1 STUBBS ALDERTON & MARKILES, LLP Heather A. Antoine (SBN 246917) 2 [email protected] Jeffrey F. Gersh (SBN 87124) 3 [email protected] Michael A. Bernet (SBN 306657) 4 [email protected] Jose A. Meneses (SBN 346449) 5 [email protected] 15260 Ventura Boulevard, 20th Floor 6 Sherman Oaks, California 91403 Telephone: (818) 444-4548 7 Attorneys for Plaintiff, 8 NAKED WHEY, INC. 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 NAKED WHEY, INC., a Florida 13 corporation Case No. 2:24-cv-00828-MRA-SSC

14 Plaintiff(s), [Discovery Document: 15 v. Referred to Magistrate Judge Stephanie S. Christensen] 16 NAKED WARRIOR RECOVERY LLC, a Delaware limited liability 17 company, and DOES 1 through STIPULATED PROTECTIVE 10, inclusive, ORDER1 18 Defendant(s). 19

20 The parties, through their undersigned counsel of record, and 21 subject to the Court’s approval, hereby stipulate to the entry of a 22 Protective Order in this action as follows. 23 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to 3 involve production of confidential, proprietary, or private information for 4 which special protection from public disclosure and from use for any 5 purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the court to 7 enter the following Stipulated Protective Order. The parties 8 acknowledge that this Order does not confer blanket protections on all 9 disclosures or responses to discovery and that the protection it affords 10 from public disclosure and use extends only to the limited information or 11 items that are entitled to confidential treatment under the applicable 12 legal principles. 13 1.2 Good Cause Statement. 14 This action is likely to involve trade secrets, customer and pricing 15 lists and other valuable research, development, commercial, financial, 16 technical and/or proprietary information for which special protection 17 from public disclosure and from use for any purpose other than 18 prosecution of this action is warranted. Such confidential and 19 proprietary materials and information consist of, among other things, 20 confidential business or financial information, information regarding 21 22 confidential business practices, or other confidential research, 23 development, or commercial information (including information 24 implicating privacy rights of third parties), information otherwise 25 generally unavailable to the public, or which may be privileged or 26 otherwise protected from disclosure under state or federal statutes, court 27 rules, case decisions, or common law. Accordingly, to expedite the flow of 1 confidentiality of discovery materials, to adequately protect information 2 the parties are entitled to keep confidential, to ensure that the parties 3 are permitted reasonable necessary uses of such material in preparation 4 for and in the conduct of trial, to address their handling at the end of the 5 litigation, and serve the ends of justice, a protective order for such 6 information is justified in this matter. It is the intent of the parties that 7 information will not be designated as confidential for tactical reasons 8 and that nothing be so designated without a good faith belief that it has 9 been maintained in a confidential, non-public manner, and there is good 10 cause why it should not be part of the public record of this case. 11 1.3 Acknowledgment of Procedure for Filing Under Seal. The 12 parties further acknowledge, as set forth in Section 12.3, below, that this 13 Stipulated Protective Order does not entitle them to file confidential 14 information under seal; Local Rule 79-5 sets forth the procedures that 15 must be followed and the standards that will be applied when a party 16 seeks permission from the court to file material under seal. 17 There is a strong presumption that the public has a right of access 18 to judicial proceedings and records in civil cases. In connection with 19 non-dispositive motions, good cause must be shown to support a filing 20 under seal. See Kamakana v. City and Cnty. of Honolulu,

22 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 23 Corp.,

, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 24 Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 25 protective orders require good cause showing), and a specific showing of 26 good cause or compelling reasons with proper evidentiary support and 27 legal justification, must be made with respect to Protected Material that 1 Disclosure or Discovery Material as CONFIDENTIAL does not— 2 without the submission of competent evidence by declaration, 3 establishing that the material sought to be filed under seal qualifies as 4 confidential, privileged, or otherwise protectable—constitute good cause. 5 Further, if a party requests sealing related to a dispositive motion 6 or trial, then compelling reasons, not only good cause, for the sealing 7 must be shown, and the relief sought shall be narrowly tailored to serve 8 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 9

