1 TUCKER ELLIS LLP Ronald G. Polly, Jr. (admitted pro hac vice) 2 ronald.polly@tuckerellis.com Alex M. Barfield SBN 275403 3 alex.barfield@tuckerellis.com 4 Christine A. Kurke (admitted pro hac vice) christine.kurke@tuckerellis.com 5 515 Flower Street Forty-Second Floor 6 Los Angeles, CA 90071-2223 7 Telephone: 216.430.3400 Facsimile: 216.430.3409 8 Attorneys for Defendant RSCR California, Inc. 9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

11 12 DESIRAY DELGADO, on behalf of Case No. 2:24-cv-07988-SB-AJR 13 herself and all others similarly situated,

AGREED PROTECTIVE ORDER

14 Plaintiff,

15 v. 16 RSCR CALIFORNIA, INC., a 17 Delaware corporation; and DOES 1 through 100, inclusive, 18 Defendants. 19 20 IT IS HEREBY STIPULATED, by and between the parties to the above-captioned 21 action through their respective counsel of record, that in order to facilitate the exchange of 22 information and documents which may be subject to confidentiality limitations on 23 disclosure due to federal laws, state laws, and privacy rights, the parties stipulate as 24 follows: 25 1. A. PURPOSES AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential, proprietary 27 or private information for which special protection from public disclosure and from use for 28 any purpose other than prosecuting this litigation may be warranted. This Stipulated 1 Protective Order is intended to comply with the California Medical Information Act 2 (“CMIA”) and the Health Insurance Portability and Accountability Act (“HIPAA”), which 3 provides that a qualified protective order may be issued by a court “with respect to 4 protected health information.” (4.45 C.F.R. § 164.512(e)(1)(v).) Accordingly, the parties 5 hereby stipulate to and jointly petition the Court to enter the following Stipulated Protective 6 Order. The parties acknowledge that this Order does not confer blanket protections on all 7 disclosures or responses to discovery and that the protection it affords from public 8 disclosure and use extends only to the limited information or items that are entitled to 9 confidential treatment under the applicable legal principles. 10 B. GOOD CAUSE STATEMENT 11 The parties assert in support of their request that protection of the identified 12 categories of confidential information as listed in Section 2.3 is necessary because this is 13 an employment law action likely to involve personal identifying information of 14 Defendant’s employees, proprietary and/or confidential information for which special 15 protection from public disclosure and from use for any purpose other than prosecution of 16 this action is warranted. Such confidential and proprietary materials and information 17 consist of, among other things, confidential personal information, information implicating 18 privacy rights of third parties (Defendant’s clients), and/or information otherwise generally 19 unavailable to the public, or which may be privileged or otherwise protected from 20 disclosure under state or federal statutes, court rules, case decisions, or common law. 21 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 22 disputes over confidentiality of discovery materials, to adequately protect information the 23 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 24 necessary uses of such material in preparation for and in the conduct of trial, to address 25 their handling at the end of the litigation, and serve the ends of justice, a protective order 26 for such information is justified in this matter. It is the intent of the parties that information 27 will not be designated as confidential for tactical reasons and that nothing be so designated 28 without a good faith belief that it has been maintained in a confidential, non-public manner, 1 and there is good cause why it should not be part of the public record of this case. 2 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 3 SEAL 4 The parties further acknowledge, as set forth in Section 12.3, 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 material 8 under seal. 9 There is a strong presumption that the public has a right to access to judicial 10 proceedings and records in civil cases. In connection with non-dispositive motions, good 11 cause must be shown to support a filing under seal. See Kamakana v. City and County of 12 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 13 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 14 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and a 15 specific showing of good cause or compelling reasons with proper evidentiary support and 16 legal justification, must be made with respect to Protected Material that a party seeks to 17 file under seal. The parties’ mere designation of Disclosure or Discovery Material as 18 CONFIDENTIAL does not— without the submission of competent evidence by 19 declaration, establishing that the material sought to be filed under seal qualifies as 20 confidential, privileged, or 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 Pintos 24 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of 25 information, document, or thing sought to be filed or introduced under seal in connection 26 with a dispositive motion or trial, the party seeking protection must articulate compelling 27 reasons, supported by specific facts and legal justification, for the requested sealing order. 28 Again, competent evidence supporting the application to file documents under seal must 1 be provided by declaration. 2 Any document that is not confidential, privileged, or otherwise protectable in its 3 entirety will not be filed under seal if the confidential portions can be redacted. If 4 documents can be redacted, then a redacted version for public viewing, omitting only the 5 confidential, privileged, or otherwise protectable portions of the document, shall be filed. 6 Any application that seeks to file documents under seal in their entirety should include an 7 explanation of why redaction is not feasible. 8 2. DEFINITIONS 9 2.1 Action: this pending federal lawsuit entitled Desiray Delgado v. RSCR 10 California, Inc., et al, U.S.D.C. CACD Case No. 2:24−cv−07988-SB−AJR. 11 2.2 Challenging Party: a party or non-party that challenges the designation of 12 information or items under this Order. 