1 || FAYER GIPSON LLP ELLIOT B. GIPSON (State Bar. No. 234020) 2 Ee ipson@ fayergipson com MICHELLE K. MILLARD (State Bar No. 298245) 3 MiMillard@ fayergipson.com 2029 Century Park East, Suite 400 4 || Los Angeles, California 90067 Telephone: 310.557.3558 5 || Facsimile: 310.557.3589 6 Attorneys for Defendant Create Music 7 || Group, Inc. 8 9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

1] SETH GORDON, an individual, CASE NO. 2:21-CV-4986-FLA-JEM 12 Plaintiff, PROPOSED] STIPULATED 13 ROTECTIVE ORDER 14 VS. Magistrate: Hon. John E. McDermott Courtroom: 640, 6" Floor 15 || CREATE MUSIC GROUP, INC., a Delaware corporation; TENTHOUSAND Action Filed: June 18, 2021 PROJECTS, LLC, a California limited Motion Cut-off: September 23, 2022 liability company; and DOES 1 through 20, Discovery Cut-off: July 22, 2022 17 || inclusive Pretrial Conference: Nov. 18, 2022 Trial Date: December 6, 2022 18 Defendants. 19 20 21 22 23 24 25 26 27 28

1 Good cause having been shown, the Court hereby GRANTS the parties’ 2 || Stipulated Protective Order and ORDERS as follows: 3 1. A. PURPOSES AND LIMITATIONS 4 5 Discovery in this action is likely to involve production of confidential, 6 || proprietary, or private information for which special protection from public disclosure 7 || and from use for any purpose other than prosecuting this litigation may be warranted. 8 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 9 || following Stipulated Protective Order. The parties acknowledge that this Order does 10 || not confer blanket protections on all disclosures or responses to discovery and that the 11 || protection it affords from public disclosure and use extends only to the limited 12 || information or items that are entitled to confidential treatment under the applicable 13 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 14 || that this Stipulated Protective Order does not entitle them to file confidential 15. || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 16 || followed and the standards that will be applied when a party seeks permission from 17 || the court to file material under seal. 18 This Stipulated Protective Order is based upon the model stipulated protective 19 || order for the Central District found the Central District website at the following URL: 20 || https://www.cacd.uscourts.gov/sites/default/files/documents/SP/AD/SAMPLE%20ST 21 || PULATED%20PROTECTIVE%200RDER. pdf 22 || The Good Cause statement has been modified to fit this particular case. 23 24 B. GOOD CAUSE STATEMENT: 25 26 i. SAFETY AND PRIVACY OF NON-PARTY DANIEL 27 HERNANDEZ AND ASSOCIATES 28

1 All people have an inalienable right to pursue and obtain safety and privacy in 2 || California. Cal. Const., art. I, § 1 (“All people are by nature free and independent and 3 || have inalienable rights. Among these are enjoying and defending life and liberty, 4 || acquiring, possessing, and protecting property, and pursuing and obtaining safety, 5 || happiness, and privacy.”) (emphasis added). There is a privacy and personal safety 6 || issue that looms over any disclosures in this case given the identity of non-party who 7 || 1s a material witness to the Action. Daniel Hernandez (a/k/a Tekashi69), who is not a 8 || party to this case, but is a defendant in a related case in the Eastern District of New 9 || York concerning alleged copyright infringement of the same works, is the artist whose 10 || song STOOPID Plaintiff alleges infringes on Plaintiffs work he refers to as “The 11 || Drop.” In addition to the “run of the mill” safety and privacy interests any celebrity 12 || might have, Mr. Hernandez has additional serious safety and privacy concerns. Mr. 13 || Hernandez has been previously incarcerated in New York state prison and was 14 || reported to have his sentence reduced due to his alleged cooperation with authorities 15 || against a notorious New York street gang. As such, any information regarding his 16 || earnings, whereabouts, or identifiable and/or contact information for him, his friends, 17 || his family, his lawyers, and his associates potentially makes them targets for that 18 || street gang. Public disclosure of this information could allow the street gang or its 19 || affiliates to threaten or harm Mr. Hernandez and his associates. As such, there is good 20 || cause for a protective order as requested herein. 21 ii. DEFENDANTS’ RIGHT TO PRIVACY AND FAIR 22 COMPETITION: KEEPING NON-PUBLIC BUSINESS 23 INFORMATION CONFIDENTIAL 24 Likewise, the Defendants have the right to protect their property and privacy 25 || under the California Constitution. California. Cal. Const., art. I, § 1 (“All people are 26 || by nature free and independent and have inalienable rights. Among these are ... 27 || acquiring, possessing, and protecting property, and pursuing and obtaining ... 28 || privacy.) (emphasis added). Here, Defendants are non-public companies who are not

