1 A. Raymond Hamrick, III (State Bar No. 93821) [email protected] 2 Jonathan Dutton (State Bar No. 272781) [email protected] 3 HAMRICK & EVANS, LLP 2600 West Olive Avenue, Suite 1020 4 Burbank, California 91505 Telephone No.: (818) 763-5292 5 Facsimile No.: (818) 763-2308

6 Attorneys for Plaintiff NTS TECHNICAL SYSTEMS, LLC 7

8 Terrence R. McInnis (State Bar No. 155416) 9 [email protected] James A. Hazlehurst (State Bar No. 257711) 10 [email protected] TROUTMAN PEPPER LOCKE LLP 11 100 Spectrum Center Drive, Suite 1500 Irvine, California 92618 12 Telephone No.: (949) 622-2700 Facsimile No: (949) 622-2739 13 Attorneys for Defendant 14 EVANSTON INSURANCE COMPANY 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA 17

18 NTS TECHNICAL SYSTEMS, Case No. 2:23-cv-09927-CV-SSC

19 LLC, a California limited liability company, STIPULATED PROTECTIVE 20 Plaintiff(s), ORDER1 21 v.

22 EVANSTON INSURANCE COMPANY; and DOES 1 23 through 10, inclusive

24 Defendant(s). 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 Counsel: Outside Counsel of Record and House Counsel (as 7 well as their support staff). 8 2.5 Designating Party: a Party or Non-Party that designates 9 information or items that it produces in disclosures or in responses to 10 discovery as “CONFIDENTIAL.” 11 2.6 Disclosure or Discovery Material: all items or information, 12 regardless of the medium or manner in which it is generated, stored, or 13 maintained (including, among other things, testimony, transcripts, and 14 tangible things), that are produced or generated in disclosures or 15 responses to discovery in this matter. 16 2.7 Expert: a person with specialized knowledge or experience in 17 a matter pertinent to the litigation who has been retained by a Party or 18 its counsel to serve as an expert witness or as a consultant in this Action. 19 2.8 Final Disposition: the later of (1) dismissal of all claims and 20 defenses in this Action, with or without prejudice; and (2) final judgment 21 22 herein after the completion and exhaustion of all appeals, rehearings, 23 remands, trials, or reviews of this Action, including the time limits for 24 filing any motions or applications for extension of time pursuant to 25 applicable law. 26 2.9 In-House Counsel: attorneys who are employees of a party to 27 this Action or a party’s underwriting and claim service manager. In- 1 outside counsel. 2 2.10 Non-Party: any natural person, partnership, corporation, 3 association, or other legal entity not named as a Party to this action. 4 2.11 Outside Counsel of Record: attorneys who are not employees 5 of a party to this Action but are retained to represent or advise a party to 6 this Action and have appeared in this Action on behalf of that party or 7 are affiliated with a law firm which has appeared on behalf of that party, 8 and includes support staff. 9 2.12 Party: any party to this Action, including all of its officers, 10 directors, employees, consultants, retained experts, and Outside Counsel 11 of Record (and their support staffs). 12 2.13 Producing Party: a Party or Non-Party that produces 13 Disclosure or Discovery Material in this Action. 14 2.14 Professional Vendors: persons or entities that provide 15 litigation- support services (e.g., photocopying, videotaping, translating, 16 preparing exhibits or demonstrations, and organizing, storing, or 17 retrieving data in any form or medium) and their employees and 18 subcontractors. 19 2.15 Protected Material: any Disclosure or Discovery Material that 20 is designated as “CONFIDENTIAL.” 21 22 2.16 Receiving Party: a Party that receives Disclosure or Discovery 23 Material from a Producing Party. 24 25 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not 27 only Protected Material (as defined above), but also (1) any information 1 copied or extracted from Protected Material; (2) all copies, excerpts, 2 summaries, or compilations of Protected Material; and (3) any 3 testimony, conversations, or presentations by Parties or their Counsel 4 that might reveal Protected Material. 5 Any use of Protected Material at trial shall be governed by the 6 orders of the trial judge. This Stipulated Protective Order does not 7 govern the use of Protected Material at trial. 8