13 2.3 “CONFIDENTIAL” Information or Items: As used in this Stipulated 14 Protective Order, “CONFIDENTIAL” Information is defined as information that the 15 producing party designates in good faith has been previously maintained in a confidential 16 manner and should be protected from disclosure and use outside the litigation because its 17 disclosure and use is restricted by statute or could potentially cause harm to the interests of 18 disclosing party or nonparties. For purposes of this Order, the parties will limit their 19 designation of “CONFIDENTIAL” Information to the following categories of information 20 or documents: 21  Identities of Defendant’s clients (individuals with developmental disabilities) and 22 any records relating to those clients’ care or subject to provisions of the CMIA 23 and HIPAA. 24  Certain personnel documents that contain confidential information (e.g. 25 employees’ social security numbers, bank account information, driver’s license 26 numbers, etc.) 27  Pre- and post-employment medical screening documents 28  Tax returns and other financial records 1  Work restriction and/or workers’ compensation records 2  Proprietary business records 3  Trade secrets 4  Records maintained in a complaint investigation 5  Records whose disclosure is restricted or prohibited by statute 6 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support 7 staff). 8 2.5 Designating Party: a Party or Non-Party that designates information or items 9 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless of the 11 medium or manner in which it is generated, stored, or maintained (including, among other 12 things, testimony, transcripts, and tangible things), that are produced or generated in 13 disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent 15 to the litigation who has been retained by a Party or its counsel to serve as an expert witness 16 or as a consultant in this Action. 17 2.8 House Counsel: attorneys who are employees of a party to this Action. House 18 Counsel does not include Outside Counsel of Record or any other outside counsel. 19 2.9 Non-Party: any natural person, partnership, corporation, association or other 20 legal entity not named as a Party to this action. 21 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 22 Action but are retained to represent or advise a party to this Action and have appeared in 23 this Action on behalf of that party or are affiliated with a law firm that has appeared on 24 behalf of that party, and includes support staff. 25 2.11 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their support 27 staffs). 28 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 1 Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation support 3 services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 5 their employees and subcontractors. 6 2.14 Protected Material: any Disclosure or Discovery Material that is designated 7 as “CONFIDENTIAL.” 8 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 9 a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only Protected 12 Material (as defined above), but also (1) any information copied or extracted from 13 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 14 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel 15 that might reveal Protected Material. Any use of Protected Material at trial shall be 16 governed by the orders of the trial judge. This Order does not govern the use of Protected 17 Material at trial. 18 The parties and all signatories to the Acknowledgment And Agreement To Be Bound 19 attached hereto as Exhibit A agree to be bound by this Stipulated Protective Order pending 20 its approval and entry by the Court. In the event that the Court modifies this Stipulated 21 Protective Order, or in the event that the Court enters a different Protective Order, the 22 Parties agree to be bound by this Stipulated Protective Order until such time as the Court 23 may enter such a different Protective Order. It is the Parties’ intent to be bound by the terms 24 of this Stipulated Protective Order pending its entry so as to allow for immediate 25 production of Protected Materials under the terms herein. 26 4. DURATION 27 Once a case proceeds to trial, information that was designated as CONFIDENTIAL 28 or maintained pursuant to this protective order used or introduced as an exhibit at trial 1 becomes public and will be presumptively available to all members of the public, including 2 the press, unless compelling reasons supported by specific factual findings to proceed 3 otherwise are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 4 1180-81 (distinguishing “good cause” showing for sealing documents produced in 5 discovery from “compelling reasons” standard when merits-related documents are part of 6 court record). Accordingly, the terms of this protective order do not extend beyond the 7 commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection. 10 Each Party or Non-Party that designates information or items for protection under 11 this Order must take care to limit any such designation to specific material that qualifies 12 under the appropriate standards. The Designating Party must designate for protection only 13 those parts of material, documents, items or oral or written communications that qualify so 14 that other portions of the material, documents, items or communications for which 15 protection is not warranted are not swept unjustifiably within the ambit of this Order. Mass, 16 indiscriminate or routinized designations are prohibited. Designations that are shown to be 17 clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 18 encumber the case development process or to impose unnecessary expenses and burdens 19 on other parties) may expose the Designating Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in this 24 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 25 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 26 must be clearly so designated before the material is disclosed or produced. 27 / / / 28 / / / 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, but 3 excluding transcripts of depositions or other pretrial or trial proceedings), that the 4 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 6 portion of the material on a page qualifies for protection, the Producing Party also must 7 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 8 margins). 