1 || required to report their financial information publicly to shareholders or the SEC. 2 || Part of the benefit of being a non-public company is being able to shield business 3 || information such as costs and revenues from one’s competitors. Defendants have 4 || been careful not to publicly publish the revenues they earn from individual artists or 5 || songs. Requiring the public disclosure of business and financial information related 6 || to the artist and song at issue in this case would violate the Defendants right to 7 || property and privacy. This action is likely to involve commercial, financial, technical 8 || and/or proprietary information for which special protection from public disclosure and 9 || from use for any purpose other than prosecution of this action is warranted. Such 10 || confidential and proprietary materials and information consist of, among other things, 11 || confidential business or financial information, information regarding confidential 12 || business practices, or other confidential research, development, or commercial 13 || information (including information implicating privacy rights of third parties), 14 || information otherwise generally unavailable to the public, or which may be privileged 15 || or otherwise protected from disclosure under state or federal statutes, court rules, case 16 || decisions, or common law. Accordingly, to expedite the flow of information, to 17 || facilitate the prompt resolution of disputes over confidentiality of discovery materials, 18 || to adequately protect information the parties are entitled to keep confidential, to 19 || ensure that the parties are permitted reasonable necessary uses of such material in 20 || preparation for and in the conduct of trial, to address their handling at the end of the 21 || litigation, and serve the ends of justice, a protective order for such information is 22 || justified in this matter. It is the intent of the parties that information will not be 23 || designated as confidential for tactical reasons and that nothing be so designated 24 || without a good faith belief that it has been maintained in a confidential, non-public 25 || manner, and there is good cause why it should not be part of the public record of this 26 || case. Competitors to the defendants would benefit from access to information 27 || regarding the defendants’ contracts, revenue reports, payments and business methods 28 || — harming defendants who benefit from their competitors not knowing such

1 || information about their businesses. For example, if competitors to defendants were to 2 || gain access to the contracts, revenue reports, payments and business methods of 3 || defendants, the competitors may alter their own contracts and pricing structures to 4 || undercut defendants in order to make their businesses more attractive to defendants’ 5 || artists. 6 iii. Document Summary Chart 7 In particular, the parties anticipate the need to designate the following 8 || documents and information as CONFIDENTIAL, and provide this list and good cause 9 || reasons pursuant to Edwards v. County of Los Angeles (C.D. Cal., Dec. 9, 2009, No. 10 || CV 08-07428 GAF (SSX) 2009 WL 4707996, at *2!: 1] Harm From Public Disclosure 12 || Revenue reports Earnings from songs 1. Harms Mr. Hernandez’s 13 and associates’ safety and 14 privacy interests to the 15 extent it makes them 16 targets of criminal gang 17 activity 18 2. Harms Defendants’ 19 privacy and property 20 interests to the extent it 21 allows competitors access 22 to otherwise non-public 23 earnings 24 1. Harms Mr. Hernandez’s 25 26 ~ | There may be other documents and information not described here that should 97 || be designated as CONF IDENTIAL for the same reasons as stated herein. The Parties reserve their rights to designate such documents and information as CONFIDENTIAL 28 || Besignating Party may challenge any such designation pursuant to the procedures ol this Stipulated Protective Order.

