L||INOSRATILAW A PROFESSIONAL LAW CORPORATION 2 || OMID NOsR ATL! 6350) CHRISTINE HARMANDAYAN (320999) 3 || LOVELEEN DHOTE (35668 1) 1801 Century Park East, Suite 840 4 || Los Angeles, California 90067 Telephone: Go) 553-5630 5 || Facsimile: (310) 553-5691 Email: [email protected] 6 || Email: [email protected] 7 || Attorneys for Plaintiff JUAN GARCIA 8 9 || WILSON TURNER KOSMO LLP DANIEL C. GUNNING C9960) 10 || STEPHANIE D. TORRE C1 6022) 402 West Broadway, Suite 1600 11 || San Diego, California 92101 Telephone: (619) 236-9600 12 Facsimile: (619) 236-9669 E-mail: [email protected] 13 || E-mail: [email protected] 14 || Attorneys for Defendant AT&T MOBILITY SERVICES LLC 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 || JUAN GARCIA, an individual,, Case No. 2:25-cv-05834 MEMF (MAAx) 19 Plaintiff, STIPULATION AND PROPOSED PROTECTIVE ORDER 20 V. Judge: Maame Ewusi—Mensah Frimpong 21 || AT&T MOBILITY SERVICES LLC, a Courtroom: 8B, 8th Floor Delaware corporation; and DOES 22 || through , inclusive, Magistrate: Maria A. Audero Courtroom: 880, 8th Floor 23 Defendants. Trial Date: Not Set 24 Complaint Filed: Mav 30. 2025 25 26 1. PURPOSES AND LIMITATIONS 27 Discovery in this action is likely to involve production of confidential, 28 || proprietary or private information for which special protection from public disclosure -l-__ Case No. 2:25-cv-05834 MEMF (MAAx)

