1 HILL, FARRER & BURRILL LLP Kevin H. Brogan (Bar No. 089427) 2 Email: [email protected] William A. Meyers (Bar No. 266322) 3 Email: [email protected] 4 300 South Grand Avenue, 37th Floor Los Angeles, CA 90071-3147 5 Telephone: (213) 620-0460 Fax: (213) 624-4840 6 Attorneys for Defendants 7 Allen Matkins Leck Gamble Mallory & 8 Natsis, LLP and Clark Libenson 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 JAMES D. MCCOOL, CASE NO. 5:19-cv-02499 PSG (KKx) 13 Plaintiff, [PROPOSED] STIPULATED 14 PROTECTIVE ORDER vs. 15 Hon. Philip S. Gutierrez ALLEN MATKINS LECK 16 GAMBLE MALLORY & NATSIS,

17 LLP; CLARK LIBENSON; and DOES 1-10, inclusive,

18 Defendants. 19

20

21 22

23 Complaint Filed: December 30, 2019 24 Trial Date: January 25, 2022

25 26

27 28 1 This proposed stipulated protective order is entered into pursuant to Local 2 Rule 7-1 by and between Plaintiff James D. McCool (“Plaintiff”) and defendants 3 Allen Matkins Leck Gamble Mallory & Natsis, LLP and Clark Libenson 4 (collectively, the “Allen Matkins Defendants”), by and through their respective 5 counsel of record. 6 1. GENERAL 7 1.1 Purposes and Limitations. Discovery in this action is likely to involve 8 production of confidential, proprietary, or private information for which special 9 protection from public disclosure and from use for any purpose other than 10 prosecuting this litigation may be warranted. Accordingly, the parties hereby 11 stipulate to and petition the Court to enter the following Stipulated Protective 12 Order. The parties acknowledge that this Order does not confer blanket protections 13 on all disclosures or responses to discovery and that the protection it affords from 14 public disclosure and use extends only to the limited information or items that are 15 entitled to confidential treatment under the applicable legal principles. The parties 16 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 17 Protective Order does not entitle them to file confidential information under seal; 18 Civil Local Rule 79-5 sets forth the procedures that must be followed and the 19 standards that will be applied when a party seeks permission from the court to file 20 material under seal. 21 1.2 Good Cause Statement. This is an action for alleged fraudulent 22 concealment in connection with Plaintiff’s purchase of a minority interest in an 23 aviation management services business, Desert Jet Holdings, LLC (“Desert Jet 24 Holdings”). This action may involve valuable and proprietary commercial, 25 financial, operational, research, development, and other confidential business 26 information for which special protection from public disclosure and from use for 27 any purpose other than prosecution of this action is warranted. In particular, the 28 parties anticipate that discovery will involve business records and other financial 1 and operational information of Desert Jet Holdings and its subsidiaries, including 2 investor records, income and balance sheet data, and tax information. 3 As a result, the parties anticipate that certain financial information that is not 4 otherwise publicly available may be produced in discovery in this litigation, and 5 that the public disclosure of such information might potentially harm the business 6 interests and/or competitive standing of Desert Jet Holdings and its subsidiaries. 7 See, e.g., Hodges v. Apple Inc., Case No. 13-cv-01128,

(N.D. 8 Cal. Nov. 18, 2013) (“Given the nature of Exhibit 4—a spreadsheet that contains 9 financial information—the Court is persuaded that there are compelling reasons to 10 file it under seal.”); see also SMD Software, Inc. v. EMove, Inc., Case No. 5:08-CV- 11 403-FL,