9 A Party or Non-Party that makes original documents available for inspection need 10 not designate them for protection until after the inspecting Party has indicated which 11 documents it would like copied and produced. During the inspection and before the 12 designation, all of the material made available for inspection shall be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 14 copied and produced, the Producing Party must determine which documents, or portions 15 thereof, qualify for protection under this Order. Then, before producing the specified 16 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 17 that contains Protected Material. If only a portion of the material on a page qualifies for 18 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by 19 making appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies the 21 Disclosure or Discovery Material on the record, before the close of the deposition all 22 protected testimony. 23 (c) for information produced in some form other than documentary and for any 24 other tangible items, that the Producing Party affix in a prominent place on the exterior of 25 the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 27 the Producing Party, to the extent practicable, shall identify the protected portion(s). 28 / / / 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 2 to designate qualified information or items does not, standing alone, waive the Designating 3 Party’s right to secure protection under this Stipulated Protective Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable efforts 5 to assure that the material is treated in accordance with the provisions of this Stipulated 6 Protective Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 9 confidentiality at any time that is consistent with the Court’s Scheduling Order. 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 11 process under Local Rule 37-1 et seq. 12 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 13 stipulation pursuant to Local Rule 37-2. 14 6.4 Duty. The burden of persuasion in any such challenge proceeding shall be on the 15 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 16 harass or impose unnecessary expenses and burdens on other parties) may expose the 17 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the 18 confidentiality designation, all parties shall continue to afford the material in question the 19 level of protection to which it is entitled under the Producing Party’s designation until the 20 Court rules on the challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed 23 or produced by another Party or by a Non-Party in connection with this Action only for 24 prosecuting, defending or attempting to settle this Action. Such Protected Material may be 25 disclosed only to the categories of persons and under the conditions described in this Order. 26 When the Action has been` terminated, a Receiving Party must comply with the provisions 27 of section 13 below (FINAL DISPOSITION). 28 Protected Material must be stored and maintained by a Receiving Party at a location 1 and in a secure manner that ensures that access is limited to the persons authorized under 2 this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 4 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 5 may disclose any information or item designated “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 7 employees of said Outside Counsel of Record to whom it is reasonably necessary to 8 disclose the information for this Action; 9 (b) the officers, directors, and employees (including House Counsel) of the 10 Receiving Party to whom disclosure is reasonably necessary for this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 12 is reasonably necessary for this Action and who have signed the “Acknowledgment and 13 Agreement to Be Bound” (Exhibit A); (d) the court and its personnel; 14 (d) court reporters and their staff; 15 (e) professional jury or trial consultants, mock jurors, and Professional Vendors 16 to whom disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (f) the author or recipient of a document containing the information or a custodian 19 or other person who otherwise possessed or knew the information; 20 (g) during their depositions, witnesses, and attorneys for witnesses, in the Action 21 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 22 the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted 23 to keep any confidential information unless they sign the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 25 ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions 26 that reveal Protected Material may be separately bound by the court reporter and may not 27 be disclosed to anyone except as permitted under this Stipulated Protective Order; and 28 / / / 1 (h) any mediator or settlement officer, and their supporting personnel, mutually 2 agreed upon by any of the parties engaged in settlement discussions. 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 4 OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation that 6 compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification shall 9 include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to issue 11 in the other litigation that some or all of the material covered by the subpoena or order is 12 subject to this Protective Order. Such notification shall include a copy of this Stipulated 13 Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be pursued by 15 the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with the 17 subpoena or court order shall not produce any information designated in this action as 18 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 19 issued, unless the Party has obtained the Designating Party’s permission. The Designating 20 Party shall bear the burden and expense of seeking protection in that court of its 21 confidential material and nothing in these provisions should be construed as authorizing or 22 encouraging a Receiving Party in this Action to disobey a lawful directive from another 23 court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 25 IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a Non-Party 27 in this Action and designated as “CONFIDENTIAL.” Such information produced by Non- 28 Parties in connection with this litigation is protected by the remedies and relief provided 1 by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party 2 from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce 4 a Non-Party’s confidential information in its possession, and the Party is