, || Marina Lang, Cal. Bar No. 251,087 [email protected] Michael D. Harris, No. 59,470 [email protected] 2 ||Brian S. Tamsut, No. 322,780 [email protected] 3 || SOCAL IP LAw GRouPp LLP 310 North Westlake Blvd., Suite 120 4 || Westlake Village, CA 91362-3788 5 || Phone: (805) 230-1350 * Fax: (805)-230-1355 Attorneys for Plaintiff Outer Aisle Gourmet LLC 6 7 Raffi V. Zerounian, SBN 236388 [email protected] 8 |! Justin P. Thiele, SBN 311787 g || [email protected] HANSON BRIDGETT LLP 10 777 S. Figueroa Street, Suite 4200 11 || Los Angeles, CA 90017 Telephone: (213) 395-7620 12 Facsimile: (213) 395-7615 13 Heather B. Repicky (BBO# 663347) 14 | [email protected] 15 || NUTTER, MCCLENNEN & FISH, LLP Seaport West, 155 Seaport Blvd. 16 || Boston, MA 02210 17 || Phone: (617) 439-2177 Attorneys for Defendant Cali’Flour Foods, LLC 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA—WESTERN DIVISION 20 |! Outer Aisle Gourmet, LLC, 21 Plaintiff, No. 2:20-cv-8544-ODW-MAA 22 V. Stipulated Protective Order 23 || Cali’Flour Foods, LLC, Magistrate Judge Audero 24 Defendant. 25 1. PURPOSES AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential, proprie- 27 || tary, or private information for which special protection from public disclosure and 28 || from use for any purpose other than prosecuting this litigation may be warranted.

1 || Accordingly, the parties hereby stipulate to and petition the Court to enter the fol- 2 || lowing Stipulated Protective Order. The parties acknowledge that this Stipulated 3 || Protective Order does not confer blanket protections on all disclosures or responses 4 || to discovery and that the protection it affords from public disclosure and use extends 5 || only to the limited information or items that are entitled to confidential treatment un- 6 || der the applicable legal principles. The parties further acknowledge, as set forth in 7 || Section 13.3 below, that this Stipulated Protective Order does not entitle them to file 8 || confidential information under seal; Local Rule 79-5 sets forth the procedures that 9 || must be followed and the standards that will be applied when a party seeks permis- 10 || sion from the Court to file material under seal. Discovery in this action 1s likely to 11 involve production of confidential, proprietary, or private information for which spe- 12 || cial protection from public disclosure and from use for any purpose other than prose- 13 || cuting this litigation may be warranted. 14 2. GOOD CAUSE STATEMENT 15 The parties are competitors. This action is likely to involve trade secrets, cus- 16 tomer and pricing lists, and other valuable research, development, commercial, finan- 17 || cial, technical, and/or proprietary information for which special protection from public 18 || disclosure and from use for any purpose other than prosecution of this action is war- 19 ||ranted. Such confidential and proprietary materials and information consist of, among 20 || other things, confidential business or financial information, information regarding 21 confidential business practices, or other confidential research, development, or com- 22 ||mercial information (including information implicating privacy rights of third parties), 23 information otherwise generally unavailable to the public, or which may be privileged 24 || or otherwise protected from disclosure under state or federal statutes, court rules, case 25 || decisions, or common law. Accordingly, to expedite the flow of information, to facili- 26 tate the prompt resolution of disputes over confidentiality of discovery materials, to 27 || adequately protect information the parties are entitled to keep confidential, to ensure 28 that the parties are permitted reasonable necessary uses of such material in preparation

