1 || Peter Dubrawski (Bar No. 65677) [email protected] 2 || Austin Smith (Bar No. 327354) aw. com 3 || HAIGHT BROWN & BONESTEEL LLP 555 South Flower Street, Forty-Fitth Floor 4 || Los Angeles, California 9007 Telephone: 213.542.8000 5 ||Facsimile: 213.542.8100 6 || Attorneys for Defendants, MVT SERVICES. LLC, dba MESILLA 7|| VALLEY TRANSPORTATION, and MVT LEASING, LLC 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 10 11 ae CASSANDRA JONES, an individual; Case No. 2:21-cv-03753-MWF-RAO 12 || C.Z.S., a minor by and through her Guardian ad Litem, NICOL AMENDED STIPULATION FOR 13 ||] BURSON, PROTECTIVE ORDER OD 14 Plaintiffs, © 15 V. MVT SERVICES, LLC, dba MESILLA VALLEY TRANSPORTATION, a 17 || business entity; MVT LEASING, LLC, a business entity; RENE DAVID 18 || MOOT, an individual; and DOES 1 through 50, inclusive, 19 Defendants. 20 21 22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 || proprietary or private information for which special protection from public 25 || disclosure and from use for any purpose other than prosecuting this litigation may 26 ||be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 || enter the following Stipulated Protective Order. The parties acknowledge that this 28 || Order does not confer blanket protections on all disclosures or responses to Case No. 2:21-cv-03753-MWF-RAC

1 || discovery and that the protection it affords from public disclosure and use extends 2 || only to the limited information or items that are entitled to confidential treatment 3 || under the applicable legal principles. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets, customer and pricing lists and 6 || other valuable research, development, commercial, financial, technical and/or 7 || proprietary information for which special protection from public disclosure and 8 || from use for any purpose other than prosecution of this action is warranted. Such 9 || confidential and proprietary materials and information consist of, among other 10 || things, confidential business or financial information, information regarding 11 || confidential business practices, or other confidential research, development, or 12 || commercial information (including information implicating privacy rights of third 13 || parties), information otherwise generally unavailable to the public, or which may be ON 14 || privileged or otherwise protected from disclosure under state or federal statutes, © 15 || court rules, case decisions, or common law. Accordingly, to expedite the flow of 16 || information, to facilitate the prompt resolution of disputes over confidentiality of 17 || discovery materials, to adequately protect information the parties are entitled to keep 18 || confidential, to ensure that the parties are permitted reasonable necessary uses of 19 such material in preparation for and in the conduct of trial, to address their handling 20 || at the end of the litigation, and serve the ends of justice, a protective order for such 21 || information is justified in this matter. It 1s the intent of the parties that information 22 || will not be designated as confidential for tactical reasons and that nothing be so 23 || designated without a good faith belief that it has been maintained in a confidential, 24 ||non-public manner, and there is good cause why it should not be part of the public 25 || record of this case. 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 || Stipulated Protective Order does not entitle them to file confidential information Case No. 2:21-cv-03753-MWF-RAC

1 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 2 || and the standards that will be applied when a party seeks permission from the court 3 || to file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 || proceedings and records in civil cases. In connection with non-dispositive motions, 6 || good cause must be shown to support a filing under seal. See Kamakana v. City and 7 || County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 8 || Corp.,

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

(E.D. Wis. 1999) (even stipulated protective orders 10 || require good cause showing), and a specific showing of good cause or compelling 11 || reasons with proper evidentiary support and legal justification, must be made with 12 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 13 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— ON 14 || without the submission of competent evidence by declaration, establishing that the © 15 || material sought to be filed under seal qualifies as confidential, privileged, or 16 || otherwise protectable—constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, then 18 || compelling reasons, not only good cause, for the sealing must be shown, and the 19 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 20 || See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 21 || each item or type of information, document, or thing sought to be filed or introduced 22 || under seal in connection with a dispositive motion or trial, the party seeking 23 || protection must articulate compelling reasons, supported by specific facts and legal 24 || justification, for the requested sealing order. Again, competent evidence supporting 25 || the application to file documents under seal must be provided by declaration. 26 Any document that is not confidential, privileged, or otherwise protectable in 27 || its entirety will not be filed under seal if the confidential portions can be redacted. 28 || If documents can be redacted, then a redacted version for public viewing, omitting Case No. 2:21-cv-03753-MWF-RAC

