1 Julian Burns King (Bar No. 298617) [email protected] 2 Elliot J. Siegel (Bar No. 312272) 3 [email protected] KING & SIEGEL LLP 4 724 South Spring Street, Suite 214 5 Los Angeles, California 90014 tel: (213) 465-4802 6 fax: (213) 289-2815 7 LAW OFFICE OF LINCOLN W. ELLIS 8 LINCOLN ELLIS (Bar No. 283657) 9 [email protected] 292 S. La Cienega Boulevard, Suite 207 10 Beverly Hills, California 90211 11 Telephone: (213) 207-6692 Facsimile: (855) 701-5136 12

Attorneys for Plaintiff 13

JEFFER MANGELS BUTLER & MITCHELL LLP 14 MARTA M. FERNANDEZ (Bar No. 120540) [email protected] 15 VINCE FARHAT (Bar No. 183794) [email protected] 16 BRIANNA FRAZIER EARLEY (Bar No. 297354) [email protected] 17 1900 Avenue of the Stars, 7th Floor Los Angeles, California 90067-4308 18 Telephone: (310) 203-8080 Facsimile: (310) 203-0567 19

Attorneys for Defendants Royal Bank of 20 Canada and City National Bank 21 UNITED STATES DISTRICT COURT 22 CENTRAL DISTRICT OF CALIFORNIA 23 Fausto Bustos, an individual, Case No. 2:21-cv-04879-JAK-(GJSx) 24 Plaintiff, vs. STIPULATED PROTECTIVE 25 ORDER Royal Bank of Canada, a 26 corporation, City National Bank, a corporation; and Does 1-10, inclusive, 27 Defendants. 1 1. A. PURPOSES AND LIMITATIONS 2 Disclosures and discovery in this action are likely to involve production of 3 confidential, proprietary or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. Accordingly, the parties hereby stipulate to and petition the Court 6 to enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to discovery 8 and that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. The parties further acknowledge, as set forth in Section 11 12.3, below, that this Stipulated Protective Order does not entitle them to file 12 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 13 that must be followed and the standards that will be applied when a party seeks 14 permission from the Court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 This action is likely to involve trade secrets, customer and pricing lists and 17 other valuable commercial, financial, technical and/or proprietary information for 18 which special protection from public disclosure and from use for any purpose other 19 than prosecution of this action is warranted. Such confidential and proprietary 20 materials and information consist of, among other things, confidential business or 21 financial information, information regarding confidential business practices, 22 individual banking information, Defendants’ technological security practices, 23 Plaintiffs’ confidential medical or personal information, and/or other confidential 24 research, development, or commercial information (including information 25 implicating privacy rights of third parties), information otherwise generally 26 unavailable to the public, or which may be privileged or otherwise protected from 27 disclosure under state or federal statutes, court rules, case decisions, or common law. 1 of disputes over confidentiality of discovery materials, to adequately protect 2 information the parties are entitled to keep confidential, to ensure that the parties are 3 permitted reasonable necessary uses of such material in preparation for and in the 4 conduct of trial, to address their handling at the end of the litigation, and serve the 5 ends of justice, a protective order for such information is justified in this matter. It is 6 the intent of the parties that information will not be designated as confidential for 7 tactical reasons and that nothing be so designated without a good faith belief that it 8 has been maintained in a confidential, non-public manner, and there is good cause 9 why it should not be part of the public record of this case. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 14 the standards that will be applied when a party seeks permission from the court to file 15 material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, 18 good cause must be shown to support a filing under seal. See Kamakana v. City and 19 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 20 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 21

