1 Marc Toberoff (S.B. #188547) mtoberoff@toberoffandassociates.com 2

TOBEROFF & ASSOCIATES, P.C.

3 23823 Malibu Road, Suite 50-363 Malibu, CA 90265 4 Telephone: (310) 246-3333 5 Facsimile: (310) 246-3103

6 Attorneys for Plaintiff/Counterclaim Defendant and 7 Third-Party Counterclaim Defendant

R. LANCE HILL and LADY AMOS LITERARY

8

WORKS LTD.

9

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

10 WOOK HWANG (pro hac vice) whwang@sheppardmullin.com 11 30 Rockefeller Plaza 12 New York, New York 10112-0015 Telephone: 212.653.8700 13 Facsimile: 212.653.8701 14 Attorneys for Defendants/Counterclaimants 15 METRO-GOLDWYN-MAYER STUDIOS INC.,

AMAZON STUDIOS LLC &

16

UNITED ARTISTS PICTURES INC.

17

UNITED STATES DISTRICT COURT

18 19 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 20 R. LANCE HILL, an individual, Case No. 2:24-cv-01587-HDV-SSC

21 Plaintiff, [PROPOSED] STIPULATED 22 v. PROTECTIVE ORDER

23

METRO-GOLDWYN-MAYER

24 STUDIOS INC., a Delaware corporation; AMAZON STUDIOS 25 LLC, a California limited liability 26 company; UNITED ARTISTS PICTURES INC., a Delaware 27 corporation; and DOES 1-10, 1 METRO-GOLDWYN-MAYER STUDIOS INC., a Delaware 2 corporation; AMAZON STUDIOS 3 LLC, a California limited liability company; UNITED ARTISTS 4 PICTURES INC., a Delaware corporation, 5

