1 | Alexander M. Kargher, SBN 259262 □□□□□□□□□□□□□□□□□□□□□□□□□□□ 2 | Lara M. Kruska, SBN 271979 □□□□□□□□□□□□□□□□□□□□□□□□□□ 3 | Samantha J. Aceves, SBN 339969 saceves(@sinciaitraun.com 4 | SINCLAIR BRAUN KARGHER LLP 15260 Ventura Blvd., Suite 715 5 | Sherman Oaks, California 91403 Telephone: 13) 429-6100 6 | Facsimile: (213) 429-6101 7 | Attorneys for Plaintiff JOHN SMITH

9 UNITED STATES DISTRICT COURT

0 CENTRAL DISTRICT OF CALIFORNIA

JOHN SMITH, Case No.: 2:23-cv-05033-WLH-RAO Plaintiff, STIPULATED PROTECTIVE 12 ORDER! VS. 13 4 JANE DOE et al., Defendants. 15 16 17 18 19 20 21 22 23 24 25 26 oO 22 ' This Stipulated Protective Order is substantially based on the model protective order under Magistrate Judge Rozella A. Oliver’s Procedures.

tt. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential 3 | proprietary, or private information for which special protection from public 4 | disclosure and from use for any purpose other than prosecuting this litigation may be > | warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 | the following Stipulated Protective Order (“Order” or “Protective Order’). The 7 | 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 12 A. GOOD CAUSE STATEMENT 13 This is a revenge porn action involving the non-consensual disclosure of 14 | sexually explicit images on the internet after extortion. This material was distributed 1S | through list-serve emails and QR codes designed to direct users to click on a link to 16 | a video that displayed Plaintiff engaging in intimate acts, in a private situation, in a 17 | private setting. This action exists to protect Plaintiffs privacy rights and to prevent 18 | the amplification of further humiliation to Plaintiff and his business. This Court has 19 | already issued an order on August 23, 2023 ordering that the parties proceed in the 20 | action under pseudonyms due to the highly confidential nature of the material that 2! | was distributed and the severity of the threatened harm of the existence of non- 22 | consensual pornography. (ECF Docket No. 14.) 23 Because the material itself was created and disseminated using various third 24 | party services including website domain hosts, QR code generators, video editing 25 | software, list-serves, newsletter generators, and various other third party services 26 | used to distribute the material, discovery in this case will likely involve trade secrets, 27 | customer and pricing lists and other valuable research, development, commercial, 28 | financial, technical and/or proprietary information for which special protection from

! | public disclosure and from use for any purpose other than prosecution of this action 2 | is warranted. Such confidential and proprietary materials and information consist of, 3 | among other things, non-consensual pornographic material, confidential business or 4 | financial information, information regarding confidential business practices, or other > | confidential research, development, or commercial information (including 6 | information implicating privacy rights of third parties), information otherwise 7 | generally unavailable to the public, or which may be privileged or otherwise 8 | protected from disclosure under state or federal statutes, court rules, case decisions, 9 | or common law. Accordingly, to expedite the flow of information, to facilitate the 10 | prompt resolution of disputes over confidentiality of discovery materials, to 11 | adequately protect information the parties are entitled to keep confidential, to ensure 12 | that the parties are permitted reasonable necessary uses of such material in 13 | preparation for and in the conduct of trial, to address their handling at the end of the 14 | litigation, and serve the ends of justice, a protective order for such information is 15 | justified in this Action. It is the intent of the parties that information will not be 16 | designated as confidential for tactical reasons and that nothing be so designated | without a good faith belief that it has been maintained in a confidential, non-public 18 | manner, and there is good cause why it should not be part of the public record of this 19 | case. 20 21 B. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 22 SEAL 23 The parties further acknowledge, as set forth in Section 12.3, below, that this 24 | Stipulated Protective Order does not entitle them to file confidential information 25 | under seal. Local Civil Rule 79-5 sets forth the procedures that must be followed and 26 | the standards that will be applied when a party seeks permission from the court to 27 | file material under seal. 28

1 There is a strong presumption that the public has a right of access to judicial 2 | proceedings and records in civil cases. In connection with non-dispositive motions, 3 | good cause must be shown to support a filing under seal. See Kamakana v. City and 4 | County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors > | Corp.,

