1 Aannggeellaat aMyl.o Tr@ayjloonre (sSdtaayte.c Bomar No. 210425) 2 JONES DAY 3161 Michelson Drive 3 Suite 800 Irvine, CA 92612 4 Telephone: (949) 553-3939 Facsimile: (949) 553-7539 5 Timothy D. Lanzendorfer (pro hac vice) 6 tlanzendorfer@jonesday.com

JONES DAY

7 325 John H. McConnell Boulevard Suite 600 8 Columbus, OH 43215 Telephone: (614) 281-3076 9 Facsimile: (614) 461-4198 Admitted Pro Hac Vice 10 Attorneys for Defendant 11 EXPERIAN INFORMATION

SOLUTIONS, INC.

12

13

UNITED STATES DISTRICT COURT

14

CENTRAL DISTRICT OF CALIFORNIA

15

16 17 DENNIS P. MOYEDA, Case No. 2:24-cv-10604-SVW-RAOx 18 Plaintiff, Hon. Stephen V. Wilson 19 v. Hon. Rozella A. Oliver 20

EXPERIAN INFORMATION STIPULATED PROTECTIVE

21 SOLUTIONS, INC. AND DOES 1–10 ORDER1

INCLUSIVE,

22 Defendants. 23 24 1. INTRODUCTION 25 1.1 Purposes and Limitations 26 Discovery in this action is likely to involve production of confidential, 27 1 This Stipulated Protective Order is substantially based on the model protective 28 order provided under Magistrate Judge Rozella A. Oliver’s Procedures. 1 proprietary or private information for which special protection from public 2 disclosure and from use for any purpose other than prosecuting this litigation may 3 be warranted. Accordingly, Plaintiff Dennis P. Moyeda and Defendant Experian 4 Information Solutions, Inc., together the “Parties,” hereby stipulate to and petition 5 the Court to enter the following Stipulated Protective Order. The parties 6 acknowledge that this Order does not confer blanket protections on all disclosures 7 or responses to discovery and that the protection it affords from public disclosure 8 and use extends only to the limited information or items that are entitled to 9 confidential treatment under the applicable legal principles. 10 1.2 Good Cause Statement 11 Good cause exists for entry of this Stipulated Protective Order. This action is 12 likely to involve sensitive and proprietary information, such as trade secrets, 13 confidential policies and procedures, and other valuable research, development, 14 commercial, financial, technical and/or proprietary information, for which special 15 protection from public disclosure and from use for any purpose other than 16 prosecution of this action is warranted. This action is also likely to involve 17 personally identifiable financial information, such as names, residential addresses, 18 credit card numbers, financial account numbers, private financial transaction 19 information, confidential debt information, social security numbers, and sensitive 20 credit reporting information, for which special protection from public disclosure 21 and from use for any purpose other than prosecution of this action is warranted. 22 Based on information anticipated to be requested, including that described 23 herein, the Parties anticipate that they will disclose sensitive personal, financial, 24 and/or proprietary information. Private information of third parties may also be 25 disclosed. It is important that this information remain protected and not be readily 26 available due to the dangers of identity theft, the constitutional privacy rights of 27 third parties, and protection of business competition interests. The unrestricted or 28 unprotected disclosure of such private, financial and/or business information would 1 result in prejudice or harm to the producing party and third parties by revealing 2 their information which could result in identity theft, loss of business and/or 3 violation of federal and state privacy laws. 4 Accordingly, to expedite the flow of information, to facilitate the prompt 5 resolution of disputes over confidentiality of discovery materials, to adequately 6 protect information the Parties are entitled to keep confidential, to ensure that the 7 Parties are permitted reasonable necessary uses of such material in preparation for 8 and in the conduct of trial, to address their handling at the end of the litigation, and 9 serve the ends of justice, a protective order for such information is justified in this 10 matter. It is the intent of the Parties that information will not be designated as 11 confidential for tactical reasons and that nothing be so designated without a good 12 faith belief that it has been maintained in a confidential, non-public manner, and 13 there is good cause why it should not be part of the public record of this case. 14 1.3 Acknowledgement of Procedure for Filing Under Seal 15 The Parties further acknowledge, as set forth in Section 12.3, below, that this 16 Stipulated Protective Order does not entitle them to file confidential information 17 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 18 and the standards that will be applied when a party seeks permission from the court 19 to file material under seal. 20 There is a strong presumption that the public has a right of access to judicial 21 proceedings and records in civil cases. In connection with non-dispositive motions, 22 good cause must be shown to support a filing under seal. See Kamakana v. City 23 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. 24 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony 25 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective 26 orders require good cause showing), and a specific showing of good cause or 27 compelling reasons with proper evidentiary support and legal justification, must be 28 made with respect to Protected Material that a party seeks to file under seal. The 1 Parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL 2 does not—without the submission of competent evidence by declaration, 3 establishing that the material sought to be filed under seal qualifies as confidential, 4 privileged, or otherwise protectable—constitute good cause. 5 Further, if a party requests sealing related to a dispositive motion or trial, 6 then compelling reasons, not only good cause, for the sealing must be shown, and 7 the relief sought shall be narrowly tailored to serve the specific interest to be 8 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 9 2010). For each item or type of information, document, or thing sought to be filed 10 or introduced under seal in connection with a dispositive motion or trial, the party 11 seeking protection must articulate compelling reasons, supported by specific facts 12 and legal justification, for the requested sealing order. Again, competent evidence 13 supporting the application to file documents under seal must be provided by 14 declaration. 15 Any document that is not confidential, privileged, or otherwise protectable in 16 its entirety will not be filed under seal if the confidential portions can be redacted. 17 If documents can be redacted, then a redacted version for public viewing, omitting 18 only the confidential, privileged, or otherwise protectable portions of the document 19 shall be filed. Any application that seeks to file documents under seal in their 20 entirety should include an explanation of why redaction is not feasible. 21 22 2. DEFINITIONS 23 2.1 Action: Dennis P. Moyeda v. Experian Information Solutions, Inc., et 24 al., Case No. 2:24-cv-10604-SVW-RAO. 25 2.2 Challenging Party: a Party or Non-Party that challenges the 26 designation of information or items under this Order. 27 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 28 how it is generated, stored or maintained) or tangible things that qualify for 1 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 2 the Good Cause Statement. 3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 4 their support staff). 