(E.D. Wis. 1999) (even stipulated protective orders require good 22 cause showing), and a specific showing of good cause or compelling reasons with 23 proper evidentiary support and legal justification, must be made with respect to 24 Protected Material that a party seeks to file under seal. The parties’ mere designation 25 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 26 submission of competent evidence by declaration, establishing that the material 27 sought to be filed under seal qualifies as confidential, privileged, or otherwise 1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the relief 3 sought shall be narrowly tailored to serve the specific interest to be protected. See 4 Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 5 item or type of information, document, or thing sought to be filed or introduced under 6 seal in connection with a dispositive motion or trial, the party seeking protection must 7 articulate compelling reasons, supported by specific facts and legal justification, for 8 the requested sealing order. Again, competent evidence supporting the application to 9 file documents under seal must be provided by declaration. 10 Any document that is not confidential, privileged, or otherwise protectable in 11 its entirety will not be filed under seal if the confidential portions can be redacted. If 12 documents can be redacted, then a redacted version for public viewing, omitting only 13 the confidential, privileged, or otherwise protectable portions of the document, shall 14 be filed. Any application that seeks to file documents under seal in their entirety 15 should include an explanation of why redaction is not feasible. 16 2. DEFINITIONS 17 2.0 Action: Fausto Bustos v. Royal Bank of Canada, et al., filed in the 18 United States District Court for the Central District of California on June 15, 2021, 19 Case No. 2:21-cv-04879-JAK-(GJSx). 20 2.1 "ATTORNEYS' EYES ONLY" Information or Items: means that subset 21 of information meeting the definition of "CONFIDENTIAL" set forth below and 22 which is so highly sensitive that disclosure would create a substantial risk of serious 23 injury that could not be avoided by less restrictive means. The Designating Party, as 24 defined below, shall bear the ultimate burden of proving that any information it has 25 designated "Confidential—Attorneys' Eyes Only" meets the foregoing definition. 26 2.2 Challenging Party: a Party or Non-Party that challenges the designation 27 of information or items under this Order. 1 how it is generated, stored or maintained) or tangible things that qualify for protection 2 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 3 Cause Statement. 4 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 5 support staff). 6 2.5 Designating Party: a Party or Non-Party that designates information or 7 items that it produces in disclosures or in responses to discovery as 8 “CONFIDENTIAL.” 9 2.6 Disclosure or Discovery Material: all items or information, regardless 10 of the medium or manner in which it is generated, stored, or maintained (including, 11 among other things, testimony, transcripts, and tangible things), that are produced or 12 generated in disclosures or responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in a matter 14 pertinent to the litigation who has been retained by a Party or its counsel to serve as 15 an expert witness or as a consultant in this Action. 16 2.8 House Counsel: attorneys who are employees of a party to this Action. 17 House Counsel does not include Outside Counsel of Record or any other outside 18 counsel. 19 2.9 Non-Party: any natural person, partnership, corporation, association or 20 other legal entity not named as a Party to this action. 21 2.10 Outside Counsel of Record: attorneys who are not employees of a party 22 to this Action but are retained to represent or advise a party to this Action and have 23 appeared in this Action on behalf of that party or are affiliated with a law firm that 24 has appeared on behalf of that party, and includes support staff. 25 2.11 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their 27 support staffs). 1 Discovery Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation support 3 services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 2.14 Protected Material: any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL” or "ATTORNEYS' EYES ONLY". 8 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 9 from a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or extracted 13 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 14 Protected Material; and (3) any testimony, conversations, or presentations by Parties 15 or their Counsel that might reveal Protected Material. 16 In the event that non-parties produce Confidential or Attorneys' Eyes Only 17 Information or Items in connection with this Action, the production may be made 18 subject to the provisions of this Order. As necessary and appropriate to uphold the 19 terms of this Order, the existence of this Order may be disclosed to any person 20 (including any non-party served with a subpoena in this action) producing 21 Confidential and Attorneys' Eyes Only Information or Items in this Action. 22 Any use of Protected Material at trial shall be governed by the orders of the 23 trial judge and other applicable authorities. This Order does not govern the use of 24 Protected Material at trial. 25 4. DURATION 26 FINAL DISPOSITION of the action is defined as the conclusion of any 27 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 1 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 2 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 3 but will have to file a separate action for enforcement of the agreement once all 4 proceedings in this case are complete. 5 Once a case proceeds to trial, information that was designated as 6 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 7 as an exhibit at trial becomes public and will be presumptively available to all 8 members of the public, including the press, unless compelling reasons supported by 9 specific factual findings to proceed otherwise are made to the trial judge in advance 10 of the trial. See Kamakana,