1 || for and in the conduct of trial, to address their handling at the end of the litigation, and 2 ||to serve the ends of justice, a protective order for such information is justified in this 3 || matter. It is the intent of the parties that information will not be designated as confi- 4 dential for tactical reasons and that nothing be so designated without a good faith be- 5 || lief that it has been maintained in a confidential, non-public manner, and there is good 6 ||cause why it should not be part of the public record of this case. 7 3. DEFINITIONS 8 3.1. Action: This pending federal lawsuit. 9 3.2. Challenging Party: A Party or Nonparty that challenges the designation 10 || of information or items under this Stipulated Protective Order. 11 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 12 || how it is generated, stored, or maintained) or tangible things that qualify for protection 13 |]under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 14 || Cause Statement. 15 3.4. “CONFIDENTIAL — ATTORNEYS’ EYES ONLY”: Information (regard- 16 || less of how it is generated, stored or maintained) or tangible things: extremely sensi- 17 || tive “CONFIDENTIAL” Information or tangible things, the disclosure of which to an- 18 other Party or Non-Party would create a substantial risk of serious harm that could not 19 || be avoided by less restrictive means. 20 3.5. Counsel: Outside Counsel of Record and In-House Counsel (as well as 21 their support staff). 22 3.6. Designating Party: A Party or Nonparty that designates information or 23 ||1tems that it produces in disclosures or in responses to discovery as “CONFIDEN- 24 || TIAL.” 25 3.7. Disclosure or Discovery Material: All items or information, regardless of 26 ||the medium or manner in which it is generated, stored, or maintained (including, 27 ||among other things, testimony, transcripts, and tangible things), that is produced or 28 || generated in disclosures or responses to discovery in this matter.

1 3.8. Expert: A person with specialized knowledge or experience in a matter 2 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 ||expert witness or as a consultant in this Action. 4 3.9. In-House Counsel: Attorneys who are employees of a party to this Ac- 5 ||tion. In-House Counsel does not include Outside Counsel of Record or any other out- 6 side counsel. 7 3.10. Nonparty: Any natural person, partnership, corporation, association, or 8 || other legal entity not named as a Party to this action. 9 3.11. Outside Counsel of Record: Attorneys who are not employees of a party 10 this Action but are retained to represent or advise a party to this Action and have 11 || appeared in this Action on behalf of that party or are affiliated with a law firm which 12 has appeared on behalf of that party, and includes support staff. 13 3.12. Party: Any party to this Action, including all its officers, directors, em- 14 || ployees, consultants, retained experts, In-House Counsel, and Outside Counsel of 15 || Record (and their support staffs). 16 3.13. Producing Party: A Party or Nonparty that produces Disclosure or Dis- 17 covery Material in this Action. 18 3.14. Professional Vendors: Persons or entities that provide litigation support 19 || services (e.g., photocopying, videotaping, translating, preparing exhibits or demon- 20 || strations, and organizing, storing, or retrieving data in any form or medium) and their 21 |}employees and subcontractors. 22 3.15. Protected Material: Any Disclosure or Discovery Material that is desig- 23 ||nated as “CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS EYES ONLY.” 24 3.16. Receiving Party: A Party that receives Disclosure or Discovery Material 25 || from a Producing Party. 26 4. SCOPE 27 The protections conferred by this Stipulated Protective Order cover not only 28 || Protected Material, but also (1) any information copied or extracted from Protected

1 || Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 2 |{and (3) any testimony, conversations, or presentations by Parties or their Counsel that 3 || might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the trial 5 ||judge. This Stipulated Protective Order does not govern the use of Protected Material 6 || at trial. 7 5. DURATION 8 Once a case proceeds to trial, all of the information that was designated as con- 9 || fidential or maintained pursuant to this Stipulated Protective Order becomes public 10 |}and presumptively will be available to all members of the public, including the press, 11 |]unless compelling reasons supported by specific factual findings to proceed otherwise 12 are made to the trial judge in advance of the trial. See Kamakana v. City and County of 13 || Honolulu,

(9th Cir. 2006) (distinguishing “good cause” show- 14 ||ing for sealing documents produced in discovery from “compelling reasons” standard 15 || when merits-related documents are part of court record). Accordingly, the terms of 16 this Stipulated Protective Order do not extend beyond the commencement of the trial. 17 Even after final disposition of this litigation, the confidentiality obligations im- 18 || posed by this Stipulated Protective Order shall remain in effect until a Designating 19 || Party agrees otherwise in writing or a court order otherwise directs. Final disposition 20 ||shall be deemed to be the later of (1) dismissal of all claims and defenses in this Ac- 21 tion, with or without prejudice; and (2) final judgment herein after the completion and 22 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, in- 23 cluding the time limits for filing any motions or applications for extension of time 24 || pursuant to applicable law. 25 6. DESIGNATING PROTECTED MATERIAL 26 6.1. Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Nonparty that designates information or items for protection un- 28 || der this Stipulated Protective Order must take care to limit any such designation to