5 2.5 Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as 7 “CONFIDENTIAL.” 8 2.6 Disclosure or Discovery Material: all items or information, regardless 9 of the medium or manner in which it is generated, stored, or maintained (including, 10 among other things, testimony, transcripts, and tangible things) that are produced or 11 generated in disclosures or responses to discovery in this matter. 12 2.7 Expert: a person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as 14 an expert witness or as a consultant in this Action. 15 2.8 House Counsel: attorneys who are employees of a party to this Action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 2.9 Non-Party: any natural person, partnership, corporation, association or 19 other legal entity not named as a Party to this action. 20 2.10 Outside Counsel of Record: attorneys who are not employees of a 21 party to this Action but are retained to represent or advise a party to this Action and 22 have appeared in this Action on behalf of that party or are affiliated with a law firm 23 that has appeared on behalf of that party, and includes support staff. 24 2.11 Party: any party to this Action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 28 Discovery Material in this Action. 1 2.13 Professional Vendors: persons or entities that provide litigation 2 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 and their employees and subcontractors. 5 2.14 Protected Material: any Disclosure or Discovery Material that is 6 designated as “CONFIDENTIAL.” 7 2.15 Receiving Party: a Party that receives Disclosure or Discovery 8 Material from a Producing Party. 9 2.16 Court: Hon. Stephen V. Wilson, Hon. Rozella A. Oliver, or any other 10 judge to which this Action may be assigned, including Court staff participating in 11 such proceedings. 12 13 3. SCOPE 14 The protections conferred by this Stipulation and Order cover not only 15 Protected Material (as defined above), but also (1) any information copied or 16 extracted from Protected Material; (2) all copies, excerpts, summaries, or 17 compilations of Protected Material; and (3) any testimony, conversations, or 18 presentations by Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 22 4. DURATION 23 Even after final disposition of this litigation, the confidentiality obligations 24 imposed by this Order shall remain in effect until a Designating Party agrees 25 otherwise in writing or a court order otherwise directs. Final disposition shall be 26 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 27 with or without prejudice; and (2) final judgment herein after the completion and 28 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 1 including the time limits for filing any motions or applications for extension of time 2 pursuant to applicable law. 3 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection under 7 this Order must take care to limit any such designation to specific material that 8 qualifies under the appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items or oral or written 10 communications that qualify so that other portions of the material, documents, 11 items or communications for which protection is not warranted are not swept 12 unjustifiably within the ambit of this Order. 13 Mass, indiscriminate, or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to 16 impose unnecessary expenses and burdens on other parties) may expose the 17 Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 24 under this Order must be clearly so designated before the material is disclosed or 25 produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 documents, but excluding transcripts of depositions or other pretrial or trial 1 proceedings), that the Producing Party affix the legend 2 “CONFIDENTIAL”(hereinafter “CONFIDENTIAL legend”), to each page that 3 contains protected material. If only a portion of the material on a page qualifies for 4 protection, the Producing Party also must clearly identify the protected portion(s) 5 (e.g., by making appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 need not designate them for protection until after the inspecting Party has indicated 8 which documents it would like copied and produced. During the inspection and 9 before the designation, all of the material made available for inspection shall be 10 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 11 documents it wants copied and produced, the Producing Party must determine 12 which documents, or portions thereof, qualify for protection under this Order. 13 Then, before producing the specified documents, the Producing Party must affix the 14 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 15 portion of the material on a page qualifies for protection, the Producing Party also 16 must clearly identify the protected portion(s) (e.g., by making appropriate markings 17 in the margins). 18 (b) Deposition testimony can be designated by the Parties as Confidential 19 Information. Such designation will be made on the record if possible, but the 20 Parties can designate portions of such testimony as Confidential Information by 21 providing written notice of such designation to the opposing Parties within thirty 22 (30) days of receipt of the transcribed testimony by counsel. Until thirty (30) days 23 after receipt of the transcribed testimony, such testimony shall be treated by the 24 Parties as Confidential Information. 25 (c) for information produced in some form other than documentary and 26 for any other tangible items, that the Producing Party affix in a prominent place on 27 the exterior of the container or containers in which the information is stored the 28 legend “CONFIDENTIAL.” If only a portion or portions of the information 1 warrants protection, the Producing Party, to the extent practicable, shall identify the 2 protected portion(s). 3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 failure to designate qualified information or items does not, standing alone, waive 5 the Designating Party’s right to secure protection under this Order for such 6 material. Upon timely correction of a designation, the Receiving Party must make 7 reasonable efforts to assure that the material is treated in accordance with the 8 provisions of this Order. 9 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 12 designation of confidentiality at any time that is consistent with the Court’s 13 Scheduling Order. 14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 15 resolution process by requesting to meet and confer with the Designating Party 16 pursuant to Local Rule 37.1 et seq., and if the issue cannot be resolved, the 17 Challenging Party shall file a motion challenging the designation. If the meet and 18 confer is regarding a motion to which Confidential Information is to be attached, 19 this is resolved by filing a motion to seal wherein both parties include their 20 positions as to whether the document(s) and information should be sealed. 21 6.3 Burden of Persuasion. The burden of persuasion in any such challenge 22 proceeding shall be on the Designating Party. Frivolous challenges, and those 23 made for an improper purpose (e.g., to harass or impose unnecessary expenses and 24 burdens on other parties) may expose the Challenging Party to sanctions. Unless 25 the Designating Party has waived or withdrawn the confidentiality designation, all 26 parties shall continue to afford the material in question the level of protection to 27 which it is entitled under the Producing Party’s designation until the Court rules on 28 the challenge. 