(distinguishing “good cause” 11 showing for sealing documents produced in discovery from “compelling reasons” 12 standard when merits-related documents are part of court record). Accordingly, for 13 such materials, the terms of this protective order do not extend beyond the 14 commencement of the trial. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. 17 Each Party or Non-Party that designates information or items for protection under this 18 Order must take care to limit any such designation to specific material that qualifies 19 under the appropriate standards. The Designating Party must designate for protection 20 only those parts of material, documents, items or oral or written communications that 21 qualify so that other portions of the material, documents, items or communications 22 for which protection is not warranted are not swept unjustifiably within the ambit of 23 this Order. 24 Mass, indiscriminate or routinized designations are prohibited. Designations 25 that are shown to be clearly unjustified or that have been made for an improper 26 purpose (e.g., to unnecessarily encumber the case development process or to impose 27 unnecessary expenses and burdens on other parties) may expose the Designating Party 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party mark each page of the document asserted to 13 contain Protected Material as “CONFIDENTIAL” or "ATTORNEYS' EYES 14 ONLY". If only a portion of the material on a page qualifies for protection, the 15 Producing Party also must clearly identify the protected portion(s) (e.g., by making 16 appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and 20 before the designation, all of the material made available for inspection shall be 21 deemed “CONFIDENTIAL” or "ATTORNEYS' EYES ONLY". After the inspecting 22 Party has identified the documents it wants copied and produced, the Producing Party 23 must determine which documents, or portions thereof, qualify for protection under 24 this Order. Then, before producing the specified documents, the Producing Party 25 must mark each page of the document asserted to contain Protected Material as 26 “CONFIDENTIAL” or "ATTORNEYS' EYES ONLY". If only a portion of the 27 material on a page qualifies for protection, the Producing Party also must clearly 1 margins). 2 (b) for testimony given in depositions, that the Designating Party identify 3 the Disclosure or Discovery Material on the record, before the close of the deposition, 4 all protected testimony. Additionally, and alternatively, any party may also designate 5 information disclosed at a deposition as Protected Material by notifying all counsel in 6 writing within thirty (30) days of receipt of the official deposition transcript or copy 7 thereof (or written notification that the transcript is available), listing the specific 8 pages and lines of the transcript and/or any exhibits that should be treated as Protected 9 Material. The entire deposition transcript (including any exhibits not previously 10 produced in discovery in the Action) shall be treated as Protected Material until the 11 expiration of the above-referenced 30-day period for designation, except that the 12 deponent (and his or her counsel, if any, and all other persons identified in Section 13 7.2 ("CONFIDENTIAL" designation) or Section 7.3 ("ATTORNEYS' EYES ONLY" 14 designation)) may review the transcript of his or her own deposition during said 15 period. Only those portions of the deposition transcript that are designated as 16 containing Protected Material shall be governed by this Order. Nothing in this Order 17 restricts the use of any portion of a deposition transcript that has not been designated 18 as Protected Material. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL” or "ATTORNEYS' EYES ONLY". If only a portion or portions 23 of the information warrants protection, the Producing Party, to the extent practicable, 24 shall identify the protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive the 27 Designating Party’s right to secure protection under this Order for such material. 1 efforts to assure that the material is treated in accordance with the provisions of this 2 Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37.1 et seq. 9 6.3 The burden of persuasion in any such challenge proceeding shall be on 10 the Designating Party. Frivolous challenges, and those made for an improper purpose 11 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 12 expose the Challenging Party to sanctions. Unless the Designating Party has waived 13 or withdrawn the confidentiality designation, all parties shall continue to afford the 14 material in question the level of protection to which it is entitled under the Producing 15 Party’s designation until the Court rules on the challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Order. When the Action has been terminated, a Receiving 22 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 27 otherwise ordered by the court or permitted in writing by the Designating Party, a 1 “CONFIDENTIAL” only to: 2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 3 as employees of said Outside Counsel of Record to whom it is reasonably necessary 4 to disclose the information for this Action; 5 (b) the officers, directors, and employees (including House Counsel) of the 6 Receiving Party to whom disclosure is reasonably necessary for this Action; 7 (c) Experts (as defined in this Order) of the Receiving Party to whom 8 disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A). Counsel for the 10 Receiving Party shall retain the signed copy of the "Acknowledgment and Agreement 11 to Be Bound"; 12 (d) the court and its personnel; 13 (e) court reporters and their staff; 14 (f) professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 (h) during their depositions, witnesses, and attorneys for witnesses, in the 20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 21 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 22 not be permitted to keep any confidential information unless they sign the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 24 agreed by the Designating Party or ordered by the court. Pages of transcribed 25 deposition testimony or exhibits to depositions that reveal Protected Material may be 26 separately bound by the court reporter and may not be disclosed to anyone except as 27 permitted under this Stipulated Protective Order; and 1 mutually agreed upon by any of the parties engaged in settlement discussions. 2 7.3 Disclosure of "ATTORNEYS EYES ONLY" Information or Items. 