9 4. TRIAL AND DURATION 10 The terms of this Stipulated Protective Order apply through Final 11 Disposition of the Action. 12 Once a case proceeds to trial, information that was designated as 13 14 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 15 Order and used or introduced as an exhibit at trial becomes public and 16 will be presumptively available to all members of the public, including 17 the press, unless compelling reasons supported by specific factual 18 findings to proceed otherwise are made to the trial judge in advance of 19 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 20 cause” showing for sealing documents produced in discovery from 21 “compelling reasons” standard when merits-related documents are part 22 of court record). Accordingly, for such materials, the terms of this 23 Stipulated Protective Order do not extend beyond the commencement of 24 the trial. 25 Even after Final Disposition of this litigation, the confidentiality 26 obligations imposed by this Stipulated Protective Order shall remain in 27 effect until a Designating Party agrees otherwise in writing or a court 1 order otherwise directs. 2 5. DESIGNATING PROTECTED MATERIAL 3 5.1 Exercise of Restraint and Care in Designating Material for 4 Protection. Each Party or Non-Party that designates information or 5 items for protection under this Order must take care to limit any such 6 designation to specific material that qualifies under the appropriate 7 standards. The Designating Party must designate for protection only 8 those parts of material, documents, items, or oral or written 9 communications that qualify so that other portions of the material, 10 documents, items, or communications for which protection is not 11 warranted are not swept unjustifiably within the ambit of this Order. 12 Mass, indiscriminate, or routinized designations are prohibited. 13 Designations that are shown to be clearly unjustified or that have been 14 made for an improper purpose (e.g., to unnecessarily encumber the case 15 development process or to impose unnecessary expenses and burdens on 16 other parties) may expose the Designating Party to sanctions. 17 18 If it comes to a Designating Party’s attention that information or 19 items that it designated for protection do not qualify for protection, that 20 Designating Party must promptly notify all other Parties that it is 21 withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise 23 provided in this Stipulated Protective Order (see, e.g., second paragraph 24 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 25 or Discovery Material that qualifies for protection under this Stipulated 26 Protective Order must be clearly so designated before the material is 27 disclosed or produced. 1 Designation in conformity with this Stipulated Protective Order 2 requires: 3 (a) for information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other pretrial or 5 trial proceedings), that the Producing Party affix at a minimum, the 6 legend “CONFIDENTIAL” to each page that contains protected 7 material. If only a portion or portions of the material on a page 8 qualifies for protection, the Producing Party also must clearly identify 9 the protected portion(s) (e.g., by making appropriate markings in the 10 margins). 11 A Party or Non-Party that makes original documents available for 12 inspection need not designate them for protection until after the 13 inspecting Party has indicated which documents it would like copied 14 and produced. During the inspection and before the designation, all of 15 the material made available for inspection shall be deemed 16 CONFIDENTIAL. After the inspecting Party has identified the 17 documents it wants copied and produced, the Producing Party must 18 determine which documents, or portions thereof, qualify for protection 19 under this Stipulated Protective Order. Then, before producing the 20 21 specified documents, the Producing Party must affix the 22 “CONFIDENTIAL” legend to each page that contains Protected 23 Material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify 25 the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 (b) for testimony given in depositions that the Designating Party 1 close of the deposition all protected testimony or within 30 days of 2 receiving the deposition transcript by affixing the “CONFIDENTIAL” 3 legend to each page that contains Protected Material. 4 (c) for information produced in some form other than 5 documentary and for any other tangible items, that the Producing Party 6 affix in a prominent place on the exterior of the container or containers 7 in which the information is stored the “CONFIDENTIAL” legend. If only 8 a portion or portions of the information warrants protection, the 9 Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an 12 inadvertent failure to designate qualified information or items does not, 13 standing alone, waive the Designating Party’s right to secure protection 14 under this Order for such material. Upon timely correction of a 15 designation, the Receiving Party must make reasonable efforts to assure 16 that the material is treated in accordance with the provisions of this 17 18 Stipulated Protective Order. 19 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may 22 challenge a designation of confidentiality at any time that is consistent 23 with the court’s Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the 25 dispute resolution process under Local Rule 37.1 et seq. and with 26 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 27 1 Discovery Motion Conference.”2 2 6.3 The burden of persuasion in any such challenge proceeding 3 shall be on the Designating Party. Frivolous challenges, and those 4 made for an improper purpose (e.g., to harass or impose unnecessary 5 expenses and burdens on other parties) may expose the Challenging 6 Party to sanctions. Unless the Designating Party has waived or 7 withdrawn the confidentiality designation, all parties shall continue to 8 afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the court rules on 10 the challenge. 11

12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected 14 Material that is disclosed or produced by another Party or by a Non- 15 Party in connection with this Action only for prosecuting, defending, or 16 17 attempting to settle this Action. Such Protected Material may be 18 disclosed only to the categories of persons and under the conditions 19 described in this Order. When the Action reaches a Final Disposition, a 20 Receiving Party must comply with the provisions of section 13 below. 21 Protected Material must be stored and maintained by a Receiving 22 Party at a location and in a secure manner that ensures that access is 23 limited to the persons authorized under this Stipulated Protective 24 Order. 25 26