1 directions, bank account and associates’ safety and 2 information, personal contact privacy interests to the 3 information extent it makes them 4 targets of criminal gang 5 activity 6 2. Harms Defendants’ 7 privacy and property 8 interests to the extent it 9 allows competitors access 10 to otherwise non-public 11 earnings 12 || Correspondence Identity of correspondents, 1. Harms Mr. Hernandez’s 13 contact information of and associates’ safety and 14 correspondents, information privacy interests to the 15 regarding revenues extent it makes them 16 targets of criminal gang 17 activity 18 2. Harms Defendants’ 19 privacy and property 20 interests to the extent it 21 allows competitors access 22 to otherwise non-public 23 earnings 24 || Miscellaneous Miscellaneous financial 1. Harms Mr. Hernandez’s 25 || financial information such as payment and associates’ safety and 26 || documents and information, account privacy interests to the 27 || information information extent it makes them 28 targets of criminal gang Cc

1 activity 2 2. Harms Defendants’ 3 privacy and property 4 interests to the extent it 5 allows competitors access 6 to otherwise non-public 7 earnings 8 9 || /d. at *2 (“The documents to be protected shall be specifically described and 10 || identified. The paragraph containing the statement of good cause should be preceded 11 || by the phrase: “GOOD CAUSE STATEMENT.” The parties shall articulate, for each 12 || document or category of documents they seek to protect, the specific prejudice or 13 || harm that will result if no protective order is entered.”). 14 15 |] 2. DEFINITIONS 16 2.1 Action: This pending federal lawsuit. 17 2.2. Challenging Party: a Party or Non-Party that challenges the designation 18 || of information or items under this Order. 19 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 20 || how it is generated, stored or maintained) or tangible things that qualify for protection 21 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 || Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 24 || support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 || items that it produces in disclosures or in responses to discovery as 27 || “CONFIDENTIAL.” 28

1 2.6 Disclosure or Discovery Material: all items or information, regardless of 2 || the medium or manner in which it is generated, stored, or maintained (including, 3 || among other things, testimony, transcripts, and tangible things), that are produced or 4 || generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 7 || expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 || House Counsel does not include Outside Counsel of Record or any other outside 10 || counsel. 1] 2.9 Non-Party: any natural person, partnership, corporation, association, or 12 || other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 || to this Action but are retained to represent or advise a party to this Action and have 15 || appeared in this Action on behalf of that party or are affiliated with a law firm which 16 || has appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 || employees, consultants, retained experts, and Outside Counsel of Record (and their 19 || support staffs). 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 || Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation support 23 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 25 || and their employees and subcontractors. 26 2.14 Protected Material: any Disclosure or Discovery Material that is 27 || designated as “CONFIDENTIAL.” 28

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 || from a Producing Party. 3 || 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 || Protected Material (as defined above), but also (1) any information copied or extracted 6 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of 7 || Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 || or their Counsel that might reveal Protected Material. Any use of Protected Material at 9 || trial shall be governed by the orders of the trial judge. This Order does not govern the 10 || use of Protected Material at trial. 11 12 4, DURATION. 13 Even after final disposition of this litigation, the confidentiality obligations 14 || imposed by this Order shall remain in effect until a Designating Party agrees 15 || otherwise in writing or a court order otherwise directs. Final disposition shall be 16 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 17 || or without prejudice; and (2) final judgment herein after the completion and 18 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 19 || including the time limits for filing any motions or applications for extension of time 20 || pursuant to applicable law. 21 22 DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 || Each Party or Non-Party that designates information or items for protection under this 25 || Order must take care to limit any such designation to specific material that qualifies 26 || under the appropriate standards. The Designating Party must designate for protection 27 || only those parts of material, documents, items, or oral or written communications that 28 || qualify so that other portions of the material, documents, items, or communications °

