1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 WESTERN DIVISION

11

12 Case No. 2:21-cv-02840-AB-AJR 13 CLEVELAND CONSTANTINE

BROWNE, ET AL., [PROPOSED] STIPULATED

14 PROTECTIVE ORDER Plaintiffs, 15 v. 16 RODNEY SEBASTIAN CLARK, an individual, ET AL., 17

18 Defendants.

19 1. GENERAL 20 1.1 Purposes and Limitations. Discovery in this action is likely to involve 21 production of confidential, proprietary, or private information for which special 22 protection from public disclosure and from use for any purpose other than prosecuting 23 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 24 petition the Court to enter the following Stipulated Protective Order. The parties 25 acknowledge that this Order does not confer blanket protections on all disclosures or 26 responses to discovery and that the protection it affords from public disclosure and 27 use extends only to the limited information or items that are entitled to confidential 28 1 treatment under the applicable legal principles. The parties further acknowledge, as 2 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 3 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 4 procedures that must be followed and the standards that will be applied when a party 5 seeks permission from the court to file material under seal. 6 1.2 Good Cause Statement. 7 This copyright infringement action has been brought by Plaintiffs against over 8 160 defendants—including many large music companies and many celebrities—and 9 discovery is likely to involve trade secrets, commercial financial, technical and/or 10 proprietary information for which special protection from public disclosure and from 11 use for any purpose other than prosecution of this action is warranted. Such sensitive 12 commercial and personal information may include, without limitation, the terms of 13 confidential recording, publishing, artist, touring, and licensing agreements between 14 Defendants and third parties, proprietary materials and information consisting of, 15 among other things, confidential business or financial information, information 16 regarding confidential business practices, or other confidential research, 17 development, or commercial information (including information implicating privacy 18 rights of Defendants and third parties), financial information, and other proprietary 19 information generally unavailable to the public. Such information may be privileged 20 or otherwise protected from disclosure under state or federal statutes, court rules, case 21 decisions, or common law, and material or information that is subject to a written 22 independent obligation of confidentiality. Accordingly, to expedite discovery, to 23 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 24 to adequately protect information the parties are entitled or obligated to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of such 26 material in preparation for and in the conduct of trial, to address their handling at the 27 end of the litigation, and to serve the ends of justice, a protective order for such 28 information is justified in this matter. It is the intent of the parties that information 1 will not be designated as confidential for tactical reasons and that nothing will be so 2 designated without a good faith belief that it has been maintained in a confidential, 3 non-public manner, and that there is good cause why it should not be part of the public 4 record of this case. 5 2. DEFINITIONS 6 2.1 Action: this action, assigned Case No. 2:21-cv-02840-AB-AJR 7 (including all actions that have been consolidated therein). 8 2.2 Challenging Party: a Party or Non-Party that challenges the designation 9 of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 13 Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 15 support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced or 22 generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 an expert witness or as a consultant in this Action. 26 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 27 Information or Items: information (regardless of how it is generated, stored or 28 maintained) or tangible things that qualify for protection under Federal Rule of Civil 1 Procedure 26(c), and as specified above in the Good Cause Statement, which belongs 2 to a Designating Party who has a good faith basis to believe that such information, if 3 known by the party to whom it is disclosed, would be inherently harmful to the 4 Designating Party’s business, privacy or other protected interests and, in addition, 5 would create a substantial risk of serious financial or other injury that cannot be 6 avoided by less restrictive means. 7 2.9 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 2.10 Non-Party: any natural person, partnership, corporation, association, or 11 other legal entity not named as a Party to this action. 12 2.11 Outside Counsel of Record: attorneys who are not employees of a party 13 to this Action but are retained to represent or advise a party to this Action and have 14 appeared in this Action on behalf of that party or are affiliated with a law firm that 15 has appeared on behalf of that party, including support staff. 16 2.12 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.14 Professional Vendors: persons or entities that provide litigation support 22 services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 2.15 Protected Material: any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 28 from a Producing Party. 1 2 3. SCOPE 3 The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or extracted 5 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 6 Protected Material; and (3) any testimony, conversations, or presentations by Parties 7 or their Counsel that might reveal Protected Material. 8 Any use of Protected Material at trial shall be governed by the orders of the 9 trial judge. This Order does not govern the use of Protected Material at trial. 