Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 1 of 16 Page ID #:399

1 Thy B. Bui (SBN 256383) 2 [email protected] Julia Levitskaia (SBN 286042) 3 [email protected] 4 CONSTANGY, BROOKS, SMITH & PROPHETE, LLP 2029 Century Park East, Suite 1100 5 Los Angeles, CA 90067 6 Telephone: 310.909.7775 Facsimile: 424.465.6630 7 8 Attorneys for Defendants BEACON HEALTH OPTIONS, INC. 9 and ROBERT MCALONAN 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION 12 13 14 JESSICA GHOLSON, an individual, Case No. 8:22-cv-00445 CJC (DFMx) 15 Plaintiff, STIPULATED PROTECTIVE ORDER 16 vs. Complaint Filed: February 17, 2022 17 Removal Date: March 22, 2022 BEACON HEALTH OPTIONS, Trial Date: May 23, 2023 18 INC., a Virginia Corporation, 19 ROBERT MCALONAN, an individual, and DOES 1 through 10, 20 inclusive, 21 Defendants. 22

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STIPULATED PRO TECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 2 of 16 Page ID #:400

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 pursuing this litigation may be 5 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 trade secrets, valuable research, development, 13 commercial, financial, technical and/or proprietary information for which special 14 protection from public disclosure and from use for any purpose other than 15 prosecution of this action is warranted. Such confidential and proprietary materials 16 and information consist of, among other things, confidential business or financial 17 information, information regarding confidential business practices, or other 18 confidential research, development, or commercial information (including 19 information implicating privacy rights of third parties and medical information), 20 information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to 25 keep confidential, to ensure that the parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a protective order 28 for such information is justified in this matter. It is the intent of the parties that 1 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 3 of 16 Page ID #:401

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 a 3 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 UNDER SEAL FILING PROCEDURE 6 The parties further acknowledge, as set forth in Section 14.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. There is a strong presumption that the public has a right 11 of access to judicial proceedings and records in civil cases. In connection with non- 12 dispositive motions, good cause must be shown to support a filing under seal. See 13 Kamakana v. City and County of Honolulu,

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

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

(E.D. Wis. 1999) (even 16 stipulated protective orders require good cause showing), and a specific showing of 17 good cause or compelling reasons with proper evidentiary support and legal 18 justification, must be made with respect to Protected Material that a party seeks to 19 file under seal. The parties' mere designation of Disclosure or Discovery Material as 20 CONFIDENTIAL does not— without the submission of competent evidence by 21 declaration, establishing that the material sought to be filed under seal qualifies as 22 confidential, privileged, or otherwise protectable—constitute good cause. 23 Further, if a party requests sealing related to a dispositive motion or trial, then 24 compelling reasons, not only good cause, for the sealing must be shown, and the 25 relief sought shall be narrowly tailored to serve the specific interest to be protected. 26 See Pintos v. Pacific Creditors Ass'n.,

(9th Cir. 2010). For 27 each item or type of information, document, or thing sought to be filed or introduced 28 under seal, the party seeking protection must articulate compelling reasons, 2 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 4 of 16 Page ID #:402

1 supported by specific facts and legal justification, for the requested sealing order. 2 Again, competent evidence supporting the application to file documents under seal 3 must be provided by declaration. 4 Any document that is not confidential, privileged, or otherwise protectable in 5 its entirety will not be filed under seal if the confidential portions can be redacted. If 6 documents can be redacted, then a redacted version for public viewing, omitting 7 only the confidential, privileged, or otherwise protectable portions of the document, 8 shall be filed. Any application that seeks to file documents under seal in their 9 entirety should include an explanation of why redaction is not feasible. 10 4. DEFINITIONS 11 4.1 Action: this pending federal lawsuit, styled Jessica Gholson v. Beacon 12 Health Options, Inc., et al. (Case No. 8:22-cv-00445 CJC (DFMx). 13 4.2 Challenging Party: a Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 4.3 "CONFIDENTIAL" Information or Items: information 16 (regardless of how it is generated, stored or maintained) or tangible things that 17 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified 18 above in the Good Cause Statement. 19 4.4 Counsel: Outside Counsel of Record and House Counsel (as well 20 as their support staff). 21 4.5 Designating Party: a Party or Non-Party that designates 22 information or items that it produces in disclosures or in responses to discovery as 23 "CONFIDENTIAL." 24 4.6 Disclosure or Discovery Material: all items or information, 25 regardless of the medium or manner in which it is generated, stored, or maintained 26 (including, among other things, testimony, transcripts, and tangible things), that are 27 produced or generated in disclosures or responses to discovery. 28 4.7 Expert: a person with specialized knowledge or experience in a 3 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 5 of 16 Page ID #:403

