Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 1 of 15 Page ID #:267

1 NAZGOLE HASHEMI (SBN 291711) [email protected] 2 TANNAZ HASHEMI (SBN 296640) 3 [email protected] 4 LegalAxxis, Inc. 1999 Avenue of the Stars, Suite 1100 5 Century City, CA 90067 6 Telephone: (424) 249-3685 Facsimile: (424) 208-0622 7 Attorneys for Plaintiff 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 BRENDA CORNEJO, an individual, Case No. 2:22-cv-6022-JFW (Ex) Hon. Judge John F. Walter 12 Plaintiff, Hon. Mag. Charles F. Eick 13 v. [P__ R_ O__ P_ O_ S_ E__ D_ ] PROTECTIVE ORDER 14 15 LOWE’S HOME CENTERS, LLC, a [DISCOVERY MATTER] 16 limited liability company; SEDGWICK CLAIMS MANAGEMENT SERVICES, Filing Date: 7/20/22 17 INC., a corporation; and DOES 1-10, Removal Date: 8/24/22 18 Trial: 8/28/23 Defendants. 19 20 21 1. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 medical, proprietary, or private information for which special protection from 24 public disclosure and from use for any purpose other than prosecuting this 25 litigation may be warranted. Accordingly, the parties hereby stipulate to and 26 petition the Court to enter the following Stipulated Protective Order. The parties 27 acknowledge that this Order does not confer blanket protections on all disclosures 28 or responses to discovery and that the protection it affords from public disclosure 1 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 2 of 15 Page ID #:268

1 and use extends only to the limited information or items that are entitled to confidential 2 treatment under the applicable legal principles. 3 GOOD CAUSE STATEMENT 4 This action is likely to involve confidential commercial, financial, medical, and/or 5 proprietary information for which special protection from public disclosure and from use 6 for any purpose other than prosecution of this action is warranted. Such confidential and 7 proprietary materials and information consist of, among other things, confidential 8 business, financial, personnel, and/or medical records and information (including 9 information implicating privacy rights of third parties), information otherwise generally 10 unavailable to the public, or which may be privileged or otherwise protected from 11 disclosure under state or federal statutes, court rules, case decisions, or common law. 12 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 13 disputes over confidentiality of discovery materials, to adequately protect information 14 the parties are entitled to keep confidential, to ensure that the parties are permitted 15 reasonable necessary uses of such material in preparation for and in the conduct of trial, 16 to address their handling at the end of the litigation, and serve the ends of justice, a 17 protective order for such information is justified in this matter. It is the intent of the 18 parties that information will not be designated as confidential for tactical reasons and 19 that nothing be so designated without a good faith belief that it has been maintained in a 20 confidential, non-public manner, and there is good cause why it should not be part of the 21 public record of this case. 22 ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 23 The parties further acknowledge, as set forth in Section 12.3, below, that this 24 Stipulated Protective Order does not entitle them to file confidential information under 25 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 26 standards that will be applied when a party seeks permission from the court to file 27 material under seal. 28 There is a strong presumption that the public has a right of access to judicial 2 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 3 of 15 Page ID #:269

1 proceedings and records in civil cases. In connection with non-dispositive 2 motions, good cause must be shown to support a filing under seal. See Kamakana 3 v. City and County of Honolulu,

(9th Cir. 2006); Phillips v. 4 Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. 5 Sony Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated 6 protective orders require good cause showing), and a specific showing of good 7 cause or compelling reasons with proper evidentiary support and legal justification, 8 must be made with respect to Protected Material that a party seeks to file under 9 seal. The parties’ mere designation of Disclosure or Discovery Material as 10 CONFIDENTIAL does not—without the submission of competent evidence by 11 declaration, establishing that the material sought to be filed under seal qualifies as 12 confidential, privileged, or otherwise protectable—constitute good cause. 13 Further, if a party requests sealing related to a dispositive motion or trial, 14 then compelling reasons, not only good cause, for the sealing must be shown, and 15 the relief sought shall be narrowly tailored to serve the specific interest to be 16 protected. See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 17 2010). For each item or type of information, document, or thing sought to be filed 18 or introduced under seal in connection with a dispositive motion or trial, the party 19 seeking protection must articulate compelling reasons, supported by specific facts 20 and legal justification, for the requested sealing order. Again, competent evidence 21 supporting the application to file documents under seal must be provided by 22 declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in 24 its entirety will not be filed under seal if the confidential portions can be redacted. 25 If documents can be redacted, then a redacted version for public viewing, omitting 26 only the confidential, privileged, or otherwise protectable portions of the 27 document, shall be filed. Any application that seeks to file documents under seal 28 in their entirety should include an explanation of why redaction is not feasible. 3 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 4 of 15 Page ID #:270

