1 || EDWIN PAIRAVI, Bar No. 257290 [email protected] NOTE: CHANGES HAVE BEEN 2 || JOSHUA M. MOHRSAZ, Bar No. 307759 MADE TO THIS DOCUMENT 3 [email protected] PAIRAVI LAW, P.C. See 44 3, 14 4 || 1875 Century Park East, Suite 480 Los Angeles, California 90067 5 || Telephone: (310) 789-2063 6 Facsimile: (310) 789-2064 7 || Attorneys for Plaintiff, MAURICE DIARIAN 8 9 || RYAN L. EDDINGS, Bar No. 256519 reddings @littler. com 10 || VAN A M. COHN, Bar No. 314619 reglin@t ittler.com 11 || LITTLER MENDELSON, P.C. 5200 North Palm Avenue, Suite 302 12 || Fresno, CA 93704.2225 felephone: 8399) 244-7500 13 || Fax No.: (559) 244-7525 14 || Attorneys for Defendant, FIRST TRANSIT, INC. 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 || MAURICE DIARIAN, an Case No. 2:20-cv-02957-FMO (AFMx) Individual, 19 JPROPOSED!| ORDER GRANTING Plaintiff, PARTIES’ STIPULATED 20 PROTECTIVE ORDER V. 21 FIRST TRANSIT, INC., a Delaware 22 || Corporation; and DOES 1| through 50, inclusive, 23 Defendants. 24 25 26 27 28 P.C. 4898-8017-6354.1 070993.1157

1] 1. A. PURPOSES AND LIMITATIONS 2 Disclosure and discovery activity in this action are likely to involve 3 || production of confidential, proprietary, or private information for which special 4 || protection from public disclosure and from use for any purpose other than prosecuting 5 || this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 || petition the court to enter the following Stipulated Protective Order. The parties 7 || acknowledge that this Order does not confer blanket protections on all disclosures or 8 || responses to discovery and that the protection it affords from public disclosure and use 9 || extends only to those limited information or items that are entitled to confidential 10 || treatment under the applicable legal principles. The parties further acknowledge that 11 || this Order does not constitute waiver of any right, privilege, or objection with respect 12 || to confidential, proprietary, or private information. The parties further acknowledge, 13 |) as set forth in Section 12.3 below, that this Stipulated Protective Order requires them 14 || to file confidential information under seal; Local Rule 79-5 sets forth the procedures 15 || that must be followed and the standards that will be applied when a party seeks 16 || permission from the court to file materials under seal. 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve commercial, financial, proprietary, and/or 19 || other private information for which special protection from public disclosure and from 20 || use for any purpose other than prosecution of this action is warranted. Such 21 || confidential, proprietary, and/or private materials and information consist of, among 22 || other things, confidential business or financial information, information regarding 23 || confidential business practices, or other confidential commercial information 24 || (including information that could potentially implicate the privacy rights of non- 25 || parties), information otherwise generally unavailable to the public, or which may be 26 || privileged or otherwise protected from disclosure under state or federal statutes, court 27 || rules, case decisions, or common law. Accordingly, to expedite the flow of 28 || information, to facilitate the prompt resolution of disputes over confidentiality of © 4828-8017-6354.1 070993.1157 2.

1 || discovery materials, to adequately protect information the parties are entitled to keep 2 || confidential, to ensure that the parties are permitted reasonable necessary uses of such 3 || material in preparation for and in the conduct of trial, to address their handling at the end of the litigation, and serve the ends of justice, a protective order for such 5 || information is justified in this matter. It is the intent of the parties that information 6 || will not be designated as confidential for tactical reasons and that nothing be so 7 || designated without a good faith belief that it has been maintained in a confidential, 8 || non-public manner, and there is good cause why it should not be part of the public 9 || record of this case. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 12 The parties further acknowledge, as set forth in Section 12.3, below, that 13 || this Stipulated Protective Order does not entitle them to file confidential information 14 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 15 || the standards that will be applied when a party seeks permission from the court to file 16 || material under seal. 17 There is a strong presumption that the public has a right of access to 18 |) judicial proceedings and records in civil cases. In connection with non-dispositive 19 || motions, good cause must be shown to support a filing under seal. See Kamakana v. 20 || City and County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. 21 || Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 22 || Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated protective 23 || orders require good cause showing), and a specific showing of good cause or 24 || compelling reasons with proper evidentiary support and legal justification, must be 25 || made with respect to Protected Material that a party seeks to file under seal. The 26 || parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 27 || does not—without the submission of competent evidence by declaration, establishing 28 || that the material sought to be filed under seal qualifies as confidential, privileged, or © 4828-8017-6354.1 070993.1157 3,

