1 Mark D. Campbell (SBN 180528) [email protected] 2 Matt Light (SBN 294007) [email protected] 3 Abigail Hudson (SBN 327632) [email protected] 4 SHOOK, HARDY & BACON L.L.P. 2049 Century Park East, Suite 3000 5 Los Angeles, California 90067 Telephone: 424-285-8330 6 Fax: 424-204-9093

7 Attorneys for Plaintiffs VOGUE RECOVERY CALIFORNIA LLC 8 VOGUE RECOVERY ARIZONA LLC VOGUE RECOVERY CENTER LLC 9 David D. Piper (SBN 179889) 10 [email protected] Elizabeth A. Kendrick (SBN 341529) 11 [email protected] Lucas Garcia (SBN 341529) 12 KEESAL, YOUNG & LOGAN A Professional Corporation 13 400 Oceangate, Suite 1400 Long Beach, California 90802 14 Telephone: 562-436-2000 Fax: 562-436-7416 15 Attorneys for Defendants 16

17 UNITED STATES DISTRICT COURT 18 CENTRAL DISTRICT OF CALIFORNIA 19 VOGUE RECOVERY CALIFORNIA Case No. 2:22-cv-06751-MCS-AFM 20 LLC, et al.,

21 Plaintiffs, [PROPOSED] STIPULATED AMENDED PROTECTIVE ORDER1 22 v. DISCOVERY MATTER 23 CMJ RECOVERY CA LLC, et al.,

24 Defendants. 25 26 27 28 1 This Stipulated Protective Order is based substantially on the model protective order 1 Plaintiffs Vogue Recovery Center LLC, Vogue Recovery Arizona LLC, and 2 Vogue Recovery California LLC (collectively, “Plaintiffs”) and defendants CMJ 3 Recovery NV LLC, CMJ Recovery AZ LLC, and CMJ Recovery CA LLC, Shaul 4 Kopelwitz, Michael Milch, Joel Strulovics, Yisroel Herzka (collectively, “Defendants”) 5 hereby jointly submit for the Court’s approval in the above-captioned action this 6 proposed Stipulated Amended Protective Order, which, at the request of third party 7 medical insurers and providers, adds to the original Protective Order (Dkt. 30) 8 provisions relating to Information or Items designated as “HIGHLY CONFIDENTIAL 9 – ATTORNEYS’ EYES ONLY”: 10 11 1. A. PURPOSES AND LIMITATIONS 12 Discovery in this action is likely to involve production of confidential, 13 proprietary or private information for which special protection from public disclosure 14 and from use for any purpose other than prosecuting this litigation may be warranted. 15 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 16 Stipulated Amended Protective Order. The parties acknowledge that this Order does not 17 confer blanket protections on all disclosures or responses to discovery and that the 18 protection it affords from public disclosure and use extends only to the limited 19 information or items that are entitled to confidential treatment under the applicable legal 20 principles. 21 22 B. GOOD CAUSE STATEMENT 23 This action is likely to involve confidential healthcare billing, payment, and 24 operations information and other valuable commercial, financial, and/or proprietary 25 and/or private information for which special protection from public disclosure and from 26 use for any purpose other than prosecution of this action is warranted. Such confidential 27 and proprietary materials and information consist of, among other things, confidential 1 or other confidential commercial information (including information implicating 2 privacy rights of third parties, such as healthcare patients), information otherwise 3 generally unavailable to the public, or which may be privileged or otherwise protected 4 from disclosure under state or federal statutes, court rules, case decisions, or common 5 law. Accordingly, to expedite the flow of information, to facilitate the prompt resolution 6 of disputes over confidentiality of discovery materials, to adequately protect 7 information the parties are entitled to keep confidential, to ensure that the parties are 8 permitted reasonable necessary uses of such material in preparation for and in the 9 conduct of trial, to address their handling at the end of the litigation, and serve the ends 10 of justice, a protective order for such information is justified in this matter. It is the 11 intent of the parties that information will not be designated as confidential for tactical 12 reasons and that nothing be so designated without a good faith belief that it has been 13 maintained in a confidential, non-public manner, and there is good cause why it should 14 not be part of the public record of this case. 15 16 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 17 SEAL 18 The parties further acknowledge, as set forth in Section 12.3, below, that this 19 Stipulated Protective Order does not entitle them to file confidential information under 20 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 21 standards that will be applied when a party seeks permission from the court to file 22 material under seal. 23 There is a strong presumption that the public has a right of access to judicial 24 proceedings and records in civil cases. In connection with non-dispositive motions, 25 good cause must be shown to support a filing under seal. See Kamakana v. City and 26 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 