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1 Todd M. Friedman (SBN 216752) Adrian R. Bacon (SBN 280332) Meghan E. George (SBN 274525) 2 Thomas E. Wheeler (SBN 308789)

LAW OFFICES OF TODD M. FRIEDMAN, P.C.

3 21031 Ventura Blvd, Suite 340 Woodland Hills, CA 91364 4 Phone: 323-306-4234s Fax: 866-633-0228 5 tfriedman@toddflaw.com abacon@toddflaw.com mgeorge@toddflaw.com 6 twheeler@toddflaw.com Attorneys for Plaintiffs, and all others similarly situated 7

UNITED STATES DISTRICT COURT

8

9 CENTRAL DISTRICT OF CALIFORNIA

10 EDWIN BAZARGANFARD and Case No. 2:21-CV-02272-CBM-PLAx 11 B thA emR sA eK lv eG s O anL dA aN ll, oo tn h eb re sh sa il mf o ilf a rly

situated, 12

13 Plaintiffs, STIPULATED PROTECTIVE v. ORDER 14

CLUB 360 LLC; ABC FINANCIAL

SERVICES, LLC; JEHANGIR

15 MEHER, and DOES 1 – 10,

16 Defendants,

17

18

I. PURPOSES AND LIMITATIONS

19 A. Discovery in this action is likely to involve production of 20 21 confidential, proprietary, or private information for which special 22 protection from public disclosure and from use for any purpose other 23 than prosecuting this litigation may be warranted. Accordingly, the 24 1

STIPULATED PROTECTIVE ORDER

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1 parties hereby stipulate to and petition the Court to enter the 2 following Stipulated Protective Order. The parties acknowledge that 3 this Order does not confer blanket protections on all disclosures or 4 responses to discovery and that the protection it affords from public 5 disclosure and use extends only to the limited information or items 6 7 that are entitled to confidential treatment under the applicable legal 8 principles. The parties further acknowledge, as set forth in Section 9 XIII(C), below, that this Stipulated Protective Order does not entitle 10 them to file confidential information under seal; Civil Local Rule 79- 11 5 sets forth the procedures that must be followed and the standards 12 that will be applied when a party seeks permission from the Court to 13 14 file material under seal. 15 II. GOOD CAUSE STATEMENT 16 A. This action is likely to involve trade secrets, customer and 17 pricing lists and other valuable research, development, commercial, 18 financial, technical and/or proprietary information for which special 19 protection from public disclosure and from use for any purpose other 20 21 than prosecution of this action is warranted. Such confidential and 22 proprietary materials and information consist of, among other 23 things, confidential business or financial information, information 24 2

STIPULATED PROTECTIVE ORDER

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1 regarding confidential business practices, or other confidential 2 research, development, or commercial information (including 3 information implicating privacy rights of third parties), information 4 otherwise generally unavailable to the public, or which may be 5 privileged or otherwise protected from disclosure under state or 6 7 federal statutes, court rules, case decisions, or common law. 8 Accordingly, to expedite the flow of information, to facilitate the 9 prompt resolution of disputes over confidentiality of discovery 10 materials, to adequately protect information the parties are entitled 11 to keep confidential, to ensure that the parties are permitted 12 reasonable necessary uses of such material in preparation for and in 13 14 the conduct of trial, to address their handling at the end of the 15 litigation, and serve the ends of justice, a protective order for such 16 information is justified in this matter. It is the intent of the parties 17 that information will not be designated as confidential for tactical 18 reasons and that nothing be so designated without a good faith belief 19 that it has been maintained in a confidential, non-public manner, 20 21 and there is good cause why it should not be part of the public record 22 of this case. 23 24 3

