Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 1 of 18 Page ID #:2119

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION 3 4 TREVOR BAUER, 5 Case No. 8:22-cv-00868-JVS-ADS 6 Plaintiff, Assigned for all purposes to the Hon. James V. Selna 7 v. 8 AMENDED STIPULATED LINDSEY C. HILL and NIRANJAN 9 PROTECTIVE ORDER FRED THIAGARAJAH, 10 **NOTE CHANGES MADE BY THE COURT 11 Defendants. 12 13 14 15 16 17 1. INTRODUCTION 18 1.1 PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary, or private information for which special protection from public disclosure 21 and from use for any purpose other than in connection with this litigation. 22 Accordingly, the parties hereby stipulate to and petition the Court to enter the 23 following Stipulated Protective Order. The parties acknowledge that this Stipulated 24 Protective Order does not confer blanket protections on all disclosures or responses 25 to discovery and that the protection it affords from public disclosure and use extends 26 only to the limited information or items that are entitled to confidential treatment 27 under the applicable legal principles. The parties further acknowledge, as set forth in 28 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 2 of 18 Page ID #:2120

1 Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 2 confidential information under seal. Civil Local Rule 79-5 sets forth the procedures 3 that must be followed and the standards that will be applied when a party seeks 4 permission from the court to file material under seal. 5 1.2 GOOD CAUSE STATEMENT 6 The Parties agree that good cause exists for the entry of this pretrial protective 7 order. Discovery may involve the production of parties’ and non-parties’ personal 8 and/or sensitive information, financial records, personal communications and contact 9 information, health records, and other records kept confidential for law enforcement 10 investigatory purposes. 11 2. DEFINITIONS 12 2.1 Action: This pending federal lawsuit, Bauer v. Hill and Thiagarajah, 13 Case No. 22-cv-00868. 14 2.2 Challenging Party: A Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 Confidential: Personal, sensitive, and/or non-public information which 17 is in the possession of a Designating Party and (a) visually depicts (i.e., photographs, 18 images, or videos) sexual acts or explicit nudity (i.e., naked breasts, buttocks, or 19 genitalia); (b) includes communications between a Party and any non-party that is 20 sexual in nature; (c) includes protected medical information; (d) private financial 21 information; (e) personally identifiable information, such as addresses and social __________________________________________ 22 security numbers; (f) may violate a Party’s or Non Party’s right to privacy; (g) is 23 subject to the official information privilege under applicable law, including, but not 24 limited to, California Evidence Code Section 1040, Kelly v. City of San Jose, 114

(N.D. Cal. 1987), and/or Soto v. City of Concord,

, 613 26 (N.D. Cal. 1995); and/or (h) qualifies for protection under Federal Rule of Civil 27 Procedure 26(c) or other applicable legal requirements. 28 2 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 3 of 18 Page ID #:2121

1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 2 support staff). 3 2.5 Designating Party: A Party or Non-Party that designates information or 4 items that it produces in disclosures or in responses to discovery as 5 “CONFIDENTIAL.” 6 2.6 Disclosure or Discovery Material: All items or information, regardless 7 of the medium or manner in which it is generated, stored, or maintained (including, 8 among other things, testimony, transcripts, and tangible things), that are produced or 9 generated in disclosures or responses to discovery in this matter. 10 2.7 Expert: A person with specialized knowledge or experience in a matter 11 pertinent to the litigation who has been retained by a Party or its counsel to serve as 12 an expert witness or as a consultant in this Action. 13 2.8 House Counsel: Attorneys who are employees of a party to this Action. 14 House Counsel does not include Outside Counsel of Record or any other outside 15 counsel. 16 2.9 Non-Party: Any natural person, partnership, corporation, association, or 17 other legal entity not named as a Party to this action. 18 2.10 Outside Counsel of Record: Attorneys who are not employees of a party 19 to this Action but are retained to represent or advise a party to this Action and have 20 appeared in this Action on behalf of that party or are affiliated with a law firm which 21 has appeared on behalf of that party, and includes support staff. 22 2.11 Party: Any party to this Action, including all of its agents, consultants, 23 retained experts, and Outside Counsel of Record (and their support staffs). 24 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 2.13 Professional Vendors: Persons or entities that provide litigation support 27 services (e.g., photocopying, videotaping, translating, preparing exhibits or 28 3 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 4 of 18 Page ID #:2122