1 || only the confidential, privileged, or otherwise protectable portions of the document 2 || shall be filed. Any application that seeks to file documents under seal in their 3 || entirety should include an explanation of why redaction is not feasible. 4 5 || 2. DEFINITIONS 6 2.1 Action: United States District Court for the Central District of 7 || California Case No: 2:21-cv-03753-MWEF-RAO. 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. ON 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 1t 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 or 22 || 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. Case No. 2:21-cv-03753-MWF-RAC

l 2.9 Non-Party: any natural person, partnership, corporation, association or 2 || 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 || that 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 ON 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 21/3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 || Protected Material (as defined above), but also (1) any information copied or 24 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 || compilations of Protected Material; and (3) any testimony, conversations, or 26 || presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 || trial judge. This Order does not govern the use of Protected Material at trial. Case No. 2:21-cv-03753-MWF-RAC

2 DURATION 3 Once a case proceeds to trial, information that was designated as 4 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 5 ||as an exhibit at trial becomes public and will be presumptively available to all 6 || members of the public, including the press, unless compelling reasons supported by 7 || specific factual findings to proceed otherwise are made to the trial judge in advance 8 || of the trial. See Kamakana,

(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 ON 14 5.1 Exercise of Restraint and Care in Designating Material for Protection. © 15 || Each Party or Non-Party that designates information or items for protection under 16 || this Order must take care to limit any such designation to specific material that 17 || qualifies under the appropriate standards. The Designating Party must designate for 18 || protection only those parts of material, documents, items or oral or written 19 || communications that qualify so that other portions of the material, documents, items 20 |] or communications for which protection is not warranted are not swept unjustifiably 21 || within the ambit of this Order. 22 Mass, indiscriminate or routinized designations are prohibited. Designations 23 || that are shown to be clearly unjustified or that have been made for an improper 24 || purpose (e.g., to unnecessarily encumber the case development process or to impose 25 ||] unnecessary expenses and burdens on other parties) may expose the Designating 26 || Party to sanctions. 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, that Designating Party must Case No. 2:21-cv-03753-MWF-RAC

1 || promptly notify all other 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. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or electronic 9 || documents, but excluding transcripts of depositions or other pretrial or trial 10 || proceedings), that the Producing Party affix at a minimum, the legend 11 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

12 || contains protected material. If only a portion of the material on a page qualifies for 13 || protection, the Producing Party also must clearly identify the protected portion(s) ON (e.g., by making appropriate markings in the margins). © 15 A Party or Non-Party that makes original documents available for inspection 16 || need not designate them for protection until after the inspecting Party has indicated 17 || which documents it would like copied and produced. During the inspection and 18 || before the designation, all of the material made available for inspection shall be 19 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 || documents it wants copied and produced, the Producing Party must determine which 21 |}documents, or portions thereof, qualify for protection under this Order. Then, 22 || before producing the specified documents, the Producing Party must affix the 23 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 24 || portion of the material on a page qualifies for protection, the Producing Party also 25 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 26 in the margins). 27 (b) for testimony given in depositions that the Designating Party identifies 28 || the Disclosure or Discovery Material on the record, before the close of the Case No. 2:21-cv-03753-MWF-RAC