, 1210-11 (9th Cir. 2002); Makar Welbon v. Sony Electrics, 6 | Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 7 | good cause showing), and a specific showing of good cause or compelling reasons 8 | with proper evidentiary support and legal justification, must be made with respect to 9 || Protected Material that a party seeks to file under seal. The parties’ mere designation 10 | of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 11 | submission of competent evidence by declaration, establishing that the material 12 | sought to be filed under seal qualifies as confidential, privileged, or otherwise 13 | protectable—constitute good cause. Further, if a party requests sealing related to a dispositive motion or trial, then 15 | compelling reasons, not only good cause, for the sealing must be shown, and the 16 | relief sought shall be narrowly tailored to serve the specific interest to be protected. 17 | See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 18 | item or type of information, document, or thing sought to be filed or introduced under 19 | seal in connection with a dispositive motion or trial, the party seeking protection must 20 | articulate compelling reasons, supported by specific facts and legal justification, for 21 | the requested sealing order. Again, competent evidence supporting the application to 22 | file documents under seal must be provided by declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in 24 | its entirety will not be filed under seal if the confidential portions can be redacted 25 || reasonably. If documents can be redacted, then a redacted version for public viewing, 26 | omitting only the confidential, privileged, or otherwise protectable portions of the 27 | document, shall be filed. Any application that seeks to file documents under seal in 28 | their entirety should include an explanation of why redaction is not feasible.

l 2} 2. DEFINITIONS 3 2.1 Action: this pending USDC lawsuit in the Central District of California, 4 | Case No. 2:23-cv-050330-WLH-RAO. 5 2.2 Challenging Party: a Party or Non-Party that challenges the designation 6 | of information or items under this Order. 7 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 8 | how it is generated, stored, or maintained) or tangible things that qualify for 9 | protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 10 | Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 | their support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 1 items that it produces in disclosures or in responses to discovery as 1S | “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 | of the medium or manner in which it is generated, stored, or maintained (including, 18 | among other things), testimony, transcripts, and tangible things, that are produced or 19 | generated in disclosures or responses to discovery in this Action. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 2! | pertinent to this Action who has been retained by a Party or its Counsel to serve as 22 | an expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 | House Counsel does not include Outside Counsel of Record or any other outside 25 | counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association or 27 | other legal entity not named as a Party to this Action. 28 aS H-]H1AMH*

1 2.10 Outside Counsel of Record: attorneys who are not employees of a party 2 | to this Action but are retained to represent or advise a party to this Action and have 3 | appeared in this action on behalf of that party or are affiliated with a law firm which 4 | has appeared on behalf of that party, including their support staff. For purposes of > | this Stipulated Protective Order, the term “Outside Counsel of Record” shall also 6 | include pro se litigants. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 | employees, consultants, retained experts, and Outside Counsel of Record (and their 9 || support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 | Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 | demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 | and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 | designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 | from a Producing Party. 20 21} 3, SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23] Protected Material (as defined above), but also (1) any information copied or 24] extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 | compilations of Protected Material; and (3) any testimony, conversations, or 26 | presentations by Parties or their Counsel that might reveal Protected Material. 27 28 aay ASH

1 Any use of Protected Material at trial shall be governed by a separate 2 | agreement or the orders of the trial judge. This Order does not govern the use of Protected Material at trial. 4 This order is intended to supplement the Court’s August 23, 2023 order that 5 | the parties proceed in the action under pseudonyms due to the highly confidential 6 | nature of the material that was distributed and the severity of the threatened harm of 7 | the existence of non-consensual pornography, which is attached hereto as Exhibit B. 8 | (ECF Docket No. 14.) 9 10} 4, DURATION Once a case proceeds to trial, information that was designated as 12, | CONFIDENTIAL or maintained pursuant to this protective order used or introduced as an exhibit at trial becomes public and will be presumptively available to all 14 | members of the public, including the press, unless compelling reasons supported by | specific factual findings to proceed otherwise are made to the trial judge in advance 16 | of the trial. See Kamakana,

(distinguishing “good cause” 17 | showing for sealing documents produced in discovery from “compelling reasons” 18 | standard when merits-related documents are part of the court record). Accordingly, 19 | the terms of this protective Order do not extend beyond the commencement of the 20 | trial for such exhibits so used or introduced at trial. 21 221 5, DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection: 24 | Each Party or Non-Party that designates information or items for protection under 25] this Order must take care to limit any such designation to specific material that 26 | qualifies under the appropriate standards. The Designating Party must designate for 27 | protection only those parts of material, documents, items or oral or written 28 || communications that qualify so that other portions of the material, documents, items, AA