1 || otherwise protectable—constitute good cause. 2 Further, if a party requests sealing related to a dispositive motion or trial, 3 || then compelling reasons, not only good cause, for the sealing must be shown, and the 4 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 5 || See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each 6 || item or type of information, document, or thing sought to be filed or introduced under 7 || seal in connection with a dispositive motion or trial, the party seeking protection must 8 || articulate compelling reasons, supported by specific facts and legal justification, for 9 || the requested sealing order. Again, competent evidence supporting the application to 10 || file documents under seal must be provided by declaration. 11 Any document that is not confidential, privileged, or otherwise 12 || protectable in its entirety will not be filed under seal if the confidential portions can be 13 || redacted. If documents can be redacted, then a redacted version for public viewing, 14 || omitting only the confidential, privileged, or otherwise protectable portions of the 15 || document, shall be filed. Any application that seeks to file documents under seal in 16 |) their entirety should include an explanation of why redaction 1s not feasible. 17 2. DEFINITIONS 18 2.0 Action: United States District Court, Central District of California 19 || Case No. 2:20-cv-02957-FMO (AFMx). 20 2.1 Challenging Party: a Party or Non-Party that challenges the 21 || designation of information or items under this Order. 22 2.2. “CONFIDENTIAL” Information or Items: information (regardless 23 || of how it is generated, stored or maintained) or tangible things that qualify for 24 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 25 || Good Cause Statement. For the purposes of this matter, Confidential Information also 26 || includes any surveillance footage produced in this matter as well as personnel file of 27 || third-parties, whether used in whole or in part. 28 Pai 4828-8017-6354.1 070993.1157 4.

1 2.3. Counsel (without qualifier): Outside Counsel of Record and 2 || House Counsel (as well as their support staff). 3 2.4 Designating Party: a Party or Non-Party that designates 4 || information or items that it produces in disclosures or in responses to discovery as 5 | “CONFIDENTIAL.” 6 2.5 Disclosure _or Discovery Material: all items or information, 7 || regardless of the medium or manner in which it is generated, stored, or maintained 8 || (including, among other things, testimony, transcripts, and tangible things), that are 9 || produced or generated in disclosures or responses to discovery in this matter. 10 2.6 Expert: a person with specialized knowledge or experience in a 11 || matter pertinent to the litigation who has been retained by a Party or its counsel to 12 || serve as an expert witness or as a consultant in this Action. 13 2.7 House Counsel: attorneys who are employees of a party to this 14 || Action. House Counsel does not include Outside Counsel of Record or any other 15 || outside counsel. 16 2.8 Non-Party: any natural person, partnership, corporation, 17 || association, or other legal entity not named as a Party to this Action. 18 2.9 Outside Counsel of Record: attorneys who are not employees of a 19 || party to this action but are retained to represent or advise a party to this Action and 20 || have appeared in this Action on behalf of that party or are affiliated with or employed 21 || by a law firm which has appeared on behalf of that party. 22 2.10 Party: any Party to this Action, including all of its officers, 23 || directors, employees, consultants, retained experts, and Outside Counsel of Record 24 || (and their support staffs). 25 2.11 Producing Party: a Party or Non-Party that produces Disclosure or 26 || Discovery Material in this action. 27 2.12 Professional Vendors: persons or entities that provide litigation 28 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or © 4828-8017-6354.1 070993.1157 5.