1 2. DEFINITIONS 2 2.1 Action: the above-captioned case. 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 4 information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 6 generated, stored or maintained) or tangible things that qualify for protection under 7 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 8 Statement. 9 2.4 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as 10 well as their support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or items that it 12 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 13 2.6 Disclosure or Discovery Material: all items or information, regardless of the 14 medium or manner in which it is generated, stored, or maintained (including, among 15 other things, testimony, transcripts, and tangible things), that are produced or generated 16 in disclosures or responses to discovery in this matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to 18 the litigation who has been retained by a Party or its counsel to serve as an expert 19 witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. House 21 Counsel does not include Outside Counsel of Record or any other outside counsel. 22 2.9 Non-Party: any natural person, partnership, corporation, association or other legal 23 entity not named as a Party to this action. 24 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 25 action but are retained to represent or advise a party to this Action and have appeared in 26 this action on behalf of that party or are affiliated with a law firm which has appeared on 27 behalf of that party, and includes support staff. 28 2.11 Party: any party to this action, including all of its officers, directors, employees, 4 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 5 of 15 Page ID #:271

1 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 2 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 3 Material in this action. 4 2.13 Professional Vendors: persons or entities, not employed by or affiliated with a 5 Party, that provide litigation support services (e.g., photocopying, videotaping, 6 translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving 7 data in any form or medium) and their employees and subcontractors. 8 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 9 “CONFIDENTIAL.” 10 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from a 11 Producing Party. 12 3. SCOPE 13 The protections conferred by this Stipulation and Order cover not only 14 Protected Material (as defined above), but also (1) any information copied or 15 extracted from Protected Material; (2) all copies, excerpts, summaries, or 16 compilations of Protected Material; and (3) any testimony, conversations, or 17 presentations by Parties or their Counsel that might reveal Protected Material. Any 18 use of Protected Material at trial shall be governed by the orders of the trial judge. 19 This Order does not govern the use of Protected Material at trial. 20 4. DURATION 21 Once a case proceeds to trial, information that was designated as 22 CONFIDENTIAL or maintained pursuant to this protective order and used or 23 introduced as an exhibit at trial becomes public and will be presumptively 24 available to all members of the public, including the press, unless compelling 25 reasons supported by specific factual findings to proceed otherwise are made to the 26 trial judge in advance of the trial. See Kamakana,

-81 27 (distinguishing “good cause” showing for sealing documents produced in 28 discovery from “compelling reasons” standard when merits-related documents are 5 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 6 of 15 Page ID #:272

1 part of court record). Accordingly, the terms of this protective order do not extend 2 beyond the commencement of the trial. 3 Even after final disposition of this litigation, the confidentiality obligations 4 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 5 in writing or a court order otherwise directs. Final disposition shall be deemed to be the 6 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 7 and (2) final judgment herein after the completion and exhaustion of all appeals, 8 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 9 any motions or applications for extension of time pursuant to applicable law. 10 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 12 Non-Party that designates information or items for protection under this Order must 13 take care to limit any such designation to specific material that qualifies under the 14 appropriate standards. The Designating Party must designate for protection only 15 those parts of material, documents, items or oral or written communications that 16 qualify so that other portions of the material, documents, items or communications 17 for which protection is not warranted are not swept unjustifiably within the ambit of 18 this Order. Mass, indiscriminate or routinized designations are prohibited. 19 Designations that are shown to be clearly unjustified or that have been made for an 20 improper purpose (e.g., to unnecessarily encumber the case development process or 21 to impose unnecessary expenses and burdens on other parties) may expose the 22 Designating Party to sanctions. If it comes to a Designating Party’s attention that 23 information or items that it designated for protection do not qualify for protection, 24 that Designating Party must promptly notify all other Parties that it is withdrawing 25 the inapplicable designation. 26 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order, or 27 as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 28 protection under this Order must be clearly so designated before the material is 6 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 7 of 15 Page ID #:273

1 disclosed or produced. Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, but 3 excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page 5 that contains protected material. 6 (b) for testimony given in depositions that the Designating Party identifies the 7 Disclosure or Discovery Material on the record, before the close of the deposition all 8 protected testimony. 9 (c) for information produced in some form other than documentary and for any 10 other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” 13 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 14 designate qualified information or items does not, standing alone, waive the 15 Designating Party’s right to secure protection under this Order for such material. 16 Upon timely correction of a designation, the Receiving Party must make reasonable 17 efforts to assure that the material is treated in accordance with the provisions of this 18 Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 21 confidentiality at any time that is consistent with the Court’s Scheduling Order. 22 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process 23 under Local Rule 37-1 et seq. 24 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 25 stipulation pursuant to Local Rule 37-2. 26 6.4 The burden of persuasion in any such challenge proceeding shall be on the 27 Designating Party. Frivolous challenges, and those made for an improper purpose 28 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 7 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 8 of 15 Page ID #:274