! | or oral or written communications that qualify so that other portions of the material, 2 | documents, items, or communications for which protection is not warranted are not 3] swept unjustifiably within the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations 5 | that are shown to be clearly unjustified or that have been made for an improper 6 | purpose (e.g., to unnecessarily encumber the case development process or to impose 7 | unnecessary expenses and burdens on other parties) may expose the Designating 8 | Party to sanctions. ? If it comes to a Designating Party’s attention that information or items that it 10 | designated for protection do not qualify for protection, that Designating Party must | promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in 13 | this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 14 | stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 15 | under this Order must be clearly so designated before the material is disclosed or 16 | produced. 17 Designation in conformity with this Order requires: 18 (a) for information in documentary form (e.g., paper or electronic documents, 19 | but excluding transcripts of depositions or other pretrial or trial proceedings), that the 20 | Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 21 | “CONFIDENTIAL legend”), to each page that contains protected material. If only 22 | a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings 24 | in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 | need not designate them for protection until after the inspecting Party has indicated 27 | which documents it would like copied and produced. During the inspection and 28 | before the designation, all of the material made available for inspection shall be

! | deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 2 | it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing 4 | the specified documents, the Producing Party must affix the “CONFIDENTIAL > | legend” to each page that contains Protected Material. If only a portion of the material 6 | ona page qualifies for protection, the Producing Party also must clearly identify the 7 | protected portion(s) (e.g., by making appropriate markings in the margins). 8 (b) for testimony given in depositions that the Designating Party identifies the 9 | Disclosure or Discovery Material on the record, before the close of the deposition all 10 | protected testimony. MI (c) for information produced in some form other than documentary and for 12 | any other tangible items, that the Producing Party affix in a prominent place on the 13] exterior of the container or containers in which the information is stored the legend 14 | “CONFIDENTIAL.” If only a portion or portions of the information warrants 15 | protection, the Producing Party, to the extent practicable, shall identify the protected 16 | portion(s). 17 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 | failure to designate qualified information or items does not, standing alone, waive 19 | the Designating Party’s right to secure protection under this Order for such material. 20 | Upon timely correction of a designation, the Receiving Party must make reasonable 21 | efforts to assure that the material is treated in accordance with the provisions of this 22 Order. 23 4! 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. Unless a prompt challenge to a Designating Party’s confidentiality 28 || designation is necessary to avoid foreseeable, substantial unfairness, unnecessary

! | economic burdens, or a significant disruption or delay of the litigation, a Party does 2 | not waive its right to challenge a confidentiality designation by electing not to mount 3 | achallenge promptly after the original designation is disclosed. 4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute > | resolution process under Local Rule 37.1 et seq. 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 purpose 8 | (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 9 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 10 | or withdrawn the confidentiality designation, all parties shall continue to afford the 11 | material in question the level of protection to which it is entitled under the Producing 12 | Party’s designation until the Court rules on the challenge. 13 ay 7, ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that is 16 | disclosed or produced by another Party or by a Non-Party in connection with this 17 | Action only for prosecuting, defending, or attempting to settle this Action. Such 18 | Protected Material may be disclosed only to the categories of persons and under the 19 | conditions described in this Order. When the Action has been terminated, a 20 | Receiving Party must comply with the provisions of section 13 below (FINAL 21 | DISPOSITION). 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 Order. 25 7.2 Disclosure _of “CONFIDENTIAL” Information or Items. Unless 26 | otherwise ordered by the court or permitted in writing by the Designating Party, a 27 | Receiving Party may disclose any information or item designated 28 | “CONFIDENTIAL.” only to: aS □□ ____—_—_—

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 | employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 | disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the 5 | Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 | disclosure is reasonably necessary for this Action and who have signed the 8 | “Acknowledgment and Agreement to Be Bound” (Exhibit A); ? (d) the court and its personnel; 10 (e) court reporters and their staff; (f) professional jury or trial consultants, mock jurors, and Professional 12 | Vendors to whom disclosure is reasonably necessary for this Action and who have 13] signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 | Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 | requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 19 | not be permitted to keep any confidential information unless they sign the 20 | “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 21 | agreed by the Designating Party or ordered by the court. Pages of transcribed 22 | deposition testimony or exhibits to depositions that reveal Protected Material may be 23 || separately bound by the court reporter and may not be disclosed to anyone except as 24 | permitted under this Stipulated Protective Order; and 23 | (i) any mediator or settlement officer, and their supporting personnel, mutually 26 || agreed upon by any of the parties engaged in settlement discussions. 27 28

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 > | “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 | include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 | issue in the other litigation that some or all of the material covered by the subpoena 10 | or order is subject to this Protective Order. Such notification shall include a copy of 11 | this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 | by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with 15 | the subpoena or court order shall not produce any information designated in this 16 | action as “CONFIDENTIAL” before a determination by the court from which the 17 | 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 2! | 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 (a) The terms of this Order are applicable to information produced by a Non- 26 | Party in this Action and designated as “CONFIDENTIAL.” Such information 27 | produced by Non-Parties in connection with this litigation is protected by the 28

