] 3 5 6 UNITED STATES DISTRICT COURT 7 FOR THE EASTERN DISTRICT OF CALIFORNIA ° ROBERT BURNHAM, et al., Case No. 2:24-cv-03298-DC-CSK " Plaintiffs, ORDER GRANTING MODIFIED 11 STIPULATED PROTECTIVE ORDER 12 (ECF No .30) FORTRESS NORTH AMERICA, 13 || L.L.C., et al., 14 Defendants. 15 16 The Court has reviewed the parties’ stipulated protective order below (ECF No. 17 || 30), and finds it comports with the relevant authorities and the Court’s Local Rule. See 18 || L.R. 141.1. The Court APPROVES the protective order, subject to the following 19 || clarification. 20 The Court’s Local Rules indicate that once an action is closed, it “will not retain 21 || jurisdiction over enforcement of the terms of any protective order filed in that action.” L.R. 22 || 141.1(f); see Bylin Heating Sys., Inc. v. Thermal Techs., Inc.,

, at *2 23 || (E.D. Cal. Oct. 29, 2012) (noting that courts in the district generally do not retain 24 || jurisdiction for disputes concerning protective orders after closure of the case). Thus, the 25 || Court will not retain jurisdiction over this protective order once the case is closed. 26 || Dated: October 6, 2025 27 Ch Spo \ GHI 500 KIM 28 |} 4 burns298.24 UNITED STATES MAGISTRATE JUDGE

1 DOWNEY BRAND LLP MEGHAN M. BAKER (Bar No. 243765) 2 [email protected] ALEXANDRA K. LAFOUNTAIN (Bar No. 301003) 3 [email protected] 621 Capitol Mall, 18th Floor 4 Sacramento, California 95814 Telephone: 916.444.1000 5 Facsimile: 916.444.2100

6 Attorneys for Plaintiffs ROBERT BURNHAM and SIERRA NEVADA CONSULTING, INC. 7 TORY E. GRIFFIN (Bar No. 186181) 8 AVALON JOHNSON FITZGERALD (Bar No. 288167) REYNOLDS TILBURY WOODWARD LLP 9 11601 Blocker Drive, Ste. 105 Auburn, CA 95603 10 Phone: (530) 885-8500 Fax: (530) 885-8113 11 Email: [email protected]

