1 || ROBERT HAMPTON ROGERS - Bar No. 106206 JOSEPH S. DZIDA — Bar No. 89459 2 irOg □□□ eeraatioey com

CALLANAN, ROGERS & DZIDA, LLP

3 || 800 South Figueroa Street, Suite 1100 Los Angeles, California 90017-2521 4 || Telephone: (213) 599-7595 ; Facsimile: (213) 599-7596

‘ Attorneys for Plaintiff AKANESI K. VANISI

7 HOWARD & HOWARD ATTORNEYS PLLC Robert L. Rosenthal, (SBN 173047) 8 ee A. Ellis, (SBN 272868) 2049 Century Park East, Suite 330 9 || Los Angeles, CA 90067 Telephone: oy 303-7700 10 || Facsimile: (424) 274-3202 Email: rir@h2law.com 11 |] re@h2law.com Attorneys for Defendant Worldwide Flight Services, Inc.

13 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 17 || AKANESI K. VANISI, an individual, Case No. 2:18-cv-6908 RSLW (RAOx) 18 Plaintiff, STIPULATION AND [PROPOSED]

PROTECTIVE ORDER

Vv. Assigned for All Purposes to: 20 || WORLDWIDE FLIGHT SERVICES, Hon. Ronald S. W, Lew INC. and DOES 1-25 Inclusive, 21 Action Filed: July 6, 2018 Defendant. 22 Trial Date: None Set 23 24 25 26 27 28

PROTECTIVE ORDER

2 || 1. A. PURPOSES AND LIMITATIONS 3 This protective order ("Protective Order") is issued to expedite the flow of discovery 4 || materials, to facilitate the prompt resolution of disputes over confidentiality of discovery 5 || materials, to adequately protect information the parties are entitled to keep confidential, to 6 || ensure that only materials the parties are entitled to keep confidential are subject to such 7 || treatment, and to ensure that the parties are permitted reasonably necessary uses of such 8 || materials in preparation for and in the conduct of trial, pursuant to Fed. R. Civ. P. 26(c) and 9 || any other applicable rule of this Court. Accordingly, the parties hereby stipulate to and 10 |] petition the Court to enter the following Stipulation And Protective Order. The parties 11 |}acknowledge that this Order does not confer blanket protections on all disclosures or 12 ||responses to discovery and that the protection it affords from public disclosure and use 13 || extends only to the limited information or items that are entitled to confidential treatment 14 || under the applicable legal principles. Unless modified, superseded or terminated pursuant to 15 j}the terms contained in this Order, this Protective Order shall remain in effect through the 16 |j conclusion of this litigation and thereafter as set forth below. 17 B. GOOD CAUSE STATEMENT 18 This action is likely to involve medical information concerning Plaintiff as well as 19 || financial information concerning Defendant, including confidential business information, 20 || structuring and/or other valuable commercial and proprietary information for which special 21 || protection from public disclosure and from use for any purpose other than prosecution of 22 || this action is warranted. Such confidential and proprietary materials and information consist 23 || of, among other things, confidential business or financial information, information regarding 24 || confidential business practices, or other confidential, development, or commercial 25 || information (including information implicating privacy rights of third parties), information 26 || otherwise generally unavailable to the public, or which may be privileged or otherwise 27 || protected from disclosure under state or federal statutes, court rules, case decisions, or 28 ||common law. Accordingly, to expedite the flow of information, to facilitate the prompt

1 |;resolution of disputes over confidentiality of discovery materials, to adequately protect 2||information the parties are entitled to keep confidential, to ensure that the parties are 3 || permitted reasonable necessary uses of such material in preparation for and in the conduct 4 || of trial, to address their handling at the end of the litigation, and serve the ends of justice, 5 || there is good cause for a protective order for such information. It is the intent of the parties 6 || that information will not be designated as confidential for tactical reasons and that nothing 7 || be so designated without a good faith belief that it has been maintained in a confidential, 8 || non-public manner, and there is good cause why it should not be part of the public record of 9 || this case. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 || Stipulation And Protective Order does not entitle them to file confidential information under 13 || seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the standards 14 || that will be applied when a party seeks permission from the court to file materia! under seal. 15 || There is a strong presumption that the public has a right of access to judicial proceedings 16 and records in civil cases. In connection with non-dispositive motions, good cause must be 17 || shown to support a filing under seal. See Kamakana y. City and County of Honolulu, 447 18 || F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th 19 || Cir. 2002), Makar -Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) 20 || (even stipulated protective orders require good cause showing), and a specific showing of 21 || good cause or compelling reasons with proper evidentiary support and legal justification, 22 || must be made with respect to Protected Material that a party seeks to file under seal. The 23 || parties' mere designation of Disclosure or Discovery Material as CONFIDENTIAL does 24 || not— without the submission of competent evidence by declaration, establishing that the 25 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 26 || protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, then 28 || compelling reasons, not only good cause, for the sealing must be shown, and the relief sought

