1 [email protected] STEPHANIE L. GASE (pro hac vice) 2 [email protected] DANIEL A. JOHNSON (pro hac vice) 3 [email protected] LEADER BERKON COLAO & SILVERSTEIN LLP 4 550 South Hope Street, Suite 1850 Los Angeles, CA 90071 5 Telephone: (213) 234-1750 Facsimile: (213) 234-1747 6 Attorneys for Plaintiffs 7 Creative Intellects Inc. and Intellects Capital LLC

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

10 CREATIVE INTELLECTS INC. and Civil Action No. 2:21-cv-02670-RGK-AFM 11 INTELLECTS CAPITAL LLC, Individually and Derivatively on 12 Behalf of Nominal Defendants 13 ATLANTIC CROSS EQUIPMENT, LLC and A.X.E., LLC, 14

15 Plaintiffs, STIPULATED [PROPOSED] PROTECTIVE ORDER1 16 vs. 17 PATRICK HAYGOOD, ROBERT 18 THOMPSON, TRACEY RENEE 19 MCKINNEY, RESERVATION LAND MANAGEMENT (A 20 PROFESSIONAL CORPORATION), 21 and SABINE HOLDINGS, LLC,

22 Defendants, 23 and 24

25 ATLANTIC CROSS EQUIPMENT, LLC, and A.X.E., LLC, 26 27 28 1 This Stipulated Protective Order is based substantially on the model protective 1 Nominal Defendants. 2 PATRICK HAYGOOD, TRACEY 3 RENEE MCKINNEY, 4 RESERVATION LAND MANAGEMENT, ATLANTIC 5 CROSS EQUIPMENT, LLC, AND 6 A.X.E., LLC

7 Counter-Claim Plaintiffs, 8 vs. 9

10 CREATIVE INTELLECTS INC. and INTELLECTS CAPITAL LLC, a 11 limited liability company; HATEL 12 BHAKTA, an individual person; MITESH SOLANKI, an individual 13 person; ERIC TABARY, an 14 individual person,

15 Counter-Claim Defendants. 16 17 18 1 A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 23 enter the following Stipulated Protective Order. The parties acknowledge that this 24 Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 only to the limited information or items that are entitled to confidential treatment 27 under the applicable legal principles. 28 1 B. GOOD CAUSE STATEMENT 2 This action is likely to involve personal and business financial information for 3 which special protection from public disclosure and from use for any purpose other 4 than prosecution of this action is warranted. Such confidential and proprietary 5 materials and information consist of, among other things, confidential personal or 6 business financial information, such as bank statements or other financial records, 7 and information otherwise generally unavailable to the public, or which may be 8 privileged or otherwise protected from disclosure under state or federal statutes, 9 court rules, case decisions, or common law. Accordingly, to expedite the flow of 10 information, to facilitate the prompt resolution of disputes over confidentiality of 11 discovery materials, to adequately protect information the parties are entitled to keep 12 confidential, to ensure that the parties are permitted reasonable necessary uses of 13 such material in preparation for and in the conduct of trial, to address their handling 14 at the end of the litigation, and serve the ends of justice, a protective order for such 15 information is justified in this matter. It is the intent of the parties that information 16 will not be designated as confidential for tactical reasons and that nothing be so 17 designated without a good faith belief that it has been maintained in a confidential, 18 non-public manner, and there is good cause why it should not be part of the public 19 record of this case. 20 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 21 SEAL 22 The parties further acknowledge, as set forth in Section 12.3, below, that this 23 Stipulated Protective Order does not entitle them to file confidential information 24 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 25 and the standards that will be applied when a party seeks permission from the court 26 to file material under seal. 27 There is a strong presumption that the public has a right of access to judicial 28 proceedings and records in civil cases. In connection with non-dispositive motions, 1 good cause must be shown to support a filing under seal. See Kamakana v. City and 2 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 3 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 4 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 5 good cause showing), and a specific showing of good cause or compelling reasons 6 with proper evidentiary support and legal justification, must be made with respect to 7 Protected Material that a party seeks to file under seal. The parties’ mere designation 8 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 9 submission of competent evidence by declaration, establishing that the material 10 sought to be filed under seal qualifies as confidential, privileged, or otherwise 11 protectable—constitute good cause. 12 Further, if a party requests sealing related to a dispositive motion or trial, then 13 compelling reasons, not only good cause, for the sealing must be shown, and the 14 relief sought shall be narrowly tailored to serve the specific interest to be protected. 15 See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For 16 each item or type of information, document, or thing sought to be filed or introduced 17 under seal in connection with a dispositive motion or trial, the party seeking 18 protection must articulate compelling reasons, supported by specific facts and legal 19 justification, for the requested sealing order. Again, competent evidence supporting 20 the application to file documents under seal must be provided by declaration. 21 Any document that is not confidential, privileged, or otherwise protectable in 22 its entirety will not be filed under seal if the confidential portions can be redacted. 23 If documents can be redacted, then a redacted version for public viewing, omitting 24 only the confidential, privileged, or otherwise protectable portions of the document, 25 shall be filed. Any application that seeks to file documents under seal in their 26 entirety should include an explanation of why redaction is not feasible. 27 2. DEFINITIONS 28 1 2.1 Action: Creative Intellects Inc., et al v. Patrick Haygood, et al, Case 2 No. 2:21-cv-02670-RGK-AFM. 3 2.2 Challenging Party: a Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless 6 of how it is generated, stored or maintained) or tangible things that qualify for 7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 8 the Good Cause Statement. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 10 their support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless 15 of the medium or manner in which it is generated, stored, or maintained (including, 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8 House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9 Non-Party: any natural person, partnership, corporation, association or 25 other legal entity not named as a Party to this action. 26 2.10 Outside Counsel of Record: attorneys who are not employees of a party 27 to this Action but are retained to represent or advise a party to this Action and have 28 1 appeared in this Action on behalf of that party or are affiliated with a law firm that 2 has appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only 18 Protected Material (as defined above), but also (1) any information copied or 19 extracted from Protected Material; (2) all copies, excerpts summaries, or 20 compilations of Protected Material; and (3) any testimony, conversations, or 21 presentations by Parties or their Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of the 23 trial judge. This Order does not govern the use of Protected Material at trial. 24 4. DURATION 25 Once a case proceeds to trial, information that was designated as 26 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 27 as an exhibit at trial becomes public and will be presumptively available to all 28 members of the public, including the press, unless compelling reasons supported by 1 specific factual findings to proceed otherwise are made to the trial judge in advance 2 of the trial. See Kamakana,