1 || deposition all protected testimony. 2 (c) for information produced in some form other than documentary and 3 || for any other tangible items, that the Producing Party affix in a prominent place on 4 || the exterior of the container or containers in which the information is stored the 5 || legend “CONFIDENTIAL.” If only a portion or portions of the information 6 || warrants protection, the Producing Party, to the extent practicable, shall identify the 7 || protected portion(s). 8 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 9 || failure to designate qualified information or items does not, standing alone, waive 10 || the Designating Party’s right to secure protection under this Order for such material. 11 || Upon timely correction of a designation, the Receiving Party must make reasonable 12 || efforts to assure that the material is treated in accordance with the provisions of this 13 || Order. ON 14 © 15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 17 || designation of confidentiality at any time that is consistent with the Court’s 18 || Scheduling Order. 19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 20 || resolution process under Local Rule 37.1 et seq. 21 6.3 The burden of persuasion in any such challenge proceeding shall be on 22 || the Designating Party. Frivolous challenges, and those made for an improper 23 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 24 || parties) may expose the Challenging Party to sanctions. Unless the Designating 25 || Party has waived or withdrawn the confidentiality designation, all parties shall 26 || continue to afford the material in question the level of protection to which it is 27 || entitled under the Producing Party’s designation until the Court rules on the 28 || challenge. Case No. 2:21-cv-03753-MWF-RAC

1||7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1. Basic Principles. A Receiving Party may use Protected Material that is 3 || disclosed or produced by another Party or by a Non-Party in connection with this 4 || Action only for prosecuting, defending or attempting to settle this Action. Such 5 || Protected Material may be disclosed only to the categories of persons and under the 6 || conditions described in this Order. When the Action has been terminated, a 7 || Receiving Party must comply with the provisions of section 13 below (FINAL 8 || DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 || location and in a secure manner that ensures that access is limited to the persons 11 || authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 || otherwise ordered by the court or permitted in writing by the Designating Party, a ON 14 || Receiving Party may disclose any information or item designated © 15 || “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 || well as employees of said Outside Counsel of Record to whom it is reasonably 18 || necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 || disclosure is reasonably necessary for this Action and who have signed the 23 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 || Vendors to whom disclosure is reasonably necessary for this Action and who have 28 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); Case No. 2:21-cv-03753-MWF-RAC

l (g) the author or recipient of a document containing the information or a 2 || custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in the 4 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they 6 || will not be permitted to keep any confidential information unless they sign the 7 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 || agreed by the Designating Party or ordered by the court. Pages of transcribed 9 || deposition testimony or exhibits to depositions that reveal Protected Material may 10 || be separately bound by the court reporter and may not be disclosed to anyone except 11 || as permitted under this Stipulated Protective Order; and 12 (i) any mediator or settlement officer, and their supporting personnel, 13 || mutually agreed upon by any of the parties engaged in settlement discussions. ON 14 © 1518. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 16 IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 || that compels disclosure of any information or items designated in this Action as 19 || “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification 21 shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order 23 || to issue in the other litigation that some or all of the material covered by the 24 || subpoena or order is subject to this Protective Order. Such notification shall include 25 ||a copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be 27 || pursued by the Designating Party whose Protected Material may be affected. 28 If the Designating Party timely seeks a protective order, the Party served with Case No. 2:21-cv-03753-MWF-RAC

1 || the subpoena or court order shall not produce any information designated in this 2 || action as “CONFIDENTIAL” before a determination by the court from which the 3 || subpoena or order issued, unless the Party has obtained the Designating Party’s 4 || permission. The Designating Party shall bear the burden and expense of seeking 5 || protection in that court of its confidential material and nothing in these provisions 6 || should be construed as authorizing or encouraging a Receiving Party in this Action 7 || to disobey a lawful directive from another court. 8 91/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a

12 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 13 || produced by Non-Parties in connection with this litigation is protected by the ON 14 || remedies and relief provided by this Order. Nothing in these provisions should be © 15 || construed as prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 || produce a Non-Party’s confidential information in its possession, and the Party is 18 || subject to an agreement with the Non-Party not to produce the Non-Party’s 19 || confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality 22 ||agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 || specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 || Non-Party, if requested. 28 (c) If the Non-Party fails to seek a protective order from this court within Case No. 2:21-cv-03753-MWF-RAC