27 2 Judge Christensen’s Procedures are available at 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 2 Unless otherwise ordered by the court or permitted in writing by the 3 Designating Party, a Receiving Party may disclose any information or 4 item designated “CONFIDENTIAL” only: 5 (a) to the Receiving Party’s Outside Counsel of Record in this 6 Action, as well as employees of said Outside Counsel of Record to whom 7 it is reasonably necessary to disclose the information for this Action; 8 (b) to the officers, directors, and employees (including In-House 9 Counsel) of the Receiving Party to whom disclosure is reasonably 10 necessary for this Action; 11 (c) to Experts (as defined in this Order) of the Receiving Party to 12 whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) to the court and its personnel; 15 (e) to court reporters and their staff; 16 (f) to professional jury or trial consultants, mock jurors, and 17 Professional Vendors to whom disclosure is reasonably necessary for 18 this Action and who have signed the “Acknowledgment and Agreement 19 to Be Bound” (Exhibit A); 20 (g) to the author or recipient of a document containing the 21 22 information or a custodian or other person who otherwise possessed or 23 knew the information; 24 (h) during their depositions, to witnesses, and attorneys for 25 witnesses, in the Action to whom disclosure is reasonably necessary, 26 provided: (1) the deposing party requests that the witness sign the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 1 unless they sign the “Acknowledgment and Agreement to Be Bound” 2 (Exhibit A), unless otherwise agreed by the Designating Party or 3 ordered by the court. Pages of transcribed deposition testimony or 4 exhibits to depositions that reveal Protected Material may be separately 5 bound by the court reporter and may not be disclosed to anyone except 6 as permitted under this Stipulated Protective Order; 7 (i) to any mediator or settlement officer, and their supporting 8 personnel, mutually agreed upon by any of the parties engaged in 9 settlement discussions; 10 (j) insurers, reinsurers, third party claims administers or 11 managers for an insurer, and regulators; and 12 (k) any other person that the Designating Party agrees to in 13 writing. 14

15

16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in 19 other litigation that compels disclosure of any information or items 20 designated in this Action as “CONFIDENTIAL,” that Party must: 21 22 (a) promptly notify in writing the Designating Party. Such 23 notification shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the 25 subpoena or order to issue in the other litigation that some or all of the 26 material covered by the subpoena or order is subject to this Protective 27 Order. Such notification shall include a copy of this Stipulated 1 Protective Order; and 2 (c) cooperate with respect to all reasonable procedures sought to 3 be pursued by the Designating Party whose Protected Material may be 4 affected. 5 If the Designating Party timely seeks a protective order, the 6 Party served with the subpoena or court order shall not produce any 7 information designated in this action as “CONFIDENTIAL” before a 8 determination by the court from which the subpoena or order issued, 9 unless the Party has obtained the Designating Party’s permission. The 10 Designating Party shall bear the burden and expense of seeking 11 protection in that court of its confidential material and nothing in these 12 provisions should be construed as authorizing or encouraging a 13 Receiving Party in this Action to disobey a lawful directive from another 14 court. 15

16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 9.1 Application. The terms of this Stipulated Protective Order 19 are applicable to information produced by a Non-Party in this Action and 20 21 designated as “CONFIDENTIAL.” Such information produced by Non- 22 Parties in connection with this litigation is protected by the remedies 23 and relief provided by this Order. Nothing in these provisions should be 24 construed as prohibiting a Non-Party from seeking additional 25 protections. 26 9.2 Notification. In the event that a Party is required, by a valid 27 discovery request, to produce a Non-Party’s confidential information in 1 Party not to produce the Non-Party’s confidential information, then the 2 Party shall: 3 (a) promptly notify in writing the Requesting Party and the 4 Non-Party that some or all of the information requested is subject to a 5 confidentiality agreement with a Non-Party; 6 (b) make the information requested available for inspection by 7 the Non-Party, if requested. 8 9.3 Conditions of Production. If the Non-Party fails to seek a 9 protective order from this court within 14 days of receiving the notice 10 and accompanying information, the Receiving Party may produce the 11 Non-Party’s confidential information responsive to the discovery request. 12 If the Non-Party timely seeks a protective order, the Receiving Party 13 shall not produce any information in its possession or control that is 14 subject to the confidentiality agreement with the Non-Party before a 15 determination by the court. Absent a court order to the contrary, the 16 Non-Party shall bear the burden and expense of seeking protection in 17 this court of its Protected Material. 18