, 677–79 (9th Cir. 2010). For each item or type of 10 information, document, or thing sought to be filed or introduced under 11 seal in connection with a dispositive motion or trial, the party seeking 12 protection must articulate compelling reasons, supported by specific 13 facts and legal justification, for the requested sealing order. Again, 14 competent evidence supporting the application to file documents under 15 seal must be provided by declaration. 16 Any document that is not confidential, privileged, or otherwise 17 protectable in its entirety will not be filed under seal if the confidential 18 portions can be redacted. If documents can be redacted, then a redacted 19 version for public viewing, omitting only the confidential, privileged, or 20 otherwise protectable portions of the document, shall be filed. Any 21 22 application that seeks to file documents under seal in their entirety 23 should include an explanation of why redaction is not feasible. 24 25 2. DEFINITIONS 26 2.1 Action: this pending federal lawsuit. 27 2.2 Challenging Party: a Party or Non-Party that challenges the 1 designation of information or items under this Order. 2 2.3 “CONFIDENTIAL” Information or Items: information 3 (regardless of how it is generated, stored or maintained) or tangible 4 things that qualify for protection under Rule 26(c) of the Federal Rules of 5 Civil Procedure, and as specified above in the Good Cause Statement. 6 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 7 Information or Items: Information (regardless of how it is generated, 8 stored or maintained) or tangible things that qualify for protection under 9 Federal Rule of Civil Procedure 26(c), and as specified above in the Good 10 Cause Statement. “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES 11 ONLY” Information or Items is extremely sensitive “CONFIDENTIAL” 12 Information or Items, the disclosure of which to another Party or Non- 13 Party would create a substantial risk of serious harm that could not be 14 avoided by less restrictive means. 15 2.5 Counsel: Outside Counsel of Record and House Counsel (as 16 well as their support staff). 17 2.6 Designating Party: a Party or Non-Party that designates 18 information or items that it produces in disclosures or in responses to 19 discovery as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 20 ATTORNEYS’ EYES ONLY.” 21 22 2.7 Disclosure or Discovery Material: all items or information, 23 regardless of the medium or manner in which it is generated, stored, or 24 maintained (including, among other things, testimony, transcripts, and 25 tangible things), that are produced or generated in disclosures or 26 responses to discovery in this matter. 27 2.8 Expert: a person with specialized knowledge or experience in 1 its counsel to serve as an expert witness or as a consultant in this Action. 2 2.9 Final Disposition: the later of (1) dismissal of all claims and 3 defenses in this Action, with or without prejudice; and (2) final judgment 4 herein after the completion and exhaustion of all appeals, rehearings, 5 remands, trials, or reviews of this Action, including the time limits for 6 filing any motions or applications for extension of time pursuant to 7 applicable law. 8 2.10 In-House Counsel: attorneys who are employees of a party to 9 this Action. In-House Counsel does not include Outside Counsel of 10 Record or any other outside counsel. 11 2.11 Non-Party: any natural person, partnership, corporation, 12 association, or other legal entity not named as a Party to this action. 13 2.12 Outside Counsel of Record: attorneys who are not employees 14 of a party to this Action but are retained to represent or advise a party to 15 this Action and have appeared in this Action on behalf of that party or 16 are affiliated with a law firm which has appeared on behalf of that party, 17 and includes support staff. 18 2.13 Party: any party to this Action, including all of its officers, 19 directors, employees, consultants, retained experts, and Outside Counsel 20 of Record (and their support staffs). 21 22 2.14 Producing Party: a Party or Non-Party that produces 23 Disclosure or Discovery Material in this Action. 24 2.15 Professional Vendors: persons or entities that provide 25 litigation- support services (e.g., photocopying, videotaping, translating, 26 preparing exhibits or demonstrations, and organizing, storing, or 27 retrieving data in any form or medium) and their employees and 1 2.16 Protected Material: any Disclosure or Discovery Material that 2 is designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 3 ATTORNEYS’ EYES ONLY.” 4 2.17 Receiving Party: a Party that receives Disclosure or Discovery 5 Material from a Producing Party. 6 3. SCOPE 7 The protections conferred by this Stipulation and Order cover not 8 only Protected Material (as defined above), but also (1) any information 9 copied or extracted from Protected Material; (2) all copies, excerpts, 10 summaries, or compilations of Protected Material; and (3) any 11 testimony, conversations, or presentations by Parties or their Counsel 12 that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the 14 orders of the trial judge. This Stipulated Protective Order does not 15 govern the use of Protected Material at trial. 16

