1 JOHN W. HOWARD (SBN 80200) MOLLY M. LENS (Cal. Bar SCOTT J. STREET (SBN 258962) #283867) 2 JW Howard/ Attorneys, Ltd. O’Melveny & Myers LLP 600 West Broadway, Suite 1400 1999 Avenue of the Stars, 8th Floor 3 San Diego, CA 92101 Los Angeles, California 90067-6035 Tel: 619-234-2842; Fax 619-234-1716 Tel: (310) 553-6700 4 [email protected] Fax: (310) 246-6779 [email protected] [email protected] 5 NICHOLAS R. BARRY (pro hac vice) NATASHA W. TELEANU (pro hac 6 IAN PRIOR (pro hac vice) vice) America First Legal Foundation O’MELVENY & MYERS LLP 7 611 Pennsylvania Ave, SE #231 1301 Avenue of the Americas, 17th Washington, DC 20003 Floor 8 Telephone: (615) 431-9303 New York, New York 10019 [email protected] Telephone: +1 212 326 2000 9 [email protected] Facsimile: +1 212 326 2061 [email protected] 10 Counsel for Plaintiff JOSHUA REVESZ (pro hac vice) 11 O’Melveny & Myers LLP 1625 Eye Street, NW Washington, 12 DC 20006 Telephone: (202) 383-5300 13 Facsimile: (202) 383-5414 [email protected] 14 Attorneys for Defendants 15