1 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 || and their employees and subcontractors. 3 2.13 Protected Material: any Disclosure or Discovery Material that is 4 || designated as “CONFIDENTIAL.” 5 2.14 Receiving Party: a Party that receives Disclosure or Discovery 6 || Material from a Producing Party. 7 || 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 || Protected Material (as defined above), but also (1) any information copied or extracted 10 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of 11 || Protected Material; and (3) any testimony, conversations, or presentations by Parties 12 || or their Counsel that might reveal Protected Material. However, the protections 13 || conferred by this Stipulation and Order do not cover the following information: (a) 14 || any information that is in the public domain at the time of disclosure to a Receiving 15 || Party or becomes part of the public domain after its disclosure to a Receiving Party as 16 || aresult of publication not involving a violation of this Order, including becoming part 17 || of the public record through trial or otherwise; and (b) any information known to the 18 || Receiving Party prior to the disclosure or obtained by the Receiving Party after the 19 || disclosure from a source who obtained the information lawfully and under no 20 || obligation of confidentiality to the Designating Party. Any use of Protected Material at 21 || trial shall be governed by a separate agreement or order. This Order does not govern 22 || the use of Protected Information at trial. 23 |) 4. DURATION 24 Even after the final disposition of this litigation, the confidentiality 25 || obligations imposed by this Order shall remain in effect until a Designating Party 26 || agrees otherwise in writing or a court order directs otherwise. Final disposition shall 27 || be deemed to be the later of (1) dismissal of all claims and defenses in this action, 28 || with or without prejudice; and (2) final judgment herein after the completion and © 4828-8017-6354.1 070993.1157 6.

1 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 2 | including time limits for filing any motion or applications for extension of time 3 || pursuant to applicable law. 4] 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise _of Restraint and Care in Designating Materials for 6 || Protection. Each Party or Non-Party that designates information or items for 7 || protection under this Order must take care to limit any such designation to specific 8 || material that qualifies under the appropriate standards. The Designating Party must 9 || designate for protection only those parts of material, documents, items, or oral or 10 || written communications that qualify — so that other portions of the materials, 11 || documents, items, or communications for which protection is not warranted are not 12 || swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized 13 || designations are prohibited. Designations that are shown to be clearly unjustified or 14 || that have been made for an improper purpose (e.g., to unnecessarily encumber the 15 || case development process or to impose unnecessary expenses and burdens on other 16 || parties) expose the Designating Party to sanctions. If it comes to a Designating Party’s 17 || attention that information or items that it designated for protection do not qualify for 18 || protection, that Designated Party must promptly notify all other Parties that it is 19 || withdrawing the mistaken designation. 20 5.2 Manner and Timing of Designation. Except as otherwise provided 21 || in this Order (see, e.g., second paragraph of section 5.2(a) below) or as otherwise 22 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 || under this Order must be clearly so designated before the material is disclosed or 24 || produced. Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 || documents, but excluding transcripts of depositions or other pretrial or trial 27 || proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each 28 || page that contains protected materials. If only a portion or portions of the material on © 4828-8017-6354.1 070993.1157 7.

1 || a page qualifies for protection, the Producing Party also must clearly identify the 2 || protected portions(s) (e.g., by making appropriate markings in the margins). A Party 3 || or Non-Party that makes original documents or materials available for inspection need 4 || not designate them for protection until after the inspecting Party has indicated which 5 || material it would like copied and produced. During the inspection and before the 6 || designation, all of the material made available for inspection shall be deemed 7 | “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 8 || copied and produced, the Producing Party must determine which documents, or 9 || portions thereof, qualify for protection under this Order. Then, before producing the 10 || specified documents, the Producing Party must affix the “CONFIDENTIAL” legend 11 || to each page that contains Protected Material. If only a portion of portions of the 12 || material qualifies for protection, the Producing Party must clearly identify the 13 || protected portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in deposition or in other pretrial or trial 15 || proceedings, that the Designating Party identify on the record, before the close of the 16 || deposition, hearing, or other proceeding, all protected testimony. 17 (c) for information produced in some form other than documentary 18 || and for any other tangible items, that the Producing Party affix in a prominent place 19 || on the exterior of the container or containers in which the information or item is stored 20 || the legend “CONFIDENTIAL.” If only a portion or portions of the information or 21 || item warrant protection, the Producing Party, to the extent practicable, shall identify 22 || the protected portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 || failure to designate qualified information or items does not, standing alone, waive the 25 || Designating Party’s right to secure protection under this Order for such material. 26 || Upon timely correction of a designation, the Receiving Party must make reasonable 27 || efforts to assure that the material is treated in accordance with the provisions of this 28 || Order. © 4828-8017-6354.1 070993.1157 8.

1 2 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 4 || designation of confidentiality at any time. Unless a prompt challenge to a Designating 5 || Party’s confidentiality designation is necessary to avoid foreseeable delay of the 6 || litigation, a Party does not waive its right to challenge a confidentiality designation by 7 || electing not to mount a challenge promptly after the original designation is disclosed. 8 6.2. Meet and Confer. The Challenging Party shall initiate the dispute 9 || resolution process under Local Rule 37-1 et seq. 10 6.3. Joint Stipulation. Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2.