1 expose the Challenging Party to sanctions. Unless the Designating Party has waived 2 or withdrawn the confidentiality designation, all parties shall continue to afford the 3 material in question the level of protection to which it is entitled under the Producing 4 Party’s designation until the Court rules on the challenge. 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 7 produced by another Party or by a Non-Party in connection with this Action only, for 8 prosecuting, defending or attempting to settle this Action. Such Protected Material 9 may be disclosed only to the categories of persons and under the conditions described 10 in this Order. When the Action has been terminated, a Receiving Party must comply 11 with the provisions of section 13 below (FINAL DISPOSITION). Protected Material 12 must be stored and maintained by a Receiving Party at a location and in a secure 13 manner that ensures that access is limited to the persons authorized under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by 15 the court or permitted in writing by the Designating Party, a Receiving Party may 16 disclose any information or item designated “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 18 employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) of the Receiving 21 Party to whom disclosure is reasonably necessary for this Action; 22 (c) experts (as defined in this Order) of the Receiving Party to whom disclosure is 23 reasonably necessary for this Action and who have signed the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 28 whom disclosure is reasonably necessary for this Action and who have signed the 8 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 9 of 15 Page ID #:275

1 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (g) the author or recipient of a document containing the information or a custodian or 3 other person who otherwise possessed or knew the information; 4 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to 5 whom disclosure is reasonably necessary provided: (1) the deposing party requests that 6 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 7 to keep any confidential information unless they sign the “Acknowledgment and 8 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 9 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 10 depositions that reveal Protected Material may be separately bound by the court reporter 11 and may not be disclosed to anyone except as permitted under this Stipulated Protective 12 Order; and 13 (i) any mediator or settlement officer, and their supporting personnel, mutually 14 agreed upon by any of the parties engaged in settlement discussions. 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 16 IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation that 18 compels disclosure of any information or items designated in this Action as 19 “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification shall include a 21 copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order to issue in 23 the other litigation that some or all of the material covered by the subpoena or order is 24 subject to this Protective Order. Such notification shall include a copy of this Protective 25 Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 27 Designating Party whose Protected Material may be affected. If the Designating Party 28 timely seeks a protective order, the Party served with the subpoena or court order shall 9 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 10 of 15 Page ID #:276

1 not produce any information designated in this action as “CONFIDENTIAL” before a 2 determination by the court from which the subpoena or order issued, unless the Party has 3 obtained the Designating Party’s permission. The Designating Party shall bear the 4 burden and expense of seeking protection in that court of its confidential material and 5 nothing in these provisions should be construed as authorizing or encouraging a 6 Receiving Party in this Action to disobey a lawful directive from another court. 7 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 8 PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by a Non-Party in 10 this Action and designated as “CONFIDENTIAL.” Such information produced by Non- 11 Parties in connection with this litigation is protected by the remedies and relief provided 12 by this Order. Nothing in these provisions should be construed as prohibiting a Non- 13 Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to produce a 15 Non-Party’s confidential information in its possession, and the Party is subject to an 16 agreement with the Non-Party not to produce the Non-Party’s confidential information, 17 then the Party shall: 18 1) promptly notify in writing the Requesting Party and the Non-Party that some or all 19 of the information requested is subject to a confidentiality agreement with a Non-Party; 20 2) promptly notify in writing the Requesting Party and the Non-Party that some or all 21 of the information requested is subject to a confidentiality agreement with a Non-Party; 22 3) make the information requested available for inspection by the Non-Party, if 23 requested. 24 (c) If the Non-Party fails to seek a protective order from this court within 14 days of 25 receiving the notice and accompanying information, the Receiving Party may produce 26 the Non-Party’s confidential information responsive to the discovery request. If the 27 Non-Party timely seeks a protective order, the Receiving Party shall not produce any 28 information in its possession or control that is subject to the confidentiality agreement 10 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 11 of 15 Page ID #:277

1 with the Non-Party before a determination by the court. Absent a court order to the 2 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 3 court of its Protected Material. 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 6 Material to any person or in any circumstance not authorized under this Stipulated 7 Protective Order, the Receiving Party must immediately (a) notify in writing the 8 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 9 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 10 unauthorized disclosures were made of all the terms of this Order, and (d) request such 11 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 12 attached hereto as Exhibit A. 13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain inadvertently 16 produced material is subject to a claim of privilege or other protection, the obligations of 17 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 18 This provision is not intended to modify whatever procedure may be established in an e- 19 discovery order that provides for production without prior privilege review. Pursuant to 20 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 21 effect of disclosure of a communication or information covered by the attorney-client 22 privilege or work product protection, the parties may incorporate their agreement in the 23 stipulated protective order submitted to the court. 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 26 seek its modification by the court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 28 Order, no Party waives any right it otherwise would have to object to disclosing or 11 PROTECTIVE ORDER Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 12 of 15 Page ID #:278

