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1 || DAVID G. SPIVAK (SBN 179684) [email protected] 2 || CAROLINE TAHMASSIAN (SBN 285680) 3 carolineWspivaklaw.com 4 MAYA CHEAITANI (SBN 335777) [email protected] NOTE: CHANGES MADE BY THE COURT 5 || THE SPIVAK LAW FIRM 6 8605 Santa Monica Blvd., PMB 42554 West Hollywood, CA 90069 7 || Telephone: (213) 725-9094 g || Facsimile: (213) 634-2485 9 || Attorneys for Plaintiff, 190 || YOUSSIF GAYED, and all others similarly situated "1 (Additional Attorneys for Parties on Next Page) 12 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 14 15 YOUSSIF GAYED, on behalf of himself | Case No. 2:21-cv-03828-DSF-JPR and all others similarly situated, and the 16 |! general public, DISCOVERY MATTER 17 Plaintiff, STIPULATED PROTECTIVE 18 ORDER 19 Vs. 50 Action filed: 3/5/2021 22ND CENTURY TECHNOLOGIES, 21 ||} INC., a New Jersey corporation; and The Honorable Magistrate Judge Jean 4 || DOES 1-50, inclusive, P. Rosenbluth U.S. Magistrate Judge om 2 Defendants. Courtroom: 690 24 25 SPIVAK LAW Employee “ Attorneys 26 reba 27 aaa cats rx 28

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1 ATTORNEY FOR DEFENDANT 2 1|W. BRAD ENGLISH 3 || LEE E. BAINS, JR. MITCHELL GREGGS 4 || FRIEDA A. TAYLOR 5 [email protected] 6 [email protected] mgreggs(@maynardcooper.com 7 [email protected] 8 MAYNARD COOPER & GALE 655 Gallatin Street SW 9 || Huntsville, AL 35801 10 || Telephone: 256-512-5705 "1 Facsimile: 256-512-5740

12 || Attorneys for Defendant 22ND CENTURY TECHNOLOGIES, INC. 13 14 15 16 17 18 19 20 21 22 — 2

25 SPIVAK LAW Employee “ Attorneys 26 see aasea 27 Glasto 28

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1 Counsel for Plaintiff YOUSSIF GAYED (“Plaintiff”) and Defendant 22ND 2 ||CENTURY TECHNOLOGIES, INC. (“Defendant”), by and through their 3 || respective counsel of record, stipulate as follows: 4 |} 1. INTRODUCTION 5 1.1 PURPOSES AND LIMITATIONS 6 Discovery in this action may involve production of confidential, proprietary 7 ||or private information for which special protection from public disclosure and 8 || from use for any purpose other than prosecuting this litigation may be warranted. 9 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 10 || following Stipulated Protective Order. The parties acknowledge that this Order 11 |}does not confer blanket protections on all disclosures or responses to discovery 12 |/and that the protection it affords from public disclosure and use extends only to 13 || the limited information or items that are entitled to confidential treatment under 14 || the applicable legal principles. 15 1.2 ~GOOD CAUSE STATEMENT 16 This employment class action arises under the California Labor Code, 17 regarding rest breaks and meal periods, payment of wages, failure to indemnify, 18 || waiting time penalties, and unfair competition. Discovery in this case will likely 19 ||]lead to the exchange of proprietary business information and employment 20 || practices or records for which special protection from public disclosure and from 21 |;use for any purpose other than prosecution of this action is warranted. Such 22 ||confidential and proprietary materials and information may consist of, among _ 23 || other things, confidential business or financial information, information regarding —_ 24 ||confidential business practices, or other confidential research, development, or 25 || commercial information (including information implicating privacy rights of third “ee nea parties), information otherwise generally unavailable to the public, or which may Sone 27 || be privileged or otherwise protected from disclosure under state or federal statutes, a cvs 28 ||court rules, case decisions, or common law. Accordingly, to expedite the flow of