27 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 1 cause showing), and a specific showing of good cause or compelling reasons with 2 proper evidentiary support and legal justification, must be made with respect to 3 Protected Material that a party seeks to file under seal. The parties’ mere designation of 4 Disclosure or Discovery Material as CONFIDENTIAL or HIGHLY CONFIDENTIAL 5 – ATTORNEYS’ EYES ONLY does not—without the submission of competent 6 evidence by declaration, establishing that the material sought to be filed under seal 7 qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the relief 10 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 11 v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item or type 12 of information, document, or thing sought to be filed or introduced under seal in 13 connection with a dispositive motion or trial, the party seeking protection must 14 articulate compelling reasons, supported by specific facts and legal justification, for the 15 requested sealing order. Again, competent evidence supporting the application to file 16 documents under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in its 18 entirety will not be filed under seal if the confidential portions can be redacted. If 19 documents can be redacted, then a redacted version for public viewing, omitting only 20 the confidential, privileged, or otherwise protectable portions of the document, shall be 21 filed. Any application that seeks to file documents under seal in their entirety should 22 include an explanation of why redaction is not feasible. 23 24 2. DEFINITIONS 25 2.1 Action: This pending federal lawsuit, VOGUE RECOVERY CALIFORNIA 26 LLC, et al. vs. CMJ RECOVERY CA LLC, et al., Case No. 2:22-cv-06751-MCS-AFM. 27 2.2 Challenging Party: a Party or Non-Party that challenges the 1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 2 is generated, stored or maintained) or tangible things that qualify for protection under 3 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 4 Statement. 5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 6 their support staff). 7 2.5 Designating Party: a Party or Non-Party that designates information or 8 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” 9 or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless 11 of the medium or manner in which it is generated, stored, or maintained (including, 12 among other things, testimony, transcripts, and tangible things), that are produced or 13 generated in disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter 15 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 16 expert witness or as a consultant in this Action. 17 2.8 House Counsel: attorneys who are employees of a party to this Action. 18 House Counsel does not include Outside Counsel of Record or any other outside 19 counsel. 20 2.9 Non-Party: any natural person, partnership, corporation, association or 21 other legal entity not named as a Party to this action. 22 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 23 this Action but are retained to represent or advise a party to this Action and have 24 appeared in this Action on behalf of that party or are affiliated with a law firm that has 25 appeared on behalf of that party, and includes support staff. 26 2.11 Party: any party to this Action, including all of its officers, directors, 27 employees, consultants, retained experts, and Outside Counsel of Record (and their 1 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.13 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 6 their employees and subcontractors. 7 2.14 Protected Material: any Disclosure or Discovery Material that is designated 8 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 9 ONLY." 10 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 11 from a Producing Party. 12 2.16 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 13 Information or Items: extremely sensitive “CONFIDENTIAL” Information or Items, 14 the disclosure of which to another Party or Non-Party would create a substantial risk of 15 serious harm that could not be avoided by less restrictive means. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected 18 Material (as defined above), but also (1) any information copied or extracted from 19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 20 Material; and (3) any testimony, conversations, or presentations by Parties or their 21 Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of the trial 23 judge. This Order does not govern the use of Protected Material at trial. 24 25 4. DURATION 26 Once a case proceeds to trial, information that was designated as 27 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 1 of the public, including the press, unless compelling reasons supported by specific 2 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 3 See Kamakana,