1 || 14 days of receiving the notice and accompanying information, the Receiving Party 2 ||may produce the Non-Party’s confidential information responsive to the discovery 3 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 4 || not produce any information in its possession or control that is subject to the 5 || confidentiality agreement with the Non-Party before a determination by the court. 6 || Absent a court order to the contrary, the Non-Party shall bear the burden and 7 || expense of seeking protection in this court of its Protected Material. 8 9} }10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 || Protected Material to any person or in any circumstance not authorized under this 12 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts ON 14 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or © 15 || persons to whom unauthorized disclosures were made of all the terms of this Order, 16 || and (d) request such person or persons to execute the “Acknowledgment and 17 || Agreement to Be Bound” that is attached hereto as Exhibit A. 18 19/}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 || inadvertently produced material is subject to a claim of privilege or other protection, 23 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 25 || procedure may be established in an e-discovery order that provides for production 26 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 27 (e), insofar as the parties reach an agreement on the effect of disclosure of a 28 || communication or information covered by the attorney-client privilege or work Case No. 2:21-cv-03753-MWF-RAC

1 || product protection, the parties may incorporate their agreement in the stipulated 2 || protective order submitted to the court. 3 4/12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 || person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 || Protective Order, no Party waives any right it otherwise would have to object to 9 || disclosing or producing any information or item on any ground not addressed in this 10 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 || ground to use in evidence of any of the material covered by this Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 || Protected Material must comply with Local Civil Rule 79-5. Protected Material ON 14 || may only be filed under seal pursuant to a court order authorizing the sealing of the © 15 || specific Protected Material at issue. If a Party’s request to file Protected Material 16 || under seal is denied by the court, then the Receiving Party may file the information 17 || in the public record unless otherwise instructed by the court. 18 19]}13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 21 || days of a written request by the Designating Party, each Receiving Party must return 22 all Protected Material to the Producing Party or destroy such material. As used in 23 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 ||summaries, and any other format reproducing or capturing any of the Protected 25 || Material. Whether the Protected Material is returned or destroyed, the Receiving 26 || Party must submit a written certification to the Producing Party (and, if not the same 27 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 28 || (by category, where appropriate) all the Protected Material that was returned or Case No. 2:21-cv-03753-MWF-RAC

1 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 2 || abstracts, compilations, summaries or any other format reproducing or capturing any 3 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 4 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 5 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 6 || reports, attorney work product, and consultant and expert work product, even if such 7 || materials contain Protected Material. Any such archival copies that contain or 8 || constitute Protected Material remain subject to this Protective Order as set forth in 9 || Section 4 (DURATION). 10}|// 11 |]// 12 ||// 13 ||// ON 14 //

16 |1// ||// 18 // // 20 || // \|// 22 |\// 23 // 24 |} // 25 ||// 26 // 27 \\// 28 Case No. 2:21-cv-03753-MWF-RAC

1}/14. VIOLATION 2 || Any violation of this Order may be punished by appropriate measures including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 4|}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 || Dated: October 8, 2021 PANISH SHEA & BOYLE LLP 6 7 8 By: /s/ Pete Kaufman Brian Panish, Pete Kaufman, Whitney T. Smith 9 Attorneys for Plaintiffs, CASSANDRA JONES, C.Z.S, a minor, by and through her Guardian ad 10 Litem, NICOLE BURSON 11

12 || Dated: October 8, 2021 HAIGHT BROWN & BONESTEEL LLP 2B ON 14 By: /s/ Peter Dubrawski Peter Dubrawski, Austin Smith 15 Attorneys for Defendants, MVT SERVICES, 16 LLC, dba MESILLA VALLEY TRANSPORTATION, and MVT LEASING, LLC 17 1g Dated: October 8, 2021 HIGGS, FLETCHER & MACK LLP

19 20 By: /s/ Peter S. Doody Peter S. Doody, Nicholas S. Brauns Attorneys for Defendant, RENE DAVID MOOT