! | remedies and relief provided by this Order. Nothing in these provisions should be 2 | construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 | produce a Non-Party’s confidential information in its possession, and the Party is > | subject to an agreement with the Non-Party not to produce the Non-Party’s 6 | confidential information, then the Party shall: 7 (1) 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 agreement 9 | with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated '1 | Protective Order in this Action, the relevant discovery request(s), and a reasonably | snecific description of the information requested; and 13 (3) make the information requested available for inspection by the Non- 14 | Party, if requested. 15 (c) If the Non-Party fails to object or seek a protective order from this court 16 | within 14 days of receiving the notice and accompanying information, the Receiving 17 | Party may produce the Non-Party’s confidential information responsive to the 18 | discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 | Party shall not produce any information in its possession or control that is subject to 20 | the confidentiality agreement with the Non-Party before a determination by the court. 2! | Absent a court order to the contrary, the Non-Party shall bear the burden and expense 22 | of seeking protection in this court of its Protected Material. 23 24! 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 | Protected Material to any person or in any circumstance not authorized under this 27 | Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

! | to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 | persons to whom unauthorized disclosures were made of all the terms of this Order, 3 | and (d) request such person or persons to execute the “Acknowledgment and 4 | Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6] 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 | PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 | inadvertently produced material is subject to a claim of privilege or other protection, 10 | the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 | Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 | may be established in an e-discovery order that provides for production without prior 13 | privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 | parties reach an agreement on the effect of disclosure of a communication or 15 | information covered by the attorney-client privilege or work product protection, the 16 | parties may incorporate their agreement in the stipulated protective order submitted 17 | to the court. 18 19 112. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 | person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, no Party waives any right it otherwise would have to object to 24 | disclosing or producing any information or item on any ground not addressed in this 25 | Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 | ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may

! | 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 60 8 | days of a written request by the Designating Party, each Receiving Party must return 9 | all Protected Material to the Producing Party or destroy such material. As used in this 10 | subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 | summaries, and any other format reproducing or capturing any of the Protected 12 | Material. Whether the Protected Material is returned or destroyed, the Receiving 13 | Party must submit a written certification to the Producing Party (and, if not the same 14 | person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 15 | (by category, where appropriate) all the Protected Material that was returned or 16 | destroyed and (2) affirms that the Receiving Party has not retained any copies, | abstracts, compilations, summaries or any other format reproducing or capturing any 18 | of the Protected Material. Notwithstanding this provision, Counsel and parties 19 | appearing pro se are entitled to retain an archival copy of all pleadings, motion 20 | papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 2! | deposition and trial exhibits, expert reports, attorney work product, and consultant 22 | and expert work product, even if such materials contain Protected Material. Any 23] such archival copies that contain or constitute Protected Material remain subject to 24 | this Protective Order as set forth in Section 4 (DURATION). 25 26] 14. VIOLATION 27 Any violation of this Order may be punished by appropriate measures 28 | including, without limitation, contempt proceedings and/or monetary sanctions.

l 2 | ITIS SO STIPULATED. 3 4 | DATED: /s/- Alexander M. Kargher 5 ALEXANDER M. KARGHER LARA M. KRUSKA 6 SAMANTHA J. ACEVES 7 Attorneys for Plaintiff JOHN SMITH 8 DATED: /s/- Jane Doe JANE DOE 10 In Propria Persona 11 12 | DATED: /s/- J. David Nick J. DAVID NICK 13 Attorneys for Defendant B.F. 14 1s | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 16 17 | DATED: ___2/6/2025 Razelis Qa. OC. HON. ROZELLA A. OLIVER 18 United States Magistrate Judge 19 20 21 22 23 24 25 26 27 28 $$

EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 L [print or type full name], of 5 [print or type full address], declare under penalty of perjury that 6 | I have read in its entirety and understand the Stipulated Protective Order that was 7 | issued by the United States District Court for the Central District of California on 8 | [date] in the case of John Smith v. Jane Doe, et al., Case No. 2:23-cv-05033-WLH- 9 | RAO. I agree to comply with and to be bound by all the terms of this Stipulated 10 | Protective Order and I understand and acknowledge that failure to so comply could 11 | expose me to sanctions and punishment in the nature of contempt. I solemnly promise 12 | that I will not disclose in any manner any information or item that is subject to this 13 | Stipulated Protective Order to any person or entity except in strict compliance with | the provisions of this Order. 15 | I further agree to submit to the jurisdiction of the United States District Court for the 16 | Central District of California for enforcing the terms of this Stipulated Protective 17 | Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint [print or type full name] of 19 [print or type full address and 20 | telephone number] as my California agent for service of process in connection with 21 | this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23! Date: 24 | City and State where sworn and signed: 25 26 | Printed name: 27 28 | Signature: IT