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the Court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) Parties to the Action; 17 (b) the Receiving Party’s Outside Counsel of Record in this Action, as 18 well as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (c) the officers, directors, and employees (including House Counsel) of 21 the Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (d) Experts (as defined in this Order) of the Receiving Party to whom 23 disclosure is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (e) the Court and its personnel; 26 (f) court reporters and their staff; 27 (g) professional jury or trial consultants, mock jurors, and Professional 28 Vendors to whom disclosure is reasonably necessary for this Action and who have 1 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (h) the author or recipient of a document containing the information or a 3 custodian or other person who otherwise possessed or knew the information; 4 (i) during their depositions, witnesses, and attorneys for witnesses, in the 5 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 6 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 7 will not be permitted to keep any confidential information unless they sign the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 9 agreed by the Designating Party or ordered by the Court. Pages of transcribed 10 deposition testimony or exhibits to depositions that reveal Protected Material may 11 be separately bound by the court reporter and may not be disclosed to anyone 12 except as permitted under this Stipulated Protective Order; and 13 (j) any mediator or settlement officer, and their supporting personnel, 14 mutually agreed upon by any of the parties engaged in settlement discussions. 15 16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 If a Party is served with a subpoena or a court order issued in other litigation 19 that compels disclosure of any information or items designated in this Action as 20 “CONFIDENTIAL,” that Party must: 21 (a) promptly notify in writing the Designating Party. Such notification 22 shall include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the subpoena or order 24 to issue in the other litigation that some or all of the material covered by the 25 subpoena or order is subject to this Protective Order. Such notification shall 26 include a copy of this Stipulated Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to be 28 pursued by the Designating Party whose Protected Material may be affected. If the 1 Designating Party timely seeks a protective order, the Party served with the 2 subpoena or court order shall not produce any information designated in this action 3 as “CONFIDENTIAL” before a determination by the court from which the 4 subpoena or order issued, unless the Party has obtained the Designating Party’s 5 permission. The Designating Party shall bear the burden and expense of seeking 6 protection in that court of its confidential material and nothing in these provisions 7 should be construed as authorizing or encouraging a Receiving Party in this Action 8 to disobey a lawful directive from another court. 9 10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 14 produced by Non-Parties in connection with this litigation is protected by the 15 remedies and relief provided by this Order. Nothing in these provisions should be 16 construed as prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 produce a Non-Party’s confidential information in its possession, and the Party is 19 subject to an agreement with the Non-Party not to produce the Non-Party’s 20 confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non-Party 22 that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 specific description of the information requested; and 27 (3) make the information requested available for inspection by the 28 Non-Party, if requested. 1 (c) If the Non-Party fails to seek a protective order from this Court within 2 14 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s confidential information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the Court. 7 Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this Court of its Protected Material. 9 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best 15 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 16 person or persons to whom unauthorized disclosures were made of all the terms of 17 this Order, and (d) request such person or persons to execute the “Acknowledgment 18 and Agreement to Be Bound” that is attached hereto as Exhibit A. 19 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other 24 protection, the obligations of the Receiving Parties are those set forth in Federal 25 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 26 whatever procedure may be established in an e-discovery order that provides for 27 production without prior privilege review. Pursuant to Federal Rule of Evidence 28 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 1 of a communication or information covered by the attorney-client privilege or work 2 product protection, the parties may incorporate their agreement in the stipulated 3 protective order submitted to the Court. 4 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order, no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in 11 this Stipulated Protective Order. Similarly, no Party waives any right to object on 12 any ground to use in evidence of any of the material covered by this Protective 13 Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Local Civil Rule 79-5. Protected Material 16 may only be filed under seal pursuant to a court order authorizing the sealing of the 17 specific Protected Material at issue. If a Party’s request to file Protected Material 18 under seal is denied by the Court, then the Receiving Party may file the information 19 in the public record unless otherwise instructed by the Court. 20 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 days of a written request by the Designating Party, each Receiving Party must 24 return all Protected Material to the Producing Party or destroy such material. As 25 used in this subdivision, “all Protected Material” includes all copies, abstracts, 26 compilations, summaries, and any other format reproducing or capturing any of the 27 Protected Material. Whether the Protected Material is returned or destroyed, the 28 Receiving Party must submit a written certification to the Producing Party (and, if 1 not the same person or entity, to the Designating Party) by the 60 day deadline that 2 (1) identifies (by category, where appropriate) all the Protected Material that was 3 returned or destroyed and (2) affirms that the Receiving Party has not retained any 4 copies, abstracts, compilations, summaries or any other format reproducing or 5 capturing any of the Protected Material. Notwithstanding this provision, Counsel 6 are entitled to retain an archival copy of all pleadings, motion papers, trial, 7 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 8 and trial exhibits, expert reports, attorney work product, and consultant and expert 9 work product, even if such materials contain Protected Material. Any such archival 10 copies that contain or constitute Protected Material remain subject to this Protective 11 Order as set forth in Section 4 (DURATION). 12 13 14. VIOLATION 14 Any violation of this Order may be punished by any and all appropriate 15 measures including, without limitation, contempt proceedings and/or monetary 16 sanctions. 17 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