17 18 4. TRIAL AND DURATION 19 The terms of this Stipulated Protective Order apply through Final 20 Disposition of the Action. 21 Once a case proceeds to trial, information that was designated as 22 CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 23 ONLY or maintained pursuant to this Stipulated Protective Order and 24 used or introduced as an exhibit at trial becomes public and will be 25 presumptively available to all members of the public, including the 26 press, unless compelling reasons supported by specific factual findings 27 1 See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” 2 showing for sealing documents produced in discovery from “compelling 3 reasons” standard when merits-related documents are part of court 4 record). Accordingly, for such materials, the terms of this Stipulated 5 Protective Order do not extend beyond the commencement of the trial. 6 Even after Final Disposition of this litigation, the confidentiality 7 obligations imposed by this Stipulated Protective Order shall remain in 8 effect until a Designating Party agrees otherwise in writing or a court 9 order otherwise directs. 10

11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for 13 Protection. Each Party or Non-Party that designates information or 14 items for protection under this Order must take care to limit any such 15 designation to specific material that qualifies under the appropriate 16 standards. The Designating Party must designate for protection only 17 18 those parts of material, documents, items, or oral or written 19 communications that qualify so that other portions of the material, 20 documents, items, or communications for which protection is not 21 warranted are not swept unjustifiably within the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. 23 Designations that are shown to be clearly unjustified or that have been 24 made for an improper purpose (e.g., to unnecessarily encumber the case 25 development process or to impose unnecessary expenses and burdens on 26 other parties) may expose the Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or 1 items that it designated for protection do not qualify for protection, that 2 Designating Party must promptly notify all other Parties that it is 3 withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise 5 provided in this Stipulated Protective Order (see, e.g., second paragraph 6 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 7 or Discovery Material that qualifies for protection under this Stipulated 8 Protective Order must be clearly so designated before the material is 9 disclosed or produced. 10 Designation in conformity with this Stipulated Protective Order 11 requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or 14 trial proceedings), that the Producing Party affix at a minimum, the 15 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 16 17 ATTORNEYS’ EYES ONLY” to each page that contains protected 18 material. If only a portion or portions of the material on a page 19 qualifies for protection, the Producing Party also must clearly identify 20 the protected portion(s) (e.g., by making appropriate markings in the 21 margins). 22 A Party or Non-Party that makes original documents available for 23 inspection need not designate them for protection until after the 24 inspecting Party has indicated which documents it would like copied 25 and produced. During the inspection and before the designation, all of 26 the material made available for inspection shall be deemed 27 CONFIDENTIAL. After the inspecting Party has identified the 1 documents it wants copied and produced, the Producing Party must 2 determine which documents, or portions thereof, qualify for protection 3 under this Stipulated Protective Order. Then, before producing the 4 specified documents, the Producing Party must affix the 5 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 6 EYES ONLY” legend to each page that contains Protected Material. If 7 only a portion or portions of the material on a page qualifies for 8 protection, the Producing Party also must clearly identify the protected 9 portion(s) (e.g., by making appropriate markings in the margins). 10 (b) for testimony given in depositions that the Designating Party 11 identify the Disclosure or Discovery Material on the record, before the 12 close of the deposition all protected testimony. 13 (c) for information produced in some form other than 14 documentary and for any other tangible items, that the Producing Party 15 affix in a prominent place on the exterior of the container or containers 16 in which the information is stored the “CONFIDENTIAL” or “HIGHLY 17 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend. If only a 18 portion or portions of the information warrants protection, the Producing 19 20 Party, to the extent practicable, shall identify the protected portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an 22 inadvertent failure to designate qualified information or items does not, 23 standing alone, waive the Designating Party’s right to secure protection 24 under this Order for such material. Upon timely correction of a 25 designation, the Receiving Party must make reasonable efforts to assure 26 that the material is treated in accordance with the provisions of this 27 Stipulated Protective Order. 1 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may 4 challenge a designation of confidentiality at any time that is consistent 5 with the court’s Scheduling Order. 6 6.2 Meet and Confer. The Challenging Party shall initiate the 7 dispute resolution process under Local Rule 37.1 et seq. and with 8 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 9 Discovery Motion Conference.”2 10 6.3 The burden of persuasion in any such challenge proceeding 11 shall be on the Designating Party. Frivolous challenges, and those 12 made for an improper purpose (e.g., to harass or impose unnecessary 13 expenses and burdens on other parties) may expose the Challenging 14 Party to sanctions. Unless the Designating Party has waived or 15 withdrawn the confidentiality designation, all parties shall continue to 16 afford the material in question the level of protection to which it is 17 18 entitled under the Producing Party’s designation until the court rules on 19 the challenge. 20 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected 23 Material that is disclosed or produced by another Party or by a Non- 24 Party in connection with this Action only for prosecuting, defending, or 25 attempting to settle this Action. Such Protected Material may be 26

27 2 Judge Christensen’s Procedures are available at 1 disclosed only to the categories of persons and under the conditions 2 described in this Order. When the Action reaches a Final Disposition, a 3 Receiving Party must comply with the provisions of section 13 below. 4 Protected Material must be stored and maintained by a Receiving 5 Party at a location and in a secure manner that ensures that access is 6 limited to the persons authorized under this Stipulated Protective 7 Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 9 Unless otherwise ordered by the court or permitted in writing by the 10 Designating Party, a Receiving Party may disclose any information or 11 item designated “CONFIDENTIAL” only: 12 (a) to the Receiving Party’s Outside Counsel of Record in this 13 Action, as well as employees of said Outside Counsel of Record to whom 14 it is reasonably necessary to disclose the information for this Action; 15 (b) to the officers, directors, and employees (including House 16 Counsel) of the Receiving Party to whom disclosure is reasonably 17 necessary for this Action; 18 (c) to Experts (as defined in this Order) of the Receiving Party to 19 whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 22 (d) to the court and its personnel; 23 (e) to court reporters and their staff; 24 (f) to professional jury or trial consultants, mock jurors, and 25 Professional Vendors to whom disclosure is reasonably necessary for 26 this Action and who have signed the “Acknowledgment and Agreement 27 to Be Bound” (Exhibit A); 1 information or a custodian or other person who otherwise possessed or 2 knew the information; 3 (h) during their depositions, to witnesses, and attorneys for 4 witnesses, in the Action to whom disclosure is reasonably necessary, 5 provided: (1) the deposing party requests that the witness sign the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 7 witness will not be permitted to keep any confidential information 8 unless they sign the “Acknowledgment and Agreement to Be Bound” 9 (Exhibit A), unless otherwise agreed by the Designating Party or 10 ordered by the court. Pages of transcribed deposition testimony or 11 exhibits to depositions that reveal Protected Material may be separately 12 bound by the court reporter and may not be disclosed to anyone except 13 as permitted under this Stipulated Protective Order; and 14 (i) to any mediator or settlement officer, and their supporting 15 personnel, mutually agreed upon by any of the parties engaged in 16 settlement discussions. 17 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 18 ONLY” Information or Items. Unless otherwise ordered by the 19 Court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 22 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 23 to all of the same individuals to whom “CONFIDENTIAL” 24 materials may be disclosed, except for the officers, directors, and 25 employees (including House Counsel) of the Receiving Party. 26 27 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in 4 other litigation that compels disclosure of any information or items 5 designated in this Action as “CONFIDENTIAL” or “HIGHLY 6 CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” that Party must: 7 (a) promptly notify in writing the Designating Party. Such 8 notification shall include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the 10 subpoena or order to issue in the other litigation that some or all of the 11 material covered by the subpoena or order is subject to this Protective 12 Order. Such notification shall include a copy of this Stipulated 13 14 Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to 16 be pursued by the Designating Party whose Protected Material may be 17 affected. 18 If the Designating Party timely seeks a protective order, the 19 Party served with the subpoena or court order shall not produce any 20 information designated in this action as “CONFIDENTIAL” or 21 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before a 22 determination by the court from which the subpoena or order issued, 23 unless the Party has obtained the Designating Party’s permission. The 24 Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these 26 provisions should be construed as authorizing or encouraging a 27 Receiving Party in this Action to disobey a lawful directive from another 1 court. 2 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 9.1 Application. The terms of this Stipulated Protective Order 6 are applicable to information produced by a Non-Party in this Action and 7 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 8 ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties 9 in connection with this litigation is protected by the remedies and relief 10 provided by this Order. Nothing in these provisions should be construed 11 as prohibiting a Non-Party from seeking additional protections. 12 9.2 Notification. In the event that a Party is required, by a valid 13 discovery request, to produce a Non-Party’s confidential information in 14 its possession, and the Party is subject to an agreement with the Non- 15 Party not to produce the Non-Party’s confidential information, then the 16 Party shall: 17 (a) promptly notify in writing the Requesting Party and the 18 Non-Party that some or all of the information requested is subject to a 19 confidentiality agreement with a Non-Party; 20 21 (b) make the information requested available for inspection by 22 the Non-Party, if requested. 23 9.3 Conditions of Production. If the Non-Party fails to seek a 24 protective order from this court within 14 days of receiving the notice 25 and accompanying information, the Receiving Party may produce the 26 Non-Party’s confidential information responsive to the discovery request. 27 If the Non-Party timely seeks a protective order, the Receiving Party 1 subject to the confidentiality agreement with the Non-Party before a 2 determination by the court. Absent a court order to the contrary, the 3 Non-Party shall bear the burden and expense of seeking protection in 4 this court of its Protected Material. 5 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 7 MATERIAL 8 If a Receiving Party learns that, by inadvertence or otherwise, it 9 has disclosed Protected Material to any person or in any circumstance 10 not authorized under this Stipulated Protective Order, the Receiving 11 Party must immediately (a) notify in writing the Designating Party of 12 the unauthorized disclosures, (b) use its best efforts to retrieve all 13 unauthorized copies of the Protected Material, (c) inform the person or 14 persons to whom unauthorized disclosures were made of all the terms of 15 this Order, and (d) request such person or persons to execute the 16 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 20 OTHERWISE PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that 22 certain inadvertently produced material is subject to a claim of privilege 23 or other protection, the obligations of the Receiving Parties are those set 24 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 25 provision is not intended to modify whatever procedure may be 26 established in an e-discovery order that provides for production without 27 1 Rules of Evidence, insofar as the parties reach an agreement on the 2 effect of disclosure of a communication or information covered by the 3 attorney-client privilege or work product protection, the parties may 4 incorporate their agreement in the stipulated protective order 5 submitted to the court. 6 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Stipulated 9 Protective Order abridges the right of any person to seek its 10 modification by the court in the future. 11 12.2 Right to Assert Other Objections. By stipulating to the entry 12 of this Stipulated Protective Order no Party waives any right it 13 otherwise would have to object to disclosing or producing any 14 information or item on any ground not addressed in this Stipulated 15 Protective Order. Similarly, no Party waives any right to object on any 16 17 ground to use in evidence of any of the material covered by this 18 Stipulated Protective Order. 19 12.3 Filing Protected Material. A Party that seeks to file under 20 seal any Protected Material must comply with Local Rule 79-5. 21 Protected Material may only be filed under seal pursuant to a court 22 order authorizing the sealing of the specific Protected Material at issue. 23 If a Party's request to file Protected Material under seal is denied by the 24 court, then the Receiving Party may file the information in the public 25 record unless otherwise instructed by the court. 26

