Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 1 of 17 Page ID #:920

1 LATHROP GPM LLP Nancy Sher Cohen (State Bar No. 81706) 2 [email protected] 3 Ronald A. Valenzuela (State Bar No. 210025) [email protected] 4 2049 Century Park East, Suite 3500S 5 Los Angeles, CA 90067 Telephone: 310.789.4600 6 Facsimile: 310.789.4601 7 Attorneys for Plaintiffs 8 BASF Corporation et al. 9

10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 BASF CORPORATION, et al., Case No. 2:20-cv-2586-GW-(Ex) 14 Plaintiffs, STIPULATED PROTECTIVE 15 vs. ORDER 16 CAL-TRON PLATING INC., et al., 17 Defendants. 18 19

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1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve valuable commercial, financial, technical, 13 settlement-related and/or proprietary information for which special protection from 14 public disclosure and from use for any purpose other than prosecution of this action 15 is warranted. Such confidential and proprietary materials and information consist 16 of, among other things, confidential business or financial information, information 17 regarding confidential business practices, or other confidential commercial 18 information (including information implicating privacy rights of third parties), 19 information otherwise generally unavailable to the public, or which may be 20 privileged or otherwise protected from disclosure under state or federal statutes, 21 court rules, case decisions, or common law. Accordingly, to expedite the flow of 22 information, to facilitate the prompt resolution of disputes over confidentiality of 23 discovery materials, to adequately protect information the parties are entitled to 24 keep confidential, to ensure that the parties are permitted reasonable necessary uses 25 of such material in preparation for and in the conduct of trial, to address their 26 handling at the end of the litigation, and serve the ends of justice, a protective order 27 for such information is justified in this action. It is the intent of the parties that 28 2 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 3 of 17 Page ID #:922

1 information will not be designated as confidential for tactical reasons and that 2 nothing be so designated without a good faith belief that it has been maintained in 3 a confidential, non-public manner, and there is good cause why it should not be part 4 of the public record of this case. 5 3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 14(c), below, that 7 this Stipulated Protective Order does not entitle them to file confidential 8 information under seal; Local Civil Rule 79-5 sets forth the procedures that must be 9 followed and the standards that will be applied when a party seeks permission from 10 the court to file material under seal. There is a strong presumption that the public 11 has a right of access to judicial proceedings and records in civil cases. In 12 connection with non-dispositive motions, good cause must be shown to support a 13 filing under seal. See Kamakana v. City and County of Honolulu,

, 14 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp.,

, 1210-11 (9th 15 Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 16 1999) (even stipulated protective orders require good cause showing), and a 17 specific showing of good cause or compelling reasons with proper evidentiary 18 support and legal justification, must be made with respect to Protected Material that 19 a party seeks to file under seal. The parties’ mere designation of Disclosure or 20 Discovery Material as CONFIDENTIAL does not—without the submission of 21 competent evidence by declaration, establishing that the material sought to be filed 22 under seal qualifies as confidential, privileged, or otherwise protectable—constitute 23 good cause. 24 Further, competent evidence supporting the application to file documents 25 under seal must be provided by declaration. If a party requests sealing related to a 26 dispositive motion or trial, then compelling reasons, not only good cause, for the 27 sealing must be shown, and the relief sought shall be narrowly tailored to serve the 28 3 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 4 of 17 Page ID #:923