1 || shall be narrowly tailored to serve the specific interest to be protected. See Pintos v. Pacific 2 || Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of information, 3 ||document, or thing sought to be filed or introduced under seal in connection with a 4 || dispositive motion or trial, the party seeking protection must articulate compelling reasons, 5 |{supported by specific facts and legal justification, for the requested sealing order. Again, 6||competent evidence supporting the application to file documents under seal must be 7 provided by declaration. Any document that is not confidential, privileged, or otherwise 8 || protectable in its entirety will not be filed under seal if the confidential portions can be 9 || redacted. If documents can be redacted, then a redacted version for public viewing, omitting 10 || only the confidential, privileged, or otherwise protectable portions of the document, shall be 11 || filed. Any application that seeks to file documents under seal in their entirety should include 12 || an explanation of why redaction is not feasible. 13 2, DEFINITIONS 14 2.1 Action: This pending lawsuit, entitled Akanesi K. Vanisi v. Worldwide Flight 15 || Services, Inc., Case No. 2:18-cv-6908 RSLW (RAOw). 16 2.2 ‘Challenging Party: A Party or Non-Party that challenges the designation of 17 |] information or items under this Order. 18 2.3 "CONFIDENTIAL" Information or Items: information (regardless of how it 19 |/is generated, stored or maintained) or tangible things that qualify for protection under 20 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement. 21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 22 || support staff). 23 2.) Designating Party: a Party or Non-Party that designates information or items 24 || that it produces in disclosures or in responses to discovery as "CONFIDENTIAL." 25 2.6 Disclosure or Discovery Material: all items or information, regardless of the 26 ||medium or manner in which they are generated, stored, or maintained (including, among 27 || other things, testimony, transcripts, and tangible things), that are produced or generated in 28 || disclosures or responses to discovery in this matter.

i 2.7. Expert: a person with specialized knowledge or experience in a matter 2 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert 3 witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 || House Counsel does not include Outside Counsel of Record or any other outside counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association or other 7 || legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to this 9 || Action but are retained to represent or advise a party to this Action and have appeared in this 10 || Action on behalf of that party or are affiliated with a law firm that has appeared on behalf 11 || of that party, and includes support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, 13 || employees, consultants, retained experts, and Outside Counsel of Record (and their support 14 || staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 16 || Material in this Action. 17 2.13 Professional Vendors: persons or entities that provide litigation support - 18 || services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, 19 || and organizing, storing, or retrieving data in any form or medium) and their employees and 20 || subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is designated as 22 || "CONFIDENTIAL." 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 24 || a Producing Party. 25 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only Protected 27 || Material (as defined above), but also (1) any information copied or extracted from Protected 28 |} Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3)