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

, 1176 (9th Cir. 2006), Phillips v. Gen. 12 Motors Corp.,

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

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

(9th Cir. 2010). For each 25 item or type of information, document, or thing sought to be filed or introduced under 26 seal, the party seeking protection must articulate compelling reasons, supported by 27 specific facts and legal justification, for the requested sealing order. Again, competent 28 1 evidence supporting the application to file documents under seal must be provided by 2 declaration. 3 Any document that is not confidential, privileged, or otherwise protectable in its 4 entirety will not be filed under seal if the confidential portions can be redacted. If 5 documents can be redacted, then a redacted version for public viewing, omitting only 6 the confidential, privileged, or otherwise protectable portions of the document, shall 7 be filed. Any application that seeks to file documents under seal in their entirety 8 should include an explanation of why redaction is not feasible. 9 4. DEFINITIONS 10 4.1 Action: This pending federal lawsuit entitled Juan Garcia v. AT&T 11 Mobility Services LLC, Case No. 2:25-cv-05834 MEMF (MAAx). 12 4.2 Challenging Party: a Party or Non-Party that challenges the designation 13 of information or items under this Order. 14 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for protection 16 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 17 Cause Statement. 18 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 19 support staff). 20 4.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 4.6 Disclosure or Discovery Material: all items or information, regardless of 24 the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery. 27 28 1 4.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 expert witness or as a consultant in this Action. 4 4.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 5 this Action, with or without prejudice; and (2) final judgment herein after the 6 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 7 this Action, including the time limits for filing any motions or applications for 8 extension of time pursuant to applicable law. 9 4.9 House Counsel: attorneys who are employees of a party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 4.10 Non-Party: any natural person, partnership, corporation, association or 13 other legal entity not named as a Party to this action. 14 4.11 Outside Counsel of Record: attorneys who are not employees of a party 15 to this Action but are retained to represent a party to this Action and have appeared in 16 this Action on behalf of that party or are affiliated with a law firm that has appeared 17 on behalf of that party, and includes support staff. 18 4.12 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staffs). 21 4.13 Producing Party: a Party or Non-Party that produces Disclosure or 22 Discovery Material in this Action. 23 4.14 Professional Vendors: persons or entities that provide litigation support 24 services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 4.15 Protected Material: any Disclosure or Discovery Material that is 28 designated as “CONFIDENTIAL.” 1 4.16 Receiving Party: a Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 5. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or extracted 6 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 7 Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the trial 10 judge and other applicable authorities. This Order does not govern the use of Protected 11 Material at trial. 12 6. DURATION 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15 as an exhibit at trial becomes public and will be presumptively available to all 16 members of the public, including the press, unless compelling reasons supported by 17 specific factual findings to proceed otherwise are made to the trial judge in advance of 18 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing 19 for sealing documents produced in discovery from “compelling reasons” standard 20 when merits-related documents are part of court record). Accordingly, the terms of 21 this protective order do not extend beyond the commencement of the trial. 22 Even after Final Disposition of this litigation, the confidentiality obligations 23 imposed by this Stipulated Protective Order shall remain in effect until a Designating 24 Party agrees otherwise in writing or a court order otherwise directs. 25 7. DESIGNATING PROTECTED MATERIAL 26 7.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under this 28 Order must take care to limit any such designation to specific material that qualifies 1 under the appropriate standards. The Designating Party must designate for protection 2 only those parts of material, documents, items or oral or written communications that 3 qualify so that other portions of the material, documents, items or communications for 4 which protection is not warranted are not swept unjustifiably within the ambit of this 5 Order. 6 Mass, indiscriminate or routinized designations are prohibited. Designations 7 that are shown to be clearly unjustified or that have been made for an improper 8 purpose (e.g., to unnecessarily encumber the case development process or to impose 9 unnecessary expenses and burdens on other parties) may expose the Designating Party 10 to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it 12 designated for protection do not qualify for protection, that Designating Party must 13 promptly notify all other Parties that it is withdrawing the inapplicable designation. 14 7.2 Manner and Timing of Designations. Except as otherwise provided in 15 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 16 qualifies for protection under this Order must be clearly so designated before the 17 material is disclosed or produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic documents, 20 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 21 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 22 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 23 portion of the material on a page qualifies for protection, the Producing Party also 24 must clearly identify the protected portion(s) (e.g., by making appropriate markings in 25 the margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 28 which documents it would like copied and produced. During the inspection and before 1 the designation, all of the material made available for inspection shall be deemed 2 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 3 copied and produced, the Producing Party must determine which documents, or 4 portions thereof, qualify for protection under this Order. Then, before producing the 5 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 6 to each page that contains Protected Material. If only a portion of the material on a 7 page qualifies for protection, the Producing Party also must clearly identify the 8 protected portion(s) (e.g., by making appropriate markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identifies the 10 Disclosure or Discovery Material on the record, before the close of the deposition all 11 protected testimony. 12 (c) for information produced in some form other than documentary and for any 13 other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive the 20 Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 8.1. 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. 28 1 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process, which shall comply with Local Rule 37.1 et seq., and with Section 3 4 of Judge Audero’s Procedures (“Mandatory Telephonic Conference for Discovery 4 Disputes’’).1 5 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 6 joint stipulation pursuant to Local Rule 37-2. 7 8.4 Burden of Persuasion. The burden of persuasion in any such challenge 8 proceeding shall be on the Designating Party. Frivolous challenges, and those made 9 for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens 10 on other parties) may expose the Challenging Party to sanctions. Unless the 11 Designating Party has waived or withdrawn the confidentiality designation, all parties 12 shall continue to afford the material in question the level of protection to which it is 13 entitled under the Producing Party’s designation until the Court rules on the challenge. 14 9. ACCESS TO AND USE OF PROTECTED MATERIAL 15 9.1 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 Receiving 20 Party must comply with the provisions of section 15 below (FINAL DISPOSITION) 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 25 otherwise ordered by the court or permitted in writing by the Designating Party, a 26 27 1 Judge Audero’s Procedures are available at 28 1 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 2 only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 4 employees of said Outside Counsel of Record to whom it is reasonably necessary to 5 disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 9 is reasonably necessary for this Action and who have signed the “Acknowledgment 10 and Agreement to Be Bound” (Exhibit A) 11 (d) the court and its personnel; 12 (e) court reporters and their staff; 13 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 14 to whom disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, witnesses, and attorneys for witnesses, in the 19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 20 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 21 not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 23 by the Designating Party or ordered by the court. Pages of transcribed deposition 24 testimony or exhibits to depositions that reveal Protected Material may be separately 25 bound by the court reporter and may not be disclosed to anyone except as permitted 26 under this Stipulated Protective Order; and 27 (i) any mediators or settlement officers and their supporting personnel, mutually 28 agreed upon by any of the parties engaged in settlement discussions. 1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 2 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 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 or 10 order is subject to this Protective Order. Such notification shall include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued by 13 the Designating Party whose Protected Material may be affected. If the Designating 14 Party timely seeks a protective order, the Party served with the subpoena or court 15 order shall not produce any information designated in this action as 16 “CONFIDENTIAL” before a determination by the court from which the subpoena or 17 order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party shall bear the burden and expense of seeking protection in that 19 court of its confidential material and nothing in these provisions should be construed 20 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 directive from another court. 22 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 23 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this Action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the 27 remedies and relief provided by this Order. Nothing in these provisions should be 28 construed as prohibiting a Non-Party from seeking additional protections. 1 (b) In the event that a Party is required, by a valid discovery request, to produce 2 a Non-Party’s confidential information in its possession, and the Party is subject to an 3 agreement with the Non-Party not to produce the Non-Party’s confidential 4 information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a 10 reasonably specific description of the information requested; and 11 (3) make the information requested available for inspection by the Non- 12 Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 14 days of receiving the notice and accompanying information, the Receiving Party may 15 produce the Non-Party’s confidential information responsive to the discovery request. 16 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 17 any information in its possession or control that is subject to the confidentiality 18 agreement with the Non-Party before a determination by the court. Absent a court 19 order to the contrary, the Non-Party shall bear the burden and expense of seeking 20 protection in this court of its Protected Material. 21 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 26 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 27 persons to whom unauthorized disclosures were made of all the terms of this Order, 28 1 and (d) request such person or persons to execute the “Acknowledgment an 2 Agreement to Be Bound” attached hereto as Exhibit A. 3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 4 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil\ 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work product protection, the 13 parties may incorporate their agreement in the stipulated protective order submitted to 14 the court. 15 14. MISCELLANEOUS 16 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 14.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order, no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 14.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material. If a Party’s request to file Protected Material under seal is 27 denied by the court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the court. 1 15. FINAL DISPOSITION 2 After the Final Disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 16 attorney work product, and consultant and expert work product, even if such materials 17 contain Protected Material. Any such archival copies that contain or constitute 18 Protected Material remain subject to this Protective Order as set forth in Section 6 19 (DURATION). 20 /// 21 /// 22 /// 23 // 24 /// 25 /// 26 /// 27 /// 28 /// 1 16. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 Dated: September 5, 2025 N O S R A T I L A W