1 specific interest to be protected. See Pintos v. Pacific Creditors Ass’n,

665, 677-79 (9th Cir. 2010). For each item or type of information, document, or 3 thing sought to be filed or introduced under seal in connection with a dispositive 4 motion or trial, the party seeking protection must articulate compelling reasons, 5 supported by specific facts and legal justification, for the requested sealing order. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 its entirety will not be filed under seal if the confidential portions can be redacted. 8 If documents can be redacted, then a redacted version for public viewing, omitting 9 only the confidential, privileged, or otherwise protectable portions of the document, 10 shall be filed. Any application that seeks to file documents under seal in their 11 entirety should include an explanation of why redaction is not feasible. 12 4. DEFINITIONS 13 (a) Action: the above-captioned lawsuit. 14 (b) Challenging Party: a Party or Non-Party that challenges 15 the designation of information or items under this Order. 16 (c) “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that 18 qualify for protection under Federal Rule of Civil Procedure 26(c), 19 and as specified above in the Good Cause Statement. 20 (d) Counsel: Outside Counsel of Record and House Counsel (as well as 21 their support staff). 22 (e) Designating Party: a Party or Non-Party that designates Disclosure or 23 Discovery Material (as defined below) as “CONFIDENTIAL.” 24 (f) Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or 26 maintained (including, among other things, testimony, transcripts, and 27 tangible things), that are produced or generated in disclosures or 28 responses to discovery in this Action. 4 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 5 of 17 Page ID #:924

1 (g) Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its 3 Counsel to serve as an expert witness or as a consultant in this Action. 4 (h) Final Disposition: the conclusion of any appellate proceedings, or, if 5 no appeal is taken, when the time for filing of an appeal has run. 6 (i) House Counsel: attorneys who are employees of a party to this Action. 7 House Counsel does not include Outside Counsel of Record or any 8 other outside counsel. 9 (j) Non-Party: any natural person, partnership, corporation, association, 10 or other legal entity not named as a Party to this action. 11 (k) Outside Counsel of Record: attorneys who are not employees of a 12 party to this Action but are retained to represent or advise a party to 13 this Action and have appeared in this Action on behalf of that party or 14 are affiliated with a law firm which has appeared on behalf of that 15 party, and includes support staff. 16 (l) Party: any party to this Action, including all of its officers, directors, 17 employees, Experts, House Counsel, and Outside Counsel of Record 18 (and their support staffs). 19 (m) Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 (n) Professional Vendors: persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, 23 preparing exhibits or demonstrations, and organizing, storing, or 24 retrieving data in any form or medium) and their employees and 25 subcontractors. 26 (o) Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 (p) Receiving Party: a Party that receives Disclosure or Discovery 5 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 6 of 17 Page ID #:925

1 Material from a Producing Party. 2 (q) Third Party: a person or entity that is not a party to the Stipulation. 3 5. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the 10 trial judge. This Order does not govern the use of Protected Material at trial. 11 6. DURATION 12 Except as set forth below, the terms of this protective order apply through 13 Final Disposition of the Action. The parties may stipulate that they will be 14 contractually bound by the terms of this agreement beyond Final Disposition, but 15 will have to file a separate action for enforcement of the agreement once all 16 proceedings in this case are complete. 17 Once a case proceeds to trial, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this protective order used or 19 introduced as an exhibit at trial becomes public and will be presumptively available 20 to all members of the public, including the press, unless compelling reasons 21 supported by specific factual findings to proceed otherwise are made to the trial 22 judge in advance of the trial. See Kamakana,

(distinguishing 23 “good cause” showing for sealing documents produced in discovery from 24 “compelling reasons” standard when merits-related documents are part of court 25 record). Accordingly, for such materials, the terms of this protective order do not 26 extend beyond the commencement of the trial. 27 7. DESIGNATING PROTECTED MATERIAL 28 6 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 7 of 17 Page ID #:926