| || any testimony, conversations, or presentations by Parties or their Counsel that might reveal 2 || Protected Material. Any use of Protected Materia! at trial shall be governed by the orders of 3 || the trial judge. This Order does not govern the use of Protected Material at trial. 4\/4. DURATION 5 Once a case proceeds to trial, information that was designated as CONFIDENTIAL 6 ||or maintained pursuant to this protective order used or introduced as an exhibit at trial 7 || becomes public and will be presumptively available to all members of the public, including 8 ||the press, unless compelling reasons supported by specific factual findings to proceed 9 || otherwise are made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 10 || 1180-81 (distinguishing "good cause" showing for sealing documents produced in discovery 11 || from "compelling reasons" standard when merits-related documents are part of court ||record). Accordingly, the terms of this protective order do not extend beyond the 13 || commencement of the trial. 14 Even after final disposition of this litigation, the confidentiality obligations imposed 15 | by this Order shall remain in effect until a Designating Party agrees otherwise in writing or 16 ||a court order otherwise directs. Final disposition shall be deemed to be the later of (1) 17 || dismissal of all claims and defenses in this Action, with or without prejudice; and (2) final 18 judgment herein after the completion and exhaustion of all appeals, rehearings, remands, 19 ||trials, or reviews of this Action, including the time limits for filing any motions or 20 || applications for extension of time pursuant to applicable law. 21/5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 | Each Party or Non-Party that designates information or items for protection alder this Order 24 must take care to limit any such designation to specific material that qualifies under the 25 || appropriate standards. The Designating Party must designate for protection only those parts 26 || of material, documents, items or oral or written communications that qualify so that other 27 || portions of the material, documents, items or communications for which protection is not 28 || warranted are not swept unjustifiably within the ambit of this Order.

1 || Mass, indiscriminate or routinized designations are prohibited. Designations that are shown 2||to be clearly unjustified or that have been made for an improper purpose (e.g., to 3 || unnecessarily encumber the case development process or to impose unnecessary expenses 4 || and burdens on other parties) may expose the Designating Party to sanctions. 5 If it comes to a Designating Party's attention that information or items that it 6 || designated for protection do not qualify for protection, that Designating Party must promptly 7 || notify all other Parties that it is withdrawing the inapplicable designation. 8 5.2 Manner and Timing of Designations. Except as otherwise provided in this 9 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 10 || ordered, Disclosure or Discovery Material that qualifies for protection under this Order must 11 || be clearly so designated before the material is disclosed or produced. 12 || Designation in conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic documents, but 14 || excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing 15 || Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter "CONFIDENTIAL 16 || legend"), to each page that contains protected material. If only a portion of the material on a 17 || page qualifies for protection, the Producing Party also must clearly identify the protected 18 || portion(s) (¢.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for inspection need 20 |;not designate them for protection until after the inspecting Party has indicated which 21 ||documents it would like copied and produced. During the inspection and before the 22 |\designation, all of the material made available for inspection shall be deemed 23 ||"CONFIDENTIAL." After the inspecting Party has identified the documents it wants copied 24 || and produced, the Producing Party must determine which documents, or portions thereof, 25 || qualify for protection under this Order. Then, before producing the specified documents, the 26 || Producing Party must affix the "CONFIDENTIAL legend" to each page that contains Protected Material. If only a portion of the material on a page qualifies for protection, the 28

|| Producing Party also must clearly identify the protected portion(s) (¢.g., by making 2 || appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating Party identifies the 4 || Disclosure or Discovery Material on the record, before the close of the deposition all 5 || protected testimony. 6 (c) for information produced in some form other than documentary and for any 7 || other tangible items, that the Producing Party affix in a prominent place on the exterior of 8 |j the container or containers in which the information is stored the legend "CONFIDENTIAL" 9 || If only a portion or portions of the information warrants protection, the Producing Party, to 10 || the extent practicable, shall identify the protected portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 12 || designate qualified information or items does not, standing alone, waive the Designating 13 Party's right to secure protection under this Order for such material. Upon timely correction 14 || ofa designation, the Receiving Party must make reasonable efforts to assure that the material 15 || is treated in accordance with the provisions of this Order. 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges, Any Party or Non-Party may challenge a designation 18 || of confidentiality at any time that is consistent with the Court's Scheduling Order. 19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 20 || process under Local Rule 37-1 et. seq. 21 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 22 || stipulation pursuant to Local Rule 37-2. 23 6.4 The burden of persuasion in any such challenge proceeding shall be on the 24 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 25 harass or impose unnecessary expenses and burdens on other parties) may expose the 26 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the 27 || confidentiality designation, all parties shall continue to afford the material in question the 28