10 11 4. DURATION 12 Once a case proceeds to trial, all of the court-filed information to be introduced 13 that was previously designated as confidential or maintained pursuant to this 14 protective order becomes public and will be presumptively available to all members 15 of the public, including the press, unless compelling reasons supported by specific 16 factual findings to proceed otherwise are made to the trial judge in advance of the 17 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 18 2006) (distinguishing “good cause” showing for sealing documents produced in 19 discovery from “compelling reasons” standard when merits-related documents are 20 part of court record). Accordingly, the terms of this protective order do not extend 21 beyond the commencement of the trial. 22 23 5. DESIGNATING PROTECTED MATERIAL 24 5.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under this 26 Order must take care to limit any such designation to specific material that qualifies 27 under the appropriate standards. The Designating Party must designate for protection 28 only those parts of material, documents, items, or oral or written communications that 1 qualify so that other portions of the material, documents, items, or communications 2 for which protection is not warranted are not swept unjustifiably within the ambit of 3 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 Party 8 to sanctions. 9 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 11 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 19 documents, but excluding transcripts of depositions or other pretrial or trial 20 proceedings), that the Producing Party affix, at a minimum, the legend 21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), or “HIGHLY 22 CONFIDENTIAL - ATTORNEYS’ EYES ONLY” (hereinafter “HIGHLY 23 CONFIDENTIAL legend”), to each page that contains protected material. If only a 24 portion or portions of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 A Party or Non-Party that makes original documents available for inspection 28 need not designate them for protection until after the inspecting Party has indicated 1 which documents it would like copied and produced. During the inspection and 2 before the designation, all of the material made available for inspection shall be 3 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 4 it wants copied and produced, the Producing Party must determine which documents, 5 or portions thereof, qualify for protection under this Order. Then, before producing 6 the specified documents, the Producing Party must affix the “CONFIDENTIAL 7 legend” or “HIGHLY CONFIDENTIAL legend” to each page that contains Protected 8 Material. If only a portion or portions of the material on a page qualifies for 9 protection, the Producing Party also must clearly identify the protected portion(s) 10 (e.g., by making appropriate markings in the margins). 11 (b) for testimony given in depositions that the Designating Party identify 12 the Disclosure or Discovery Material on the record, before the close of the deposition. 13 (c) for information produced in some form other than documentary and 14 for any other tangible items, that the Producing Party affix in a prominent place on 15 the exterior of the container or containers in which the information is stored the legend 16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 17 ONLY.” If only a portion or portions of the information warrants protection, the 18 Producing Party, to the extent practicable, shall identify the protected portion(s). 19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 failure to designate qualified information or items does not, standing alone, waive the 21 Designating Party’s right to secure protection under this Order for such material. 22 Upon timely correction of a designation, the Receiving Party must make reasonable 23 efforts to assure that the material is treated in accordance with the provisions of this 24 Order. 25 26 27 28 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Magistrate Judge Richlin’s Civil Procedures. Any discovery 7 motion must strictly comply with the procedures set forth in Judge Richlin’s Civil 8 Procedures. 9 6.3 Burden. The burden of persuasion in any such challenge proceeding 10 shall be on the Designating Party. Frivolous challenges, and those made for an 11 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 12 other parties) may expose the Challenging Party to sanctions. Unless the Designating 13 Party has waived or withdrawn the confidentiality designation, all parties shall 14 continue to afford the material in question the level of protection to which it is entitled 15 under the Producing Party’s designation until the Court rules on the challenge. 16 17 7. ACCESS TO AND USE OF PROTECTED MATERIAL 18 7.1 Basic Principles. A Receiving Party may use Protected Material that is 19 disclosed or produced by another Party or by a Non-Party in connection with this 20 Action only for prosecuting, defending, or attempting to settle this Action. Such 21 Protected Material may be disclosed only to the categories of persons and under the 22 conditions described in this Order. When the Action has been terminated, a Receiving 23 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 28 otherwise ordered by the Court or permitted in writing by the Designating Party, a 1 Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of 7 the 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 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment 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 14 Vendors to whom disclosure is reasonably necessary for this Action and who have 15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) the author or recipient of a document containing the information or 17 a custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, witnesses, and attorneys for witnesses, in 19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 20 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 21 will not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 23 agreed by the Designating Party or ordered by the Court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material may be 25 separately bound by the court reporter and may not be disclosed to anyone except as 26 permitted under this Stipulated Protective Order; and 27 (i) any mediator or settlement officer, and their supporting personnel, 28 mutually agreed upon by any of the parties engaged in settlement discussions. 