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1 | TROUTMAN PEPPER HAMILTON DHF LAW, PC SANDERS LLP Devin Fok (SBN 256599) 2 || Ronald I. Raether (SBN 303118) devin@devintoklaw com ronald [email protected] Ainat Kiewe (SBN 207439) 3 || 5 Park Plaza, Suite 1400 ainat@devinfoklaw com Irvine, CA 92614-2545 2304 Huntington Drive, Suite 4 || Telephone: 949-622-2722 210 Facsimile: 949-622-2739 San Marino, CA 91108 5 Telephone: (388) 651-6411 Jessica Lohr (SBN 302348) Facsimile: (818 484-2023 6 || [email protected] 11682 El Camino Real, Suite 400 Attorneys for Plaintiff Ashley 7 || San Diego, CA 92130-2092 Ronshae Jones Telephone: 858-509-6000 8 || Facsimile: 858-509-6040 9 || Attorneys for Defendant RP Gres Ie pel 10 1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 13 | ASHLEY RONSHAE JONES, Case No. 2:22-cv-04367-MCS-AFM 14 Plaintiff, STIPULATED PROTECTIVE ORDER! 15 Vv. 16 || RP ON-SITE, LLC, and DOES 1-10, inclusive, 17 Defendants. 18 19 20 21 22 23 24 25 26 27 ! This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge 28 Alexander F. MacKinnon’s Procedures.

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1 || 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 || proprietary, or private information for which special protection from public 4 || disclosure and from use for any purpose other than prosecuting this litigation may be 5 || warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 || the following Stipulated Protective Order. The parties acknowledge that this Order 7 || does not confer blanket protections on all disclosures or responses to discovery and 8 || that the protection it affords from public disclosure and use extends only to the 9 || limited information or items that are entitled to confidential treatment under the 10 || applicable legal principles. 11 A. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, pricing lists and other valuable 13 || research, development, commercial, financial, technical and/or proprietary 14 || information for which special protection from public disclosure and from use for any 15 || purpose other than prosecution of this action is warranted. Such confidential and 16 || proprietary materials and information consist of, among other things, consumer 17 || information the disclosure of which is regulated by federal and/or state law, 18 || confidential business or financial information, sensitive personal information, 19 || information regarding confidential business practices, or other confidential research, 20 || development, or commercial information (including information implicating privacy 21 || rights of third parties), information otherwise generally unavailable to the public, or 22 || which may be privileged or otherwise protected from disclosure under state or federal 23 || statutes, court rules, case decisions, or common law. Accordingly, to expedite the 24 || flow of information, to facilitate the prompt resolution of disputes over 25 || confidentiality of discovery materials, to adequately protect information the parties 26 || are entitled to keep confidential, to ensure that the parties are permitted reasonable 27 || necessary uses of such material in preparation for and in the conduct of trial, to 28 || address their handling at the end of the litigation, and serve the ends of justice, a 140249680 -2- Case No. 2:22-cv-04367-MCS-AFM

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1 || protective order for such information is justified in this matter. It is the intent of the 2 || parties that information will not be designated as confidential for tactical reasons and 3 || that nothing be so designated without a good faith belief that it has been maintained 4 || in a confidential, non-public manner, and there is good cause why it should not be 5 || part of the public record of this case. 6 B. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 7 SEAL 8 The parties further acknowledge, as set forth in Section 12.3 below, that this 9 || Stipulated Protective Order does not entitle them to file confidential information 10 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 11 || the standards that will be applied when a party seeks permission from the court to 12 || file material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 || proceedings and records in civil cases. In connection with non-dispositive motions, 15 || good cause must be shown to support a filing under seal. See Kamakana vy. City and 16 || County of Honolulu,

, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 17 || Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 18 || Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 19 || good cause showing), and a specific showing of good cause or compelling reasons 20 || with proper evidentiary support and legal justification, must be made with respect to 21 || Protected Material that a party seeks to file under seal. The parties’ mere designation 22 || of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 23 || submission of competent evidence by declaration, establishing that the material 24 || sought to be filed under seal qualifies as confidential, privileged, or otherwise 25 || protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, then 27 || compelling reasons, not only good cause, for the sealing must be shown, and the 28 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 140249680 -3- Case No. 2:22-cv-04367-MCS-AFM