STIPULATED PROTECTIVE ORDER

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1 III. DEFINITIONS 2 A. Action: This pending federal lawsuit 3 B. Challenging Party: A Party or Non-Party that challenges the 4 designation of information or items under this Order. 5 C. “CONFIDENTIAL” Information or Items: Information 6 7 (regardless of how it is generated, stored or maintained) or tangible 8 things that qualify for protection under Federal Rule of Civil 9 Procedure 26(c), and as specified above in the Good Cause 10 Statement. 11 D. Counsel: Outside Counsel of Record and House Counsel (as 12 well as their support staff). 13 14 E. Designating Party: A Party or Non-Party that designates 15 information or items that it produces in disclosures or in responses 16 to discovery as “CONFIDENTIAL.” 17 F. Disclosure or Discovery Material: All items or information, 18 regardless of the medium or manner in which it is generated, stored, 19 or maintained (including, among other things, testimony, 20 21 transcripts, and tangible things), that are produced or generated in 22 disclosures or responses to discovery in this matter. 23 24 4

STIPULATED PROTECTIVE ORDER

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1 G. Expert: A person with specialized knowledge or experience in 2 a matter pertinent to the litigation who has been retained by a Party 3 or its counsel to serve as an expert witness or as a consultant in this 4 Action. 5 H. House Counsel: Attorneys who are employees of a party to this 6 7 Action. House Counsel does not include Outside Counsel of Record 8 or any other outside counsel. 9 I. Non-Party: Any natural person, partnership, corporation, 10 association, or other legal entity not named as a Party to this action. 11 J. Outside Counsel of Record: Attorneys who are not employees 12 of a party to this Action but are retained to represent or advise a 13 14 party to this Action and have appeared in this Action on behalf of 15 that party or are affiliated with a law firm which has appeared on 16 behalf of that party, and includes support staff. 17 K. Party: Any party to this Action, including all of its officers, 18 directors, employees, consultants, retained experts, and Outside 19 Counsel of Record (and their support staffs). 20 21 L. Producing Party: A Party or Non-Party that produces 22 Disclosure or Discovery Material in this Action. 23 24 5

STIPULATED PROTECTIVE ORDER

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1 M. Professional Vendors: Persons or entities that provide 2 litigation support services (e.g., photocopying, videotaping, 3 translating, preparing exhibits or demonstrations, and organizing, 4 storing, or retrieving data in any form or medium) and their 5 employees and subcontractors. 6 7 N. Protected Material: Any Disclosure or Discovery Material that 8 is designated as “CONFIDENTIAL.” 9 O. Receiving Party: A Party that receives Disclosure or Discovery 10 Material from a Producing Party. 11

IV. SCOPE

12 A. The protections conferred by this Stipulation and Order cover 13 14 not only Protected Material (as defined above), but also (1) any 15 information copied or extracted from Protected Material; (2) all 16 copies, excerpts, summaries, or compilations of Protected Material; 17 and (3) any testimony, conversations, or presentations by Parties or 18 their Counsel that might reveal Protected Material. 19 B. Any use of Protected Material at trial shall be governed by the 20 21 orders of the trial judge. This Order does not govern the use of Protected 22 Material at trial. 23 24 6

STIPULATED PROTECTIVE ORDER

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1 V. DURATION 2 A. Once a case proceeds to trial, all of the information that was 3 designated as confidential or maintained pursuant to this Protective 4 Order becomes public and will be presumptively available to all 5 members of the public, including the press, unless compelling 6 7 reasons supported by specific factual findings to proceed otherwise 8 are made to the trial judge in advance of the trial. See Kamakana v. 9 City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 10 (distinguishing “good cause” showing for sealing documents 11 produced in discovery from “compelling reasons” standard when 12 merits-related documents are part of court record). Accordingly, the 13 14 terms of this Protective Order do not extend beyond the 15 commencement of the trial. 16 VI. DESIGNATING PROTECTED MATERIAL 17 A. Exercise of Restraint and Care in Designating Material for 18 Protection 19 1. Each Party or Non-Party that designates information or 20 21 items for protection under this Order must take care to limit 22 any such designation to specific material that qualifies under 23 the appropriate standards. The Designating Party must 24 7