6 Counterclaimants, 7 v. 8

R. LANCE HILL, an individual; and

9 LADY AMOS LITERARY WORKS LTD., a Canadian corporation, 10 11 Counterclaim Defendant and Third-Party 12 Counterclaim Defendant. 13 14 1. INTRODUCTION 15 1.1 Purposes and Limitations. Discovery in this action is likely to involve 16 production of confidential, proprietary, or private information for which special 17 protection from public disclosure and from use for any purpose other than 18 prosecuting this litigation may be warranted. Accordingly, the parties hereby 19 stipulate to and petition the court to enter the following Stipulated Protective Order. 20 The parties acknowledge that this Order does not confer blanket protections on all 21 disclosures or responses to discovery and that the protection it affords from public 22 disclosure and use extends only to the limited information or items that are entitled 23 to confidential treatment under the applicable legal principles. 24 1.2 Good Cause Statement. This action is likely to involve confidential 25 agreements, financial documents reflecting, inter alia, revenues and deductible 26 expenses, trade secrets, and other valuable commercial, financial, and/or proprietary 27 information for which special protection from public disclosure and from use for 1 proprietary materials and information consist of, among other things, confidential 2 business or financial information, information regarding confidential business 3 practices, or other confidential commercial information (including information 4 implicating privacy rights of third parties), information otherwise generally 5 unavailable to the public, or which may be privileged or otherwise protected from 6 disclosure under state or federal statutes, court rules, case decisions, or common 7 law. Accordingly, to expedite the flow of information, to facilitate the prompt 8 resolution of disputes over confidentiality of discovery materials, to adequately 9 protect information the parties are entitled to keep confidential, to ensure that the 10 parties are permitted reasonable necessary uses of such material in preparation for 11 and in the conduct of trial, to address their handling at the end of the litigation, and 12 serve the ends of justice, a protective order for such information is justified in this 13 matter. It is the intent of the parties that information will not be designated as 14 confidential for tactical reasons and that nothing be so designated without a good 15 faith belief that it has been maintained in a confidential, non-public manner, and 16 there is good cause why it should not be part of the public record of this case. 17 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties 18 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 19 Protective Order does not entitle them to file confidential information under seal; 20 Local Rule 79-5 sets forth the procedures that must be followed and the standards 21 that will be applied when a party seeks permission from the court to file material 22 under seal. 23 There is a strong presumption that the public has a right of access to judicial 24 proceedings and records in civil cases. In connection with non-dispositive motions, 25 good cause must be shown to support a filing under seal. See Kamakana v. City and 26 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of 27 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon 1 protective orders require good cause showing), and a specific showing of good 2 cause or compelling reasons with proper evidentiary support and legal justification, 3 must be made with respect to Protected Material that a party seeks to file under seal. 4 The parties’ mere designation of Disclosure or Discovery Material as 5 CONFIDENTIAL does not—without the submission of competent evidence by 6 declaration, establishing that the material sought to be filed under seal qualifies as 7 confidential, privileged, or otherwise protectable—constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the 10 relief sought shall be narrowly tailored to serve the specific interest to be protected. 11 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each 12 item or type of information, document, or thing sought to be filed or introduced 13 under seal in connection with a dispositive motion or trial, the party seeking 14 protection must articulate compelling reasons, supported by specific facts and legal 15 justification, for the requested sealing order. Again, competent evidence supporting 16 the application to file documents under seal must be provided by declaration. 17 Any document that is not confidential, privileged, or otherwise protectable in 18 its entirety will not be filed under seal if the confidential portions can be redacted. If 19 documents can be redacted, then a redacted version for public viewing, omitting 20 only the confidential, privileged, or otherwise protectable portions of the document, 21 shall be filed. Any application that seeks to file documents under seal in their 22 entirety should include an explanation of why redaction is not feasible. 23 2. DEFINITIONS 24 2.1 Action: this pending federal lawsuit, Hill v. Metro-Goldwyn-Mayer 25 Studios Inc., et al., Case No. 2:24-cv-01587-HDV-SSC. 26 2.2 Challenging Party: a Party or Non-Party that challenges the designation 27 of information or items under this Order. 1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 2 how it is generated, stored or maintained) or tangible things that qualify for 3 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as specified 4 above in the Good Cause Statement. 5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 6 their support staff). 7 2.5 Designating Party: a Party or Non-Party that designates information or 8 items that it produces in disclosures or in responses to discovery as 9 “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless 11 of the medium or manner in which it is generated, stored, or maintained (including, 12 among other things, testimony, transcripts, and tangible things), that are produced or 13 generated in disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter 15 pertinent to the litigation who has been retained by a Party or its counsel to serve as 16 an expert witness or as a consultant in this Action. 17 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 18 this Action, with or without prejudice; and (2) final judgment herein after the 19 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of 20 this Action, including the time limits for filing any motions or applications for 21 extension of time pursuant to applicable law. 22 2.9 In-House Counsel: attorneys who are employees of a party to this 23 Action. In-House Counsel does not include Outside Counsel of Record or any other 24 outside counsel. 25 2.10 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 2.11 Outside Counsel of Record: attorneys who are not employees of a party 1 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 has appeared on behalf of that party, and includes support staff. 3 2.12 Party: any party to this Action (including, in the case of Defendants, 4 their direct and indirect parents and their subsidiaries), including all of its officers, 5 directors, employees, consultants, retained experts, and Outside Counsel of Record 6 (and their support staffs). 7 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.14 Professional Vendors: persons or entities that provide litigation- 10 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 and their employees and subcontractors. 