1 || for which protection is not warranted are not swept unjustifiably within the ambit of 2 || this Order. Mass, indiscriminate, or routinized designations are prohibited. 3 || Designations that are shown to be clearly unjustified or that have been made for an 4 || improper purpose (e.g., to unnecessarily encumber the case development process or to 5 || impose unnecessary expenses and burdens on other parties) may expose the 6 || Designating Party to sanctions. If it comes to a Designating Party’s attention that 7 || information or items that it designated for protection do not qualify for protection, that 8 || Designating Party must promptly notify all other Parties that it is withdrawing the 9 || inapplicable designation. 10 5.2. Manner and Timing of Designations. Except as otherwise provided in 11 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 12 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 13 || under this Order must be clearly so designated before the material is disclosed or 14 || produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 || documents, but excluding transcripts of depositions or other pretrial or trial 18 || proceedings), that the Producing Party affix at a minimum, the legend 19 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”’), to each page that 20 || contains protected material. If only a portion or portions of the material on a page 21 || qualifies for protection, the Producing Party also must clearly identify the protected 22 || portion(s) (e.g., by making appropriate markings in the margins). A Party or Non- 23 || Party that makes original documents available for inspection need not designate them 24 || for protection until after the inspecting Party has indicated which documents it would 25 || like copied and produced. During the inspection and before the designation, all of the 26 || material made available for inspection shall be deemed “CONFIDENTIAL.” After the 27 || inspecting Party has identified the documents it wants copied and produced, the 28 || Producing Party must determine which documents, or portions thereof, qualify for

1 || protection under this Order. Then, before producing the specified documents, the 2 || Producing Party must affix the “CONFIDENTIAL legend” to each page that contains 3 || Protected Material. If only a portion or portions 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 (b) for testimony given in depositions that the Designating Party identify the 7 || Disclosure or Discovery Material on the record, before the close of the deposition all 8 || protected testimony. 9 (c) for information produced in some form other than documentary and for 10 || any other tangible items, that the Producing Party affix in a prominent place on the 11 || exterior of the container or containers in which the information is stored the legend 12 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 || protection, the Producing Party, to the extent practicable, shall identify the protected 14 || 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 the 17 || 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 || Order. 21 22 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 || designation of confidentiality at any time that is consistent with the Court’s 25 || Scheduling Order. 26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 || resolution process under Local Rule 37.1 et seq. 28 in

1 6.3 The burden of persuasion in any such challenge proceeding shall be on 2 || the Designating Party. Frivolous challenges, and those made for an improper purpose 3 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 || expose the Challenging Party to sanctions. Unless the Designating Party has waived or 5 || withdrawn the confidentiality designation, all parties shall continue to afford the 6 || material in question the level of protection to which it is entitled under the Producing 7 || Party’s designation until the Court rules on the challenge. 8 9 ||7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1 Basic Principles. A Receiving Party may use Protected Material that is 11 || disclosed or produced by another Party or by a Non-Party in connection with this 12 || Action only for prosecuting, defending, or attempting to settle this Action. Such 13 || Protected Material may be disclosed only to the categories of persons and under the 14 || conditions described in this Order. When the Action has been terminated, a Receiving 15 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 16 || Protected Material must be stored and maintained by a Receiving Party at a location 17 || and in a secure manner that ensures that access is limited to the persons authorized 18 || under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 || otherwise ordered by the court or permitted in writing by the Designating Party, a 21 || Receiving Party may disclose any information or item designated “CONFIDENTIAL” 22 || only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 24 || as employees of said Outside Counsel of Record to whom it is reasonably necessary to 25 || disclose the information for this Action; 26 (b) the officers, directors, and employees (including House Counsel) of the 27 || Receiving Party to whom disclosure is reasonably necessary for this Action; 28 14