subject to an 5 agreement with the Non-Party not to produce the Non-Party’s confidential information, 6 then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party that some 8 or all of the information requested is subject to a confidentiality agreement with a Non- 9 Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 11 in this Action, the relevant discovery request(s), and a reasonably specific description of 12 the information requested; and 13 (3) make the information requested available for inspection by the Non-Party, if 14 requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 days 16 of receiving the notice and accompanying information, the Receiving Party may produce 17 the Non-Party’s confidential information responsive to the discovery request. If the Non- 18 Party timely seeks a protective order, the Receiving Party shall not produce any 19 information in its possession or control that is subject to the confidentiality agreement with 20 the Non-Party before a determination by the court. Absent a court order to the contrary, the 21 Non-Party shall bear the burden and expense of seeking protection in this court of its 22 Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the 27 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 28 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 1 unauthorized disclosures were made of all the terms of this Order, and (d) request such 2 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 3 attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain inadvertently 7 produced material is subject to a claim of privilege or other protection, the obligations of 8 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 9 This provision is not intended to modify whatever procedure may be established in an e- 10 discovery order that provides for production without prior privilege review. Pursuant to 11 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 12 effect of disclosure of a communication or information covered by the attorney-client 13 privilege or work product protection, the parties may incorporate their agreement in the 14 stipulated protective order submitted to the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 17 to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 19 Order, no Party waives any right it otherwise would have to object to disclosing or 20 producing any information or item on any ground not addressed in this Stipulated 21 Protective Order. Similarly, no Party waives any right to object on any ground to use in 22 evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 24 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 25 under seal pursuant to a court order authorizing the sealing of the specific Protected 26 Material at issue. If a Party’s request to file Protected Material under seal is denied by the 27 court, then the Receiving Party may file the information in the public record unless 28 otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 days 3 of a written request by the Designating Party, each Receiving Party must destroy such 4 material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, 5 compilations, summaries, and any other format reproducing or capturing any of the 6 Protected Material. The Receiving Party must submit a written certification to the 7 Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 8 day deadline that (1) all the Protected Material was destroyed and (2) affirms that the 9 Receiving Party has not retained any copies, abstracts, compilations, summaries or any 10 other format reproducing or capturing any of the Protected Material. Notwithstanding this 11 provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, 12 trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and 13 trial exhibits, expert reports, attorney work product, and consultant and expert work 14 product, even if such materials contain Protected Material. Any such archival copies that 15 contain or constitute Protected Material remain subject to this Protective Order as set forth 16 in Section 4. 17 14. VIOLATION 18 Any violation of this Order may be punished by appropriate measures including, 19 without limitation, contempt proceedings and/or monetary sanctions. 20 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 22 23 DATED: December 3, 2024 24 THE NOURMAND LAW FIRM, APC TUCKER ELLIS LLP

25 By: /s/ James A. De Sario By: /s/ Alex M. Barfield 26 Michael Nourmand Alex M. Barfield James A. De Sario Attorneys for Defendant RSCR California, 27 Attorneys for Plaintiff Desiray Delgado Inc. 28 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 DATED:_1_2_/0_4_/2_0_2_4_______________ 4 5 6 Honorable A. Joel Richlin 7 United States Magistrate Judge 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, _________________________________ [print or type full name], of 5 _________________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 ______________________, the case of Desiray Delgado v. RSCR California, Inc., et al., 9 U.S.D.C. CACD Case No. 2:24-cv-07988-SB-AJR. I agree to comply with and to be 10 bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment in the 12 nature of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person or entity 14 except in strict compliance with the provisions of this Order. I further agree to submit to 15 the jurisdiction of the United States District Court for the Central District of California for 16 enforcing the terms of this Stipulated Protective Order, even if such enforcement 17 proceedings occur after termination of this action. I hereby appoint 18 _________________________________ [print or type full name] of 19 _____________________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date:____________________________________ 24 City and State where sworn and signed:_______________________________________ 25 26 Printed name:______________________________ 27 28 Signature:_________________________________ 1 CERTIFICATE OF SERVICE 2 The undersigned counsel for Defendant hereby certifies that a true and correct copy 3 of the forgoing document was filed with the Court and served electronically through the 4 CM-ECF (Electronic Case Filing) system to all counsel of record to those registered to 5 receive a Notice of Electronic Filing for this case on this 3rd day of December, 2024. 6 /s/ Alex M. Barfield 7 Alex M. Barfield 8

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