73 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: October 12, 2021 25 7 . 26 } . On , . 27|| HON. ROZELLA A. OLIVER 28 United States Magistrate Judge

Case No. 2:21-cv-03753-MWF-RAC

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4||I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that 7 || was issued by the United States District Court for the Central District of California 8 || on [date] in the case of Cassandra Jones et al. v. MVT Services, LLC et al., Case # 9 || 2:21-cv-03753-MWE-RAO. I agree to comply with and to be bound by all the 10 || terms of this Stipulated Protective Order and I understand and acknowledge that 11 || failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any 13 || information or item that is subject to this Stipulated Protective Order to any person ON 14 || or entity except in strict compliance with the provisions of this Order. © 15 ||I further agree to submit to the jurisdiction of the United States District Court for the 16 || Central District of California for enforcing the terms of this Stipulated Protective 17 || Order, even if such enforcement proceedings occur after termination of this action. 18 || | hereby appoint [print or type full name] of 19 [print or type full address and 20 || telephone number] as my California agent for service of process in connection with 21 || this action or any proceedings related to enforcement of this Stipulated Protective 22 || Order. 23 || Date: 24 || City and State where sworn and signed: 25 26 || Printed name: 27 28 || Signature: Case No. 2:21-cv-03753-MWF-RAC

1 PROOF OF SERVICE 2 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 || Jones, et al. v. MVT Services, LLC, et al. Case No. 2:21-cv-03753-MWF-RAO 4 _ At the time of service, I was over 18 years of age and not a party to this 5 ||action. Iam employed in the County of Los Angeles, State of California. My business address is 555 South Flower Street, Forty-Fifth Floor, Los Angeles, CA 6 7 _On October 11, 2021, I served true copies of the following document(s) described as STIPULATED PROTECTIVE ORDER on the interested parties in 8 || this action as follows: 9 SEE ATTACHED SERVICE LIST 10 BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed the document(s) with the Clerk of the Court by using the CM/ECF system. 11 Participants in the case who are registered CM/ECF users will be served by □□□ CM/ECF system. Participants in the case who are not registered CM/ECF users will 12 || be served by mail or by other means permitted by the court rules. 13 I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am employed in the office 14 of a member of the bar of this Court at whose direction the service was made. 15 Executed on October 11, 2021, at Los Angeles, California.

17 /s/ Julie C. Mentesana 18 Julie C. Mentesana 19 20 21 22 23 24 25 26 27 28 Case No. 2:21-cv-03753-MWF-RAC

1 SERVICE LIST Jones, et al. v. MVT Services, LLC, et al. 2 Case No. 2:21-cv-03753-MWF-RAO 3 || Brian J. Panish, Esq. Nick Movagar, Esq. Peter Kaufman, Esq. MOVAGAR & YAMIN, PLC 4 Whitney Smith, <4. 4929 Wilshire Blvd., Suite 960 PANISH SHEA & BOYLE LLP Los Angeles, CA 90010 5 11111 Santa Monica Boulevard, Suite 700 Telephone: 877.771.8175 6 || Los Angeles, CA 90025 Facsimile: 323.475.7773 Email:[email protected] || Telephone: 310.477.1700 [email protected] Facsimile: 310.477.1699 8 || Email: [email protected] [email protected] Attorneys for Plaintiffs 9 [email protected] 0 [email protected] 1 Attorneys for Plaintiffs 11 Peter S. Doody 12 || Nicholas D. Brauns HIGGS FLETCHER & MACK LLP _13]}401 West A Street, Suite 2600 San Diego, CA 92101-7910 14}/Telephone: 619.236.1551 Facsimile: 619.696.1410 15 || Email: [email protected] [email protected] 16 richardson iggslaw.com 17 || Attorneys for Defendant, Rene David Moot 18 19 20 21 22 23 24 25 26 27 28 Case No. 2:21-cv-03753-MWF-RAC