13 6.4 The burden of persuasion in any such challenge proceeding shall be on 14 || the Designating Party. Frivolous challenges, and those made for an improper purpose 15 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 16 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 17 || the confidentiality designation, all parties shall continue to afford the material in 18 || question the level of protection to which it is entitled under the Designating Party’s 19 || designation until the court rules on the challenge. 20 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that it 22 || disclosed or produced by another Party or by a Non-Party in connection with this case 23 || only for prosecuting, defending, or attempting to settle this litigation. Such Protected 24 || Material may be disclosed only to the categories of persons and under the conditions 25 || described in this Order. When the litigation has been terminated, a Receiving Party 26 || must comply with the provisions of section 13 below (FINAL DISPOSITION). 27 Protected Material must be stored and maintained by the Receiving Party 28 || at a location and in a secure manner that ensures that access is limited to the persons © 4828-8017-6354.1 070993.1157 9,

1 || authorized under this Order. 2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 || otherwise ordered by the court or permitted in writing by the Designating Party, a 4 || Receiving Party may disclose any information or item designated “CONFIDENTIAL” 5 || only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this action, as 7 || well as employees of said Outside Counsel of Record to whom it is reasonably 8 || necessary to disclose the information for this litigation; 9 (b) the officers, directors, and employees (including House Counsel) 10 || of Receiving Party to whom it is reasonably necessary to disclose the information for 11 || this litigation and who have signed the “Acknowledgement and Agreement to Be 12 || Bound (Exhibit A); 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 || disclosure is reasonably necessary for this litigation and who have signed the 15 || “Acknowledgement and Agreement to Be Bound (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff, professional jury or trial consultants, 18 || mock jurors, and Professional Vendors to whom disclosure is reasonably necessary 19 || for this litigation and who have signed “Acknowledgement to Be Bound” (Exhibit A). 20 (f) during their depositions, witnesses in this action to whom it is 21 || reasonably necessary to disclose the information for this litigation and who have 22 || signed the “Acknowledgement to Be Bound” (Exhibit A). However, unless otherwise 23 || agreed by the Designating Party or ordered by the court, pages of transcribed 24 || deposition testimony or exhibits to depositions that reveal Protected Material must be 25 || separately bound by the court reporter and may not be disclosed to anyone except as 26 || permitted under this Stipulated Protective Order. 27 (g) the author or recipient of a document containing the information or 28 || a custodian or other person who otherwise possessed or knew the information. von 4828-8017-6354.1 070993.1157 10.

1] 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 | IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other 4 || litigation that compels disclosure of any information or items designated in this action 5 | as “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 || shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or 9 || order to issue in the other litigation some or all of the material covered by the 10 || subpoena or order is subject to this Protective Order. Such notification shall include a 11 || copy of this Stipulated Protective Order; 12 (c) not produce any Protected Materials subject to the subpoena prior 13 || to the date of production indicated in the subpoena; and 14 (d) cooperate with respect to all reasonable procedures sought to be 15 || pursued by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served 17 || with the subpoena or court order shall not produce any information designated in this 18 || action as “CONFIDENTIAL” before a determination by the court from which the 19 || subpoena or order issued, unless the Party has obtained the Designating Party’s 20 || permission. The Designating Party shall bear the burden and expense of seeking 21 || protection in the court of its confidential material — and nothing in these provisions 22 || should be construed as authorizing or encouraging a Receiving Party in this action to 23 || disobey a lawful directive from another court. 24 |) 9. A__NON-PARTY’S PROTECTED MATERIAL SOUGHT □□ □□ 25 || PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by 27 || a Non-Party in this action and designated as “CONFIDENTIAL.” Such information 28 || produced by Non-Parties in connection with this litigation is protected by the © 4828-8017-6354.1 070993.1157 11.