1 specific material that qualifies under the appropriate standards. The Designating Party 2 ||must designate for protection only those parts of material, documents, items, or oral or 3 || written communications that qualify so that other portions of the material, documents, 4 |}items, or communications for which protection is not warranted are not swept unjusti- 5 || fiably within the ambit of this Stipulated Protective Order. 6 Mass, indiscriminate, or routinized designations are prohibited. Designations 7 that are shown to be clearly unjustified or that have been made for an improper pur- 8 || pose (e.g., to unnecessarily encumber the case development process or to impose un- 9 ||necessary expenses and burdens on other parties) may expose the Designating Party to 10 || sanctions. 11 6.2. Manner and Timing of Designations. 12 Except as otherwise provided in this Stipulated Protective Order or as otherwise 13 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 || under this Stipulated Protective Order must be clearly so designated before the mate- 15 ||rial is disclosed or produced. 16 Designation in conformity with this Stipulated Protective Order requires the fol- 17 || lowing: 18 (a) For information in documentary form (e.g., paper or electronic docu- 19 ||ments, but excluding transcripts of depositions or other pretrial or trial proceedings), 20 || that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or 21 ||“CONFIDENTIAL — ATTORNEYS EYES ONLY” to each page that contains pro- 22 tected material. If only a portion or portions of the material on a page qualifies for 23 || protection, the Producing Party also must clearly identify the protected portion(s) 24 ||(e.g., by making appropriate markings in the margins). 25 A Party or Nonparty 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 before 28 ||the designation, all of the material made available for inspection shall be deemed

1 ||““CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 2 ||copied and produced, the Producing Party must determine which documents, or por- 3 || tions thereof, qualify for protection under this Stipulated Protective Order. Then, be- 4 || fore producing the specified documents, the Producing Party must affix the legend 5 ||“CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” to each 6 || page that contains Protected Material. If only a portion or portions of the material on a 7 page qualifies for protection, the Producing Party also must clearly identify the pro- 8 || tected portion(s) (e.g., by making appropriate markings in the margins). 9 (b) For testimony given in depositions, that the Designating Party identify 10 || the Disclosure or Discovery Material (i) on the record, before the close of the deposi- 11 || tion, as protected testimony; or (11) by written notice of such designation sent within 12 || fourteen (14) calendar days after receipt of the transcript of the testimony. The parties 13 ||shall treat all deposition testimony as “CONFIDENTIAL — ATTORNEYS’ EYES 14 |} ONLY” hereunder until the expiration of fourteen (14) calendar days after the receipt 15 || of the transcript. Unless so designated, there shall be no duty to treat the transcript as 16 || confidential after the expiration of the 14-day period, unless otherwise stipulated or 17 || ordered. The parties may modify this procedure for any particular deposition or pro- 18 ceeding by agreement either on the record or in writing. 19 (c) For information produced in nondocumentary form, and for any other 20 || tangible items, that the Producing Party affix in a prominent place on the exterior of 21 ||the container or containers in which the information is stored the legend “CONFI- 22 || DENTIAL or “CONFIDENTIAL — ATTORNEYS EYES ONLY.” If only a portion 23 || or portions of the information warrants protection, the Producing Party, to the extent 24 || practicable, shall identify the protected portion(s). 25 6.3. Inadvertent Failure to Designate. 26 If timely corrected, an inadvertent failure to designate qualified information or 27 ||items does not, standing alone, waive the Designating Party’s right to secure protec- 28 |/tion under this Stipulated Protective Order for such material. Upon timely correction