16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18

19 BRIAN BENEKER Case No.: 2:24-cv-01659-JFW-SSC 20 Plaintiff,

21 v. STIPULATED PROTECTIVE

22 CBS STUDIOS, INC. and ORDER1 PARAMOUNT GLOBAL, 23 Defendants. 24

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

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 15 Byrd v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar- 16 Welbon v. Sony Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 17 protective orders require good cause showing), and a specific showing of good 18 cause or compelling reasons with proper evidentiary support and legal justification, 19 must be made with respect to Protected Material that a party seeks to file under 20 seal. The parties’ mere designation of Disclosure or Discovery Material as 21 CONFIDENTIAL does not—without the submission of competent evidence by 22 declaration, establishing that the material sought to be filed under seal qualifies as 23 confidential, privileged, or otherwise protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, 25 then compelling reasons, not only good cause, for the sealing must be shown, and 26 the relief sought shall be narrowly tailored to serve the specific interest to be 27 protected. See Pintos v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 1 or introduced under seal in connection with a dispositive motion or trial, the party 2 seeking protection must articulate compelling reasons, supported by specific facts 3 and legal justification, for the requested sealing order. Again, competent evidence 4 supporting the application to file documents under seal must be provided by 5 declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 its entirety will not be filed under seal if the confidential portions can be redacted. 8 If documents can be redacted, then a redacted version for public viewing, omitting 9 only the confidential, privileged, or otherwise protectable portions of the document, 10 shall be filed. Any application that seeks to file documents under seal in their 11 entirety should include an explanation of why redaction is not feasible. 12 13 2. DEFINITIONS 14 2.1 Action: Brian Beneker v. CBS Studios et al., No. 2:24-cv-01659-JFW- 15 SSC. 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified 21 above in the Good Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 23 their support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless 1 among other things, testimony, transcripts, and tangible things), that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 an expert witness or as a consultant in this Action. 6 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses 7 in this Action, with or without prejudice; and (2) final judgment herein after the 8 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 9 this Action, including the time limits for filing any motions or applications for 10 extension of time pursuant to applicable law. 11 2.9 In-House Counsel: attorneys who are employees of a party to this 12 Action. In-House Counsel does not include Outside Counsel of Record or any other 13 outside counsel. 14 2.10 Non-Party: any natural person, partnership, corporation, association, or 15 other legal entity not named as a Party to this action. 16 2.11 Outside Counsel of Record: attorneys who are not employees of a party 17 to this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm which 19 has appeared on behalf of that party, and includes support staff. 20 2.12 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.14 Professional Vendors: persons or entities that provide litigation- 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 1 2.15 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 4 from a Producing Party. 5 6 3. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 For the avoidance of doubt, the designation of any documents or information 13 as “confidential” under this Stipulation and Order does not cover the following 14 information: (a) any information that is independently in the public domain at the 15 time of disclosure to a Receiving Party or becomes part of the public domain after 16 its disclosure to a Receiving Party as a result of publication not involving a 17 violation of this Order and (b) any information independently known to the 18 Receiving Party prior to the disclosure or obtained by the Receiving Party after the 19 disclosure from a source who obtained the information lawfully and under no 20 obligation of confidentiality to the Designating Party. For the avoidance of doubt, 21 however, any documents designated as “confidential” pursuant to this Stipulation 22 and Order must be treated as such, unless and until the designation is withdrawn 23 and/or the Court rules otherwise or the document is otherwise independently in the 24 possession of the author or intended recipient(s) of a document (including persons 25 who are “CC’d” or “BCC’d”) prior to the designation of the document as 26 “confidential”. 27 Any use of Protected Material at trial shall be governed by the orders of the 1 Material at trial. 2 3 4. TRIAL AND DURATION 4 The terms of this Stipulated Protective Order apply through Final Disposition 5 of the Action. 6 Once a case proceeds to trial, information that was designated as 7 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 8 used or introduced as an exhibit at trial becomes public and will be presumptively 9 available to all members of the public, including the press, unless compelling 10 reasons supported by specific factual findings to proceed otherwise are made to the 11 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 12 (distinguishing “good cause” showing for sealing documents produced in discovery 13 from “compelling reasons” standard when merits-related documents are part of 14 court record). Accordingly, for such materials, the terms of this Stipulated 15 Protective Order do not extend beyond the commencement of the trial. 16 Even after Final Disposition of this litigation, the confidentiality obligations 17 imposed by this Stipulated Protective Order shall remain in effect until a 18 Designating Party agrees otherwise in writing or a court order otherwise directs. 19 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 20 defenses in this Action, with or without prejudice; and (2) final judgment herein 21 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 22 reviews of this Action, including the time limits for filing any motions or 23 applications for extension of time pursuant to applicable law. 24 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under 1 qualifies under the appropriate standards. 2 Mass, indiscriminate, or routinized designations are prohibited. Designations 3 that are shown to be clearly unjustified or that have been made for an improper 4 purpose (e.g., to unnecessarily encumber the case development process or to 5 impose unnecessary expenses and burdens on other parties) may expose the 6 Designating Party to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise provided in 11 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) 12 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 13 qualifies for protection under this Stipulated Protective Order must be clearly so 14 designated before the material is disclosed or produced. 15 Designation in conformity with this Stipulated Protective Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Producing Party affix at a minimum, the legend 19 “CONFIDENTIAL” to each page that contains protected material. 20 A Party or Non-Party that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and 23 before the designation, all of the material made available for inspection shall be 24 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 25 it wants copied and produced, the Producing Party must determine which 26 documents qualify for protection under this Stipulated Protective Order. Then, 27 before producing the specified documents, the Producing Party must affix the 1 portion or portions of the material on a page qualifies for protection, the Producing 2 Party also must clearly identify the protected portion(s) (e.g., by making 3 appropriate markings in the margins). 4 (b) for testimony given in depositions, the Designating Party may 5 provisionally designate the entirety of deposition testimony as “CONFIDENTIAL,” 6 with the obligation to identify more specific portions of the testimony as to which 7 protection is sought within 30 days following receipt of the deposition transcript (or 8 within the time otherwise agreed by the Parties). 9 (c) for information produced in some form other than documentary and 10 for any other tangible items, that the Producing Party affix in a prominent place on 11 the exterior of the container or containers in which the information is stored the 12 “CONFIDENTIAL” legend. If only a portion or portions of the information 13 warrants protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Stipulated Protective Order. 21 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the court’s 25 Scheduling Order. Unless a prompt challenge to a Designating Party’s 26 confidentiality designation is necessary to avoid foreseeable, substantial unfairness, 27 unnecessary economic burdens, or a significant disruption or delay of the litigation, 1 electing not to mount a challenge promptly after the original designation is 2 disclosed. 3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 4 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 5 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2 6 6.3 The burden of persuasion in any such challenge proceeding shall be on 7 the Designating Party. Frivolous challenges, and those made for an improper 8 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 9 parties) may expose the Challenging Party to sanctions. Unless the Designating 10 Party has waived or withdrawn the confidentiality designation (including by failing 11 to file the stipulation required by Local Rule 37-2.1), all parties shall continue to 12 afford the material in question the level of protection to which it is entitled under 13 the Producing Party’s designation until the court rules on the challenge. 14 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that 17 is disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action reaches a Final Disposition, a 21 Receiving Party must comply with the provisions of section 13 below. 22 Protected Material must be stored and maintained by a Receiving Party at a 23 location and in a secure manner that ensures that access is limited to the persons 24 authorized under this Stipulated Protective Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 26