1 || level of protection to which it is entitled under the Producing Party's designation until the 2 || Court rules on the challenge. 3 7, ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected Material that is 5 || disclosed or produced by another Party or by a Non-Party in connection with this Action 6 || only for prosecuting, defending or attempting to settle this Action. Such Protected Material 7 || may be disclosed only to the categories of persons and under the conditions described in this 8 Order. When the Action has been terminated, a Receiving Party must comply with the 9 || provisions of section 13 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a location 11 ||and in a secure manner that ensures that access is limited to the persons authorized under 12 || this Order. 13 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise 14 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party may 15 || disclose any information or item designated "CONFIDENTIAL" only to: 16 (a) the Receiving Party's Outside Counsel of Record in this Action, as well as 17 || employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose 18 || the information for this Action; 19 (b) Plaintiff, the officers, directors, and employees (including House Counsel) of 20 || the Receiving Party to whom disclosure is reasonably necessary for this Action 21 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 22 ||is reasonably necessary for this Action and who have signed the "Acknowledgment and 23 || Agreement to Be Bound" (Exhibit A); 24 (d) _ the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 27 \|to whom disclosure is reasonably necessary for this Action and who have signed the 28 "Acknowledgment and Agreement to Be Bound" (Exhibit A);

1 (g) the author or recipient of a document containing the information or a custodian 2 || or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 4||to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 5 || the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be permitted to 6 || keep any confidential information unless they sign the ‘Acknowledgment and Agreement to 7 || Be Bound" (Exhibit A), unless otherwise Agreed by the Designating Party or ordered by the 8||court. Pages of transcribed deposition testimony or exhibits to depositions that reveal 9 || Protected Material may be separately bound by the court reporter and may not be disclosed 10 |}to anyone except as permitted under this Stipulation And Protective Order; and 11 (i) | any mediator or settlement officer, and their supporting personnel, mutually 12 |j agreed upon by any of the parties engaged in settlement discussions. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 || IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation that 16}/compels disclosure of any information or items designated in this Action as "CONFIDENTIAL," that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 || include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to issue 21 |j in the other litigation that some or all of the material covered by the subpoena or order is 22 || subject to this Protective Order. Such notification shall include a copy of this Stipulation and 23 || Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by 25 || the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with the 27 || subpoena or court order shall not produce any information designated in this action as 28 || "CONFIDENTIAL" before a determination by the court from which the subpoena or order

1 issued, unless the Party has obtained the Designating Party's permission. The Designating 2 || Party shall bear the burden and expense of seeking protection in that court of its confidential 3 || material and nothing in these provisions should be construed as authorizing or encouraging 4 □□ Receiving Party in this Action to disobey a lawful directive from another court. 5 9. A__NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 6 || PRODUCED IN THIS LITIGATION “7 (a) The terms of this Order are applicable to information produced by a Non-Party 8 || in this Action and designated as "CONFIDENTIAL" Such information produced by Non- 9 || Parties in connection with this litigation is protected by the remedies and relief provided by 10 }j this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from 11 || seeking additional protections. 12 (b) In the event that a Party is required, by a valid discovery request, to produce a 13 ||Non-Party's confidential information in its possession, and the Party is subject to an 14 || agreement with the Non-Party not to produce the Non-Party's confidential information, then 15 the Party shall: 16 (1) promptly notify in writing the Requesting Party and the Non-Party that 17 || some or all of the information requested is subject to a confidentiality agreement with a Non- 18 || Party; 19 (2) promptly provide the Non-Party with a copy of the Stipulation And 20 || Protective Order in this Action, the relevant discovery request(s), and a reasonably specific 21 || description of the information requested; and 22 (3) | make the information requested available for inspection by the Non- 23 || Party, if requested. 24 (c) Ifthe Non-Party fails to seek a protective order from this court within 14 days 25 || of receiving the notice and accompanying information, the Receiving Party may produce the 26 || Non-Party's confidential information responsive to the discovery request. If the Non-Party 27 || timely seeks a protective order, the Receiving Party shall not produce any information in its 28 || possession or control that is subject to the confidentiality agreement with the Non-Party