1 || remedies and relief provided by this Order. Nothing in these provisions should be 2 || construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, 4 || to produce a Non-Party’s confidential information in its possession, and the Party is 5 || subject to an agreement with the Non-Party not to produce the Non-Party’s 6 || confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 || that some or all of the information requested in subject to a confidentiality agreement 9 |) with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 || Protective Order in this litigation, the relevant discovery request(s), and a reasonably 12 || specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 || Non-Party. 15 (c) Ifthe Non-Party fails to object or seek a protective order from this 16 || court within 14 days of receiving the notice and accompanying information, the 17 || Receiving Party may produce the Non-Party’s confidential information responsive to 18 || the discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 || Party shall not produce any information in its possession or control that is subject to 20 || the confidentiality agreement with the Non-Party before a determination by the court. 21 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 22 || of seeking protection in this court of its Protected Material. 23 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has 25 || disclosed Protected Material to any person or in any circumstance not authorized 26 || under this Stipulated Protective Order, the Receiving Party must immediately (a) 27 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its best 28 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the von 4828-8017-6354.1 070993.1157 12.

1 || person or persons to whom authorized disclosures were made of all of the terms of 2 || this Order, and (d) request such person or persons to execute the “Acknowledgement 3 || and Agreement to Be Bound” that is attached hereto as Exhibit A. 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 | PROTECTED MATERIALS 6 When a Producing Party gives notice to a Receiving Party that certain 7 || inadvertently produced material is subject to a claim of privilege or other protection, 8 || the obligations of the Receiving Party are those set forth in Federal Rules of Civil 9 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 || may be established in e-discovery order that provides for production without prior 11 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 || parties reach an agreement on the effect of disclosure of a communication or 13 || information covered by the attorney-client privilege or work product protection, the 14 || parties may incorporate their agreement in the stipulated protective order submitted to 15 || the court. 16 | 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 18 || person to seek its termination or modification by the court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 || Protective Order no Party waives any right, privilege, or protection it otherwise would 21 || have to object to disclosing or producing any information or item. Similarly, no Party 22 || waives any right to object on any ground to use in evidence of any of the material 23 || covered by this Protective Order. 24 12.3 Filing Protected Material. Protected Material must be filed under seal. 25 || A Party that seeks to file under seal any Protected Material must comply with United 26 || States District Court Central District of California Local Rule 79-5. 27 28 4828-8017-6354.1 070993.1157 13.

1] 13. FINAL DISPOSITION 2 Within 60 days after final disposition of this action, as defined in 3 || paragraph 4, each Receiving Party must return all Protected Material to the Producing 4 || Party or destroy such material. As used in this subdivision, “all Protected Material” 5 | includes all copies, abstracts, compilations, summaries, and any other format 6 || reproducing or capturing any of the Protected Material. 7 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 the entire case file, including but not limited to all 15 || pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 16 || correspondence, deposition and trial exhibits, expert reports, attorney work product, 17 || and consultant and expert work product, even if such materials contain Protected 18 || Material. Any such archival copies that contain or constitute Protected Material 19 || remain subject to this Protective Order as set forth in Section 4 (DURATION). 20 || 14. The Court retains the ability to remedy and/or punish violations of this Order. 21 97 || PURSUANT TO STIPULATION AND FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 . 24 (Wy 95 || DATED: 3/26/2021 Alexander F. MacKinnon 26 United States Magistrate Judge 27 28 4828-8017-6354.1 070993.1157 14.

1 2 3 EXHIBIT A 4 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 5 6 I, [print or type full name], of 7 || [print or type full address], declare under the penalty of perjury that I have read in its 8 || entirety and understand the Stipulated Protective Order that was issued by the United 9 || States District Court for the Central District of California on [___] in the case of 10 || Maurice Diarian vy. First Transit, Inc., U.S. District Court for the Central District of 11 || California, Case No. 2:20-cv-02957-FMO (AFMx). I agree to comply with and to be 12 | bound by all the terms of this Stipulated Protective Order and I understand and 13 || acknowledge that failure to so comply could expose me to sanctions and punishment 14 || in the nature of contempt. I solemnly promise that I will not disclose in any manner 15 || any information or item that is subject to this Stipulated Protective Order to any 16 || person or entity except in strict compliance with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States District Court 18 || for the Central District of California for the purpose of enforcing the terms of the 19 || Stipulated Protective Order, even if such enforcement proceedings occur after the 20 || termination of this action. 21 I hereby appoint [print or type full name] of 22 || [print or type full address and telephone number] as my California agent for service of 23 || process in connection with this action or any proceedings related to enforcement of 24 || this Stipulated Protective Order. 25 26 || Date: 27 || City and State Where Sworn and Signed: 28 || Printed Name: 4828-8017-6354.1 070993.1157 15.

1 || Signature: 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 28 von 4828-8017-6354.1 070993.1157 16.