(distinguishing “good cause” 3 showing for sealing documents produced in discovery from “compelling reasons” 4 standard when merits-related documents are part of court record). Accordingly, the 5 terms of this protective order do not extend beyond the commencement of the trial. 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items or oral or written 12 communications that qualify so that other portions of the material, documents, items 13 or communications for which protection is not warranted are not swept unjustifiably 14 within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 28 Designation in conformity with this Order requires: 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion of the material on a page qualifies for 6 protection, the Producing Party also must clearly identify the protected portion(s) 7 (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, before 15 producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 portion of the material on a page qualifies for protection, the Producing Party also 18 must clearly identify the protected portion(s) (e.g., by making appropriate markings 19 in the margins). 20 (b) for testimony given in depositions that the Designating Party 21 identifies the Disclosure or Discovery Material on the record, before the close of the 22 deposition all protected testimony. 23 (c) for information produced in some form other than documentary 24 and for any other tangible items, that the Producing Party affix in a prominent place 25 on the exterior of the container or containers in which the information is stored the 26 legend “CONFIDENTIAL.” If only a portion or portions of the information 27 warrants protection, the Producing Party, to the extent practicable, shall identify the 28 protected portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time that is consistent with the Court’s 10 Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 resolution process under Local Rule 37-1 et seq. 13 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 14 joint stipulation pursuant to Local Rule 37-2. 15 6.4 The burden of persuasion in any such challenge proceeding shall be on 16 the Designating Party. Frivolous challenges, and those made for an improper 17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 18 parties) may expose the Challenging Party to sanctions. Unless the Designating 19 Party has waived or withdrawn the confidentiality designation, all parties shall 20 continue to afford the material in question the level of protection to which it is 21 entitled under the Producing Party’s designation until the Court rules on the 22 challenge. 23 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material that is 25 disclosed or produced by another Party or by a Non-Party in connection with this 26 Action only for prosecuting, defending or attempting to settle this Action. Such 27 Protected Material may be disclosed only to the categories of persons and under the 28 conditions described in this Order. When the Action has been terminated, a 1 Receiving Party must comply with the provisions of section 13 below (FINAL 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 11 well as employees of said Outside Counsel of Record to whom it is reasonably 12 necessary to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of 14 the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the 23 author or recipient of a document containing the information or a custodian or other 24 person who otherwise possessed or knew the information; (h) during their 25 depositions, witnesses, and attorneys for witnesses, in the Action to whom disclosure 26 is reasonably necessary provided: (1) the deposing party requests that the witness 27 sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted to keep 28 any confidential information unless they sign the “Acknowledgment and Agreement 1 to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 2 ordered by the court. Pages of transcribed deposition testimony or exhibits to 3 depositions that reveal Protected Material may be separately bound by the court 4 reporter and may not be disclosed to anyone except as permitted under this Stipulated 5 Protective Order; and (i) any mediator or settlement officer, and their supporting 6 personnel, mutually agreed upon by any of the parties engaged in settlement 7 discussions. 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 that compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification 14 shall include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or 16 order to issue in the other litigation that some or all of the material covered by the 17 subpoena or order is subject to this Protective Order. Such notification shall include 18 a copy of this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be 20 pursued by the Designating Party whose Protected Material may be affected. If the 21 Designating Party timely seeks a protective order, the Party served with the 22 subpoena or court order shall not produce any information designated in this action 23 as “CONFIDENTIAL” before a determination by the court from which the subpoena 24 or order issued, unless the Party has obtained the Designating Party’s permission. 25 The Designating Party shall bear the burden and expense of seeking protection in 26 that court of its confidential material and nothing in these provisions should be 27 construed as authorizing or encouraging a Receiving Party in this Action to disobey 28 a lawful directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the 6 remedies and relief provided by this Order. Nothing in these provisions should be 7 construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party 22 may produce the Non-Party’s confidential information responsive to the discovery 23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 not produce any information in its possession or control that is subject to the 25 confidentiality agreement with the Non-Party before a determination by the court. 26 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 27 of seeking protection in this court of its Protected Material. 28 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 1 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 2 Protected Material to any person or in any circumstance not authorized under this 3 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 4 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 5 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 6 or persons to whom unauthorized disclosures were made of all the terms of this 7 Order, and (d) request such person or persons to execute the “Acknowledgment and 8 Agreement to Be Bound” that is attached hereto as Exhibit A. 9 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 10 PROTECTED MATERIAL 11 When a Producing Party gives notice to Receiving Parties that certain 12 inadvertently produced material is subject to a claim of privilege or other protection, 13 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 14 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 15 may be established in an e-discovery order that provides for production without prior 16 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 17 the parties reach an agreement on the effect of disclosure of a communication or 18 information covered by the attorney-client privilege or work product protection, the 19 parties may incorporate their agreement in the stipulated protective order submitted 20 to the court. 21 12. MISCELLANEOUS 22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 23 person to seek its modification by the Court in the future. 24 12.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order, no Party waives any right it otherwise would have to object to 26 disclosing or producing any information or item on any ground not addressed in this 27 Stipulated Protective Order. Similarly, no Party waives any right to object on any 28 ground to use in evidence of any of the material covered by this Protective Order. 1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 3 only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material at issue. If a Party’s request to file Protected Material 5 under seal is denied by the court, then the Receiving Party may file the information 6 in the public record unless otherwise instructed by the court. 7 13. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 4, within 60 9 days of a written request by the Designating Party, each Receiving Party must return 10 all Protected Material to the Producing Party or destroy such material. As used in 11 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected 13 Material. Whether the Protected Material is returned or destroyed, the Receiving 14 Party must submit a written certification to the Producing Party (and, if not the same 15 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 16 (by category, where appropriate) all the Protected Material that was returned or 17 destroyed and (2) affirms that the Receiving Party has not retained any copies, 18 abstracts, compilations, summaries or any other format reproducing or capturing any 19 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 20 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 22 reports, attorney work product, and consultant and expert work product, even if such 23 materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). 26 14. VIOLATION 27 Any violation of this Order may be punished by appropriate measures 28 including, without limitation, contempt proceedings and/or monetary sanctions. 1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 Dated: August 23, 2021 LEADER BERKON COLAO & SILVERSTEIN LLP 4 5 By: /s/ Stephanie L. Gase Bobbie R. Bailey 6 Stephanie L. Gase (pro hac vice) 7 Daniel A. Johnson (pro hac vice) 8117 Preston Road, Suite 300 8 Dallas, Texas 75225 9 Telephone: (469) 482-5227 Facsimile: (212) 486-3099 10 Email: [email protected] 11 Email: [email protected] Email: [email protected] 12 13 Attorneys for Plaintiffs Creative Intellects Inc. and 14 Intellects Capital LLC 15 16 Dated: August 23, 2021 THE ACADIANA LAW FIRM, LLC