27 2 Judge Christensen’s Procedures are available at 1 otherwise ordered by the court or permitted in writing by the Designating Party, a 2 Receiving Party may disclose any information or item designated 3 “CONFIDENTIAL” only: 4 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as 5 well as employees of said Outside Counsel of Record to whom it is reasonably 6 necessary to disclose the information for this Action 7 (b) to the officers, directors, and employees (including House Counsel) of 8 the Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) to Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) to the court and its personnel; 13 (e) to court reporters and their staff; 14 (f) to professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) to the author or recipient of a document containing the information or 18 a custodian or other person who otherwise possessed or knew the information; 19 (h) any deposition or non-trial hearing witness in the Action (including, 20 for the avoidance of doubt, in preparation for such testimony) who previously did 21 not have access to the Confidential Materials (including any counsel for such 22 individuals); provided, provided: (1) the witness signs the “Acknowledgment and 23 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to 24 keep any confidential information unless they sign the “Acknowledgment and 25 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 26 Party or ordered by the court; and 27 (i) to any mediator or settlement officer, and their supporting personnel, 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 other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification 7 shall include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 a copy of this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be 13 pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 with the subpoena or court order shall not produce any information designated in 16 this action as “CONFIDENTIAL” before a determination by the court from which 17 the subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 9.1 Application. The terms of this Stipulated Protective Order are 26 applicable to information produced by a Non-Party in this Action and designated as 27 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 1 Nothing in these provisions should be construed as prohibiting a Non-Party from 2 seeking additional protections. 3 9.2 Notification. In the event that a Party is required, by a valid discovery 4 request, to produce a Non-Party’s confidential information in its possession, and the 5 Party is subject to an agreement with the Non-Party not to produce the Non- 6 Party’s confidential information, then the Party shall: 7 (a) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non-Party; 10 (b) make the information requested available for inspection by the Non- 11 Party, if requested. 12 9.3 Conditions of Production. If the Non-Party fails to seek a protective 13 order from this court within 14 days of receiving the notice and accompanying 14 information, the Receiving Party may produce the Non-Party’s confidential 15 information responsive to the discovery request. If the Non-Party timely seeks a 16 protective order, the Receiving Party shall not produce any information in its 17 possession or control that is subject to the confidentiality agreement with the Non- 18 Party before a determination by the court. Absent a court order to the contrary, with 19 the court having discretion to shift costs, the Non-Party shall bear the burden and 20 expense of seeking protection in this court of its Protected Material. 21 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 writing the Designating Party of the unauthorized disclosures, (b) use its best 27 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 1 this Order, and (d) request such person or persons to execute the “Acknowledgment 2 and Agreement to Be Bound” (Exhibit A). 3 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other 8 protection, the obligations of the Receiving Parties are those set forth in Rule 9 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended 10 to modify whatever procedure may be established in an e-discovery order that 11 provides for production without prior privilege review. Pursuant to Federal Rule of 12 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of 13 disclosure of a communication or information covered by the attorney-client 14 privilege or work product protection, the parties may incorporate their agreement in 15 the stipulated protective order submitted to the court. 16 17 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 19 abridges the right of any person to seek its modification by the court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 Stipulated Protective Order no Party waives any right it otherwise would have to 22 object to disclosing or producing any information or item on any ground not 23 addressed in this Stipulated Protective Order. Similarly, no Party waives any right 24 to object on any ground to use in evidence of any of the material covered by this 25 Stipulated Protective Order. And nothing in these provisions should be construed 26 as prohibiting a Party from seeking additional protections. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party's request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 6 13. FINAL DISPOSITION 7 After the Final Disposition of this Action, as defined in paragraph 4, within 8 60 days of a written request by the Designating Party, each Receiving Party must 9 return all Protected Material to the Producing Party or destroy such material. As 10 used in this subdivision, “all Protected Material” includes all copies, abstracts, 11 compilations, summaries, and any other format reproducing or capturing any of the 12 Protected Material. Whether the Protected Material is returned or destroyed, the 13 Receiving Party must submit a written certification to the Producing Party (and, if 14 not the same person or entity, to the Designating Party) by the 60 day deadline that 15 (1) identifies (by category, where appropriate) all the Protected Material that was 16 returned or destroyed and (2) affirms that the Receiving Party has not retained any 17 copies, abstracts, compilations, summaries or any other format reproducing or 18 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 19 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 20 and hearing transcripts, legal memoranda, correspondence, deposition and trial 21 exhibits, expert reports, attorney work product, and consultant and expert work 22 product, even if such materials contain Protected Material. Any such archival 23 copies that contain or constitute Protected Material remain subject to this Protective 24 Order as set forth in Section 4. 25 /// 26 /// 27 /// 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished by any 3 |) and all appropriate measures including, without limitation, contempt proceedings 4 || and/or monetary sanctions. 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7