1 Unless otherwise ordered by the Court or permitted in writing by the 2 Designating Party, a Receiving Party may disclose any information or item designated 3 “HIGHLY CONFIDENTIAL” only to those identified in Sections 7(a), (c)-(g) and 4 (i), above, and 7(h) above to the extent counsel has a good faith belief that the witness 5 is designated to testify for the Designating Party under Rule 30(b)(6) or otherwise has 6 or would be expected to have knowledge of the contents of the document, or of its 7 subject matter, and to no one else. 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 9 PRODUCED IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 that compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL” that Party must: 13 (a) promptly notify in writing the Designating Party. Such notification shall 14 include a copy of the subpoena or court order; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the subpoena 17 or order is subject to this Protective Order. Such notification shall include a copy of 18 this Stipulated Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 the subpoena or court order shall not produce any information designated in this action 23 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a determination by 24 the court from which the subpoena or order issued, unless the Party has obtained the 25 Designating Party’s permission. The Designating Party shall bear the burden and 26 expense of seeking protection in that court of its confidential material and nothing in 27 these provisions should be construed as authorizing or encouraging a Receiving Party 28 in this Action to disobey a lawful directive from another court. 1 2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 3 PRODUCED IN THIS LITIGATION 4 (a) The terms of this Order are applicable to information produced by a Non- 5 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 6 CONFIDENTIAL.” Such information produced by Non-Parties in connection with 7 this litigation is protected by the remedies and relief provided by this Order. Nothing 8 in these provisions should be construed as prohibiting a Non-Party from seeking 9 additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to produce 11 a Non-Party’s confidential information in its possession, and the Party is subject to an 12 agreement with the Non-Party not to produce the Non-Party’s confidential 13 information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this Court within 14 23 days of receiving the notice and accompanying information, the Receiving Party may 24 produce the Non-Party’s confidential information responsive to the discovery request. 25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 26 any information in its possession or control that is subject to the confidentiality 27 agreement with the Non-Party before a determination by the Court. Absent a court 28 1 order to the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this Court of its Protected Material. 3 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 10 persons to whom unauthorized disclosures were made of all the terms of this Order, 11 and (d) request such person or persons to execute the “Acknowledgment and 12 Agreement to Be Bound” that is attached hereto as Exhibit A. 13 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 22 parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted 25 to the Court. 26 27 28 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the specific 12 Protected Material at issue; good cause must be shown in the request to file under 13 seal. If a Party’s request to file Protected Material under seal is denied by the Court, 14 then the Receiving Party may file the information in the public record unless 15 otherwise instructed by the Court. 16 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, within 60 days of a written request by 19 the Designating Party, each Receiving Party must return all Protected Material to the 20 Producing Party or destroy such material. As used in this subdivision, “all Protected 21 Material” includes all copies, abstracts, compilations, summaries, and any other 22 format reproducing or capturing any of the Protected Material. Whether the Protected 23 Material is returned or destroyed, the Receiving Party must submit a written 24 certification to the Producing Party (and, if not the same person or entity, to the 25 Designating Party) by the 60 day deadline that (1) identifies (by category, where 26 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 27 that the Receiving Party has not retained any copies, abstracts, compilations, 28 summaries or any other format reproducing or capturing any of the Protected Material. 1 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 2 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 3 correspondence, deposition and trial exhibits, expert reports, attorney work product, 4 and consultant and expert work product, even if such materials contain Protected 5 Material. Any such archival copies that contain or constitute Protected Material 6 remain subject to this Protective Order as set forth in Section 4 (DURATION). 7 14. VIOLATION OF ORDER 8 Any violation of this Order may be punished by any and all appropriate 9 measures including, without limitation, contempt proceedings and/or monetary 10 sanctions.