I || before a determination by the court. Absent a court order to the contrary, the Non-Party shall 2 || bear the burden and expense of seeking protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 || Protected Material to any person or in any circumstance not authorized under this Stipulation And Protective Order, the Receiving Party must immediately (a) notify in writing the 7 || Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 8 || unauthorized copies of the Protected Material, (c) inform the person or persons to whom 9 || unauthorized disclosures were made of all the terms of this Order, and (d) request such 10 |) person or persons to execute the "Acknowledgment and Agreement to Be Bound" that is ]] jj attached hereto as Exhibit A. 12 11, INADVERTENT PRODUCTION OF PRIVILEGED OR OTHER WISE 13 || PROTECTED MATERIAL 14 When a Producing Party gives notice to Receiving Parties that certain inadvertently 15 || produced material is subject to a claim of privilege or other protection, the obligations of the 16 || Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 17 || provision is not intended to modify whatever procedure may be established in an e-discovery 18 || order that provides for production without prior privilege review. Pursuant to Federal Rule 19 || of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of 20 || disclosure of a communication or information covered by the attorney-client privilege or 21 || work product protection, the parties may incorporate their agreement in the stipulated 22 || protective order submitted to the court. 23 12. MISCELLANEOUS 24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 25 || to seek its modification by the Court in the future. 26 || 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 27 || Order, no Party waives any right it otherwise would have to object to disclosing or producing 28 || any information or item on any ground not addressed in this Stipulation And Protective an

1 |] Order. Similarly, no Party waives any right to object on any ground to use in evidence of 2 || any of the material covered by this Protective Order. 3 12.3. Filing Protected Material. A Party that seeks to file under seal any Protected 4 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 5 || under seal pursuant to a court order authorizing the sealing of the specific Protected Material 6 || at issue. If a Party's request to file Protected Material under seal is denied by the court, then 7 || the Receiving Party may file the information in the public record unless otherwise instructed 8 || by the court. 9 13. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 4, within 60 days of 11 ||a written request by the Designating Party, each Receiving Party must return all Protected 12 || Material to the Producing Party or destroy such material. As used in this subdivision, "all 13 || Protected Material" includes all copies, abstracts, compilations, summaries, and any other 14 ||format reproducing or capturing any of the Protected Material. Whether the Protected 15 || Material is returned or destroyed, the Receiving Party must submit a written certification to 16 || the Producing Party (and, if not the same person or entity, to the Designating Party) by the 17 || 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 18 || that was returned or destroyed and (2) affirms that the Receiving Party has not retained any 19 || copies, abstracts, compilations, summaries or any other format reproducing or capturing any 20 \l of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 21 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 22 || memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work 23 || product, and consultant and expert work product, even if such materials contain Protected 24 Material. Any such archival copies that contain or constitute Protected Material remain 25 || subject to this Protective Order as set forth in Section 4 (DURATION). 26 14. VIOLATION 27 Any violation of this Order may be punished by appropriate measures including, 28 || without limitation, contempt proceedings and/or monetary sanctions. 49.

1|| IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. post “ye 3|| DATED: By ©, 2019 CALLANAN, ROGERS & DZIDA, LLP

JOSEPH S, DZIDA

bk Dt 2D ° By: 6 Joseph S. Dzida 7 Attorneys for Plaintiff AKANESI K. VANISI g||DATED: July 4, 2019 HOWARD & HOWARD ATTORNEYS PLLC ° i yl 10 CU KM By: 11 ee Rosenthal 12 Ryan A. Ellis Attorneys for Defendant WORLDWIDE 13 FLIGHT SERVICES, INC. 14 15

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

16 . 17 k . On , 2 ™ DATED: August 19, 2019 18 Hon. Rozella A. Oliver United States Magistrate Judge 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND [print or type full name], of 5 [print or type full address], declare under penalty of perjury ¢ || that I have read in its entirety and understand the Stipulated Protective Order that 7 || was issued by the United States District Court for the Central District of California g || on [date] in the case of Akanesi K. Vanisi v. Worldwide Flight Services, Inc., Case 9 No. 2:18-cv-6908 RSLW (RAOx). I agree to comply with and to be bound by all the 19 || terms of this Stipulated Protective Order and I understand and acknowledge that 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 except 14 in strict compliance with the provisions of this Order. I further agree to submit to the 15 jurisdiction of the United States District Court for the Central District of California 16||for enforcing the terms of this Stipulated Protective Order, even if such WV enforcement proceedings occur after termination of this action. 18 I hereby appoint 19 [print or type full name] of 20 [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 ||this action or any proceedings related to enforcement of this Stipulated Protective 23 || Order. 24 25 || Date: 26 || City and State where sworn and signed: 27 || Signature: 28 || Printed name: