1 Navid Yadegar (SBN 205315) [email protected] 2 Navid Soleymani (SBN 219190) [email protected] 3 Nathan Benyamin (SBN 341510) [email protected] 4 YADEGAR, MINOOFAR & SOLEYMANI LLP 1875 Century Park East, Suite 1240 5 Los Angeles, California 90067 6 Telephone: (310) 499-0140 Facsimile: (888) 667-9576 7

8 Attorneys for Plaintiff GLAREH TAFRESHI 9

10 Leslie Helmer (SBN 150296) [email protected] 11 Nare Avagyan (SBN 292608) [email protected] 12 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 400 South Hope St., Suite 1200 13 Los Angeles, CA 90071 Telephone: (213) 239-9800 14 Attorneys for Defendant 15 WALGREEN PHARMACY SERVICES MIDWEST, LLC 16 17 UNITED STATES DISTRICT COURT

18 CENTRAL DISTRICT OF CALIFORNIA

19 GLAREH TAFRESHI, an individual; Case No. 2:24-cv-05960-PSG(RAOx) 20 Plaintiff, 21 STIPULATED PROTECTIVE ORDER vs. (DISCOVERY MATTER) 22 WALGREEN PHARMACY 23 SERVICES MIDWEST, LLC, an Action Filed: June 7, 2024 Illinois limited liability company; and Removal Date: July 16, 2024 24 DOES 1 through 10, inclusive, Trial Date: None 25 Defendants. District Judge: Hon. Philip S. Gutierrez Magistrate Judge: Hon. Rozella A. Oliver 26

27 28 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 disclosure 4 and from use for any purpose other than pursuing this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 6 Stipulated Protective Order. The parties acknowledge that this Order does not confer 7 blanket protections on all disclosures or responses to discovery and that the protection it 8 affords from public disclosure and use extends only to the limited information or items 9 that are entitled to confidential treatment under the applicable legal principles. 10 2. GOOD CAUSE STATEMENT 11 This action is likely to involve trade secrets, proprietary business information, 12 medical records and personal information of percipient witnesses for which special 13 protection from public disclosure and from use for any purpose other than prosecution 14 of this action is warranted. Such confidential materials and information consist of, 15 among other things, information protected by the Health Insurance Portability and 16 Accountability Act, Walgreens’ confidential and proprietary business records and 17 information, including information and records relative to Walgreens’ employees, 18 information otherwise generally unavailable to the public, or which may be privileged 19 or otherwise protected from disclosure under state or federal statutes, court rules, case 20 decisions, or common law. Accordingly, to expedite the flow of information, to 21 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 22 to adequately protect information the parties are entitled to keep confidential, to ensure 23 that the parties are permitted reasonable necessary uses of such material in preparation 24 for and in the conduct of trial, to address their handling at the end of the litigation, and 25 serve the ends of justice, a protective order for such information is justified in this 26 matter. It is the intent of the parties that information will not be designated as 27 confidential for tactical reasons and that nothing be so designated without a good faith 28 1 belief that it has been maintained in a confidential, non-public manner, and there is good 2 cause why it should not be part of the public record of this case. 3 3. ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE 4 The parties further acknowledge, as set forth in Section 14.3, below, that this 5 Stipulated Protective Order does not entitle them to file confidential information under 6 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 7 standards that will be applied when a party seeks permission from the court to file 8 material under seal. There is a strong presumption that the public has a right of access to 9 judicial proceedings and records in civil cases. In connection with non-dispositive 10 motions, good cause must be shown to support a filing under seal. See Kamakana v. 11 City and County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. 12 Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 13 Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 14 require good cause showing), and a specific showing of good cause or compelling 15 reasons with proper evidentiary support and legal justification, must be made with 16 respect to Protected Material that a party seeks to file under seal. The parties’ mere 17 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 18 without the submission of competent evidence by declaration, establishing that the 19 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 20 protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, then 22 compelling reasons, not only good cause, for the sealing must be shown, and the relief 23 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 24 v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item or type 25 of information, document, or thing sought to be filed or introduced under seal, the party 26 seeking protection must articulate compelling reasons, supported by specific facts and 27 legal justification, for the requested sealing order. Again, competent evidence 28 1 supporting the application to file documents under seal must be provided by declaration. 2 Any document that is not confidential, privileged, or otherwise protectable in its 3 entirety will not be filed under seal if the confidential portions can be redacted. If 4 documents can be redacted, then a redacted version for public viewing, omitting only 5 the confidential, privileged, or otherwise protectable portions of the document, shall be 6 filed. Any application that seeks to file documents under seal in their entirety should 7 include an explanation of why redaction is not feasible. 8 4. DEFINITIONS 9 4.1 Action: this pending federal lawsuit bearing case number 2:24-cv-05960- 10 PSG(RAOx). 11 4.2 Challenging Party: a Party or Non-Party that challenges the designation of 12 information or items under this Order. 13 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how 14 it is generated, stored or maintained) or tangible things that qualify for protection under 15 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 16 Statement. 17 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 18 support staff). 19 4.5 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL.” 22 4.6 Disclosure or Discovery Material: all items or information, regardless of 23 the medium or manner in which it is generated, stored, or maintained (including, among 24 other things, testimony, transcripts, and tangible things), that are produced or generated 25 in disclosures or responses to discovery. 26 4.7 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 28 1 expert witness or as a consultant in this Action. 2 4.8 House Counsel: attorneys who are employees of a party to this Action. 3 House Counsel does not include Outside Counsel of Record or any other outside 4 counsel. 5 4.9 Non-Party: any natural person, partnership, corporation, association or 6 other legal entity not named as a Party to this action. 7 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 8 this Action but are retained to represent a party to this Action and have appeared in this 9 Action on behalf of that party or are affiliated with a law firm that has appeared on 10 behalf of that party, and includes support staff. 11 4.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 14 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 15 Discovery Material in this Action. 16 4.13 Professional Vendors: persons or entities that provide litigation support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 19 their employees and subcontractors. 20 4.14 Protected Material: any Disclosure or Discovery Material that is designated 21 as “CONFIDENTIAL.” 22 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 23 a Producing Party. 24 5. SCOPE 25 The protections conferred by this Stipulation and Order cover not only Protected 26 Material (as defined above), but also (1) any information copied or extracted from 27 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 28 1 Material; and (3) any testimony, conversations, or presentations by Parties or their 2 Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial 4 judge and other applicable authorities. This Order does not govern the use of Protected 5 Material at trial. 6 6. DURATION 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Order shall remain in effect until a Designating Party agrees 9 otherwise in writing or a court order otherwise directs. Final disposition shall be 10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with or 11 without prejudice; and (2) final judgment herein after the completion and exhaustion 12 of all appeals, rehearings, remands, trials, or reviews of this Action, including the time 13 limits for filing any motions or applications for extension of time pursuant to applicable 14 law. 15 7. DESIGNATING PROTECTED MATERIAL 16 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 17 Party or Non-Party that designates information or items for protection under this Order 18 must take care to limit any such designation to specific material that qualifies under the 19 appropriate standards. The Designating Party must designate for protection only those 20 parts of material, documents, items or oral or written communications that qualify so 21 that other portions of the material, documents, items or communications for which 22 protection is not warranted are not swept unjustifiably within the ambit of this Order. 23 Mass, indiscriminate or routinized designations are prohibited. Designations that 24 are shown to be clearly unjustified or that have been made for an improper purpose 25 (e.g., to unnecessarily encumber the case development process or to impose unnecessary 26 expenses and burdens on other parties) may expose the Designating Party to sanctions. 27 If it comes to a Designating Party’s attention that information or items that it 28 1 designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 7.2 Manner and Timing of Designations. Except as otherwise provided in this 4 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 5 qualifies for protection under this Order must be clearly so designated before the 6 material is disclosed or produced. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or electronic 9 documents, but excluding transcripts of depositions or other pretrial or trial 10 proceedings), that the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion of the material on a page qualifies for 13 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 14 by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection need 16 not designate them for protection until after the inspecting Party has indicated which 17 documents it would like copied and produced. During the inspection and before the 18 designation, all of the material made available for inspection shall be deemed 19 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 20 copied and produced, the Producing Party must determine which documents, or portions 21 thereof, qualify for protection under this Order. Then, before producing the specified 22 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 23 that contains Protected Material. If only a portion of the material on a page qualifies for 24 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 25 by making appropriate markings in the margins). 26 (b) for testimony given in depositions that the Designating Party identifies the 27 Disclosure or Discovery Material on the record, before the close of the deposition all 28 1 protected testimony. 2 (c) for information produced in some form other than documentary and for any 3 other tangible items, that the Producing Party affix in a prominent place on the exterior 4 of the container or containers in which the information is stored the legend 5 “CONFIDENTIAL.” If only a portion or portions of the information warrants 6 protection, the Producing Party, to the extent practicable, shall identify the protected 7 portion(s). 8 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 9 to designate qualified information or items does not, standing alone, waive the 10 Designating Party’s right to secure protection under this Order for such material. Upon 11 timely correction of a designation, the Receiving Party must make reasonable efforts to 12 assure that the material is treated in accordance with the provisions of this Order. 13 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 8.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 15 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 16 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 17 process under Local Rule 37-1 et seq. 18 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 19 stipulation pursuant to Local Rule 37-2. 20 8.4 The burden of persuasion in any such challenge proceeding shall be on the 21 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 22 to harass or impose unnecessary expenses and burdens on other parties) may expose the 23 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 24 the confidentiality designation, all parties shall continue to afford the material in 25 question the level of protection to which it is entitled under the Producing Party’s 26 designation until the Court rules on the challenge. 27 /// 28 1 9. ACCESS TO AND USE OF PROTECTED MATERIALS 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this Action 4 only for prosecuting, defending or attempting to settle this Action. Such Protected 5 Material may be disclosed only to the categories of persons and under the conditions 6 described in this Order. When the Action has been terminated, a Receiving Party must 7 comply with the provisions of section 15 below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons 10 authorized under this Order. 11 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 12 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 13 may disclose any information or item designated “CONFIDENTIAL” only to: 14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 15 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this Action; 17 (b) the officers, directors, and employees (including House Counsel) of the 18 Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 20 is reasonably necessary for this Action and who have signed the “Acknowledgment and 21 Agreement to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 25 whom disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 28 1 custodian or other person who otherwise possessed or knew the information; 2 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 3 to whom disclosure is reasonably necessary provided: (1) the deposing party requests 4 that the witness sign the form attached as Exhibit A hereto; and (2) they will not be 5 permitted to keep any confidential information unless they sign the “Acknowledgment 6 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 7 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 8 depositions that reveal Protected Material may be separately bound by the court reporter 9 and may not be disclosed to anyone except as permitted under this Stipulated Protective 10 Order; and 11 (i) any mediators or settlement officers and their supporting personnel, mutually 12 agreed upon by any of the parties engaged in settlement discussions. 13 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation that 16 compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order 21 to issue in the other litigation that some or all of the material covered by the subpoena or 22 order is subject to this Protective Order. Such notification shall include a copy of this 23 Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued 25 by the Designating Party whose Protected Material may be affected. If the Designating 26 Party timely seeks a protective order, the Party served with the subpoena or court order 27 shall not produce any information designated in this action as “CONFIDENTIAL” 28 1 before a determination by the court from which the subpoena or order issued, unless the 2 Party has obtained the Designating Party’s permission. The Designating Party shall bear 3 the burden and expense of seeking protection in that court of its confidential material 4 and nothing in these provisions should be construed as authorizing or encouraging a 5 Receiving Party in this Action to disobey a lawful directive from another court. 6 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a 9 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the remedies 11 and relief provided by this Order. Nothing in these provisions should be construed as 12 prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 16 information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non- 18 Party that some or all of the information requested is subject to a confidentiality 19 agreement with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 specific description of the information requested; and 23 (3) make the information requested available for inspection by the 24 Non-Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 26 14 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. If 28 1 Non-Party timely seeks a protective order, the Receiving Party shall not produce any 2 ||information in its possession or control that is subject to the confidentiality agreement 3 || with the Non-Party before a determination by the court. Absent a court order to the 4 ||contrary, the Non-Party shall bear the burden and expense of seeking protection in this 5 || court of its Protected Material. 6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 ||Protected Material to any person or in any circumstance not authorized under this 9 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 10 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 11 unauthorized copies of the Protected Material, (c) inform the person or persons to 12 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 13 person or persons to execute the “Acknowledgment and Agreement to Be Bound” 14 || attached hereto as Exhibit A 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 ||When a Producing Party gives notice to Receiving Parties that certain inadvertently 18 produced material is subject to a claim of privilege or other protection, the obligations 19 |lof the Receiving Parties are those set forth in Federal Rule of Civil Procedure 20 ||26(b)\(S5\(B). This provision is not intended to modify whatever procedure may be 21 ||/established in an e-discovery order that provides for production without prior privilege 22 ||review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 23 ||an agreement on the effect of disclosure of a communication or information covered by 24 ||the attorney-client privilege or work product protection, the parties may incorporate 25 ||their agreement in the stipulated protective order submitted to the court. 26 14. MISCELLANEOUS 27 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 -1L- STIPULATED PROTECTIVE ORDER

1 person to seek its modification by the Court in the future. 2 14.2 Right to Assert Other Objections. By stipulating to the entry of this 3 Protective Order, no Party waives any right it otherwise would have to object to 4 disclosing or producing any information or item on any ground not addressed in this 5 Stipulated Protective Order. Similarly, no Party waives any right to object on any 6 ground to use in evidence of any of the material covered by this Protective Order. 7 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected 8 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 9 under seal pursuant to a court order authorizing the sealing of the specific Protected 10 Material. If a Party’s request to file Protected Material under seal is denied by the court, 11 then the Receiving Party may file the information in the public record unless otherwise 12 instructed by the court. 13 15. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraph 6, within 60 15 days of a written request by the Designating Party, each Receiving Party must return all 16 Protected Material to the Producing Party or destroy such material. As used in this 17 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected 19 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 20 must submit a written certification to the Producing Party (and, if not the same person or 21 entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, 22 where appropriate) all the Protected Material that was returned or destroyed and (2) 23 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 24 summaries or any other format reproducing or capturing any of the Protected Material. 25 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 26 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 27 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 28 1 ||consultant and expert work product, even if such materials contain Protected Material. 2 || Any such archival copies that contain or constitute Protected Material remain subject to 3 || this Protective Order as set forth in Section 6 (DURATION). 4 16. VIOLATION 5 Any violation of this Order may be punished by appropriate measure including, 6 || without limitation, contempt proceedings and/or monetary sanctions. 7 \|IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 Dated: September 25, 2024 YADEGAR, MINOOFAR & SOLEYMANI 10 11 By: /s/ Navid Yadegar Navid Yadegar ~ 12 Navid Soleymani 13 Attorneys for Plaintiff 14 GLAREH TAFRESHI 15 16 DATED: September 25, 2024 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 17 is A i Ned 19 By: Leslie H. Helmer 20 Nare Avagyan 21 Attorneys for Defendant WALGREEN PHARMACY SERVICES 22 MIDWEST, LLC 23 24 25 26 27 28 -13- STIPULATED PROTECTIVE ORDER

1 ATTESTATION 2 Pursuant to Local Civil Rule 5-4.3(a)(2)(i), I hereby attest that Leslie H. Helmer 3 of Ogletree, Deakins, Nash, Smoak & Stewart, P.C., counsel for Defendant, on whose 4 behalf this filing is jointly submitted, has concurred in this filing content, and has 5 authorized me to file this document. 6 Dated: September 25, 2024 YADEGAR, MINOOFAR & SOLEYMANI LLP 7

8 By: _/s/ Navid Yadegar______________ Navid Yadegar 9

10

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 4 ||DATED: _ 9/27/2024 Rapetiis, On, Cz... 7 ROZELLA A.OLIVER 3 United States Magistrate Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -15- STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, _______________________________________ [print or type full name], of 5 ____________________________________________ [print or type full address], 6 declare under penalty of perjury that I have read in its entirety and understand the 7 Stipulated Protective Order that was issued by the United States District Court for the 8 Central District of California on _________________________ [date] in the case of 9 Tafreshi v. Walgreen Pharmacy Services Midwest, LLC, et al, Case No.: 2:24-cv- 10 05960-PSG(RAOx). I agree to comply with and to be bound by all the terms of this 11 Stipulated Protective Order and I understand and acknowledge that failure to so comply 12 could expose me to sanctions and punishment in the nature of contempt. I solemnly 13 promise that I will not disclose in any manner any information or item that is subject to 14 this Stipulated Protective Order to any person or entity except in strict compliance with 15 the provisions of this Order. I further agree to submit to the jurisdiction of the United 16 States District Court for the Central District of California for the purpose of enforcing 17 the terms of this Stipulated Protective Order, even if such enforcement proceedings 18 occur after termination of this action. I hereby appoint 19 ____________________________ [print or type full name] of 20 _______________________________ [print or type full address and telephone number] 21 as my California agent for service of process in connection with this action or any 22 proceedings related to enforcement of this Stipulated Protective Order. 23 Date: ________________________________ 24

25 City and State where sworn and signed: __________________________________

26 Printed name: _________________________________ 27 Signature: ________________________ 28