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1 || See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each 2 || 1tem or type of information, document, or thing sought to be filed or introduced under 3 || seal in connection with a dispositive motion or trial, the party seeking protection must 4 || articulate compelling reasons, supported by specific facts and legal justification, for 5 || the requested sealing order. Again, competent evidence supporting the application to 6 || file documents under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 || its entirety will not be filed under seal if the confidential portions can be redacted. If 9 || documents can be redacted, then a redacted version for public viewing, omitting only 10 || the confidential, privileged, or otherwise protectable portions of the document, shall 11 || be filed. Any application that seeks to file documents under seal in their entirety 12 || should include an explanation of why redaction 1s not feasible. 13 || 2. DEFINITIONS 14 2.1 Action: This pending federal lawsuit, Ashley Ronshae Jones v. RP On- 15 || Site, LLC, et al., Case No. 2:22-cv-04367-MCS-AFM. 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 || of information or items under this Order. 18 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 19 || how it is generated, stored or maintained) or tangible things that qualify for protection 20 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 21 || Cause Statement. 22 2.4 Counsel (without qualifier): Outside Counsel of Record and House 23 || Counsel (as well as their support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 || items that it produces in disclosures or in responses to discovery as 26 || “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless 28 || of the medium or manner in which it is generated, stored, or maintained (including, 140249680 -4- Case No. 2:22-cv-04367-MCS-AFM

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1 || among other things, testimony, transcripts, and tangible things), that are produced or 2 || generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 || an expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this action. 7 || House Counsel does not include Outside Counsel of Record or any other outside 8 || counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association, or 10 || other legal entity not named as a Party to this action. 11 2.10 Qutside Counsel of Record: attorneys who are not employees of a party 12 || to this Action but are retained to represent or advise a party to this Action and have 13 || appeared in this Action on behalf of that party or are affiliated with a law firm that 14 || has appeared on behalf of that party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 || employees, consultants, retained experts, and Outside Counsel of Record (and their 17 || support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 || Discovery Material in this action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 23 || and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 || designated as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that recetves Disclosure or Discovery Material 27 || from a Producing Party. 28 140249680 -5- Case No. 2:22-cv-04367-MCS-AFM

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1 || 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 || Protected Material (as defined above), but also (1) any information copied or 4 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 || compilations of Protected Material; and (3) any testimony, conversations, or 6 || presentations by Parties or their Counsel that might reveal Protected Material. 7 || However, the protections conferred by this Stipulation and Order do not cover the 8 || following information: (a) any information that is in the public domain at the time of 9 || disclosure to a Receiving Party or becomes part of the public domain after its 10 || disclosure to a Receiving Party as a result of publication not involving a violation of 11 || this Order, including becoming part of the public record through trial or otherwise; 12 || and (b) any information known to the Receiving Party prior to the disclosure or 13 || obtained by the Receiving Party after the disclosure from a source who obtained the 14 || information lawfully and under no obligation of confidentiality to the Designating 15 || Party. 16 Any use of Protected Material at trial shall be governed by the orders of the 17 || trial judge. This Order does not govern the use of Protected Material at trial. 18 || 4. DURATION 19 Once a case proceeds to trial, information that was designated as 20 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 21 |} as an exhibit at trial becomes public and will be presumptively available to all 22 || members of the public, including the press, unless compelling reasons supported by 23 || specific factual findings to proceed otherwise are made to the trial judge in advance 24 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 25 || showing for sealing documents produced in discovery from “compelling reasons” 26 || standard when merits-related documents are part of court record). Accordingly, the 27 || terms of this protective order do not extend beyond the commencement of the trial. 28 140249680 -6- Case No. 2:22-cv-04367-MCS-AFM

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1 Even after final disposition of this litigation, the confidentiality obligations 2 || imposed by this Order shall remain in effect until a Designating Party agrees 3 || otherwise in writing or a court order otherwise directs. Final disposition shall be 4 || deemed to be the later of (1) dismissal of all claims and defenses in this action, with 5 || or without prejudice; and (2) final judgment herein after the completion and 6 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 7 || including the time limits for filing any motions or applications for extension of time 8 || pursuant to applicable law. 9 || 5. DESIGNATING PROTECTED MATERIAL 10 5.1 Exercise of Restraint and Care in Designating Material for Protection. 11 || Each Party or Non-Party that designates information or items for protection under 12 || this Order must take care to limit any such designation to specific material that 13 || qualifies under the appropriate standards. The Designating Party must designate for 14 || protection only those parts of material, documents, items or oral or written 15 || communications that qualify so that other portions of the material, documents, items 16 || or communications for which protection is not warranted are not swept unjustifiably 17 || within the ambit of this Order. 18 Mass, indiscriminate or routinized designations are prohibited. Designations 19 || that are shown to be clearly unjustified or that have been made for an improper 20 || purpose (e.g., to unnecessarily encumber the case development process or to impose 21 || unnecessary expenses and burdens on other parties) may expose the Designating 22 || Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items that it 24 || designated for protection do not qualify for protection, that Designating Party must 25 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 26 5.2 Manner and Timing of Designations. Except as otherwise provided in 27 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 28 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 140249680 -7- Case No. 2:22-cv-04367-MCS-AFM