17 18 By: /s/ Thomas Ainsworth Robichaux Thomas Ainsworth Robichaux (pro hac vice) 19 1317 Milan Street 20 New Orleans, LA 70115 Telephone: (504) 605-0610 21 Facsimile: (504) 605-0620 22 Email: [email protected]

23 AND 24 Kevin J. Grochow 25 KUTAK ROCK LLP 26 5 Park Plaza, Suite 1500 Irvine, CA 92614 27 Telephone: (949) 417-0999 28 Facsimile: (949) 417-5394 Attorneys for Defendants Patrick Haygood, 2 Tracey Renee McKinney, Reservation Land 3 Management, A.X.E., LLC, and Atlantic Cross Equipment, LLC 5 All signatories listed, and on whose behalf the filing is submitted, concur in the 6 || filing’s content and have authorized the filing. IT IS SO ORDERED. g || Dated: August 24, 2021 . fo... 11 Alexander F. MacKinnon 12 United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________, of _________________, declare 4 under penalty of perjury that I have read in its entirety and understand the Stipulated 5 Protective Order that was issued by the United States District Court for the Central 6 District of California on [date] in the case of Creative Intellects Inc., et al v. Patrick 7 Haygood, et al, Case No. 2:21-cv-02670-RGK-AFM. I agree to comply with and to 8 be bound by all the terms of this Stipulated Protective Order and I understand and 9 acknowledge that failure to so comply could expose me to sanctions and punishment 10 in the nature of contempt. I solemnly promise that I will not disclose in any manner 11 any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. I 13 further agree to submit to the jurisdiction of the United States District Court for the 14 Central District of California for enforcing the terms of this Stipulated Protective 15 Order, even if such enforcement proceedings occur after termination of this action. 16 I hereby appoint __________________________ of 17 _______________________________________ [print or type full address and 18 telephone number] as my California agent for service of process in connection with 19 this action or any proceedings related to enforcement of this Stipulated Protective 20 Order. 21

22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28