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1 ||information, to facilitate the prompt resolution of disputes over confidentiality of 2 ||discovery materials, to adequately protect information the parties are entitled to 3 ||keep confidential, to ensure that the parties are permitted reasonable necessary 4 || uses of such material in preparation for and in the conduct of trial, to address their 5 || handling at the end of the litigation, and serve the ends of justice, a protective order 6 || for such information is justified in this matter. It 1s the intent of the parties that 7 ||information will not be designated as confidential for tactical reasons and that 8 || nothing be so designated without a good faith belief that it has been maintained in 9 ||a confidential, non-public manner, and there is good cause why it should not be 10 || part of the public record of this case. 11 The parties further acknowledge, as set forth in Section 12.3, below, that 12 |/this Stipulated Protective Order does not entitle them to file confidential 13 |}information under seal; Local Civil Rule 79-5 sets forth the procedures that must 14 || be followed and the standards that will be applied when a party seeks permission 15 || from the court to file material under seal. 16 || 2. DEFINITIONS 17 2.1 Action: this pending federal lawsuit, YOUSSIF GAYED, et al. v. 22ND 18 || CENTURY TECHNOLOGIES, INC., et al., Case No. 2:21-cv-03828-DSF-JPR. 19 2.2 Challenging Party: a Party or Non-Party that challenges the designation 20 || of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 22 ||how it is generated, stored or maintained) or tangible things that qualify for _ 23 ||protection under Federal Rule of Civil Procedure 26(c), and as specified above in —_ 24 || the Good Cause Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their SPIVAK LAW me QE 26 || Support staff). ent 27 2.5 Designating Party: a Party or Non-Party that designates information or aioe 28 |}items that it produces in disclosures or in responses to discovery as

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1 || “CONFIDENTIAL.” 2 2.6 Disclosure or Discovery Material: all items or information, regardless 3 || of the medium or manner in which it is generated, stored, or maintained (including, 4 ||among other things, testimony, transcripts, and tangible things), that are produced 5 ||or generated in disclosures or responses to discovery in this matter. 6 2.7 Expert: a person with specialized knowledge or experience in a matter 7 || pertinent to the litigation who has been retained by a Party or its counsel to serve 8 ||as an expert witness or as a consultant in this Action. 9 2.8 House Counsel: attorneys who are employees of a party to this Action. 10 || House Counsel does not include Outside Counsel of Record or any other outside 11 {| counsel. 12 2.9 Non-Party: any natural person, partnership, corporation, association or 13 || other legal entity not named as a Party to this action. 14 2.10 Outside Counsel of Record: attorneys who are not employees of a party 15 || to this Action but are retained to represent or advise a party to this Action and have 16 || appeared in this Action on behalf of that party or are affiliated with a law firm that 17 || has appeared on behalf of that party, and includes support staff. 18 2.11 Party: any party to this Action, including all of its officers, directors, 19 |}employees, consultants, retained experts, and Outside Counsel of Record (and 20 || their support staffs). 21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 22 || Discovery Material in this Action. ae 23 2.13 Professional Vendors: persons or entities that provide litigation support —_ 24 ||/services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 || demonstrations, and organizing, storing, or retrieving data in any form or medium) “ee nea and their employees and subcontractors. geet 27 2.14 Protected Material: any Disclosure or Discovery Material that is aioe 28 || designated as “CONFIDENTIAL.”

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1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 || from a Producing Party. 3 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 || 4. DURATION 12 Once a case proceeds to trial, information that was designated as 13 |} CONFIDENTIAL or maintained pursuant to this protective order used or 14 |/introduced as an exhibit at trial becomes public and will be presumptively 15 ||available to all members of the public, including the press, unless compelling 16 ||reasons supported by specific factual findings to proceed otherwise are made to 17 || the trial judge in advance of the trial. See Kamakana v. City & Cnty. of Honolulu, 18 ||

, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for 19 |]sealing documents produced in discovery from “compelling reasons” standard 20 || when merits-related documents are part of court record). Accordingly, the terms 21 || of this protective order do not extend beyond the commencement of the trial. 22 ||5. DESIGNATING PROTECTED MATERIAL ae 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. —_ 24 || Each Party or Non-Party that designates information or items for protection under 25 ||this Order must take care to limit any such designation to specific material that ‘et qualifies under the appropriate standards. The Designating Party must designate Sone 27 □□ □□□ protection only those parts of material, documents, items or oral or written eles 28 ||communications that qualify so that other portions of the material, documents,