1 matter pertinent to the litigation who has been retained by a Party or its counsel to 2 serve as an expert witness or as a consultant in this Action. 3 4.8 House Counsel: attorneys who are employees of a party to this 4 Action. House Counsel does not include Outside Counsel of Record or any other 5 outside counsel. 6 4.9 Non-Party: any natural person, partnership, corporation, 7 association or other legal entity not named as a Party to this action. 8 4.10 Outside Counsel of Record: attorneys who are not employees of a party 9 to this Action but are retained to represent a party to this Action and have appeared 10 in this Action on behalf of that party or are affiliated with a law firm that has 11 appeared on behalf of that party, and includes support staff. 12 4.11 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 16 Discovery Material in this Action. 17 4.13 Professional Vendors: persons or entities that provide litigation support 18 services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) 20 and their employees and subcontractors. 21 4.14 Protected Material: any Disclosure or Discovery Material that is 22 designated as "CONFIDENTIAL." 23 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 24 from a Producing Party. 25 5. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 Protected Material (as defined above), but also (1) any information copied or 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 4 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 6 of 16 Page ID #:404

1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 trial judge and other applicable authorities. This Order does not govern the use of 5 Protected Material at trial. 6 6. DURATION 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 9 as an exhibit at trial becomes public and will be presumptively available to all 10 members of the public, including the press, unless compelling reasons supported by 11 specific factual findings to proceed otherwise are made to the trial judge in advance 12 of the trial. See Kamakana,

(distinguishing "good cause" 13 showing for sealing documents produced in discovery from "compelling reasons" 14 standard when merits-related documents are part of court record). Accordingly, the 15 terms of this protective order do not extend beyond the commencement of the trial. 16 7. DESIGNATING PROTECTED MATERIAL 17 7.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection under 19 this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 21 protection only those parts of material, documents, items or oral or written 22 communications that qualify so that other portions of the material, documents, items 23 or communications for which protection is not warranted are not swept unjustifiably 24 within the ambit of this Order. 25 Mass, indiscriminate or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 unnecessary expenses and burdens on other parties) may expose the Designating 5 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 7 of 16 Page ID #:405

1 Party to sanctions. 2 If it comes to a Designating Party's attention that information or items that it 3 designated for protection do not qualify for protection, that Designating Party must 4 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 7.2 Manner and Timing of Designations. Except as otherwise provided in 6 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 7 that qualifies for protection under this Order must be clearly so designated before 8 the material is disclosed or 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 affix at a minimum, the legend 13 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that 14 contains protected material. If only a portion of the material on a page qualifies for 15 protection, the Producing Party also must clearly identify the protected portion(s) 16 (e.g., by making 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." After the inspecting Party has identified the 22 documents it wants copied and produced, the Producing Party must determine which 23 documents, or portions thereof, qualify for protection under this Order. Then, before 24 producing the specified documents, the Producing Party must affix the 25 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a 26 portion of the material on a page qualifies for protection, the Producing Party also 27 must clearly identify the protected portion(s) (e.g., by making appropriate markings 28 in the margins). 6 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 8 of 16 Page ID #:406