13 2.15 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 16 from a Producing Party. 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Stipulated Protective Order does not govern the use of Protected 25 Material at trial. 26 4. TRIAL AND DURATION 27 The terms of this Stipulated Protective Order apply through Final Disposition 1 Once a case proceeds to trial, information that was designated as 2 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and 3 used or introduced as an exhibit at trial becomes public and will be presumptively 4 available to all members of the public, including the press, unless compelling 5 reasons supported by specific factual findings to proceed otherwise are made to the 6 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81 7 (distinguishing “good cause” showing for sealing documents produced in discovery 8 from “compelling reasons” standard when merits-related documents are part of court 9 record). Accordingly, for such materials, the terms of this Stipulated Protective 10 Order do not extend beyond the commencement of the trial. 11 Even after Final Disposition of this litigation, the confidentiality obligations 12 imposed by this Stipulated Protective Order shall remain in effect until a 13 Designating Party agrees otherwise in writing or a court order otherwise directs. 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection under 17 this Order must take care to limit any such designation to specific material that 18 qualifies under the appropriate standards. The Designating Party must designate for 19 protection only those parts of material, documents, items, or oral or written 20 communications that qualify so that other portions of the material, documents, 21 items, or communications for which protection is not warranted are not swept 22 unjustifiably within the ambit of this Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper 25 purpose (e.g., to unnecessarily encumber the case development process or to impose 26 unnecessary expenses and burdens on other parties) may expose the Designating 27 Party to sanctions. 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) 6 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 7 qualifies for protection under this Stipulated Protective Order must be clearly so 8 designated before the material is disclosed or produced. 9 Designation in conformity with this Stipulated Protective Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL” to each page that contains protected material. If only a portion 14 or portions of the material on a page qualifies for protection, the Producing Party 15 also must clearly identify the protected portion(s) (e.g., by making appropriate 16 markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and 20 before the designation, all of the material made available for inspection shall be 21 deemed CONFIDENTIAL. After the inspecting Party has identified the documents 22 it wants copied and produced, the Producing Party must determine which 23 documents, or portions thereof, qualify for protection under this Stipulated 24 Protective Order. Then, before producing the specified documents, the Producing 25 Party must affix the “CONFIDENTIAL” legend to each page that contains Protected 26 Material. If only a portion or portions of the material on a page qualifies for 27 protection, the Producing Party also must clearly identify the protected portion(s) 1 (b) for testimony given in depositions, that the Designating Party 2 identify the Disclosure or Discovery Material: (i) on the record, before the close of 3 the deposition all protected testimony; or (ii) within 7 days following receipt of the 4 final deposition transcript by written notice to counsel of record for any signatory. 5 Unless otherwise agreed, the entirety of any deposition transcript (preliminary or 6 final) shall be treated CONFIDENTIAL in its entirety until the time for designation 7 set forth herein has passed. After the expiration of that period, the transcript shall be 8 treated only as actually designated. 9 (c) for information produced in some form other than documentary 10 and for any other tangible items, that the Producing Party affix in a prominent place 11 on the exterior of the container or containers in which the information is stored the 12 “CONFIDENTIAL” legend. If only a portion or portions of the information 13 warrants protection, the Producing Party, to the extent practicable, shall identify the 14 protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 16 failure to designate qualified information or items does not, standing alone, waive 17 the Designating Party’s right to secure protection under this Order for such material. 18 Upon timely correction of a designation, the Receiving Party must make reasonable 19 efforts to assure that the material is treated in accordance with the provisions of this 20 Stipulated Protective Order. 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 designation of confidentiality at any time that is consistent with the court’s 24 Scheduling Order. 25 26 27 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 3 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”1 4 6.3 The burden of persuasion in any such challenge proceeding shall be on 5 the Designating Party. Frivolous challenges, and those made for an improper 6 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 7 parties) may expose the Challenging Party to sanctions. Unless the Designating 8 Party has waived or withdrawn the confidentiality designation, all parties shall 9 continue to afford the material in question the level of protection to which it is 10 entitled under the Producing Party’s designation until the court rules on the 11 challenge. 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under the 17 conditions described in this Order. When the Action reaches a Final Disposition, a 18 Receiving Party must comply with the provisions of section 13 below. 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Stipulated Protective Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only: 26 27 1 Judge Christensen’s Procedures are available at https://www.cacd.uscourts.gov/honorable- stephanie-s-christensen. 1 (a) to the Receiving Party’s Outside Counsel of Record in this 2 Action, as well as employees of said Outside Counsel of Record to whom it is 3 reasonably necessary to disclose the information for this Action; 4 (b) to the officers, directors, and employees (including House 5 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 6 Action; 7 (c) to Experts (as defined in this Order) of the Receiving Party to 8 whom disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (d) to the court and its personnel; 11 (e) to court reporters and their staff; 12 (f) to professional jury or trial consultants, mock jurors, and 13 Professional Vendors to whom disclosure is reasonably necessary for this Action 14 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 15 A); 16 (g) to the author or recipient of a document containing the 17 information or a custodian or other person who otherwise possessed or knew the 18 information; 19 (h) during their depositions, to witnesses, and attorneys for 20 witnesses, in the Action to whom disclosure is reasonably necessary, provided: (1) 21 the deposing party requests that the witness sign the “Acknowledgment and 22 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to 23 keep any confidential information unless they sign