19

20 Dated: February 7, 2025 CARDOZA LAW CORPORATION

21 22 By: /s/ Michael F. Cardoza Michael F. Cardoza 23 Attorneys for Plaintiff 24 DENNIS P. MOYEDA 25 26 27 28 1 D ated: February 7, 2025 JONES DAY 2 3 By: /s/ Timothy D. Lanzendorfer Timothy D. Lanzendorfer 4 5 By: /s/ Angela M. Taylor 6 Angela M. Taylor

7 Attorneys for

EXPERIAN INFORMATION

8 SOLUTIONS, INC. 9

10

SIGNATURE CERTIFICATION

11 Pursuant to Local Rule 5-4.3.4(a)(2), I hereby certify that all other signatories 12 listed, on whose behalf this filing is submitted, concur with the contents of this 13 filing and have authorized the filing. 14 /s/ Timothy D. Lanzendorfer 15 Timothy D. Lanzendorfer

16 17 18 19 20 21 22 23 24 25 26 27 28 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2

DATED: 2/7/2025

4 . 5 Rayells, Or, OC 6 | United States Mavisirate Judge 7 g 9 10 i 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -17- □□□ □□□

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 perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Dennis P. Moyeda v. Experian Information Solutions, Inc., 8 et al., 2:24-cv-10604-SVW-RAOx. I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge that 10 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 12 information or item that is subject to this Stipulated Protective Order to any person 13 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 for 15 the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of 17 this action. I hereby appoint __________________________ [print or type full 18 name] of _______________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28