1 (a) Exercise of Restraint and Care in Designating Material for Protection. 2 Each Party or Non-Party that designates information or items for protection 3 under this Order must take care to limit any such designation to specific material 4 that qualifies under the appropriate standards. The Designating Party must 5 designate for protection only those parts of material, documents, items, or oral or 6 written communications that qualify so that other portions of the material, 7 documents, items, or communications for which protection is not warranted are not 8 swept unjustifiably within the ambit of this Order. 9 Mass, indiscriminate, or routinized designations are prohibited. Designations 10 that are shown to be clearly unjustified or that have been made for an improper 11 purpose (e.g., to unnecessarily encumber the case development process or to 12 impose unnecessary expenses and burdens on other parties) may expose the 13 Designating Party to sanctions. 14 If it comes to a Designating Party’s attention that information or items that it 15 designated for protection do not qualify for protection, that Designating Party must 16 promptly notify all other Parties that it is withdrawing the inapplicable designation. 17 (b) Manner and Timing of Designations. 18 Except as otherwise provided in this Order, or as otherwise stipulated or 19 ordered, Disclosure or Discovery Material that qualifies for protection under this 20 Order must be clearly so designated before the material is disclosed or produced. 21 For information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), 23 designation in conformity with this Order requires the Producing Party affix at a 24 minimum, the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL 25 legend”), to each page that contains protected material. If only a portion or portions 26 of the material on a page qualifies for protection, the Producing Party also must 27 clearly identify the protected portion(s) (e.g., by making appropriate markings in 28 7 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 8 of 17 Page ID #:927

1 the margins). 2 A Party or Non-Party that makes original documents available for inspection 3 need not designate them for protection until after the inspecting Party has indicated 4 which documents it would like copied and produced. During the inspection and 5 before the designation, all of the material made available for inspection shall be 6 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 7 documents it wants copied and produced, the Producing Party must determine 8 which documents, or portions thereof, qualify for protection under this Order. Then, 9 before producing the specified documents, the Producing Party must affix the 10 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 11 portion or portions of the material on a page qualifies for protection, the Producing 12 Party also must clearly identify the protected portion(s) (e.g., by making 13 appropriate markings in the margins). 14 For testimony given in depositions, designation in conformity with this Order 15 requires the Designating Party to identify the Disclosure or Discovery Material on 16 the record, before the close of the deposition, all protected testimony. 17 For information produced in some form other than documentary and for any 18 other tangible items, designation in conformity with this Order requires that the 19 Producing Party affix in a prominent place on the exterior of the container or 20 containers in which the information is stored the legend “CONFIDENTIAL.” If 21 only a portion or portions of the information warrants protection, the Producing 22 Party, to the extent practicable, shall identify the protected portion(s). 23 (c) Inadvertent Failures to Designate. 24 If timely corrected, an inadvertent failure to designate qualified information 25 or items does not, standing alone, waive the Designating Party’s right to secure 26 protection under this Order for such material. Upon timely correction of a 27 designation, the Receiving Party must make reasonable efforts to assure that the 28 8 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 9 of 17 Page ID #:928

1 material is treated in accordance with the provisions of this Order. 2 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 (a) Timing of Challenges. 4 Any Party or Non-Party may challenge a designation of confidentiality at any 5 time that is consistent with the Court’s Scheduling Order. 6 (b) Meet and Confer. 7 The Challenging Party shall initiate the dispute resolution process under 8 Local Rule 37.1 et seq., with the exception that the Designating Party must provide 9 its portion of the Joint Stipulation under Local Rule 37-2.2 first, followed by the 10 Challenging Party adding its portion second. The burden of persuasion in any such 11 challenge proceeding shall be on the Designating Party. Frivolous challenges, and 12 those made for an improper purpose (e.g., to harass or impose unnecessary 13 expenses and burdens on other parties) may expose the Challenging Party to 14 sanctions. Unless the Designating Party has waived or withdrawn the 15 confidentiality designation, all parties shall continue to afford the material in 16 question the level of protection to which it is entitled under the Producing Party’s 17 designation until the Court rules on the challenge. 18 9. ACCESS TO AND USE OF PROTECTED MATERIAL 19 (a) Basic Principles. 20 A Receiving Party may use Protected Material that is disclosed or produced 21 by another Party or by a Non-Party in connection with this Action only for 22 prosecuting, defending, or attempting to settle this Action. Such Protected Material 23 may be disclosed only to the categories of persons and under the conditions 24 described in this Order. Protected Material must be stored and maintained by a 25 Receiving Party at a location and in a secure manner that ensures that access is 26 limited to the persons authorized under this Order. 27 (b) Disclosure of “CONFIDENTIAL” Information or Items. 28 9 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 10 of 17 Page ID #:929