1 (b) for testimony given in depositions that the Designating Party 2 identifies the Disclosure or Discovery Material on the record, before the close of the 3 deposition all protected testimony. 4 (c) for information produced in some form other than documentary and 5 for any other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information is stored the 7 legend "CONFIDENTIAL." If only a portion or portions of the information 8 warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party's right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 Order. 16 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court's 19 Scheduling Order. 20 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37-1 et seq. 22 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 23 joint stipulation pursuant to Local Rule 37-2. 24 8.4 The burden of persuasion in any such challenge proceeding shall be on 25 the Designating Party. Frivolous challenges, and those made for an improper 26 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 27 parties) may expose the Challenging Party to sanctions. Unless the Designating 28 Party has waived or withdrawn the confidentiality designation, all parties shall 7 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 9 of 16 Page ID #:407

1 continue to afford the material in question the level of protection to which it is 2 entitled under the Producing Party's designation until the Court rules on the 3 challenge. 4 9. ACCESS TO AND USE OF PROTECTED MATERIAL 5 9.1 Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a 10 Receiving Party must comply with the provisions of section 15 below (FINAL 11 DISPOSITION). 12 Protected Material must be stored and maintained by a Receiving Party at a 13 location and in a secure manner that ensures that access is limited to the persons 14 authorized under this Order. 15 9.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 16 otherwise ordered by the court or permitted in writing by the Designating Party, a 17 Receiving Party may disclose any information or item designated 18 "CONFIDENTIAL" only to: 19 (a) the Receiving Party's Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of 23 the Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 27 (d) the court and its personnel; 28 (e) court reporters and their staff; 8 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 10 of 16 Page ID #:408

1 (f) professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 4 (g) the author or recipient of a document containing the information or 5 a custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in 7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 8 party requests that the witness sign the form attached as Exhibit A hereto; and 9 (2) they will not be permitted to keep any confidential information unless they sign 10 the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 11 agreed by the Designating Party or ordered by the court. Pages of transcribed 12 deposition testimony or exhibits to depositions that reveal Protected Material may 13 be separately bound by the court reporter and may not be disclosed to anyone except 14 as permitted under this Stipulated Protective Order; and 15 (i) any mediators or settlement officers and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions. 17 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 18 PRODUCED IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that compels disclosure of any information or items designated in this Action as 21 "CONFIDENTIAL," that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification 23 shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or 25 order to issue in the other litigation that some or all of the material covered by the 26 subpoena or order is subject to this Protective Order. Such notification shall include 27 a copy of this Stipulated Protective Order; and 28 (c) cooperate with respect to all reasonable procedures sought to be 9 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 11 of 16 Page ID #:409

1 pursued by the Designating Party whose Protected Material may be affected. If the 2 Designating Party timely seeks a protective order, the Party served with the 3 subpoena or court order shall not produce any information designated in this action 4 as "CONFIDENTIAL" before a determination by the court from which the 5 subpoena or order issued, unless the Party has obtained the Designating Party's 6 permission. The Designating Party shall bear the burden and expense of seeking 7 protection in that court of its confidential material and nothing in these provisions 8 should be construed as authorizing or encouraging a Receiving Party in this Action 9 to disobey a lawful directive from another court. 10 11. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 Non-Party in this Action and designated as "CONFIDENTIAL." Such information 14 produced by Non-Parties in connection with this litigation is protected by the 15 remedies and relief provided by this Order. Nothing in these provisions should be 16 construed as prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 produce a Non-Party's confidential information in its possession, and the Party is 19 subject to an agreement with the Non-Party not to produce the Non-Party's 20 confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non-Party 22 that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 specific description of the information requested; and 27 (3) make the information requested available for inspection by the 28 Non-Party, if requested. 10 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 12 of 16 Page ID #:410

1 (c) If the Non-Party fails to seek a protective order from this court 2 within 14 days of receiving the notice and accompanying information, the Receiving 3 Party may produce the Non-Party's confidential information responsive to the 4 discovery request. If the Non-Party timely seeks a protective order, the Receiving 5 Party shall not produce any information in its possession or control that is subject to 6 the confidentiality agreement with the Non-Party before a determination by the 7 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this court of its Protected Material. 9 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the "Acknowledgment an 17 Agreement to Be Bound" attached hereto as Exhibit A. 18 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, 22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 may be established in an e-discovery order that provides for production without 25 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 26 as the parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the 28 parties may incorporate their agreement in the stipulated protective order submitted 11 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 13 of 16 Page ID #:411