12 JAMES F. BENNETT (MO BAR NO. 46826, Pro Hac Vice) REBECCA MCLAUGHLIN (MO BAR. NO. 71969, Pro Hac Vice) 13 DOWD BENNETT LLP 7676 Forsyth Blvd., Suite 1900 14 St. Louis, MO 63105 Phone: (314) 889-7300 15 Email: [email protected] Email: [email protected] 16 Attorneys for Defendants Fortress North America, LLC, and 17 Compass Minerals International, Inc. 18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION 20 ROBERT BURNHAM; SIERRA NEVADA Case No. 2:24-cv-03298-DC-CSK CONSULTING, INC., a Nevada corporation, 21 Related Case No: 2:24-cv-03297-DC-CSK Plaintiffs, 22 v. STIPULATED PROTECTIVE ORDER 23 FORTRESS NORTH AMERICA, LLC, a 24 California limited liability company, COMPASS MINERALS INTERNATIONAL, 25 INC., a Delaware corporation, and DOES - 10, inclusive, 26 Defendants. 27 1 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Disclosure and discovery activity in this action are likely to involve production of 4 confidential, proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated 7 Protective Order. The parties acknowledge that this Order does not confer blanket protections on 8 all disclosures or responses to discovery and that the protection it affords from public disclosure 9 and use extends only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, 11 below, that this Stipulated Protective Order does not entitle them to file confidential information 12 under seal; Local Rule 141 sets forth the procedures that must be followed and the standards that 13 will be applied when a party seeks permission from the court to file material under seal. 14 1.2 GOOD CAUSE STATEMENT 15 This action is likely to involve confidential documents relating to private employment 16 records, personnel file documents, sensitive health and medical information, financial records, and 17 personal identifying information of parties and third-party witnesses (i.e., addresses, telephone 18 numbers) for which special protection from public disclosure and from use for any purpose other 19 than prosecution of this action is not warranted. Such private, confidential, and proprietary 20 materials and information consist of, among other things, documents produced in connection with 21 employee records, personnel file information, health and medical information, personal identifying 22 information of any party or third-party witnesses otherwise generally unavailable to the public, 23 private financial information, confidential corporate records, and other information that may be 24 privileged or otherwise protected from disclosure under state or federal statutes, court rules, case 25 decisions, or common law. 26 Without a Protective Order, uncontrolled disclosure of the above-identified categories of 27 materials would result in harm, including invasion of the privacy interests of the parties and non- 1 and non-parties, including but not limited to private employment records, private health and 2 medical information, private financial information, and private contact information. There is good 3 cause and a particularized need for a Protective Order to preserve the interests of confidentiality 4 and privacy in employment and personnel records, health and medical records, private and internal 5 corporate records, sensitive financial information, and the personal identifying information of 6 parties and third-party witnesses. Accordingly, to expedite the flow of information, to facilitate the 7 prompt resolution of disputes over confidentiality of discovery materials, to adequately protect 8 information the parties are entitled to keep confidential, to ensure that the parties are permitted 9 reasonably necessary uses of such material in preparation for and in the conduct of trial, to address 10 their handling at the end of the litigation, and serve the ends of justice, a protective order for such 11 information is justified in this matter. 12 It is the intent of the parties that information will not be designated as confidential for 13 tactical reasons and that nothing be so designated without a good faith belief that it has been 14 maintained in a confidential, non-public manner, and there is good cause why it should not be part 15 of the public record in this case. The parties therefore stipulate that there is Good Cause for, and 16 hereby jointly request that the honorable Court issue and enter, a Protective Order regarding 17 confidential documents consistent with the terms and provisions of this Stipulation. 18 2. DEFINITIONS 19 2.1 Challenging Party: a Party or Non-Party that challenges the designation of 20 information or items under this Order. 21 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 22 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule 23 of Civil Procedure 26(c). Pursuant to Local Rule 141.1(c)(1), the parties identify the following 24 types of information they believe to be eligible for protection under this Order: (i) personnel files, 25 (ii) employment records, (iii) investigation records and other documents relating to employee and 26 personnel issues, (iv) personal health and medical information, (v) personal information of the 27 parties in this litigation or of non-parties, including but not limited to, social security numbers, 1 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as 2 well as their support staff). 3 2.4 Designating Party: a Party or Non-Party that designates information or items that it 4 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 5 2.5 Disclosure or Discovery Material: all items or information, regardless of the 6 medium or manner in which it is generated, stored, or maintained (including, among other things, 7 testimony, transcripts, and tangible things), that are produced or generated in disclosures or 8 responses to discovery in this matter. 9 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to 10 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 11 consultant in this action. 12 2.7 House Counsel: attorneys who are employees of a party to this action. House 13 Counsel does not include Outside Counsel of Record or any other outside counsel. 14 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 15 entity not named as a Party to this action. 16 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this 17 action but are retained to represent or advise a party to this action and have appeared in this action 18 on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 19 2.10 Party: any party to this action, including all of its officers, directors, employees, 20 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 21 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 22 Material in this action. 23 2.12 Professional Vendors: persons or entities that provide litigation support services 24 (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and 25 organizing, storing, or retrieving data in any form or medium) and their employees and 26 subcontractors. 27 2.13 Protected Material: any Disclosure or Discovery Material that is designated as 1 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 2 Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only Protected Material 5 (as defined above), but also (1) any information copied or extracted from Protected Material; (2) 6 all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 7 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 8 However, the protections conferred by this Stipulation and Order do not cover the following 9 information: (a) any information that is in the public domain at the time of disclosure to a 10 Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a 11 result of publication not involving a violation of this Order, including becoming part of the public 12 record through trial or otherwise; and (b) any information known to the Receiving Party prior to 13 the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained 14 the information lawfully and under no obligation of confidentiality to the Designating Party. Any 15 use of Protected Material at trial shall be governed by a separate agreement or order. 16 4. DURATION 17 Even after final disposition of this litigation, the confidentiality obligations imposed by 18 this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 19 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all 20 claims and defenses in this action, with or without prejudice; and (2) final judgment herein after 21 the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 22 including the time limits for filing any motions or applications for extension of time pursuant to 23 applicable law. 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party 26 or Non-Party that designates information or items for protection under this Order must take care to 27 limit any such designation to specific material that qualifies under the appropriate standards. The 1 oral or written communications that qualify – so that other portions of the material, documents, 2 items, or communications for which protection is not warranted are not swept unjustifiably within 3 the ambit of this Order. 4 Mass, indiscriminate, or routinized designations are prohibited. Designations that are 5 shown to be clearly unjustified or that have been made for an improper purpose (e.g., to 6 unnecessarily encumber or retard the case development process or to impose unnecessary 7 expenses and burdens on other parties) expose the Designating Party to sanctions. 8 It is anticipated that the Parties may produce Discovery Material related to certain vehicles, 9 equipment and other property at-issue in this action. The Parties agree not to designate Disclosure 10 or Discovery Material relating to this disputed property as “CONFIDENTIAL” unless the 11 Designating Party has a good-faith belief that the Disclosure or Discovery Material (1) is a record 12 of the Designating Party (opposed to the Receiving Party), and (2) qualifies for special protection 13 from public disclosure and from use for any purpose other than prosecution of this action pursuant 14 to Federal Rule of Civil Procedure 26, subdivision (c). If it comes to a Designating Party’s 15 attention that information or items that it designated for protection do not qualify for protection, 16 that Designating Party must promptly notify all other Parties that it is withdrawing the mistaken 17 designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order 19 (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, 20 Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 21 designated before the material is disclosed or produced. 22 Designation in conformity with this Order requires: 23 (a) For information in documentary form (e.g., paper or electronic documents, but 24 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 25 affix the legend “CONFIDENTIAL” to each page that contains protected material. 26 A Party or Non-Party that makes original documents or materials available for 27 inspection need not designate them for protection until after the inspecting Party has indicated 1 designation, all of the material made available for inspection shall be deemed 2 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and 3 produced, the Producing Party must determine which documents, or portions thereof, qualify for 4 protection under this Order. Then, before producing the specified documents, the Producing Party 5 must affix the “CONFIDENTIAL” legend to each page that contains Protected Material. 