1 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 and their employees and subcontractors. 3 2.14 Protected Material: Any Disclosure or Discovery Material that is 4 designated as “CONFIDENTIAL.” 5 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material from 6 a Producing Party. 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or extracted 10 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 11 Protected Material; and (3) any testimony, conversations, or presentations by Parties 12 or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial will be governed by the orders of the trial 14 judge. This Order does not govern the use of Protected Material at trial. 15 4. DURATION 16 Once a case proceeds to trial, all Protected Materials that are actually used at 17 trial become public and will be presumptively available to all members of the public, 18 including the press, unless compelling reasons supported by specific factual findings 19 to proceed otherwise are made to the trial judge in advance of the trial. See Kamakana 20 v. City and County of Honolulu,

(9th Cir. 2006) 21 (distinguishing “good cause” showing for sealing documents produced in discovery 22 from “compelling reasons” standard when merits-related documents are part of court 23 record). Any Party or non-party may seek to seal any Protected Material that is going 24 to be used at trial pursuant to Civil Local Rule 79-5. Protected Materials that are not 25 actually used at trial or are not otherwise filed in the public casefile in this Action (i.e. 26 through stipulation or denial of a sealing application), shall not become public and 27 will not be presumptively available to all members of the public. Even after final 28 disposition of this litigation, the confidentiality obligations imposed by this Order 4 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 5 of 18 Page ID #:2123

1 shall remain in effect until a Designating Party agrees otherwise in writing or a court 2 order otherwise directs. Final disposition shall be deemed to be the later of (1) 3 dismissal of all claims and defenses in this Action, with or without prejudice; and (2) 4 final judgment herein after the completion and exhaustion of all appeals, rehearings, 5 remands, trials, or reviews of this Action, including the time limits for filing any 6 motions or applications for extension of time pursuant to applicable law. 7 5. DESIGNATING PROTECTED MATERIAL 8 5.1 Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Non-Party that designates information or items for protection under this 10 Order must take care to limit any such designation to specific material that qualifies 11 under the appropriate standards. The Designating Party must designate for protection 12 only those parts of material, documents, items, or oral or written communications that 13 qualify so that other portions of the material, documents, items, or communications 14 for which protection is not warranted are not swept unjustifiably within the ambit of 15 this Order. 16 Mass, indiscriminate, or routinized designations are prohibited. Designations 17 that are shown to be clearly unjustified or that have been made for an improper 18 purpose (e.g., to unnecessarily encumber the case development process or to impose 19 unnecessary expenses and burdens on other parties) may expose the Designating Party 20 to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 designated for protection do not qualify for protection, that Designating Party must 23 promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2 Manner and Timing of Designations. Except as otherwise provided in 25 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 26 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection 27 under this Stipulated Protective Order must be clearly so designated before the 28 material is disclosed or produced. 5 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 6 of 18 Page ID #:2124

1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, 3 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and before 12 the designation, all of the material made available for inspection will be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 14 copied and produced, the Producing Party must determine which documents, or 15 portions thereof, qualify for protection under this Order. Then, before producing the 16 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 17 to each page that contains Protected Material. If only a portion or portions of the 18 material on a page qualifies for protection, the Producing Party also must clearly 19 identify the protected portion(s) (e.g., by making appropriate markings in the 20 margins). 21 (b) for testimony given in depositions that the Designating Party identify the 22 Disclosure or Discovery Material on the record, before the close of the deposition all 23 protected testimony. 24 (c) for information produced in some form other than documentary and for any 25 other tangible items, that the Producing Party affix in a prominent place on the exterior 26 of the container or containers in which the information is stored the legend 27 “CONFIDENTIAL.” If only a portion or portions of the information warrants 28 6 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 7 of 18 Page ID #:2125