1 to the court. 2 14. MISCELLANEOUS 3 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 4 person to seek its modification by the Court in the future. 5 14.2 Right to Assert Other Objections. By stipulating to the entry of this 6 Protective Order, no Party waives any right it otherwise would have to object to 7 disclosing or producing any information or item on any ground not addressed in this 8 Stipulated Protective Order. Similarly, no Party waives any right to object on any 9 ground to use in evidence of any of the material covered by this Protective Order. 10 14.3 Filing Protected Material. A Party that seeks to file under seal any 11 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 12 only be filed under seal pursuant to a court order authorizing the sealing of the 13 specific Protected Material. If a Party's request to file Protected Material under seal 14 is denied by the court, then the Receiving Party may file the information in the 15 public record unless otherwise instructed by the court. 16 15. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 6, within 60 18 days of a written request by the Designating Party, each Receiving Party must return 19 all Protected Material to the Producing Party or destroy such material. As used in 20 this subdivision, "all Protected Material" includes all copies, abstracts, compilations, 21 summaries, and any other format reproducing or capturing any of the Protected 22 Material. Whether the Protected Material is returned or destroyed, the Receiving 23 Party must submit a written certification to the Producing Party (and, if not the same 24 person or entity, to the Designating Party) by the 60-day deadline that (1) identifies 25 (by category, where appropriate) all the Protected Material that was returned or 26 destroyed and (2) affirms that the Receiving Party has not retained any copies, 27 abstracts, compilations, summaries or any other format reproducing or capturing any 28 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 12 STIPULATED PROT ECTIVE ORDER Case}B:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page140f16 Page ID#:412

1 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 || reports, attorney work product, and consultant and expert work product, even if such 4 || materials contain Protected Material. Any such archival copies that contain or 5 || constitute Protected Material remain subject to this Protective Order as set forth in 6 || Section 6 (DURATION). 7 16. VIOLATION 8 Any violation of this Order may be punished by appropriate measures 9 || including, without limitation, contempt proceedings and/or monetary sanctions. 10 11 || SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 3 LAW OFFICE OF MICHAEL J. CURLS 14 DATED: November 28, 2022 By: 15 Michael J. Curls, Esq. Nichelle D. Jordan, Esq. 16 Attorneys for Plaintiff 17 CONSTANGY, BROOKS, SMITH & 18 PROPHETE, LLP 19 DATED: November 29, 2022 By: 20 Thy B. Bui 21 Julia Levitskaia Attorneys for Defendants 22 BEACON HEALTH OPTIONS, INC. and 23 ROBERT MCALONAN 94 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25 26 || DATED: November 29, 2022 ( | 27 Dougla#F. McCormick 28 United States Magistrate Judge 13 STIPULATED PROTECTIVE ORDER

Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 15 of 16 Page ID #:413

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _________________________________ [print/type full name], of 5 ___________________________________________________ [print/type full 6 address], declare under penalty of perjury that I have read in its entirety and 7 understand the Stipulated Protective Order that was issued by the United States 8 District Court for the Central District of California on ___________________ [date] 9 in the case of Jessica Gholson v. Beacon Health Options, Inc., et al. (Case No. 8:22- 10 cv-00445 CJC (DFMx)). I agree to comply with and to be bound by all the terms of 11 this Stipulated Protective Order and I understand and acknowledge that failure to so 12 comply could expose me to sanctions and punishment in the nature of contempt. I 13 solemnly promise that I will not disclose in any manner any information or item that 14 is subject to this Stipulated Protective Order to any person or entity except in strict 15 compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint ________________________ [print/type 20 full name] of ________________________________________________________ 21 [print/type full address and telephone number] as my California agent for service of 22 process in connection with this action or any proceedings related to enforcement of 23 this Stipulated Protective Order. 24 Date: ______________ 25 City and State where sworn and signed: ________________________________ 26 Printed name: ____________________________ 27 Signature: _______________________________ 28 14 STIPULATED PROT ECTIVE ORDER Case 8:22-cv-00445-CJC-DFM Document 41 Filed 11/29/22 Page 16 of 16 Page ID #:414

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