1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 || disclosure is reasonably necessary for this Action and who have signed the 3 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) Plaintiff's manager Jamal Engram; 5 (e) Plaintiffs co-counsel Cooper Knowlton and Joseph Dieuvil, as well as 6 || employees of such co-counsel to whom it is reasonably necessary to disclose the 7 || information for this Action; 8 (f) the court and its personnel; 9 (g) court reporters and their staff; 10 (h) professional jury or trial consultants, mock jurors, and Professional 11 || Vendors to whom disclosure is reasonably necessary for this Action and who have 12 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (i) the author or recipient of a document containing the information or a 14 || custodian or other person who otherwise possessed or knew the information; 15 (j) during their depositions, witnesses ,and attorneys for witnesses, in the 16 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 17 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 18 || not be permitted to keep any confidential information unless they sign the 19 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 20 || by the Designating Party or ordered by the court. Pages of transcribed deposition 21 || testimony or exhibits to depositions that reveal Protected Material may be separately 22 || bound by the court reporter and may not be disclosed to anyone except as permitted 23 || under this Stipulated Protective Order; and 24 (k) any mediator or settlement officer, and their supporting personnel, 25 || mutually agreed upon by any of the parties engaged in settlement discussions. 26 27 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 28 IN OTHER LITIGATION 1D

1 If a Party is served with a subpoena or a court order issued in other litigation 2 || that compels disclosure of any information or items designated in this Action as 3 || “CONFIDENTIAL,” that Party must: 4 (a) promptly notify in writing the Designating Party. Such notification shall 5 || include a copy of the subpoena or court order; 6 (b) promptly notify in writing the party who caused the subpoena or order to 7 || issue in the other litigation that some or all of the material covered by the subpoena or 8 || order is subject to this Protective Order. Such notification shall include a copy of this 9 || Stipulated Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to be pursued 11 || by the Designating Party whose Protected Material may be affected. If the 12 || Designating Party timely seeks a protective order, the Party served with the subpoena 13 || or court order shall not produce any information designated in this action as 14 || “CONFIDENTIAL” before a determination by the court from which the subpoena or 15 || order issued, unless the Party has obtained the Designating Party’s permission. The 16 || Designating Party shall bear the burden and expense of seeking protection in that 17 || court of its confidential material and nothing in these provisions should be construed 18 || as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 19 || directive from another court. 20 21 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 22 || PRODUCED IN THIS LITIGATION 23 (a) The terms of this Order are applicable to information produced by a 24 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 25 || produced by Non-Parties in connection with this litigation is protected by the 26 || remedies and relief provided by this Order. Nothing in these provisions should be 27 || construed as prohibiting a Non-Party from seeking additional protections. 28

1 (b) In the event that a Party is required, by a valid discovery request, to 2 || produce a Non-Party’s confidential information in its possession, and the Party is 3 || subject to an agreement with the Non-Party not to produce the Non-Party’s 4 || confidential information, then the Party shall: 5 (1) promptly notify in writing the Requesting Party and the Non- 6 Party that some or all of the information requested is subject to a confidentiality 7 agreement with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a 10 reasonably specific description of the information requested; and 1] (3) make the information requested available for inspection by the 12 Non-Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 || 14 days of receiving the notice and accompanying information, the Receiving Party 15 || may produce the Non-Party’s confidential information responsive to the discovery 16 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall not 17 || produce any information in its possession or control that is subject to the 18 || confidentiality agreement with the Non-Party before a determination by the court. 19 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 20 || of seeking protection in this court of its Protected Material. 21 22 |}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 || Protected Material to any person or in any circumstance not authorized under this 25 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 27 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 28 || persons to whom unauthorized disclosures were made of all the terms of this Order, 1,