6 By: /s/ Loveleen Dhote 7 OMID NOSRATI CHRISTINE HARMANDAYAN 8 LOVELEEN DHOTE Attorneys for Plaintiff 9 JUAN GARCIA

10 Dated: September 5, 2025 WILSON TURNER KOSMO LLP

11 By: /s/ Stephanie Torres 12 DANIEL C. GUNNING

STEPHANIE D. TORRES 13 Attorneys for Defendant AT&T MOBILITY SERVICES LLC 14 15 ATTESTATION 16 Pursuant to Local Civil Rule 5-4.3.4(a)(2)(i), all signatories listed, and on 17 whose behalf the filing is submitted, concur in the filing’s content and have authorized 18 the filing. 19 Dated: September 5, 2025 /s/ Stephanie Torres Stephanie D. Torres 20 21 22 23 24 25 26 27 28 1 ORDER 2 FOR GOOD CAUSE SHOWN, IT IS i ORDERED. 3 wey 4 || Dated: 09/11/2025 i wt 5 HONO ARIA A. AUDERO

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -16-__ Case No. 2:25-cv-05834 MEMF (MAAx)

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I have 5 read in its entirety and understand the Stipulated Protective Order that was issued by 6 the United States District Court for the Central District of California on [date] 7 in the case of Juan Garcia v. AT&T Mobility Services LLC, et. al.; 8 Case No. 2:25-cv-05834 MEMF (MAAx). I agree to comply with and to be bound by 9 all 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 nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity except 13 in strict compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint [full name] of 18 [address and telephone number] as my California 19 agent for service of process in connection with this action or any proceedings related 20 to enforcement of this Stipulated Protective Order. 21 22 Signature: 23 Printed Name: 24 Date: 25 City and State Where Sworn and Signed: 26 27 28