(distinguishing “good cause” showing for sealing 4 documents produced in discovery from “compelling reasons” standard when merits- 5 related documents are part of court record). Accordingly, the terms of this protective 6 order do not extend beyond the commencement of the trial to information that becomes 7 public at trial. For information protected by this protective order that does not become 8 public at trial, the confidentiality obligations imposed by this Order shall remain in 9 effect even after final disposition of this litigation until a Designating Party agrees 10 otherwise in writing or a court order otherwise directs. Final disposition shall be deemed 11 to be the later of (1) the dismissal of all claims and defenses in this Action, with or 12 without prejudice; and (2) final judgment herein after the completion and exhaustion of 13 all appeals, rehearings, remands, trials, or reviews of this Action, including the time 14 limits for filing any motions or applications for extension of time pursuant to applicable 15 law. 16 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection under this 20 Order must take care to limit any such designation to specific material that qualifies 21 under the appropriate standards. The Designating Party must designate for protection 22 only those parts of material, documents, items or oral or written communications that 23 qualify so that other portions of the material, documents, items or communications for 24 which protection is not warranted are not swept unjustifiably within the ambit of this 25 Order. 26 Mass, indiscriminate or routinized designations are prohibited. Designations that 27 are shown to be clearly unjustified or that have been made for an improper purpose 1 unnecessary expenses and burdens on other parties) may expose the Designating Party 2 to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic documents, 13 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 14 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or “HIGHLY 15 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter “CONFIDENTIAL 16 legend”), to each page that contains protected material. If only a portion of the material 17 on a page qualifies for protection, the Producing Party also must clearly identify the 18 protected portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and before 22 the designation, all of the material made available for inspection shall be deemed 23 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 24 copied and produced, the Producing Party must determine which documents or portions 25 thereof, qualify for protection under this Order. Then, before producing the specified 26 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 27 that contains Protected Material. If only a portion of the material on a page qualifies for 1 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 2 by making appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating Party identifies 4 the Disclosure or Discovery Material on the record, before the close of the deposition, 5 all protected testimony. Alternatively, the designating party may, on the record, before 6 the close of the deposition, elect to treat the entirety of the deposition testimony as 7 “CONFIDENTIAL” pending the right to identify specific portions of the testimony as 8 “CONFIDENTIAL” within 30 days after the transcript is delivered by serving a Notice 9 of Designation as to the specific portions of the testimony that are designated 10 “CONFIDENTIAL,” and thereafter only those portions identified in the Notice of 11 Designation shall be protected by the terms of this Order. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 16 ONLY.” If only a portion or portions of the information warrants protection, the 17 Producing Party, to the extent practicable, shall identify the protected portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive the 20 Designating Party’s right to secure protection under this Order for such material. Upon 21 timely correction of a designation, the Receiving Party must make reasonable efforts to 22 assure that the material is treated in accordance with the provisions of this Order. 23 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. resolution process under Local Rule 37-1 et seq. 1 2 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 3 joint stipulation pursuant to Local Rule 37-2. 4 6.4 The burden of persuasion in any such challenge proceeding shall be on the 5 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 6 to harass or impose unnecessary expenses and burdens on other parties) may expose the 7 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 8 the confidentiality designation, all parties shall continue to afford the material in 9 question the level of protection to which it is entitled under the Producing Party’s 10 designation until the Court rules on the challenge. 11 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this Action 15 only for prosecuting, defending or attempting to settle this Action. Such Protected 16 Material may be disclosed only to the categories of persons and under the conditions 17 described in this Order. When the Action has been terminated, a Receiving Party must 18 comply with the provisions of section 13 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 23 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 24 may disclose any information or item designated “CONFIDENTIAL” only to: 25 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 26 employees of said Outside Counsel of Record to whom it is reasonably necessary to 27 disclose the information for this Action; 1 (b) the officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 16 by the Designating Party or ordered by the court. Pages of transcribed deposition 17 testimony or exhibits to depositions that reveal Protected Material may be separately 18 bound by the court reporter and may not be disclosed to anyone except as permitted 19 under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 23 Information or Items. Unless otherwise ordered by the court or permitted in writing by 24 the Designating Party, a Receiving Party may disclose any information or item 25 designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 27 employees of said Outside Counsel of Record to whom it is reasonably necessary to 1 (b) Experts (as defined in this Order) of the Receiving Party to whom disclosure 2 is reasonably necessary for this Action and who have signed the “Acknowledgment and 3 Agreement to Be Bound” (Exhibit A); 4 (c) the court and its personnel; 5 (d) court reporters and their staff to whom disclosure is reasonably necessary for 6 this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (e) professional jury or trial consultants, mock jurors, and Professional Vendors 8 to whom disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (f) the author or recipient of a document containing the information or a custodian 11 or other person who otherwise possessed or knew of the information; and 12 (g) any mediator or settlement officer, and their supporting personnel, mutually 13 agreed upon by any of the parties engaged in settlement discussions. 14