DATED: November 8, 2024 /s/ Michelle D. Volk

10 Attormey for Plaintiff 11 DATED: November 8, 2024 /s/ Nicholas R. Barry 12 Attorney for Plaintiff 13 DATED: November 8, 2024 /s/ Molly M. Lens "4 Attorney for Defendants . ATTESTATION OF FILING 7 Pursuant to Local Rule 5-4.3.4 regarding signatures, I, Michelle D. Volk, 18 hereby attest that concurrence in the filing has been obtained from counsel with 19 conformed signatures above. 50 /s/ Michelle D. Volk Michelle D. Volk 71 Attorney for Plaintiff 22 23 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 || DATED: November 12, 2024 Hon. Stephanie S. Christensen

28 United States Magistrate Judge

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated Protective 6 Order that was issued by the United States District Court for the Central District 7 of California on ___________[date] in the case of Brian Beneker v. CBS Studios 8 et al., Case No. 2:24-cv-01659-JFW. I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge 10 that failure to so comply could expose me to sanctions and punishment in the 11 nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 15 Court for the Central District of California for the purpose of enforcing the terms of 16 this Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ________________________ [print 18 or type full name] of _________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this 20 action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 23 Date: ___________________________ 24 City and State where sworn and 25 signed: ___________________________ 26 Printed name: ___________________________ 27 Signature: ___________________________ 1 CERTIFICATE OF SERVICE 2 At the time of service, I was over 18 years of age and not a party to this 3 action. I am employed by JW Howard/Attorneys, LTD. in the County of San 4 Diego, State of California. My business address is 600 West Broadway, Suite 5 1400, San Diego, California 92101. 6 On November 8, 2024, I electronically served the STIPULATED 7 PROTECTIVE ORDER and served the documents using the Court’s Electronic 8 CM/ECF Service which will send electronic notification of such filing to all 9 registered counsel.

10 I declare under penalty of perjury under the laws of the United States of 11 America that the foregoing is true and correct. 12 Executed on November 8, 2024 at San Diego, California. 13

14 /s/ Dayna Dang _ 15 Dayna Dang, Paralegal [email protected] 16

17 18 19 20 21 22 23 24 25 26 27