, at *3 (E.D.N.C. Mar. 15, 2013) (“Defendants urge that 12 these documents contain confidential information such as…expense information, 13 revenue and growth information, and relative market share.…the court agrees that 14 they too contain confidential information, the publication of which may harm the 15 parties’ business interests and competitive standing. This risk of harm outweighs 16 the public’s interest in accessing the documents.”). 17 Given the possibility of harm to business interests and competitive standing 18 in the event of public disclosure, and because it would be unduly burdensome for 19 the Court to become overly emmeshed in determining for discovery purposes the 20 confidentiality of each and every covered document or particular information 21 produced in discovery, good cause exists to enter this Stipulated Protective Order. 22 Accordingly, to expedite the flow of information, to facilitate the prompt 23 resolution of disputes over confidentiality of discovery materials, to adequately 24 protect information the parties are entitled to keep confidential, to ensure that the 25 parties are permitted reasonable necessary uses of such material in preparation for 26 and in the conduct of trial, to address their handling at the end of the litigation, and 27 serve the ends of justice, a protective order for such information is justified in this 28 matter. It is the intent of the parties that information will not be designated as 1 confidential for tactical reasons and that nothing be so designated without a good 2 faith belief that it has been maintained in a confidential, non-public manner, and 3 there is good cause why it should not be part of the public record of this case. 4 2. DEFINITIONS 5 2.1 Action: this pending federal lawsuit, styled James D. McCool v. 6 Denise Wilson, et al., United States District Court for the Central District of 7 California, Case No. 5:19-cv-02499 PSG (KKx). 8 2.2 Challenging Party: a Party or Non-Party that challenges the 9 designation of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for 12 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced 22 or generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.8 House Counsel: attorneys who are employees of a party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside 28 counsel. 1 2.9 Non-Party: any natural person, partnership, corporation, association, 2 or other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a 4 party to this Action but are retained to represent or advise a party to this Action and 5 have appeared in this Action on behalf of that party or are affiliated with a law firm 6 which has appeared on behalf of that party, and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation 13 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery 19 Material from a Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or 23 extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 compilations of Protected Material; and (3) any testimony, conversations, or 25 presentations by Parties or their Counsel that might reveal Protected Material. The 26 protections conferred by this Stipulation and Order do not extend to information or 27 documents obtained elsewhere, i.e., from sources other than through the discovery 28 process. Any use of Protected Material at trial shall be governed by the orders of 1 the trial judge. This Order does not govern the use of Protected Material at trial. 2 4. DURATION 3 Once a case proceeds to trial, all of the information that was designated as 4 confidential or maintained pursuant to this protective order becomes public and will 5 be presumptively available to all members of the public, including the press, unless 6 compelling reasons supported by specific factual findings to proceed otherwise are 7 made to the trial judge in advance of the trial. See Kamakana v. City and County of 8 Honolulu,