6 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 7 Designating Party identify on the record, before the close of the deposition, hearing, or other 8 proceeding, all protected testimony, with an exception that the Parties retain the right to designate 9 confidential material in a deposition thirty (30) days after the final deposition transcript is made 10 available. 11 (c) for information produced in some form other than documentary and for any other 12 tangible items, that the Producing Party affix in a prominent place on the exterior of the container 13 or containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a 14 portion or portions of the information or item warrant protection, the Producing Party, to the 15 extent practicable, shall identify the protected portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 17 designate qualified information or items does not, standing alone, waive the Designating Party’s 18 right to secure protection under this Order for such material. Upon timely correction of a 19 designation, the Receiving Party must make reasonable efforts to assure the Producing Party that 20 the material is treated in accordance with the provisions of this Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 23 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 24 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic 25 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 26 challenge a confidentiality designation by electing not to mount a challenge promptly after the 27 original designation is disclosed. 1 process by providing written notice of each designation it is challenging and describing the basis 2 for each challenge. To avoid ambiguity as to whether a challenge has been made, the written 3 notice must recite that the challenge to confidentiality is being made in accordance with this 4 specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in 5 good faith and must begin the process by conferring directly (in voice to voice dialogue; other 6 forms of communication are not sufficient) within 14 days of the date of service of notice. In 7 conferring, the Challenging Party must explain the basis for its belief that the confidentiality 8 designation was not proper and must give the Designating Party an opportunity to review the 9 designated material, to reconsider the circumstances, and, if no change in designation is offered, to 10 explain the basis for the chosen designation. A Challenging Party may proceed to the next stage of 11 the challenge process only if it has engaged in this meet and confer process first or establishes that 12 the Designating Party is unwilling to participate in the meet and confer process in a timely 13 manner. 14 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 15 intervention, the Designating Party shall file and serve a motion to retain confidentiality under 16 Local Rule 230 (and in compliance with Local Rule 141, if applicable) within 21 days of the 17 initial notice of challenge or within 14 days of the parties agreeing that the meet and confer 18 process will not resolve their dispute, whichever is earlier. Each such motion must be 19 accompanied by a competent declaration affirming that the movant has complied with the meet 20 and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to 21 make such a motion including the required declaration within 21 days (or 14 days, if applicable) 22 shall automatically waive the confidentiality designation for each challenged designation. In 23 addition, the Challenging Party may file a motion challenging a confidentiality designation at any 24 time if there is good cause for doing so, including a challenge to the designation of a deposition 25 transcript or any portions thereof. Any motion brought pursuant to this provision must be 26 accompanied by a competent declaration affirming that the movant has complied with the meet 27 and confer requirements imposed by the preceding paragraph. 1 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose 2 unnecessary expenses and burdens on other parties) may expose the Challenging Party to 3 sanctions. Unless the Designating Party has waived the confidentiality designation by failing to 4 file a motion to retain confidentiality as described above, all parties shall continue to afford the 5 material in question the level of protection to which it is entitled under the Producing Party’s 6 designation until the court rules on the challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 9 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 10 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 11 the categories of persons and under the conditions described in this Order. When the litigation has 12 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 13 DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a location and in 15 a secure manner that ensures that access is limited to the persons authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered 17 by the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 18 information or item designated “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 20 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 21 information for this litigation; 22 (b) the officers, directors, and employees (including House Counsel) of the Receiving 23 Party to whom disclosure is reasonably necessary for this litigation and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 26 reasonably necessary for this litigation and who have signed the “Acknowledgment and 27 Agreement to Be Bound” (Exhibit A); 1 (e) court reporters and their staff, professional jury or trial consultants, mock jurors, 2 and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who 3 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 5 necessary. Pages of transcribed deposition testimony or exhibits to depositions that reveal 6 Protected Material must be separately bound by the court reporter and may not be disclosed to 7 anyone except as permitted under this Stipulated Protective Order. 8 (g) the author or recipient of a document containing the information or a custodian or 9 other person who otherwise possessed or knew the information. 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 11 LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation that compels 13 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 14 must: 15 (a) promptly notify in writing the Designating Party. Such notification shall include a 16 copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to issue in 18 the other litigation that some or all of the material covered by the subpoena or order is subject to 19 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; 20 and 21 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 22 Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with the subpoena 24 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 25 before a determination by the court from which the subpoena or order issued, unless the Party has 26 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 27 expense of seeking protection in that court of its confidential material – and nothing in these 1 disobey a lawful directive from another court. 2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 3 LITIGATION 4 (a) The terms of this Order are applicable to information produced by a Non-Party in 5 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 6 connection with this litigation is protected by the remedies and relief provided by this Order. 7 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 8 additional protections. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 11 Material to any person or in any circumstance not authorized under this Stipulated Protective 12 Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the 13 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected 14 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the 15 terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and 16 Agreement to Be Bound” that is attached hereto as Exhibit A. 17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 18 MATERIAL 19 When a Producing Party gives notice to Receiving Parties that certain inadvertently 20 produced material is subject to a claim of privilege or other protection, the obligations of the 21 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 22 provision is not intended to modify whatever procedure may be established in an e-discovery order 23 that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 24 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a 25 communication or information covered by the attorney-client privilege or work product protection, 26 the parties may incorporate their agreement in the stipulated protective order submitted to the 27 court. 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to 3 seek its modification by the court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 5 Order no Party waives any right it otherwise would have to object to disclosing or producing any 6 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 7 Party waives any right to object on any ground to use in evidence of any of the material covered 8 by this Protective Order. 9 12.3 Filing Protected Material. Without written permission from the Designating Party 10 or a court order secured after appropriate notice to all interested persons, a Party may not file in 11 the public record in this action any Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Rule 141. Protected Material may only be filed under 13 seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. 14 Pursuant to Local Rule 141, a sealing order will issue only upon a request establishing that the 15 Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to 16 protection under the law. If a Receiving Party’s request to file Protected Material under seal 17 pursuant to Local Rule 141 is denied by the court, then the Receiving Party may file the 18 information in the public record unless otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 Within 60 days after the final disposition of this action, as defined in paragraph 4, each 21 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 22 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 23 summaries, and any other format reproducing or capturing any of the Protected Material. Whether 24 the Protected Material is returned or destroyed, the Receiving Party must submit a written 25 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) 26 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 27 Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained 1 of the Protected Material. Notwithstanding this provision, Outside Counsel are entitled to retain a 2 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 3 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 4 consultant and expert work product, even if such materials contain Protected Material. Any such 5 archival copies that contain or constitute Protected Material remain subject to this Protective Order 6 as set forth in Section 4 (DURATION). 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 DATED: September 25, 2025 DOWNEY BRAND LLP