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1 |}items or communications for which protection is not warranted are not swept 2 |;/unjustifiably within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. 4 || Designations that are shown to be clearly unjustified or that have been made for 5 ||an improper purpose (e.g., to unnecessarily encumber the case development 6 ||process or to impose unnecessary expenses and burdens on other parties) may 7 ||expose the Designating Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that 9 ||it designated for protection do not qualify for protection, that Designating Party 10 ||must promptly notify all other Parties that it is withdrawing the inapplicable 11 || designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 ||stipulated or ordered, Disclosure or Discovery Material that qualifies for 15 || protection under this Order must be clearly so designated before the material is 16 || disclosed or produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic 19 ||documents, but excluding transcripts of depositions or other pretrial or trial 20 || proceedings), that the Producing Party affix at a minimum, the legend 21 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each page that 22 ||contains protected material. If only a portion of the material on a page qualifies _~, 23 ||for protection, the Producing Party also must clearly identify the protected —_ 24 || portion(s) (e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for SPIVAK LAW mires _— 26 |/inspection need not designate them for protection until after the inspecting Party aca 27 ||has indicated which documents it would like copied and produced. During the eles 28 |/inspection and before the designation, all of the material made available for

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1 |}inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 2 ||identified the documents it wants copied and produced, the Producing Party must 3 || determine which documents, or portions thereof, qualify for protection under this 4 || Order. Then, before producing the specified documents, the Producing Party must 5 ||affix the “CONFIDENTIAL legend” to each page that contains Protected 6 || Material. If only a portion of the material on a page qualifies for protection, the 7 || Producing Party also must clearly identify the protected portion(s) (e.g., by making 8 || appropriate markings in the margins). 9 (b) for testimony given in depositions that the Designating Party 10 ||identifies the Disclosure or Discovery Material on the record, before the close of 11 || the deposition all protected testimony. 12 (c) for information produced in some form other than documentary 13 |jand for any other tangible items, that the Producing Party affix in a prominent 14 place on the exterior of the container or containers in which the information is 15 ||stored the legend “CONFIDENTIAL.” If only a portion or portions of the 16 ||information warrants protection, the Producing Party, to the extent practicable, 17 ||shall identify the protected portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 || failure to designate qualified information or items does not, standing alone, waive 20 ||the Designating Party’s right to secure protection under this Order for such 21 ||material. Upon timely correction of a designation, the Receiving Party must make 22 ||reasonable efforts to assure that the material is treated in accordance with the _ 23 ||provisions of this Order. —_ 24 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a SPIVAK LAW mires “wes 26 || designation of confidentiality at any time consistent with the Court’s Scheduling Sotee® 27 [Order aioe 28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute sets Gayed v. 22nd Century Technologies, Inc., et al. Stipulated Protective Order

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1 ||resolution process under Local Rule 37-1 et seq. 2 6.3 Joint Stipulation. Any challenge submitted to the Court shall be 3 ||submitted first via a joint stipulation pursuant to Local Rule 37-2. 4 6.4 Burden of Persuasion. The burden of persuasion in any such challenge 5 ||proceeding shall be on the Designating Party. Frivolous challenges, and those 6 ||made for an improper _purpose (e.g., to harass or impose unnecessary expenses and 7 ||burdens on other_parties) may expose the Challenging Party to sanctions. Unless 8 || the Designating Party has waived or withdrawn the confidentiality designation, all 9 || parties shall_continue to afford the material in question the level of protection to 10 || which it is_entitled under the Producing Party’s designation until the Court rules 11 |}on the challenge. 12 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 || disclosed or produced by another Party or by a Non-Party in connection with this 15 || Action only for prosecuting, defending or attempting to settle this Action. Such 16 || Protected Material may be disclosed only to the categories of persons and under 17 || the conditions described in this Order. When the Action has been terminated, a 18 || Receiving Party must comply with the provisions of section 13 below (FINAL 19 || DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 || authorized under this Order. ae 23 7.2 Disclosure “CONFIDENTIAL” Information_or_ Items. Unless —_ 24 || otherwise ordered by the court or permitted in writing by the Designating Party, a 25 ||Receiving Party may disclose any information or item designated SPIVAK LAW smpioyes “ “ere 26 || “CONFIDENTIAL” only to: ent 27 (a) the Receiving Party’s Outside Counsel of Record in this Action, aioe 28 || as well as employees of said Outside Counsel of Record to whom it is reasonably sets Gayed v. 22nd Century Technologies, Inc., et al. Stipulated Protective Order