1 protection, the Producing Party, to the extent practicable, will identify the protected 2 portion(s). 3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 failure to designate qualified information or items does not, standing alone, waive the 5 Designating Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must make reasonable 7 efforts to assure that the material is treated in accordance with the provisions of this 8 Order. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 designation of confidentiality at any time that is consistent with the applicable 12 scheduling order in this Action. 13 6.2 Meet and Confer. The Challenging Party will initiate the dispute 14 resolution process under Local Rule 37-1 et seq. Prior to bringing a motion under 15 Local Rule 37-2, the Challenging Party shall seek informal discovery dispute 16 resolution available from the Court (including, but not limited to, an informal 17 discovery conference from the assigned Magistrate Judge), unless time is of the 18 essence. 19 6.3 The burden of persuasion in any such challenge proceeding will be on 20 the Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 or withdrawn the confidentiality designation, all parties will continue to afford the 24 material in question the level of protection to which it is entitled under the Producing 25 Party’s designation until the Court rules on the challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this 7 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 8 of 18 Page ID #:2126

1 Action only for prosecuting, defending, or attempting to settle the Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a Receiving 4 Party must comply with the applicable provisions of this Stipulated Protective Order. 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 otherwise ordered by the court or permitted in writing by the Designating Party, a 10 Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only to: 12 (a) the Receiving Party; 13 (b) the Receiving Party’s Outside Counsel of Record in this Action, as well 14 as employees of said Outside Counsel of Record to whom it is reasonably necessary 15 to disclose the information for this Action; 16 (c) the agents, employees, officers, directors, interpreters, translators, and 17 insurance claims handlers (including House Counsel) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) Experts (as defined in this Order) of the Receiving Party to whom 21 disclosure is reasonably necessary for this Action and who have signed the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (e) the Court and its personnel; 24 (f) court reporters and their staff; 25 (g) professional jury or trial consultants, mock jurors, and Professional 26 Vendors to whom disclosure is reasonably necessary for this Action and who have 27 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 8 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 9 of 18 Page ID #:2127

1 (h) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (i) during their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may be 10 separately bound by the court reporter and may not be disclosed to anyone except as 11 permitted under this Stipulated Protective Order; and 12 (j) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 15 OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification will 20 include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order 22 to issue in the other litigation that some or all of the material covered by the subpoena 23 or order is subject to this Protective Order. Such notification will include a copy of 24 this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be pursued 26 by the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served with 28 the subpoena or court order will not produce any information designated in this action 9 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 10 of 18 Page ID #:2128

1 as “CONFIDENTIAL” before a determination by the court from which the subpoena 2 or order issued, unless the Party has obtained the Designating Party’s permission. The 3 Designating Party will bear the burden and expense of seeking protection in that court 4 of its confidential material and nothing in these provisions should be construed as 5 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 6 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 10 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 11 produced by Non-Parties in connection with this litigation is protected by the 12 remedies and relief provided by this Order. Nothing in these provisions should be 13 construed as prohibiting a Non-Party from seeking additional protections. 14 (b) In the event that a Party is required, by a valid discovery request, to 15 produce a Non-Party’s confidential information in its possession, and the Party is 16 subject to an agreement with the Non-Party not to produce the Non-Party’s 17 confidential information, then the Party will: 18 (1) promptly notify in writing the Requesting Party and the Non-Party 19 that some or all of the information requested is subject to a confidentiality agreement 20 with a Non-Party; 21 (2) promptly provide the Non-Party with a copy of the Stipulated 22 Protective Order in this Action, the relevant discovery request(s), and a reasonably 23 specific description of the information requested; and 24 (3) make the information requested available for inspection by the Non- 25 Party, if requested. 26 (c) If the Non-Party fails to seek a protective order from this court within 27 14 days of receiving the notice and accompanying information, the Receiving Party 28 may produce the Non-Party’s confidential information responsive to the discovery 10 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 11 of 18 Page ID #:2129

1 request. If the Non-Party timely seeks a protective order, the Receiving Party will not 2 produce any information in its possession or control that is subject to the 3 confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party will bear the burden and expense 5 of seeking protection in this court of its Protected Material. 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 12 persons to whom unauthorized disclosures were made of all the terms of this Order, 13 and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” that is attached hereto as Exhibit A. 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted 26 to the court. 27 28 11 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 12 of 18 Page ID #:2130