10

11 By: /s/ Meghan M. Baker MEGHAN M. BAKER 12 ALEXANDRA K. LAFOUNTAIN Attorneys for Plaintiffs Robert Burnham 13 and Sierra Nevada Consulting, Inc.

14

15 16 DATED: September 25, 2025 DOWD BENNETT LLP

17 By: /s/ Rebecca R. McLaughlin 18 JAMES F. BENNETT 19 REBECCA R. McLAUGHLIN Attorneys for Defendants Fortress North America, 20 LLC, and Compass Minerals International, Inc.

21

22 23 24 25 26 27 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 Order that was 6 issued by the United States District Court for the Eastern District of California on 7 __________[date] in the case of Burnham, et al. v. Fortress North America LLC, et al., Case No. 8 2:24-cv-03298-DC-CSK. I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order and I understand and acknowledge that failure to so comply could 10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will 11 not disclose in any manner any information or item that is subject to this Stipulated Protective 12 Order to any person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the 14 Eastern District of California for the purpose of enforcing the terms of this Stipulated Protective 15 Order, even if such enforcement proceedings occur after termination of this action. 16 17 Date: 18 City and State where sworn and signed: _________________________________ 19 Printed name: _______________________________ 20 Signature: __________________________________ 21 22 23 24 25 26 27