the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 25 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits 26 to depositions that reveal Protected Material may be separately bound by the court 27 reporter and may not be disclosed to anyone except as permitted under this 1 (i) to any mediator or settlement officer, and their supporting 2 personnel, mutually agreed upon by any of the parties engaged in settlement 3 discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 5 PRODUCED IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such 10 notification shall include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or 12 order to issue in the other litigation that some or all of the material covered by the 13 subpoena or order is subject to this Protective Order. Such notification shall include 14 a copy of this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be 16 pursued by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 the subpoena or court order shall not produce any information designated in this 19 action as “CONFIDENTIAL” before a determination by the court from which the 20 subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this Action 24 to disobey a lawful directive from another court. 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 9.1 Application. The terms of this Stipulated Protective Order are 1 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 2 this litigation is protected by the remedies and relief provided by this Order. Nothing 3 in these provisions should be construed as prohibiting a Non-Party from seeking 4 additional protections. 5 9.2 Notification. In the event that a Party is required, by a valid discovery 6 request, to produce a Non-Party’s confidential information in its possession, and the 7 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 8 confidential information, then the Party shall: 9 (a) promptly notify in writing the Requesting Party and the Non- 10 Party that some or all of the information requested is subject to a confidentiality 11 agreement with a Non-Party; 12 (b) make the information requested available for inspection by the 13 Non-Party, if requested. 14 9.3 Conditions of Production. If the Non-Party fails to seek a protective 15 order from this court within 14 days of receiving the notice and accompanying 16 information, the Receiving Party may produce the Non-Party’s confidential 17 information responsive to the discovery request. If the Non-Party timely seeks a 18 protective order, the Receiving Party shall not produce any information in its 19 possession or control that is subject to the confidentiality agreement with the Non- 20 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 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 1 persons to whom unauthorized disclosures were made of all the terms of this Order, 2 and (d) request such person or persons to execute the “Acknowledgment and 3 Agreement to Be Bound” (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 7 inadvertently produced material is subject to a claim of privilege or other protection, 8 the obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 9 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 10 procedure may be established in an e-discovery order that provides for production 11 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules 12 of Evidence, insofar as the parties reach an agreement on the effect of disclosure of 13 a communication or information covered by the attorney-client privilege or work 14 product protection, the parties may incorporate their agreement in the stipulated 15 protective order submitted to the court. 16 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 18 abridges the right of any person to seek its modification by the court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 Stipulated Protective Order no Party waives any right it otherwise would have to 21 object to disclosing or producing any information or item on any ground not 22 addressed in this Stipulated Protective Order. Similarly, no Party waives any right to 23 object on any ground to use in evidence of any of the material covered by this 24 Stipulated Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Local Rule 79-5. Protected Material may only 27 be filed under seal pursuant to a court order authorizing the sealing of the specific 1 is denied by the court, then the Receiving Party may file the information in the 2 public record unless otherwise instructed by the court. 3 13. FINAL DISPOSITION 4 After the Final Disposition of this Action, as defined in paragraph 4, within 5 60 days of a written request by the Designating Party, each Receiving Party must 6 return all Protected Material to the Producing Party or destroy such material. As 7 used in this subdivision, “all Protected Material” includes all copies, abstracts, 8 compilations, summaries, and any other format reproducing or capturing any of the 9 Protected Material. Whether the Protected Material is returned or destroyed, the 10 Receiving Party must submit a written certification to the Producing Party (and, if 11 not the same person or entity, to the Designating Party) by the 60 day deadline that 12 (1) identifies (by category, where appropriate) all the Protected Material that was 13 returned or destroyed and (2) affirms that the Receiving Party has not retained any 14 copies, abstracts, compilations, summaries or any other format reproducing or 15 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 16 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 17 and hearing transcripts, legal memoranda, correspondence, deposition and trial 18 exhibits, expert reports, attorney work product, and consultant and expert work 19 product, even if such materials contain Protected Material. Any such archival copies 20 that contain or constitute Protected Material remain subject to this Protective Order 21 as set forth in Section 4. 22 14. VIOLATION 23 Any violation of this Stipulated Protective Order may be punished by any and 24 all appropriate measures including, without limitation, contempt proceedings and/or 25 monetary sanctions. 26 27 1/}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 ||Dated: February 14, 2025 4 TOBEROFF & ASSOCIATES, P.C. 6 By: /s/Marc T oberoff

MARC TOBEROFF

7 Attorneys for Plaintiff/Counterclaim Defendant 8 R. Lance Hill and Third-Party Counterclaim 9 Defendant Lady Amos Literary Works, Ltd.

10 11 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 12 By: /s/Wook Hwang 13 WOOK HWANG 14 Attorneys for Defendants/Counterclaimants Metro-Goldwyn-Mayer Studios Inc., Amazon I5 Studios LLC and United Artists Pictures Inc. 16 17 18 19 20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 |} DATED: February 18, 2025 33 STEPHANIE S. CHRISTENSEN United States Magistrate Judge 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 6 perjury that I have read in its entirety and understand the Stipulated Protective Order 7 that was issued by the United States District Court for the Central District of 8 California on [date] in the case of Hill v. Metro-Goldwyn-Mayer Studios Inc., et al., 9 Case No. 2:24-cv-01587-HDV-SSC. I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 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. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ____________________ [print or type 19 full name] of __________ [print or type full address and telephone number] as 20 my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 Signature: 27