1 Unless otherwise ordered by the court or permitted in writing by the 2 Designating Party, a Receiving Party may disclose any information or item 3 designated “CONFIDENTIAL” only to: 4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 5 as employees of said Outside Counsel of Record to whom it is reasonably necessary 6 to disclose the information for this Action; 7 (b) the officers, directors, and employees (including House Counsel) of the 8 Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) 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 (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 “Acknowledgement and Agreement to Be Bound” 22 (Exhibit A); and (2) they will not be permitted to keep any confidential information 23 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 24 unless otherwise agreed by the Designating Party or ordered by the court. Pages of 25 transcribed deposition testimony or exhibits to depositions that reveal Protected 26 Material may be separately bound by the court reporter and may not be disclosed to 27 anyone except as permitted under this Stipulated Protective Order; and 28 10 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 11 of 17 Page ID #:930

1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 4 IN OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation 6 that compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification 9 shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order 11 to issue in the other litigation that some or all of the material covered 12 by the subpoena or order is subject to this Protective Order. Such 13 notification shall include a copy of this Stipulated Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be 15 pursued by the Designating Party whose Protected Material may be 16 affected. 17 If the Designating Party timely seeks a protective order, the Party served 18 with the subpoena or court order shall not produce any information designated in 19 this action as “CONFIDENTIAL” before a determination by the court from which 20 the subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this Action 24 to disobey a lawful directive from another court. 25 11. NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 26 IN THIS ACTION 27 The terms of this Order are applicable to information produced by a Non- 28 11 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 12 of 17 Page ID #:931

1 Party in this Action and designated as “CONFIDENTIAL.” Such information 2 produced by Non-Parties in connection with this litigation is protected by the 3 remedies and relief provided by this Order. Nothing in these provisions should be 4 construed as prohibiting a Non-Party from seeking additional protections. 5 In the event that a Party is required, by a valid discovery request, to produce 6 a Non-Party’s confidential information in its possession, and the Party is subject to 7 an agreement with the Non-Party not to produce the Non-Party’s confidential 8 information, then the Party shall (a) promptly notify in writing the Requesting Party 9 and the Non-Party that some or all of the information requested is subject to a 10 confidentiality agreement with a Non-Party; (b) promptly provide the Non-Party 11 with a copy of the Stipulated Protective Order in this Action, the relevant discovery 12 request(s), and a reasonably specific description of the information requested; and 13 (c) make the information requested available for inspection by the Non-Party, if 14 requested. 15 If the Non-Party fails to seek a protective order from this court within 14 16 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this court of its Protected Material. 23 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has 25 disclosed Protected Material to any person or in any circumstance not authorized 26 under this Stipulated Protective Order, the Receiving Party must immediately (i) 27 notify in writing the Designating Party of the unauthorized disclosures, (ii) use its 28 12 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 13 of 17 Page ID #:932

1 best efforts to retrieve all unauthorized copies of the Protected Material, (iii) inform 2 the person or persons to whom unauthorized disclosures were made of all the terms 3 of this Order, and (iv) request such person or persons to execute the 4 “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A. 5 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other 9 protection, the obligations of the Receiving Parties are those set forth in Federal 10 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 11 whatever procedure may be established in an e-discovery order that provides for 12 production without prior privilege review. Pursuant to Federal Rule of Evidence 13 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 14 of a communication or information covered by the attorney-client privilege or work 15 product protection, the parties may incorporate their agreement in the stipulated 16 protective order submitted to the court. 17 14. MISCELLANEOUS 18 (a) Right to Further Relief. 19 Nothing in this Order abridges the right of any person to seek its 20 modification by the Court in the future. 21 (b) Right to Assert Other Objections. 22 By stipulating to the entry of this Protective Order no Party waives any right 23 it otherwise would have to object to disclosing or producing any information or 24 item on any ground not addressed in this Stipulated Protective Order. Similarly, no 25 Party waives any right to object on any ground to use in evidence of any of the 26 material covered by this Protective Order. 27 (c) Filing Protected Material. 28 13 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 14 of 17 Page ID #:933