1 producing any information or item on any ground not addressed in this Stipulated 2 Protective Order. Similarly, no Party waives any right to object on any ground to 3 use in evidence of any of the material covered by this Protective Order. 4 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 5 Material must comply with Local Civil Rule 79-5. Protected Material may only be 6 filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material at issue. If a Party’s request to file Protected Material under seal 8 is denied by the court, then the Receiving Party may file the information in the 9 public record unless otherwise instructed by the court. 10 13. FINAL DISPOSITION 11 After the final disposition of this Action, as defined in paragraph 4, within 60 days of a 12 written request by the Designating Party, each Receiving Party must return all Protected 13 Material to the Producing Party or destroy such material. As used in this subdivision, 14 “all Protected Material” includes all copies, abstracts, compilations, summaries, and any 15 other format reproducing or capturing any of the Protected Material. Whether the 16 Protected Material is returned or destroyed, the Receiving Party must submit a written 17 certification to the Producing Party (and, if not the same person or entity, to the 18 Designating Party) by the 60 day deadline that (1) identifies (by category, where 19 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 20 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 21 any other format reproducing or capturing any of the Protected Material. 22 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 23 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 24 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 25 consultant and expert work product, even if such materials contain Protected Material. 26 Any such archival copies that contain or constitute Protected Material remain subject to 27 this Protective Order as set forth in Section 4. 28 /// 12 PROTECTIVE ORDER ase 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page13o0f15 Page ID #:279

1 |}14. VIOLATION 2 || Any violation of this Order may be punished by appropriate measures including, without 3 || limitation, contempt proceedings and/or monetary sanctions. 4 ||IT ISSO STIPULATED. 5 || DATED: October 27, 2022 LEGALAXXIS, INC. 7 Slarpyeke Ko alas oe 8 — Nazgole Hashemi, Esq. ? Tannaz Hashemi, Esq. 10 Attorneys for Plaintiff, BRENDA CORNEJO 12 || DATED: October 27, 2022 WILSON TURNER KOSMO LLP 13 14 15 By: /s/__ Nicole Roydson ROBIN A. WOFFORD 16 NICOLE R. ROYSDON 17 ERIK T. JOHNSON 18 MICHAELA P. DELACRUZ Attorneys for Defendant 19 SEDGWICK CLAIMS MANAGEMENT 0 SERVICES, INC. 21 22 23 24 25 26 27 28

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ase 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page14o0f15 Page ID #:280

, || DATED: October 27, 2022 SEYFARTH SHAW LLP 3 By: /s/ Michelle Zakarian ‘ JOSHUA A. RODINE 5 MICHELLE ZAKARIAN 6 Attorneys for Defendant LOWE’S HOME CENTERS, LLC 8 SIGNATURE CERTIFICATION 9 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I hereby certify that authorization for the 10 || filing of this document has been obtained from each of the other signatories shown above 11 |/and that all signatories concur in the filing’s content. 12 ||Dated: October 27, 2022 Sayele ~tboabernt 13 14 Nazgole Hashemi, Esq. 15 16 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: _ 10/27/2022 18 19 /S/ Charles F. Eick 20 = 31 HON. CHARLES F. EICK » United States Magistrate Judge 23 24 25 26 27 28

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Case 2:22-cv-06022-JFW-E Document 30 Filed 10/27/22 Page 15 of 15 Page ID #:281

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ______________________________________________[print or type full 4 name], of ____________________________________________[print or type full 5 address], declare under penalty of perjury that I have read in its entirety and understand 6 the Stipulated Protective Order that was issued by the United States District Court for the 7 Central District of California on _____, 20__ in the case of Brenda Cornejo v. Lowe’s 8 Home Centers, et al., Case No. 2:22-cv-6022-JFW (Ex). I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. I further agree to 14 submit to the jurisdiction of the United States District Court for the Central District of 15 California for enforcing the terms of this Stipulated Protective Order, even if such 16 enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or 20 any proceedings related to enforcement of this Stipulated Protective Order. 21 Date: ______________________________________ 22 City and State where sworn and signed: _________________________________ 23 24 Printed name: _______________________________ 25 26 Signature: __________________________________ 27 28 15 PROTECTIVE ORDER