1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the specific 12 Protected Material at issue. If a Party's request to file Protected Material under seal 13 is denied by the court, then the Receiving Party may file the information in the public 14 record unless otherwise instructed by the court. 15 13. FINAL DISPOSITION 16 After the final disposition of this Action, as defined in paragraph 4, within 60 17 days of a written request by the Designating Party, each Receiving Party must return 18 all Protected Material to the Producing Party or destroy such material. As used in this 19 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 20 summaries, and any other format reproducing or capturing any of the Protected 21 Material. Whether the Protected Material is returned or destroyed, the Receiving 22 Party must submit a written certification to the Producing Party (and, if not the same 23 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 24 (by category, where appropriate) all the Protected Material that was returned or 25 destroyed and (2) affirms that the Receiving Party has not retained any copies, 26 abstracts, compilations, summaries or any other format reproducing or capturing any 27 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 28 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 12 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 13 of 18 Page ID #:2131

1 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 2 reports, attorney work product, and consultant and expert work product, even if such 3 materials contain Protected Material. Any such archival copies that contain or 4 constitute Protected Material remain subject to this Protective Order as set forth in 5 Section 4 (DURATION). 6 14. Any willful violation of this Stipulated Protective Order may be 7 punished by civil or criminal contempt proceedings, financial or evidentiary 8 sanctions, reference to disciplinary authorities, or other appropriate action at the 9 discretion of the Court. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 14 of 18 Page ID #:2132

1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 4 DATED: December 6, 2022 /s/ Blair G. Brown 5 Blair G. Brown (admitted pro hac vice) 6 Jon R. Fetterolf (admitted pro hac vice) ZUCKERMAN SPAEDER LLP 7 1800 M Street, N.W., Suite 1000 Washington, D.C. 20036 8 Tel: (202) 778-1800 Fax: (202) 882-8106 9 [email protected] [email protected] 10 Nell Peyser (admitted pro hac vice) 11 ZUCKERMAN SPAEDER LLP 485 Madison Avenue, 10th Floor 12 New York, NY 10022 (212) 704-9600 13 [email protected] 14 Shawn Holley (Cal. Bar No. 136811) Suann C. Maclsaac (Cal Bar No. 205659) 15 KINSELA WEITZMAN ISER KUMP HOLLEY LLP 16 808 Wilshire Boulevard., 3rd Floor Santa Monica, CA 90401 17 Tel: (310) 566-9800 Fax: (310) 566-9873 18 [email protected] [email protected] 19 Attorneys for Plaintiff Trevor Bauer 20 21 WESIERSKI & ZUREK LLP 22 23 /s/ Michelle R. Prescott 24 Christopher P. Wesierski (Bar No. 086736) 25 Michelle R. Prescott (Bar No. 262638) Eileen Spadoni (Bar No. 133259) 26 Brett A. Smith (Bar No. 322707) 27 29 Orchard Road Lake Forest, CA 92630 28 14 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 15 of 18 Page ID #:2133

Tel: (949) 975-1000 1 Fax: (949) 756-0517 2 [email protected] [email protected] 3 [email protected] 4 [email protected]

5 FREEDMAN + TAITELMAN, LLP 6 /s/ Jesse A. Kaplan 7

8 Bryan J. Freedman (Bar No. 151990) Jesse A. Kaplan (Bar No. 197662) 9 1801 Century Park West, 5th Floor 10 Los Angeles, CA 90067 Tel: (310) 201-0005 11 Fax: (310) 201-0045 12 [email protected] [email protected] 13

14 Attorneys for Defendant Lindsey C. Hill 15

16 17 18 19 20 21 22 23 24 25 26 27 28 15 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 16 of 18 Page ID #:2134

ATTESTATION 1 Pursuant to Civil Local Rule 5-4.3.4(2)(i), I hereby attest that all other 2 signatories on behalf of whom this filing is submitted concur in the filing’s content 3 and have authorized the filing. 4 5 Dated: December 6, 2022 /s/ Nell Z. Peyser 6 Nell Z. Peyser 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 17 of 18 Page ID #:2135

1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 4 DATED:___1_2_/0_7_/_2_0_2_2____ ____/_s_/ _A_u_t_u_m_n_ _D_._ S_p_a_e_t_h_____________ HON. AUTUMN D. SPAETH 5 United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17 Case 8:22-cv-00868-JVS-ADS Document 78 Filed 12/07/22 Page 18 of 18 Page ID #:2136

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of 8 ___________ [insert case name and number]. I agree to comply with and to be 9 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 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 18