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1 || under this Order must be clearly so designated before the material is disclosed or 2 || produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic 5 || documents, but excluding transcripts of depositions or other pretrial or trial 6 || proceedings), that the Producing Party affix at a minimum, the legend 7 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 8 || contains protected material. If only a portion or portions of the material on a page 9 || qualifies for protection, the Producing Party also must clearly identify the protected 10 || portion(s) (e.g., by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents available for 12 || inspection need not designate them for protection until after the inspecting Party has 13 || indicated which documents it would like copied and produced. During the inspection 14 || and before the designation, all of the material made available for inspection shall be 15 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 16 || 1t wants copied and produced, the Producing Party must determine which documents, 17 || or portions thereof, qualify for protection under this Order. Then, before producing 18 || the specified documents, the Producing Party must affix the CONFIDENTIAL 19 || legend to each page that contains Protected Material. If only a portion of the material 20 || on a page qualifies for protection, the Producing Party also must clearly identify the 21 || protected portion(s) (e.g., by making appropriate markings in the margins). 22 (b) for testimony given in depositions, that the Designating Party 23 || designates Protected Material within fourteen (14) days of receiving the transcript of 24 || the testimony. 25 (c) for information produced in some form other than documentary and 26 || for any other tangible items, that the Producing Party affix in a prominent place on 27 || the exterior of the container or containers in which the information or item is stored 28 || the legend “CONFIDENTIAL.” If only a portion or portions of the information 140249680 -8- Case No. 2:22-cv-04367-MCS-AFM

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1 || warrants protection, the Producing Party, to the extent practicable, shall identify the 2 || protected 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 5 || the 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. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 || resolution process under Local Rule 37-1 et seq. 14 6.3. Joint Stipulation: Any challenge submitted to the Court shall be via a 15 || joint stipulation pursuant to Local Rule 37-2. 16 6.4 The burden of persuasion in any such challenge proceeding shall be on 17 || the Designating Party. Frivolous challenges, and those made for an improper purpose 18 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 19 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 20 || or withdrawn the confidentiality designation, all parties shall continue to afford the 21 || material in question the level of protection to which it is entitled under the Producing 22 || Party’s designation until the Court rules on the challenge. 23 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material that is 25 || disclosed or produced by another Party or by a Non-Party in connection with this 26 || Action only for prosecuting, defending, or attempting to settle this Action. Such 27 || Protected Material may be disclosed only to the categories of persons and under the 28 140249680 -9- Case No. 2:22-cv-04367-MCS-AFM

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1 || conditions described in this Order. When the Action has been terminated, a Receiving 2 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 || location and in a secure manner that ensures that access is limited to the persons 5 || authorized under this Order. 6 7.2 Disclosure “CONFIDENTIAL” Information or Items. Unless 7 || otherwise ordered by the court or permitted in writing by the Designating Party, a 8 || Receiving Party may disclose any information or item designated 9 || “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 11 |) well as employees of said Outside Counsel of Record to whom it is reasonably 12 || necessary to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of 14 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 || disclosure is reasonably necessary for this Action and who have signed the 17 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 || Vendors to whom disclosure is reasonably necessary for this Action and who have 22 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or 24 || a custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in 26 || the Action to whom disclosure is reasonably necessary provided: (1) the deposing 27 || party requests that the witness sign the form attached as Exhibit | hereto; and (2) they 28 || will not be permitted to keep any confidential information unless they sign the 140249680 - 10- Case No. 2:22-cv-04367-MCS-AFM

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1 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 || agreed by the Designating Party or ordered by the court. Pages of transcribed 3 || deposition testimony or exhibits to depositions that reveal Protected Material may be 4 || separately bound by the court reporter and may not be disclosed to anyone except as 5 || permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 || mutually agreed upon by any of the parties engaged in settlement discussions. 8 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 || INOTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 || that compels disclosure of any information or items designated in this Action as 12 || “CONFIDENTIAL,” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification 14 || shall include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or 16 || order to issue in the other litigation that some or all of the material covered by the 17 || subpoena or order is subject to this Protective Order. Such notification shall include 18 || acopy of this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be 20 || pursued by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 || the subpoena or court order shall not produce any information designated in this 23 || action as “CONFIDENTIAL” before a determination by the court from which the 24 || subpoena or order issued, unless the Party has obtained the Designating Party’s 25 || permission. The Designating Party shall bear the burden and expense of seeking 26 || protection in that court of its confidential material — and nothing in these provisions 27 || should be construed as authorizing or encouraging a Receiving Party in this Action 28 || to disobey a lawful directive from another court. 140249680 -1l1- Case No. 2:22-cv-04367-MCS-AFM