1 ||of a designation, the Receiving Party must make reasonable efforts to assure that the 2 material is treated in accordance with the provisions of this Stipulated Protective Or- 3 || der. 4 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 7.1. Timing of Challenges. 6 Any Party or Nonparty may challenge a designation of confidentiality at any 7 || time that is consistent with the Court’s Scheduling Order. 8 7.2. Meet and Confer. 9 The Challenging Party shall initiate the dispute resolution process, which shall 10 || comply with Local Rule 37.1 et seg., and with Section 4 of Judge Audero’s Proce- 11 || dures (“Mandatory Telephonic Conference for Discovery Disputes’’).! 12 7.3. Burden of Persuasion. 13 The burden of persuasion in any such challenge proceeding shall be on the Des- 14 |/ignating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 15 || harass or impose unnecessary expenses and burdens on other parties) may expose the 16 || Challenging Party to sanctions. Unless the Designating Party has waived or with- 17 || drawn the confidentiality designation, all parties shall continue to afford the material 18 ||in question the level of protection to which it is entitled under the Producing Party’s 19 || designation until the Court rules on the challenge. 20 8. ACCESS TO AND USE OF PROTECTED MATERIALS 21 8.1. Basic Principles. 22 A Receiving Party may use Protected Material that is disclosed or produced by 23 another Party or by a Nonparty in connection with this Action only for prosecuting, 24 || defending, or attempting to settle this Action. Such Protected Material may be dis- 25 closed only to the categories of persons and under the conditions described in this 26 27 28 ||! Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-ma- ria-audero.

1 || Stipulated Protective Order. When the Action reaches a final disposition, a Receiving 2 || Party must comply with the provisions of Section 14 below. 3 Protected Material must be stored and maintained by a Receiving Party at a lo- 4 ||cation and in a secure manner that ensures that access is limited to the persons author- 5 |{ized under this Stipulated Protective Order. 6 8.2 Disclosure of “CONFIDENTIAL” Information or Items. 7 Unless otherwise ordered by the Court or permitted in writing by the Designat- 8 ||ing Party, a Receiving Party may disclose any information or item designated “CON- 9 || FIDENTIAL” only to: 10 (a) The Receiving Party’s Outside Counsel of Record, as well as employees 11 || of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 12 |}information for this Action; 13 (b) The officers, directors, and employees (including In-House Counsel) of 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts of the Receiving Party to whom disclosure is reasonably neces- 16 sary for this Action and who have signed the “Acknowledgment and Agreement to Be 17 || Bound” (Exhibit A); 18 (d) The Court and its personnel; 19 (ec) Court reporters and their staff; 20 (f) | Professional jury or trial consultants, mock jurors, and Professional Ven- 21 dors to whom disclosure is reasonably necessary for this Action and who have signed 22 || the “Acknowledgment and Agreement to be Bound” (Exhibit A); 23 (g) The author or recipient of a document containing the information or a 24 || custodian or other person who otherwise possessed or knew the information; 25 (h) During their depositions, witnesses and attorneys for witnesses in the Ac- 26 tion to whom disclosure is reasonably necessary provided: (i) the deposing party re- 27 || quests that the witness sign the “Acknowledgment and Agreement to Be Bound” (Ex- 28

1 || hibit A); and (11) the witness will not be permitted to keep any confidential infor- 2 || mation unless they sign the “Acknowledgment and Agreement to Be Bound,” unless 3 || otherwise agreed by the Designating Party or ordered by the Court. Pages of tran- 4 scribed deposition testimony or exhibits to depositions that reveal Protected Material 5 ||may be separately bound by the court reporter and may not be disclosed to anyone ex- 6 ||cept as permitted under this Stipulated Protective Order; and 7 (i) | Any mediator or settlement officer, and their supporting personnel, mutu- 8 ally agreed upon by any of the parties engaged in settlement discussions. 9 8.3. Disclosure of “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” Infor- 10 mation or Items. 11 Unless otherwise ordered by the Court or permitted in writing by the Designat- 12 |}ing Party, a Receiving Party may disclose any information or item designated “CON- 13 || FIDENTIAL— ATTORNEYS’ EYES ONLY” only to: 14 (a) The Receiving Party’s Outside Counsel of Record in this Action, as 15 well as employees of said Outside Counsel of Record to whom it is reasonably 16 necessary to disclose the information for this Action; 17 (b) Experts (as defined in this Order) of the Receiving Party to whom dis- 18 closure is reasonably necessary for this Action and who have signed the “Ac- 19 knowledgment and Agreement to Be Bound” (Exhibit A); 20 (c) The Court and its personnel; 21 (d) Court reporters and their staff; 22 (ec) Professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who 24 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (f) The author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information; 27 and 28