15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 16 OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 that compels disclosure of any information or items designated in this Action as 19 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 20 ONLY,” that Party must: 21 (a) promptly notify in writing the Designating Party. Such notification shall 22 include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the subpoena or order to 24 issue in the other litigation that some or all of the material covered by the subpoena or 25 order is subject to this Protective Order. Such notification shall include a copy of this 26 Stipulated Protective Order; and 27 1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action as 5 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY” before a determination by the court from which the subpoena or order issued, 7 unless the Party has obtained the Designating Party’s permission. The Designating 8 Party shall bear the burden and expense of seeking protection in that court of its 9 confidential material and nothing in these provisions should be construed as 10 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 11 directive from another court. 12 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 14 IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 17 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 18 Non-Parties in connection with this litigation is protected by the remedies and relief 19 provided by this Order. Nothing in these provisions should be construed as prohibiting 20 a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 24 information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party 26 that some or all of the information requested is subject to a confidentiality agreement 27 with a Non-Party; 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 (3) make the information requested available for inspection by the Non- 5 Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this court within 14 7 days of receiving the notice and accompanying information, the Receiving Party may 8 produce the Non-Party’s confidential information responsive to the discovery request. 9 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 10 any information in its possession or control that is subject to the confidentiality 11 agreement with the Non-Party before a determination by the court. Absent a court order 12 to the contrary, the Non-Party shall bear the burden and expense of seeking protection 13 in this court of its Protected Material. 14 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 19 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 20 all unauthorized copies of the Protected Material, (c) inform the person or persons to 21 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 22 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 23 that is attached hereto as Exhibit A. 24 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 26 PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 3 may be established in an e-discovery order that provides for production without prior 4 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), the production 5 of a privileged or work-product protected document, whether inadvertent or otherwise, 6 is not a waiver of privilege or protection from discovery in this case or in any other 7 federal or state proceeding. Nothing contained herein, however, shall require a Party to 8 produce documents that are protected from disclosure or otherwise limit a Party’s right 9 to conduct a review of electronically stored information (ESI) for relevance, 10 responsiveness and/or privilege or other protection from discovery before production. 11 Communications involving counsel of record that post-date the filing the complaint 12 need not be placed on a privilege log. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 23 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 24 under seal pursuant to a court order authorizing the sealing of the specific Protected 25 Material at issue. If a Party’s request to file Protected Material under seal is denied by 26 the court, then the Receiving Party may file the information in the public record unless 27 otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return all 4 Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 16 work product, and consultant and expert work product, even if such materials contain 17 Protected Material. Any such archival copies that contain or constitute Protected 18 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 19 20 14. VIOLATION 21 Any violation of this Order may be punished by appropriate measures 22 including, without limitation, contempt proceedings and/or monetary sanctions. 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24

25 DATED: July 7, 2023 SHOOK, HARDY & BACON L.L.P. 26 By: /s/Matt Light 27 Mark D. Campbell 1 Attorneys for Plaintiffs VOGUE RECOVERY CALIFORNIA LLC 2 VOGUE RECOVERY ARIZONA LLC 3 VOGUE RECOVERY CENTER LLC 4 || Dated: July 7, 2023 KEESAL, YOUNG & LOGAN 5 By:/s/Elizabeth A. Kendrick 6 David D. Piper Elizabeth A. Kendrick 7 Lucas Garcia 8 Attorneys for Defendants 9 CMJ RECOVERY CA LLC, CMJ RECOVERY AZ LLC, CMJ RECOVERY 10 NV LLC, SHAUL KOPELOWITZ, 1 MICHAEL MILCH, JOEL STRULOVICS, YISROEL HERZKA 12 3 ATTESTATION 14 Pursuant to L.R. 5-4.3.4(a)(2), I attest that all signatories on whose behalf this 15 filing is submitted concur in the content of this filing and have authorized the filing. 16 17 || DATED: July 7, 2023 SHOOK, HARDY & BACON L.L.P. 18 By:_/s/Matt Light 19 Mark D. Campbell Matt Light 20 Attorneys for Plaintiffs VOGUE RECOVERY CALIFORNIA LLC VOGUE RECOVERY ARIZONA LLC 22 VOGUE RECOVERY CENTER LLC 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 ||DATED: _7/7/2023 25 Moc f-——~ t—C—CO 57 HON. ALEXANDER F. MacKINNON

38 United States Magistrate Judge 17

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 5 penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on [date] in the case of VOGUE RECOVERY CALIFORNIA 8 LLC, et al. vs. CMJ RECOVERY CA LLC, et al., Case No. 2:22-cv-06751-MCS-AFM. 9 I agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. I further agree to submit to the jurisdiction of the United 15 States District Court for the Central District of California for enforcing the terms of 16 this Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. 18 I hereby appoint________________________________[print or type full name] of 19 _________________________________________________________[print or 20 type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement 22 of this Stipulated Protective Order. 23 Date: ____________________ 24 City and State where sworn and signed: ___________________________________ 25 26 Printed Name: _______________________________ 27 28