(9th Cir. 2006) (distinguishing “good cause” 9 showing for sealing documents produced in discovery from “compelling reasons” 10 standard when merits-related documents are part of court record). Accordingly, the 11 terms of this protective order do not extend beyond the commencement of the trial. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under 15 this Order must take care to limit any such designation to specific material that 16 qualifies under the appropriate standards. The Designating Party must designate for 17 protection only those parts of material, documents, items, or oral or written 18 communications that qualify so that other portions of the material, documents, 19 items, or communications for which protection is not warranted are not swept 20 unjustifiably within the ambit of this Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to 24 impose unnecessary expenses and burdens on other parties) may expose the 25 Designating Party to sanctions or to prohibitions against any further right to 26 designate documents or information as confidential under this Order. 27 If it comes to a Designating Party’s attention that information or items that it 28 designated for protection do not qualify for protection, then that Designating Party 1 must promptly notify all parties that it is withdrawing the inapplicable designation. 2 5.2 Manner and Timing of Designations. Except as otherwise provided in 3 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 4 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 5 under this Order must be clearly so designated before the material is disclosed or 6 produced. Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 11 contains protected material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must determine 20 which documents, or portions thereof, qualify for protection under this Order. 21 Then, before producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing 24 Party also must clearly identify the protected portion(s) (e.g., by making 25 appropriate markings in the margins). 26 (b) for testimony given in depositions that the Designating Party identify 27 the Disclosure or Discovery Material on the record, before the close of the 28 deposition all protected testimony. 1 (c) for information produced in some form other than documentary and 2 for any other tangible items, that the Producing Party affix in a prominent place on 3 the exterior of the container or containers in which the information is stored the 4 legend “CONFIDENTIAL.” If only a portion or portions of the information 5 warrants protection, the Producing Party, to the extent practicable, shall identify the 6 protected portion(s). 7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this Order for such 10 material. Upon timely correction of a designation, the Receiving Party must make 11 reasonable efforts to assure that the material is treated in accordance with the 12 provisions of this Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37.1, et seq. 19 6.3 Burden. The burden of persuasion in any such challenge proceeding 20 shall be on the Designating Party. Frivolous challenges, and those made for an 21 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 22 other parties) may expose the Challenging Party to sanctions. Unless the 23 Designating Party has waived or withdrawn the confidentiality designation, all 24 parties shall continue to afford the material in question the level of protection to 25 which it is entitled under the Producing Party’s designation until the Court rules on 26 the challenge. 27 7. ACCESS TO AND USE OF PROTECTED MATERIAL 28 7.1 Basic Principles. A Receiving Party may use Protected Material that is 1 disclosed or produced by another Party or by a Non-Party in connection with this 2 Action only for prosecuting, defending, or attempting to settle this Action. Such 3 Protected Material may be disclosed only to the categories of persons and under the 4 conditions described in this Order. When the Action has been terminated, a 5 Receiving Party must comply with the provisions of Section 13 below (FINAL 6 DISPOSITION). 7 Protected Material must be stored and maintained by a Receiving Party at a 8 location and in a secure manner that ensures that access is limited to the persons 9 authorized under this Order. 10 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 11 otherwise ordered by the court or permitted in writing by the Designating Party, a 12 Receiving Party may disclose any information or item designated 13 “CONFIDENTIAL” 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) the officers, directors, and employees (including House Counsel) of 18 the Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 28 custodian or other person who otherwise possessed or knew the information; 1 (h) during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 4 will not be permitted to keep any confidential information unless they sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 6 agreed by the Designating Party or ordered by the court. Pages of transcribed 7 deposition testimony or exhibits to depositions that reveal Protected Material may 8 be separately bound by the court reporter and may not be disclosed to anyone 9 except as permitted under this Stipulated Protective Order; and 10 (i) any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 13 PRODUCED IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL,” that Party must: 17 (a) promptly notify in writing the Designating Party. Such notification 18 shall include a copy of the subpoena or court order; 19 (b) promptly notify in writing the party who caused the subpoena or order 20 to issue in the other litigation that some or all of the material covered by the 21 subpoena or order is subject to this Protective Order. Such notification shall 22 include a copy of this Stipulated Protective Order; and 23 (c) cooperate with respect to all reasonable procedures sought to be 24 pursued by the Designating Party whose Protected Material may be affected. 25 If the Designating Party timely seeks a protective order, the Party served with 26 the subpoena or court order shall not produce any information designated in this 27 action as “CONFIDENTIAL” before a determination by the court from which the 28 subpoena or order issued, unless the Party has obtained the Designating Party’s 1 permission. The Designating Party shall bear the burden and expense of seeking 2 protection in that court of its confidential material and nothing in these provisions 3 should be construed as authorizing or encouraging a Receiving Party in this Action 4 to disobey a lawful directive from another court. 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED IN THIS LITIGATION 7 (a) The terms of this Order are applicable to information produced by a 8 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 9 produced by Non-Parties in connection with this litigation is protected by the 10 remedies and relief provided by this Order. Nothing in these provisions should be 11 construed as prohibiting a Non-Party from seeking additional protections. 12 (b) In the event that a Party is required, by a valid discovery request, to 13 produce a Non-Party’s confidential information in its possession, and the Party is 14 subject to an agreement with the Non-Party not to produce the Non-Party’s 15 confidential information, then the Party shall: 16 (1) promptly notify in writing the Requesting Party and the Non-Party 17 that some or all of the information requested is subject to a confidentiality 18 agreement with a Non-Party; 19 (2) promptly provide the Non-Party with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), and a reasonably 21 specific description of the information requested; and 22 (3) make the information requested available for inspection by the 23 Non-Party, if requested. 24 (c) If the Non-Party fails to seek a protective order from this court within 25 14 days of receiving the notice and accompanying information, the Receiving Party 26 may produce the Non-Party’s confidential information responsive to the discovery 27 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 28 not produce any information in its possession or control that is subject to the 1 confidentiality agreement with the Non-Party before a determination by the court. 2 Absent a court order to the contrary, the Non-Party shall bear the burden and 3 expense of seeking protection in this court of its Protected Material. 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 writing the Designating Party of the unauthorized disclosures, (b) use its best 9 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 10 person or persons to whom unauthorized disclosures were made of all the terms of 11 this Order, and (d) request such person or persons to execute the “Acknowledgment 12 and Agreement to Be Bound” that is attached hereto as Exhibit A. 13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other 17 protection, the obligations of the Receiving Parties are those set forth in Federal 18 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 19 whatever procedure may be established in an e-discovery order that provides for 20 production without prior privilege review. Pursuant to Federal Rule of Evidence 21 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 22 of a communication or information covered by the attorney-client privilege or work 23 product protection, the parties may incorporate their agreement in the stipulated 24 protective order submitted to the court. 25 12. MISCELLANEOUS 26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 27 person to seek its modification by the Court in the future. 28 12.2 Right to Assert Other Objections. By stipulating to the entry of this 1 Protective Order no Party waives any right it otherwise would have to object to 2 disclosing or producing any information or item on any ground not addressed in 3 this Stipulated Protective Order. Similarly, no Party waives any right to object on 4 any ground to use in evidence of any of the material covered by this Protective 5 Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Civil Local Rule 79-5. Protected Material 8 may only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party’s request to file Protected Material 10 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. 12 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 4, within 60 14 days of a written request by the Designating Party, each Receiving Party must 15 return all Protected Material to the Producing Party or destroy such material. As 16 used in this subdivision, “all Protected Material” includes all copies, abstracts, 17 compilations, summaries, and any other format reproducing or capturing any of the 18 Protected Material. Whether the Protected Material is returned or destroyed, the 19 Receiving Party must submit a written certification to the Producing Party (and, if 20 not the same person or entity, to the Designating Party) by the 60 day deadline that 21 (1) identifies (by category, where appropriate) all the Protected Material that was 22 returned or destroyed and (2) affirms that the Receiving Party has not retained any 23 copies, abstracts, compilations, summaries or any other format reproducing or 24 capturing any of the Protected Material. Notwithstanding this provision, Counsel 25 are entitled to retain an archival copy of all pleadings, motion papers, trial, 26 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 27 and trial exhibits, expert reports, attorney work product, and consultant and expert 28 work product, even if such materials contain Protected Material. Any such archival 1 copies that contain or constitute Protected Material remain subject to this Protective 2 Order as set forth in Section 4 (DURATION). 3 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 DATED: July 27, 2021 TUCKER ELLIS LLP 6 7 By: /s/ John Q. Lewis 8 John Q. Lewis 9 Attorneys for Plaintiff James D. McCool 10 DATED: July 27, 2021 HILL, FARRER & BURRILL LLP 11 12 By: /s/ William A. Meyers 13 William A. Meyers 14 Attorneys for Defendants Allen Matkins Leck Gamble Mallory 15 & Natsis, LLP and Clark Libenson 16 17 SIGNATURE ATTESTION 18 Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer, William A. Meyers, attests 19 that all other signatories listed, and on whose behalf the filing is submitted, concur 20 in the filing’s content and have authorized the filing. 21 DATED: July 27, 2021 By: /s/ William A. Meyers 22 William A. Meyers Attorneys for Defendants 23 Allen Matkins Leck Gamble Mallory 24 & Natsis, LLP and Clark Libenson 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _______________________ [insert full name], of _________________________ 5 [insert full address], declare under penalty of perjury that I have read in its entirety 6 and understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of James D. 8 McCool v. Denise Wilson, et al., Case No. 5:19-cv-02499 PSG (KKx). I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order 10 and 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. I further agree to submit to the jurisdiction of the United 15 States District Court for the Central District of California for the purpose of 16 enforcing the terms of this Stipulated Protective Order, even if such enforcement 17 proceedings occur after termination of this action. I hereby appoint 18 ______________________________________ [insert full name] of 19 ______________________________________ [insert full address and telephone 20 number] as my California agent for service of process in connection with this action 21 or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 26 Signature: __________________________________