1 (g) Any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRO- 4 DUCED IN OTHER LITIGATION 5 If a Party is served with a subpoena or a court order that compels disclosure of 6 any information or items designated in this Action as “CONFIDENTIAL” or “CON- 7 || FIDENTIAL— ATTORNEYS’ EYES ONLY,” that Party must: 8 (a) Promptly notify in writing the Designating Party. Such notification shall 9 ||include a copy of the subpoena or court order; 10 (b) Promptly notify in writing the party who caused the subpoena or order to 11 |]issue in the other litigation that some or all of the material covered by the subpoena or 12 || order is subject to this Stipulated Protective Order. Such notification shall include a 13 || copy of this Stipulated Protective Order; and 14 (c) | Cooperate with respect to all reasonable procedures sought to be pursued 15 || by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with 17 ||the subpoena or court order shall not produce any information designated in this ac- 18 || tion as “CONFIDENTIAL” or “CONFIDENTIAL— ATTORNEYS’ EYES ONLY, 19 || before a determination by the Court from which the subpoena or order issued, unless 20 the Party has obtained the Designating Party’s permission. The Designating Party 21 ||shall bear the burden and expense of seeking protection in that court of its confidential 22 material, and nothing in these provisions should be construed as authorizing or en- 23 || couraging a Receiving Party in this Action to disobey a lawful directive from another 24 || court. 25 26 27 28

1 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE PRO- 2 DUCED IN THIS LITIGATION 3 10.1. Application. 4 The terms of this Stipulated Protective Order are applicable to information pro- 5 ||duced by a Nonparty in this Action and designated as “CONFIDENTIAL” or “CON- 6 || FIDENTIAL— ATTORNEYS’ EYES ONLY.” Such information produced by Non- 7 || parties in connection with this Action is protected by the remedies and relief provided 8 || by this Stipulated Protective Order. Nothing in these provisions should be construed 9 ||as prohibiting a Nonparty from seeking additional protections. 10 10.2 Notification. 11 In the event that a Party is required, by a valid discovery request, to produce a 12 || Nonparty’s confidential information in its possession, and the Party is subject to an 13 ||agreement with the Nonparty not to produce the Nonparty’s confidential information, 14 || then the Party shall: 15 (a) Promptly notify in writing the Requesting Party and the Nonparty that 16 |}some or all of the information requested is subject to a confidentiality agreement with 17 Nonparty; 18 (b) Promptly provide the Nonparty with a copy of the Stipulated Protective 19 || Order in this Action, the relevant discovery request(s), and a reasonably specific de- 20 || scription of the information requested; and 21 (c) Make the information requested available for inspection by the Nonparty, 22 ||if requested. 23 10.3. Conditions of Production. 24 If the Nonparty fails to seek a protective order from this Court within fourteen 25 ||(14) days after receiving the notice and accompanying information, the Receiving 26 || Party may produce the Nonparty’s confidential information responsive to the discov- 27 || ery request. If the Nonparty timely seeks a protective order, the Receiving Party shall 28

1 |]not produce any information in its possession or control that is subject to the confiden- 2 tiality agreement with the Nonparty before a determination by the Court. Absent a 3 ||court order to the contrary, the Nonparty shall bear the burden and expense of seeking 4 protection in this Court of its Protected Material. 5 11... UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 || Protected Material to any person or in any circumstance not authorized under this 8 || Stipulated Protective Order, the Receiving Party immediately must (1) notify in writ- 9 the Designating Party of the unauthorized disclosures, (2) use its best efforts to re- 10 || trieve all unauthorized copies of the Protected Material, (3) inform the person or per- 11 |}sons to whom unauthorized disclosures were made of all the terms of this Stipulated 12 || Protective Order, and (4) request such person or persons to execute the “Acknowledg- 13 ||ment and Agreement to be Bound” (Exhibit A). 14 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHER- 15 WISE PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain inadvert- 17 || ently produced material is subject to a claim of privilege or other protection, the obli- 18 || gations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 19 ||26(b)(5)(B). This provision is not intended to modify whatever procedure may be es- 20 || tablished in an e-discovery order that provides for production without prior privilege 21 ||/review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties 22 ||reach an agreement on the effect of disclosure of a communication or information 23 || covered by the attorney-client privilege or work product protection, the parties may 24 ||incorporate their agreement in the Stipulated Protective Order submitted to the Court. 25 13. MISCELLANEOUS 26 13.1. Right to Further Relief. 27 Nothing in this Stipulated Protective Order abridges the right of any person to 28 seek its modification by the Court in the future.