3 Unless otherwise ordered by the Court or permitting in writing by the Designating 4 Party, a Receiving Party may disclose any information or item designated 5 "ATTORNEYS' EYES ONLY" only to: 6 (a) the Receiving Party's Outside Counsel of Record in this action, as 7 well as employees of said Outside Counsel of Record to whom it is reasonably 8 necessary to disclose the information for this Action; 9 (b) Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 12 (c) court reporters and their staff; 13 (d) the court and its personnel; 14 (e) professional jury or trial consultants, mock jurors, and Professional 15 vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 17 (f) the author or recipient of a document containing the information or 18 a custodian or other person who otherwise possessed or knew the information; and 19 (g) Plaintiff Bustos to the extent Plaintiff's counsel reasonably believes 20 that disclosure to Mr. Bustos is necessary for the preparation, investigation, and 21 litigation of this Action. Mr. Bustos may view such documents outside the presence 22 of counsel, but shall not show, copy, or disseminate to any other third party any 23 information or item designated "ATTORNEYS' EYES ONLY." 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 25 OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation 27 that compels disclosure of any information or items designated in this Action as 1 (a) on or before the third business day after receipt of the subpoena or court 2 order, notify in writing (delivered personally and by e-mail) the Designating Party. 3 Such notification shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or order 5 to issue in the other litigation that some or all of the material covered by the subpoena 6 or order is subject to this Protective Order. Such notification shall include a copy of 7 this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be pursued 9 by the Designating Party whose Protected Material may be affected. If the 10 Designating Party timely seeks a protective order or seeks to quash or modify such 11 process or discovery request consistent with Local Rules 37 and 45, the Party served 12 with the subpoena or court order shall not produce any information designated in this 13 Action as “CONFIDENTIAL” or "ATTORNEYS' EYES ONLY" before a 14 determination by the court from which the subpoena or order issued, unless the Party 15 has obtained the Designating Party’s consent in writing. The Designating Party shall 16 bear the burden and expense of seeking protection in that court of its confidential 17 material and nothing in these provisions should be construed as authorizing or 18 encouraging a Receiving Party in this Action to disobey a lawful directive from 19 another court. 20 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 21 PRODUCED IN THIS LITIGATION 22 (a) The terms of this Order are applicable to information produced by a 23 Non-Party in this Action and designated as “CONFIDENTIAL” or "ATTORNEYS' 24 EYES ONLY". Such information produced by Non-Parties in connection with this 25 litigation is protected by the remedies and relief provided by this Order. Nothing in 26 these provisions should be construed as prohibiting a Non-Party from seeking 27 additional protections. 1 produce a Non-Party’s confidential information in its possession, and the Party is 2 subject to an agreement with the Non-Party not to produce the Non-Party’s 3 confidential information, then the Party shall: 4 (1) promptly notify in writing the Requesting Party and the Non-Party 5 that some or all of the information requested is subject to a confidentiality agreement 6 with a Non-Party; 7 (2) promptly provide the Non-Party with a copy of the Stipulated 8 Protective Order in this Action, the relevant discovery request(s), and a reasonably 9 specific description of the information requested; and 10 (3) make the information requested available for inspection by the Non- 11 Party, if requested. 12 (c) If the Non-Party fails to object or seek a protective order from this court 13 within 14 days of receiving the notice and accompanying information, the Receiving 14 Party may produce the Non-Party’s confidential information responsive to the 15 discovery request. If the Non-Party timely seeks a protective order, the Receiving 16 Party shall not produce any information in its possession or control that is subject to 17 the confidentiality agreement with the Non-Party before a determination by the court. 18 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 19 of seeking protection in this court of its Protected Material. 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 Protected Material to any person or in any circumstance not authorized under this 23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 26 persons to whom unauthorized disclosures were made of all the terms of this Order, 27 and (d) request such person or persons to execute the “Acknowledgment and 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the court. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the specific 24 Protected Material at issue. If a Party’s request to file Protected Material under seal 25 is denied by the court, then the Receiving Party may file the information in the public 26 record unless otherwise instructed by the court. 27 13. FINAL DISPOSITION 1 days of a written request by the Designating Party, each Receiving Party must return 2 all Protected Material to the Producing Party or destroy such material. As used in this 3 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 4 summaries, and any other format reproducing or capturing any of the Protected 5 Material. Whether the Protected Material is returned or destroyed, the Receiving 6 Party must submit a written certification to the Producing Party (and, if not the same 7 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 8 (by category, where appropriate) all the Protected Material that was returned or 9 destroyed and (2) affirms that the Receiving Party has not retained any copies, 10 abstracts, compilations, summaries or any other format reproducing or capturing any 11 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 12 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 13 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 14 reports, attorney work product, and consultant and expert work product, even if such 15 materials contain Protected Material. Any such archival copies that contain or 16 constitute Protected Material remain subject to this Protective Order as set forth in 17 Section 4 (DURATION). 18 14. VIOLATION 19 Any violation of this Order may be punished by appropriate measures 20 including, without limitation, contempt proceedings and/or monetary sanctions. 21 22 23 24 25 26 27 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 || DATED November 18, 2021 4 5 || /s/Elliot J. Siegel ‘ Attorneys for Plaintiff