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1 ||necessary to disclose the information for this Action; 2 (b) the officers, directors, and employees (including House Counsel) 3 || of the Receiving Party to whom disclosure is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to whom 5 ||disclosure is reasonably necessary for this Action and who have signed the 6 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and 10 || Professional Vendors to whom disclosure is reasonably necessary for this Action 11 |}and who have signed the “Acknowledgment and Agreement to Be Bound” 12 || (Exhibit A); 13 (g) the author or recipient of a document containing the information 14 |] or a custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, 16 {jin the Action to whom disclosure is reasonably necessary provided: (1) the 17 || deposing party requests that the witness sign the form attached as Exhibit A hereto; 18 |} and (2) they will not be permitted to keep any confidential information unless they 19 ||sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 20 ||otherwise agreed by the Designating Party or ordered by the court. Pages of 21 ||transcribed deposition testimony or exhibits to depositions that reveal Protected 22 || Material may be separately bound by the court reporter and may not be disclosed _ 23 ||/to anyone except as permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, 25 ||mutually agreed upon by any of the parties engaged in settlement discussions or “ee season 9g appointed by the Court. worsen og Wf) West Hollywood, CA 80068 epenacers 28 |I///

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1 1/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 ||that compels disclosure of any information or items designated in this Action as 5 ||“CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such 7 |{notification shall include a copy of the subpoena or court order unless prohibited 8 || by law; 9 (b) promptly notify in writing the party who caused the subpoena or 10 || order to issue in the other litigation that some or all of the material covered by the 11 |}subpoena or order is subject to this Protective Order. Such notification shall 12 |}include a copy of this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be 14 || pursued by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served 16 || with the subpoena or court order shall not produce any information designated in 17 || this action as “CONFIDENTIAL” before a determination by the court from which 18 || the subpoena or order issued, unless the Party has obtained the Designating Party’s 19 || permission. The Designating Party shall bear the burden and expense of seeking 20 || protection in that court of its confidential material and nothing in these provisions 21 || should be construed as authorizing or encouraging a Receiving Party in this Action 22 || to disobey a lawful directive from another court. om 23 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE —_ 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by “ee ne Ate 96 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such ent 27 || information produced by Non-Parties in connection with this litigation is protected aioe 28 || by the remedies and relief provided by this Order. Nothing in these provisions sonates Gayed v. 22nd Century Technologies, Inc., et al. Stipulated Protective Order

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1 |}should be construed as prohibiting a Non-Party from seeking additional 2 || protections. 3 (b) In the event that a Party is required, by a valid discovery request, 4 ||to produce a Non-Party’s confidential information in its possession, and the Party 5 ||is subject to an agreement with the Non-Party not to produce the Non-Party’s 6 || confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the 8 ||Non-Party that some or all of the information requested is subject to a 9 || confidentiality agreement with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the 11 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a 12 ||reasonably specific description of the information requested; and 13 (3) make the information requested available for inspection by 14 || the Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court 16 || within 21 days of receiving the notice and accompanying information, the 17 || Receiving Party may produce the Non-Party’s confidential information responsive 18 ||to the discovery request. If the Non-Party timely seeks a protective order, the 19 || Receiving Party shall not produce any information in its possession or control that 20 ||is subject to the confidentiality agreement with the Non-Party before a 21 || determination by the court. Absent a court order to the contrary, the Non-Party 22 ||shall bear the burden and expense of seeking protection in this court of its _, 23 || Protected Material. —_ 24 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has SPIVAK LAW pone" 26 || disclosed Protected Material to any person or in any circumstance not authorized ent 27 || under this Stipulated Protective Order, the Receiving Party must immediately (a) aioe 28 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its

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1 || best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 2 || the person or persons to whom unauthorized disclosures were made of all the terms 3 |jof this Order, and (d) request such person or persons to execute the 4 ||“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 5 ||A. 6 |j11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 |/inadvertently produced material is subject to a claim of privilege or other 10 || protection, the obligations of the Receiving Parties are those set forth in Federal 11 |}Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 12 || whatever procedure may be established in an e-discovery order that provides for 13 || production without prior privilege review. Pursuant to Federal Rule of Evidence 14 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 15 ||of a communication or information covered by the attorney-client privilege or 16 || work product protection, the parties may incorporate their agreement in the 17 stipulated protective order submitted to the court provided the Court so allows. 18 |[12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 || person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 || Protective Order, no Party waives any right it otherwise would have to object to _ 23 disclosing or producing any information or item on any ground not addressed in —_ 24 || this Stipulated Protective Order. Similarly, no Party waives any right to object on 25 ||any ground to use in evidence of any of the material covered by this Protective SPIVAK LAW smpoves “ors 26 || Order. ent 27 12.3 Filing Protected Material. A Party that seeks to file under seal any aioe 28 || Protected Material must comply with Local Civil Rule 79-5. Protected Material sets 13 Gayed v. 22nd Century Technologies, Inc., et al. Stipulated Protective Order