1 13.2. Right to Assert Other Objections. 2 By stipulating to the entry of this Stipulated Protective Order, no Party waives 3 || any right it otherwise would have to object to disclosing or producing any information 4 |/or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 5 || Party waives any right to object on any ground to use in evidence any of the material 6 ||covered by this Stipulated Protective Order. 7 13.3. Filing Protected Material. 8 A Party that seeks to file under seal any Protected Material must comply with 9 || Local Rule 79-5. Protected Material may only be filed under seal pursuant to a court 10 || order authorizing the sealing of the specific Protected Material at issue. If a Party’s re- 11 || quest to file Protected Material under seal is denied by the Court, then the Receiving 12 || Party may file the information in the public record unless otherwise instructed by the 13 || Court. 14 14. FINAL DISPOSITION 15 After the final disposition of this Action, within sixty (60) days of a written re- 16 || quest by the Designating Party, each Receiving Party must return all Protected Mate- 17 rial to the Producing Party or destroy such material. As used in this subdivision, “all 18 || Protected Material” includes all copies, abstracts, compilations, summaries, and any 19 || other format reproducing or capturing any of the Protected Material. Whether the Pro- 20 tected Material is returned or destroyed, the Receiving Party must submit a written 21 || certification to the Producing Party (and, if not the same person or entity, to the Desig- 22 ||nating Party) by the 60-day deadline that affirms that the Receiving Party has not re- 23 tained any copies, abstracts, compilations, summaries or any other format reproducing 24 || or capturing any of the Protected Material. Notwithstanding this provision, Counsel is 25 || entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 26 ||and hearing transcripts; legal memoranda; correspondence; deposition and trial exhib- 27 ||1ts; expert reports; attorney work product; and consultant and expert work product, 28

1 |}even if such materials contain Protected Material. Any such archival copies that con- 2 ||tain or constitute Protected Material remain subject to this Stipulated Protective Order 3 as set forth in Section 5. 4 15. VIOLATION 5 Any violation of this Stipulated Order may be punished by any and all appropri- 6 measures including, without limitation, contempt proceedings and/or monetary 7 || sanctions. 8 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 11 || May 4, 2021 /s/ Marina Lan Marina Lang 12 SOCAL IP LAW GROUP LLP B Attorney for Plaintiff Outer Aisle Gourmet LLC 14 Pursuant to Local Rule 5-4.3.4, Marina Lang attests that the following signatory 15 |}concurs in the filing’s content and has authorized the filing. 16 May 4, 2021 /s/ Raffi V. Zerounian , Raffi V. Zerounian M7 HANSON BRIDGETT LLP 18 Attorney for Defendant Cali’Flour Foods, LLC 19 20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED, ‘= 21 a9 |[Dated:__ 05/06/2021 Ye Maria A. ero 23 United States Magistrate Judge 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I have read in its 5 |{entirety and understand the Stipulated Protective Order that was issued by the United 6 States District Court for the Central District of California on [date] in 7 case of Outer Aisle Gourmet, LLC v. Cali’Flour Foods, LLC, No. 2:20-cv-8544- 8 || ODW-MAA. I agree to comply with and to be bound by all the terms of this Stipu- 9 || lated Protective Order, and I understand and acknowledge that failure to so comply 10 || could expose me to sanctions and punishment in the nature of contempt. I solemnly 11 || promise that I will not disclose in any manner any information or item that 1s subject 12 || to this Stipulated Protective Order to any person or entity except in strict compliance 13 || with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 || for the Central District of California for the purpose of enforcing the terms of this 16 || Stipulated Protective Order, even if such enforcement proceedings occur after termi- 17 nation of this action. I hereby appoint [full name] □□ 18 [address and telephone number] as my 19 || California agent for service of process in connection with this action or any proceed- 20 ||ings related to enforcement of this Stipulated Protective Order. 21 || Signature: 22 || Printed Name: 23 || Date: 24 || City and State where Sworn and Signed: 03 5147589.1

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