1 || and (d) request such person or persons to execute the “Acknowledgment and 2 || Agreement to Be Bound” that 1s attached hereto as Exhibit A. 3 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 Federal Rule of Civil 9 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 || may be established in an e-discovery order that provides for production without prior 11 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 || parties reach an agreement on the effect of disclosure of a communication or 13 || information covered by the attorney-client privilege or work product protection, the 14 || parties may incorporate their agreement in the stipulated protective order submitted to 15 || the court. 16 17 ||} 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 19 || person to seek its modification by the Court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 || Protective Order no Party waives any right it otherwise would have to object to 22 || disclosing or producing any information or item on any ground not addressed in this 23 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 || ground to use in evidence of any of the material covered by this Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 27 || only be filed under seal pursuant to a court order authorizing the sealing of the 28 || specific Protected Material at issue. If a Party's request to file Protected Material 1c

1 || under seal is denied by the court, then the Receiving Party may file the information in 2 || the public record unless otherwise instructed by the court. 3 4 ||13. FINAL DISPOSITION 5 After the final disposition of this Action, as defined in paragraph 4, within 60 6 || days of a written request by the Designating Party, each Receiving Party must return 7 || all Protected Material to the Producing Party or destroy such material. As used in this 8 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 || summaries, and any other format reproducing or capturing any of the Protected 10 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party 11 || must submit a written certification to the Producing Party (and, if not the same person 12 || or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 13 || category, where appropriate) all the Protected Material that was returned or destroyed 14 || and (2) affirms that the Receiving Party has not retained any copies, abstracts, 15 || compilations, summaries or any other format reproducing or capturing any of the 16 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 17 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 18 || legal memoranda, correspondence, deposition and trial exhibits, expert reports, 19 || attorney work product, and consultant and expert work product, even if such materials 20 || contain Protected Material. Any such archival copies that contain or constitute 21 || Protected Material remain subject to this Protective Order as set forth in Section 4 22 || (DURATION). 23 || 14. Any violation of this Order may be punished by any and all appropriate 24 || measures including, without limitation, contempt proceedings and/or monetary 25 || sanctions. 26 |] // 27 || // 28 || ec

1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 || Dated: January 3, 2022 4 5 || COUNSEL FOR PLAINTIFF: 6 TESSER | GROSSMAN LLP 7 BRANDON M. TESSER

ROBERT PAREDES

8 9 10 By__/s/ Brandon Tesser 11 BRANDON M. TESSER Attorneys for Plaintiff Seth Gordon 12 Dated: January 3, 2022 14 15 || COUNSEL FOR DEFENDANTS: 16 FAYER GIPSON LLP

ELLIOT B. GIPSON

7 MICHELLE K. MILLARD 18 By___/s/ Michelle K. Millard

MICHELLE K. MILLARD

19 Attorneys for Defendant Create Music Group, 0 Inc.” 21 FOX ROTHSCHILD LLP 22 TIMOTHY MATSON

NONA YEGAZARIAN

23 24 By __/s/ Nona Negazarian_ 25 NONA YEGAZARIAN Attorneys for Defendant Ten Thousand Projects, LLC 27 — 28 * Pursuant to Local Rule 5-4.3.4(2), the filer attests that all signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing.

1 2 3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED: 4 5 DATED: January 4 2022 6 7 /S/ John E. McDermott 8 United States Magistrate Judge 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 1, [print or type full name], of 5 [print or type full address], declare under penalty of perjury that 6 || 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 || [date] in the case of [insert formal name of the case and the number 9 || and initials assigned to it by the court]. I agree to comply with and to be bound by 10 || all the terms of this Stipulated Protective Order and I understand and acknowledge 11 || 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 for 16 || the purpose of enforcing the terms of this Stipulated Protective Order, even if such 17 || enforcement 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 21 || this action or any proceedings related to enforcement of this Stipulated Protective 22 || Order. 23 || Date: 24 || City and State where sworn and signed: 25 26 || Printed name: 27 28 || Signature: aA