27 HFB 2399100.1 A3761 005 28 1 HILL, FARRER & BURRILL LLP Kevin H. Brogan (Bar No. 089427) 2 Email: [email protected] William A. Meyers (Bar No. 266322) 3 Email: [email protected] 4 300 South Grand Avenue, 37th Floor Los Angeles, CA 90071-3147 5 Telephone: (213) 620-0460 Fax: (213) 624-4840 6 Attorneys for Defendants 7 Allen Matkins Leck Gamble Mallory & 8 Natsis, LLP and Clark Libenson 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 JAMES D. MCCOOL, CASE NO. 5:19-cv-02499 PSG (KKx) 13 Plaintiff, [PROPOSED] ORDER RE: 14 STIPULATED PROTECTIVE vs. 15 ORDER ALLEN MATKINS LECK 16 Hon. Philip S. Gutierrez GAMBLE MALLORY & NATSIS,

17 LLP; CLARK LIBENSON; and DOES 1-10, inclusive,

18 Defendants. 19

20

21 22

23

24 Complaint Filed: December 30, 2019 Trial Date: January 25, 2022 25

26

27 28 1 Having considered the Proposed Stipulated Protective Order of the parties, 2 | and finding that good cause exists therefor, the requested Protective Order is 3 | granted. 4 IT ISSO ORDERED aly 6 | DATED: July 29 , 2021 HON. KENLY KIYA KATO 7 United States Magistrate Judge 8 9 10

6 8 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _2-