11 12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 13

DATED:_12/3/2024______________________

14 _/s/__Scott Alan Burroughs________________ 15 Scott Alan Burroughs, Esq. 16 Stephen M. Doniger, Esq. Trevor W. Barrett, Esq. 17 Benjamin F. Tookey, Esq. 18 DONIGER / BURROUGHS 19 Garth A. Clarke, Esq. 20 LAW OFFICES OF GARTH CLARKE 21 Attorneys for Plaintiffs

22 DATED:_ 12/3/2024_____________________ 23 _/s/ Benjamin S. Akley____________________ 24 Benjamin S. Akley, Esq. 25 Shamar Toms-Anthony, Esq. Donald S. Zakarin, Esq. 26 Frank P. Scibilia, Esq. 27 James G. Sammataro, Esq. Sophia Sofferman, Esq. 28 Attorneys for the Pryor Cashman-Represented Defendants 1 2 Jean G. Vidal____________________________ Jean G. Vidal-Font, Esq. 3

FERRAIUOLI LLC

4 Attorney for Defendants Vladimir Felix p/k/a DJ Blass & Camilo Echeverria p/k/a Camilo 5

6

DATED:___ 12/3/2024____________________

7 8 /s/ Mark B. Chassman_____________________ 9 Mark B. Chassman, Esq. Ana Vasquez, Esq. 10 CHASSMAN & SEELIG, LLP 11 Richard C. Wolfe, Esq.

WOLFE LAW MIAMI, P.A.

12 Attorneys for Chassman & Seelig Represented Defendants 13 14 DATED:__ 12/3/2024____________________ 15 _/s/ David M. Given______________________ 16 David M. Given, Esq. 17 Brian S. Conlon, Esq. Robert Carroll III, Esq. 18 Nina C. Pouget, Esq. 19 PHILLIPS, ERLEWINE, GIVEN & CARLIN LLP Attorneys for Defendants Empire 20 Distribution, Inc. and William Sami Etienne Grigahcine p/k/a DJ Snake 21 22

DATED:____ 12/3/2024___________________

23 /s/ Sagar P. Parikh________________________ 24 Sagar P. Parikh, Esq. 25 BEVERLY HILLS LAW CORP., PC Attorney for Defendants Cinq Music Group, LLC & Cinq Music Publishing 26

27 28 1 2 _/s/ Bradley J. Mullins_____________________ Bradley J. Mullins, Esq. 3 Mark C. Humphrey, Esq. 4 MITCHELL SILBERBERG & KNUPP Attorneys for Defendants Aubrey Drake Graham & 5 Sound 1.0 Catalogue LP, improperly named as OVO Sound LLC 6

DATED:_____ 12/3/2024__________________

7 8 /s/ Neville L. Johnson______________________ 9 Neville L. Johnson, Esq. Douglas L. Johnson, Esq. 10 Daniel B. Lifschitz, Esq. 11 JOHNSON & JOHNSON LLP Attorneys for Defendant Rich Music, Inc 12 13

DATED:___ 12/3/2024____________________

14 15 /s/ Michael A. Trauben____________________ Michael A. Trauben, Esq. 16 Thomas K. Richards, Esq. 17 SINGH, SINGH & TRAUBEN, LLP Attorneys for Defendants Nelson Diaz 18 Martinez and Jose Angel Lopez Martinez 19

DATED:_____ 12/3/2024__________________

20 21 /s/ Kenneth D. Freundlich__________________ 22 Kenneth D. Freundlich, Esq. Jonah A. Grossbardt, Esq. 23

FREUNDLICH LAW

24 Attorneys for Defendants Benito Antonio Martinez Ocasio p/k/a Bad Bunny and Rimas Music, LLC 25

26 Pursuant to Civil L.R. 5-4.3.4(a)(2)(i), the filer attests that all other signatories listed, 27 and on whose behalf this filing is submitted, concur in the filing’s content and have 28 authorized the filing. 1 Having considered the stipulation, and finding that good cause exists, the 2 Parties’ Stipulated Protective Order is GRANTED. 3 4 DATED:_1_2_/0_4_/_20_2_4_______ __________________________________

HON. A. JOEL RICHLIN

5 United States Magistrate Judge

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on ____________ [date] in the 8 case of ___________ [insert case name and number]. I agree to comply with and 9 to be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 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 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28