1 A Party that seeks to file under seal any Protected Material must comply with 2 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to 3 a court order authorizing the sealing of the specific Protected Material at issue. If a 4 Party's request to file Protected Material under seal is denied by the court, then the 5 Receiving Party may file the information in the public record unless otherwise 6 instructed by the court. 7 15. 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 10 return all Protected Material to the Producing Party or destroy such material. As 11 used in this subdivision, “all Protected Material” includes all copies, abstracts, 12 compilations, summaries, and any other format reproducing or capturing any of the 13 Protected Material. Whether the Protected Material is returned or destroyed, the 14 Receiving Party must submit a written certification to the Producing Party (and, if 15 not the same person or entity, to the Designating Party) by the 60 day deadline that 16 identifies (by category, where appropriate) all the Protected Material that was 17 returned or destroyed, and affirms that the Receiving Party has not retained any 18 copies, abstracts, compilations, summaries or any other format reproducing or 19 capturing any of the Protected Material. 20 Notwithstanding this provision, Counsel are entitled to retain an archival 21 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 22 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 23 work product, and consultant and expert work product, even if such materials 24 contain Protected Material. Any such archival copies that contain or constitute 25 Protected Material remain subject to this Protective Order as set forth in Section 6 26 (DURATION). 27 16. VIOLATIONS 28 14 Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 15 of 17 Page ID #:934

1 Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions in the Court’s discretion. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 We hereby attest that concurrence in the filing of this stipulation was 6 obtained by each of the below identified signatories. 7 Dated: June 7, 2022 LATHROP GPM LLP 8 By: /s/ Ronald A. Valenzuela 9 Nancy Sher Cohen Ronald A. Valenzuela 10 Attorneys for Plaintiffs 11 12 Dated: June 7, 2022 VAN NESS FELDMAN LLP 13 By: /s/ Justin Panitchpakdi 14 Brian L. Zagon Justin Panitchpakdi 15 Attorneys for Defendant Cal-Tron 16 Plating, Inc.

17 18 Dated: June 7, 2022 HAMRICK & EVANS, LLP 19 By: /s/ Jeff Poole David L. Evans 20 Ilana Lohr-Schmidt 21 Jeff Poole

22 THE LAW OFFICES OF THOMAS P. 23 SCHMIDT Thomas P. Schmidt 24 Attorneys for Defendant Electronic 25 Chrome & Grinding Co., Inc.

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1 Dated: June 7. 2022 THE CRONIN LAW GROUP 2 By: /s/ Dennis J. Byrne 3 Timothy C. Cronin 4 Alan R. Johnston Dennis J. Byrne 5 Attorneys for Defendant Mid-West ‘ Fabricating Co. ; Dated: June 7, 2022 VAN RIPER LAW By: /s/ David A. Van Riper 7 David A. Van Riper 10 Attorneys for Defendant Santa Fe Rubber Products, Inc. 12 3 Dated: June 7, 2022 WEISS & ZAMAN

4 By: /s/ Thomas J. Weiss Thomas J. Weiss 15 Shawn Zaman 16 Attorneys for Defendant Vanowen Holdings, LLC 17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 || DATED: 6/15/22 By: /S/ CHARLES F. EICK 21 Hon. Charles F. Eick > United States Magistrate Judge Central District of California 23 24 25 26 27 28 16

Case 2:20-cv-02586-GW-E Document 152 Filed 06/15/22 Page 17 of 17 Page ID #:936

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of 7 California on [date] in the case of __________ [insert formal name of the 8 case and the number and initials assigned to it by the court]. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order 10 and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I 12 will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance 14 with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ________________________ [print 19 or type full name] of _________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25 Printed name: ____________________________________ 26

27 Signature: ________________________________ 28 17