7 DATED November 18, 2021 8 9 || /s/Lincoln Ellis _ 10 Attorneys for Plaintiff

11 12 || DATED: November 18, 2021 13 /s/Vinee Farhat 14 || Attorneys for Defendant 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 DATED: November 19, 2021 19 20 21 22 LA J. STANDISH 33 United States Magistrate Judge 24 25 26 27 28

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 that 6 I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [date] in the case of Fausto Bustos v. Royal Bank of Canada et al., Case No. 2:21-cv- 9 04879-JAK (GJSx). I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I 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 PROOF OF SERVICE 1 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I, Josue Avila, hereby state that I am over the age of 18 and not a party to this action. 4 I am employed in and a resident of the county where service occurred, and my business address is 724 S. Spring Street, Suite 201, Los Angeles, California 90014. 5

6 On November 22, 2021, I caused to be served the following documents described as Stipulated Protective Order on the interested parties in this action as follows: 7

8 [X] TO BE SERVED VIA EMAIL 9 Marta M. Fernandez Lincoln W. Ellis 10 [email protected] [email protected] Vince Farhat Law Office Of Lincoln W. Ellis 11 [email protected] 292 S. La Cienega Boulevard, Suite 207 12 Brianna Frazier Earley Beverly Hills, California 90211

[email protected] 13 Attorney for Plaintiff Jeffer Mangels Butler & Mitchell LLP 14 1900 Avenue of the Stars, 7th Floor 15 Los Angeles, CA 90067

16 Attorneys for Defendants 17 I declare under penalty of perjury that the above is true and correct. 18 Executed on November 22, 2021, at Los Angeles, California. 19 20 /s/Josue Avila _ 21 Josue Avila 22 23 24 25 26 27