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1 ||may only be filed under seal pursuant to a court order authorizing the sealing of 2 ||the specific Protected Material at issue. If a Party’s request to file Protected 3 || Material under seal is denied by the court, then the Receiving Party may file the 4 ||information in the public record unless otherwise instructed by the court. 5 ||13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 7 ||60 days of a written request by the Designating Party, each Receiving Party must 8 ||return all Protected Material to the Producing Party or destroy such material. As 9 ||!used in this subdivision, “all Protected Material” includes all copies, abstracts, 10 ||} compilations, summaries, and any other format reproducing or capturing any of 11 ||the Protected Material. Whether the Protected Material is returned or destroyed, 12 ||the Receiving Party must submit a written certification to the Producing Party 13 ||(and, if not the same person or entity, to the Designating Party) by the 60 day 14 ||deadline that (1) identifies (by category, where appropriate) all the Protected 15 || Material that was returned or destroyed and (2) affirms that the Receiving Party 16 ||has not retained any copies, abstracts, compilations, summaries or any other 17 || format reproducing or capturing any of the Protected Material. Notwithstanding 18 ||this provision, Counsel are entitled to retain an archival copy of all pleadings, 19 ||motion papers, trial, deposition, and hearing transcripts, legal memoranda, 20 ||correspondence, deposition and trial exhibits, expert reports, attorney work 21 || product, and consultant and expert work product, even if such materials contain 22 || Protected Material. Any such archival copies that contain or constitute Protected _, 23 ||Material remain subject to this Protective Order as set forth in Section 4 —_ 24 || (DURATION). 25 SANCTIONS SPIVAK LAW mires _— 26 Any willful violation of this Order may be punished by appropriate aca 27 ||measures including, without limitation, contempt proceedings and/or monetary esac’. 28 |] sanctions.

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1 Counsel for Defendant has authorized the filing of this Stipulation with the 2 || use of his/her electronic signature hereon. 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. THE SPIVAK LAW FIRM 7 Dated: October 21, 2022 By: /s/ David Spivak DAVID G. SPIVAK 8 CAROLINE TAHMASSIAN 9 MAYA CHEAITANI, Attorneys for Plaintiff, YOUSSIF GAYED, and all 10 others similarly situated 1] 0 MAYNARD COOPER & GALE

13 14 Dated: October 21, 2022 By: /s/ W. Brad English (authorized on 10/21/22) 15 W. BRAD ENGLISH 16 LEE E. BAINS, JR. MITCHELL GREGGS, M7 FRIEDA A. TAYLOR, Attorneys for 18 Defendant, 22ND CENTURY 19 TECHNOLOGIES, INC. 20

22 || DATED: October 26, 2022 23 THE HON. JEAN P. ROSENBLUTH 04 U.S. MAGISTRATE JUDGE

25 SPIVAK LAW Employee “ Attorneys 26 mermp □□□ 27 aaa cats rx 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 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 California 7 |jon [date] in the case of YOUSSIF GAYED), et al. v. 22ND 8 || CENTURY TECHNOLOGIES, INC., et al., Case No. 2:21-cv-03828-DSF-JPR. I 9 || agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose 11 |}me to sanctions and punishment in the nature of contempt. I solemnly promise that 12 |/I 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 with 14 ||the provisions of this Order. I further agree to submit to the jurisdiction of the 15 || United States District Court for the Central District of California for enforcing the 16 ||terms of this Stipulated Protective Order, even if such enforcement proceedings 17 |}occur after termination of this action. 18 I hereby appoint [print or type full name] 19 || of [print or type full address and 20 || telephone number] as my California agent for service of process in connection 21 || with this action or any proceedings related to enforcement of this Stipulated 22 || Protective Order. 24 || Date: 25 || City and State where sworn and signed: Saeki ateraney Pore AOE I ane 27 || Printed name: esacmcs og |[Sigmature;

sets 16 Gayed v. 22nd Century Technologies, Inc., et al. Stipulated Protective Order