27 1 13. FINAL DISPOSITION 2 After the Final Disposition of this Action, as defined in paragraph 3 4, within 60 days of a written request by the Designating Party, each 4 Receiving Party must return all Protected Material to the Producing 5 Party or destroy such material. As used in this subdivision, “all 6 Protected Material” includes all copies, abstracts, compilations, 7 summaries, and any other format reproducing or capturing any of the 8 Protected Material. Whether the Protected Material is returned or 9 destroyed, the Receiving Party must submit a written certification to 10 the Producing Party (and, if not the same person or entity, to the 11 Designating Party) by the 60 day deadline that (1) identifies (by 12 category, where appropriate) all the Protected Material that was 13 returned or destroyed and (2) affirms that the Receiving Party has not 14 retained any copies, abstracts, compilations, summaries or any other 15 format reproducing or capturing any of the Protected Material. 16 Notwithstanding this provision, Counsel is entitled to retain an archival 17 18 copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial 20 exhibits, expert reports, attorney work product, and consultant and 21 expert work product, even if such materials contain Protected Material. 22 Any such archival copies that contain or constitute Protected Material 23 remain subject to this Protective Order as set forth in Section 4. 24

25 26 27 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 || by any and all appropriate measures including, without limitation, 4 || contempt proceedings and/or monetary sanctions. 5 6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 * || DATED: 9/12/2024 /s| Michael A. Bernet ° Attorney(s) for Plaintiff(s) 10 1] DATED: 9/12/2024 /s/ Stephen M. Lobbin 3 Attorney(s) for Defendant(s) 14 15 16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 1g || DATED: September 13, 2024 LZ 19 STEPHANIE S. CHRISTENSEN 50 United States Magistrate Judge 21 22 23 24 25 26 27 28

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, _____________________________ [print or type full name], 4 of ______________________________________________________ [print 5 or type full address], declare under penalty of perjury that I have 6 read in its entirety and understand the Stipulated Protective Order 7 that was issued by the United States District Court for the Central 8 District of California on _____________________ [date] in the case of 9 Naked Whey, Inc. v. Naked Warrior Recovery LLC, Case No. 2:24-cv- 10 00828-RMA-SSC. I agree to comply with and to be bound by all the 11 terms of this Stipulated Protective Order and I understand and 12 acknowledge that failure to so comply could expose me to sanctions 13 14 and punishment in the nature of contempt. I solemnly promise that I 15 will not disclose in any manner any information or item that is subject 16 to this Stipulated Protective Order to any person or entity except in 17 strict compliance with the provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such 21 enforcement proceedings occur after termination of this action. I 22 hereby appoint ____________________________________ [print or type 23 full name] of ____________________________________________________ 24 ____________________________________ [print or type full address 25 and telephone number] as my California agent for service of process 26 in connection with this action or any proceedings related to 27 enforcement of this Stipulated Protective Order. 1 2 Date: ___________________________ 3

4 City and State where sworn and ___________________________ 5 signed: 6 7 Printed name: ___________________________ 8

9 Signature: ___________________________ 10

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