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1 || 9. A__NON-PARTY’S ~PROTECTED MATERIAL SOUGHT TO BE 2 || PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a 4 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 5 || produced by Non-Parties in connection with this litigation is protected by the 6 || remedies and relief provided by this Order. Nothing in these provisions should be 7 || construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 || produce a Non-Party’s confidential information in its possession, and the Party is 10 || subject to an agreement with the Non-Party not to produce the Non-Party’s 11 || confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non- 13 || Party that some or all of the information requested is subject to a confidentiality 14 || agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 || specific description of the information requested; and 18 (3) make the information requested available for inspection by 19 || the Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court 21 || within 14 days of receiving the notice and accompanying information, the Receiving 22 || Party may produce the Non-Party’s confidential information responsive to the 23 || discovery request. If the Non-Party timely seeks a protective order, the Receiving 24 || Party shall not produce any information in its possession or control that is subject to 25 || the confidentiality agreement with the Non-Party before a determination by the court. 26 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 27 || of seeking protection in this court of its Protected Material. 28 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 140249680 -12- Case No. 2:22-cv-04367-MCS-AFM

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1 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 2 || Protected Material to any person or in any circumstance not authorized under this 3 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 4 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 5 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 6 || persons to whom unauthorized disclosures were made of all the terms of this Order, 7 || and (d) request such person or persons to execute the “Acknowledgment and 8 || Agreement to Be Bound” that is attached hereto as Exhibit A. 9} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 10 || PROTECTED — MATERIAL 11 When a disclosure of Discovery Material and/or any other documents and 12 || materials containing information subject to a claim of privilege or any other 13 || protection is made in this Action, such disclosure does not operate as a waiver in this 14 || Action or any other federal or state proceeding if: (1) the disclosure was inadvertent; 15 || (2) the holder of the privilege or protection took reasonable steps to prevent 16 || disclosure; and (3) the holder promptly took reasonable steps to rectify the error, 17 || including following the steps identified in Federal Rule of Civil Procedure 18 || 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 19 || established in an e-discovery order that provides for production without prior 20 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 21 || parties reach an agreement on the effect of disclosure of a communication or 22 || information covered by the attorney-client privilege or work product protection, the 23 || parties may incorporate their agreement in the stipulated protective order submitted 24 || to the Court. 25 || 12. MISCELLANEOUS 26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 27 || person to seek its modification by the Court in the future. 28 140249680 - 13- Case No. 2:22-cv-04367-MCS-AFM

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1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 || Protective Order no Party waives any right it otherwise would have to object to 3 || disclosing or producing any information or item on any ground not addressed in this 4 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 || ground to use in evidence of any of the material covered by this Protective Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 8 || only be filed under seal pursuant to a court order authorizing the sealing of the 9 || specific Protected Material at issue. If a Party’s request to file Protected Material 10 || under seal is denied by the court, then the Receiving Party may file the information 11 || in the public record unless otherwise instructed by the court. 12 12.4 No Impact on Each Party’s Rights Respecting Its Own Data. Nothing 13 || in this Protective Order shall restrict or in any way modify a party’s rights with 14 || respect to the handling, use, or disclosure of its own data, documents, and other 15 || materials. 16 || 13. FINAL DISPOSITION 17 After the final disposition of this action, as defined in paragraph 4, 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 this 20 || 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 140249680 - 14- Case No. 2:22-cv-04367-MCS-AFM

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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 4 (DURATION). 7 || 14. MIOLATION 8 Any violation of this Order may be punished by appropriate measures 9 || including, without limitation, contempt proceedings and/or monetary sanctions. 10 | /// 11 || /// 12 || /// 13 || ITTS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 15 | DATED: January 26, 2023 s/Devin Fok 16 Attorneys for Plaintiff 17 18 | DATED: January 26, 2023 s/Jessica Lohr 19 aonueys for Defendants 20 21 22 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 * 24 || DATED: 1/27/2023 (Wy 25 26 United States Magistrate Judge 27 28 140249680 -15- Case No. 2:22-cv-04367-MCS-AFM

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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 was 6 || issued by the United States District Court for the Central District of California on 7 in the case of Ashley Ronshae Jones v. RP On-Site, LLC et al., Case 8 || No. 2:22-cv-04367-MCS-AFM (C.D. Cal.). I agree to comply with and to be bound 9 || by all the terms of this Stipulated Protective Order and I understand and acknowledge 10 || that failure to so comply could expose me to sanctions and punishment in the nature 11 || 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 13 || 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 enforcing the terms of this Stipulated 16 || Protective Order, even if such enforcement proceedings occur after termination of 17 || this action. 18 I hereby appoint [print or type full name] of 19 [print or type full address and _ telephone 20 || number] as my California agent for service of process in connection with this action 21 || or any proceedings related to enforcement of this Stipulated Protective Order. 22 23 || Date: 24 City and State where sworn and signed: ° Printed name: 26 97 Signature: eee 28 140249680 - 16 - Case No. 2:22-cv-04367-MCS-AFM