || produce the Non-Party’s confidential information responsive to the discovery request. 4 Ifthe Non-Party timely seeks a protective order, the Receiving Party shall not produce 5 any information in its possession or control that is subject to the confidentiality 6 ||agreement with the Non-Party before a determination by the court. Absent a court 7 order to the contrary, the Non-Party shall bear the burden and expense of seeking 8 || 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 disclosed 11 || Protected Material to any person or in any circumstance not authorized under this g 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 || persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the “Acknowledgment and 17 || Agreement to Be Bound” that is attached hereto as Exhibit A. 18 ll. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 |/inadvertently produced material is subject to a claim of privilege or other protection, 22 ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 ||may be established in an e-discovery order that provides for production without prior 25 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 26 ||parties reach an agreement on the effect of disclosure of a communication or 27 ||information covered by the attorney-client privilege or work product protection, the 28 13

1 || parties may incorporate their agreement in the stipulated protective order submitted to 2 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 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 13 || 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 in 16 ||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 this 21 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 the Protected Material that was returned or 27 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 28 abstracts, compilations, summaries or any other format reproducing or capturing any 14

1 □□ 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 14. VIOLATION 9 Any violation of this Order may be punished by appropriate measures 10 including, without limitation, contempt proceedings and/or monetary sanctions. 11 12 IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13 £ 14 || Dated: March 17, 2021 CLARKSON LAW FIRM, PC

By: /s/Ryan J. Clarkson 7 Ryan J. Clarkson 18 Attorneys for Plaintiff 19 20 || Dated: March 17, 2021 JENNER & BLOCK LLP 21 22 By: /s/ Alexander M. Smith _ 3 Alexander M. Smith Mondeies Ipiematenal. Inc. 26 27 28 15

1 ATTESTATION OF FILER 2 Pursuant to Local Rule 5-4.3.4, the undersigned filer hereby attests that all 3 signatories listed, and on whose behalf the filing is submitted, concur in the filing’s 4 content and have authorized the filing. 5 6 Dated: March 17, 2021 CLARKSON LAW FIRM, P.C.

7 /s/ Ryan J. Clarkson_______ 8 By: Ryan J. Clarkson

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27 1 The Court has read and considered the parties’ proposed stipulated protective 2 || order. 3 FOR GOOD CAUSE SHOWN, IT IS HEREBY ORDERED, THAT THE 4 ||STIPULATION IS APPROVED. 5 * Wack Dated: 3/22/2021 By: 8 Honorable Alexander McKinnon 9 United States Magistrate Judge 10 11 12 13 8 14

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 41, [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 Coleman v. Mondeléz International Inc., Case No. 2:20-cv- 9 |18100-FMO-AFM. I agree to comply with and to be bound by all 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 solemnly promise that I will not disclose in any manner any information or item that 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 ||compliance with the provisions of this Order. I further agree to submit to the 15 ||jurisdiction of the United States District Court for the Central District of California 16 || for enforcing the terms of this Stipulated Protective Order, even if such enforcement 17 || proceedings occur after termination of this action. I hereby appoint 18 [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 28 || Signature: 1k