19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 20 21 MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it 23 has disclosed Protected Material to any person or in any circumstance 24 not authorized under this Stipulated Protective Order, the Receiving 25 Party must immediately (a) notify in writing the Designating Party of 26 the unauthorized disclosures, (b) use its best efforts to retrieve all 27 unauthorized copies of the Protected Material, (c) inform the person or 1 persons to whom unauthorized disclosures were made of all the terms of 2 this Order, and (d) request such person or persons to execute the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 5 OTHERWISE PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that 7 certain inadvertently produced material is subject to a claim of privilege 8 or other protection, the obligations of the Receiving Parties are those set 9 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 10 provision is not intended to modify whatever procedure may be 11 established in an e-discovery order that provides for production without 12 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 13 14 Rules of Evidence, insofar as the parties reach an agreement on the 15 effect of disclosure of a communication or information covered by the 16 attorney-client privilege or work product protection, the parties may 17 incorporate their agreement in the stipulated protective order 18 submitted to the court. 19 20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Stipulated 22 Protective Order abridges the right of any person to seek its 23 modification by the court in the future. 24 12.2 Right to Assert Other Objections. By stipulating to the entry 25 of this Stipulated Protective Order no Party waives any right it 26 otherwise would have to object to disclosing or producing any 27 1 Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this 3 Stipulated Protective Order. 4 12.3 Filing Protected Material. A Party that seeks to file under 5 seal any Protected Material must comply with Local Rule 79-5. 6 Protected Material may only be filed under seal pursuant to a court 7 order authorizing the sealing of the specific Protected Material at issue. 8 If a Party's request to file Protected Material under seal is denied by the 9 court, then the Receiving Party may file the information in the public 10 record unless otherwise instructed by the court. 11

12 13. FINAL DISPOSITION 13 After the Final Disposition of this Action, as defined in paragraph 14 4, within 60 days of a written request by the Designating Party, each 15 Receiving Party must return all Protected Material to the Producing 16 Party or destroy such material. As used in this subdivision, “all 17 18 Protected Material” includes all copies, abstracts, compilations, 19 summaries, and any other format reproducing or capturing any of the 20 Protected Material. Notwithstanding this provision, Counsel is entitled 21 to retain an archival copy of all pleadings, motion papers, trial, 22 deposition, and hearing transcripts, legal memoranda, correspondence, 23 deposition and trial exhibits, expert reports, attorney work product, and 24 consultant and expert work product, even if such materials contain 25 Protected Material. Any such archival copies that contain or constitute 26 Protected Material remain subject to this Protective Order as set forth 27 in Section 4. Notwithstanding this provision, to the extent any party is 1 required by law or regulation or document retention policies to retain 2 rather than return or destroy any Protected Material, that party shall 3 be permitted to retain such Protected Material without the need for a 4 Court order. A parties’ retention of such Protected Material is subject to 5 the terms of this Stipulated Protective Order. 6 14. VIOLATION 7 Any violation of this Stipulated Protective Order may be punished 8 by any and all appropriate measures including, without limitation, 9 contempt proceedings and/or monetary sanctions. 10 15. AGREEMENT TO BE BOUND BY THIS STIPULATION AND 11 PROTECTIVE ORDER PENDING ITS ENTRY BY THE 12 COURT 13 The Parties and all signatories to the Certification attached hereto as 14 Exhibit A agree to be bound by this Stipulation and Protective Order 15 pending its approval and entry by the Court. In the event that the Court 16 modifies this Stipulation and Protective Order, or in the event that the 17 Court enters a different Protective Order, the Parties agree to be bound 18 by this Stipulation and Protective Order until such time as the Court 19 20 may enter such a different Order. It is the Parties’ intent to be bound by 21 the terms of this Stipulation and Protective Order pending its entry so 22 as to allow for immediate production of Protected Materials under the 23 terms herein. 24 This Stipulation and Protective Order may be executed in 25 counterparts. 26 / / 27 / / 1 || // 2 | // 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

DATED: April 1, 2025 /s| A. Raymond Hamrick, IIT

6 Attorneys for Plaintiff, NTS TECHNICAL SYSTEMS, LLC 7 fred fe 9 DATED: April 2, 2025

10 Attorneys for Defendant, EVANSTON INSURANCE 11 COMPANY 12 3 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 14 15 DATED: April 8, 2025 Zz 16 STEPHANIE S. CHRISTENSEN United States Magistrate Judge 18 19 20 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], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on 8 _________________ [date] in the case of NTS Technical Systems, LLC 9 v. Evanston Insurance Company, et al., Case No. 2:23-cv-09927-CV- 10 SSC. 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 12 failure to so comply could expose me to sanctions and punishment in 13 14 the nature of contempt. I solemnly promise that I will not disclose in 15 any manner any information or item that is subject to this Stipulated 16 Protective Order to any person or entity except in strict compliance 17 with the provisions of this Order. 18 19 20 Date: ___________________________ 21 City and State where sworn and ___________________________ 22 signed: ___________________________ 23 Printed name: ___________________________ 24 Signature: ___________________________ 25

26 27