STIPULATED PROTECTIVE ORDER

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1 designate for protection only those parts of material, 2 documents, items, or oral or written communications that 3 qualify so that other portions of the material, documents, 4 items, or communications for which protection is not 5 warranted are not swept unjustifiably within the ambit of this 6 7 Order. 8 2. Mass, indiscriminate, or routinized designations are 9 prohibited. Designations that are shown to be clearly 10 unjustified or that have been made for an improper purpose 11 (e.g., to unnecessarily encumber the case development process 12 or to impose unnecessary expenses and burdens on other 13 14 parties) may expose the Designating Party to sanctions. 15 3. If it comes to a Designating Party’s attention that 16 information or items that it designated for protection do not 17 qualify for protection, that Designating Party must promptly 18 notify all other Parties that it is withdrawing the inapplicable 19 designation. 20 21 B. Manner and Timing of Designations 22 1. Except as otherwise provided in this Order (see, e.g., 23 Section B(2)(b) below), or as otherwise stipulated or ordered, 24 8

STIPULATED PROTECTIVE ORDER

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1 Disclosure or Discovery Material that qualifies for protection 2 under this Order must be clearly so designated before the 3 material is disclosed or produced. 4 2. Designation in conformity with this Order requires the 5 following: 6 7 a. For information in documentary form (e.g., paper 8 or electronic documents, but excluding transcripts of 9 depositions or other pretrial or trial proceedings), that 10 the Producing Party affix at a minimum, the legend 11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL 12 legend”), to each page that contains protected material. 13 14 If only a portion or portions of the material on a page 15 qualifies for protection, the Producing Party also must 16 clearly identify the protected portion(s) (e.g., by making 17 appropriate markings in the margins). 18 b. A Party or Non-Party that makes original 19 documents available for inspection need not designate 20 21 them for protection until after the inspecting Party has 22 indicated which documents it would like copied and 23 produced. During the inspection and before the 24 9

STIPULATED PROTECTIVE ORDER

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1 designation, all of the material made available for 2 inspection shall be deemed “CONFIDENTIAL.” After the 3 inspecting Party has identified the documents it wants 4 copied and produced, the Producing Party must 5 determine which documents, or portions thereof, qualify 6 7 for protection under this Order. Then, before producing 8 the specified documents, the Producing Party must affix 9 the “CONFIDENTIAL legend” to each page that contains 10 Protected Material. If only a portion or portions of the 11 material on a page qualifies for protection, the Producing 12 Party also must clearly identify the protected portion(s) 13 14 (e.g., by making appropriate markings in the margins). 15 c. For testimony given in depositions, that the 16 Designating Party identify the Disclosure or Discovery 17 Material on the record, before the close of the deposition 18 all protected testimony. 19 d. For information produced in form other than 20 21 document and for any other tangible items, that the 22 Producing Party affix in a prominent place on the 23 exterior of the container or containers in which the 24 10

STIPULATED PROTECTIVE ORDER

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1 information is stored the legend “CONFIDENTIAL.” If 2 only a portion or portions of the information warrants 3 protection, the Producing Party, to the extent practicable, 4 shall identify the protected portion(s). 5 C. Inadvertent Failure to Designate 6 7 1. If timely corrected, an inadvertent failure to designate 8 qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this 10 Order for such material. Upon timely correction of a 11 designation, the Receiving Party must make reasonable efforts 12 to assure that the material is treated in accordance with the 13 14 provisions of this Order. 15 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 A. Timing of Challenges 17 1. Any party or Non-Party may challenge a designation of 18 confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 21 B. Meet and Confer 22 1. The Challenging Party shall initiate the dispute 23 resolution process under Local Rule 37.1 et seq. 24 11

STIPULATED PROTECTIVE ORDER

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1 C. The burden of persuasion in any such challenge proceeding 2 shall be on the Designating Party. Frivolous challenges, and those 3 made for an improper purpose (e.g., to harass or impose unnecessary 4 expenses and burdens on other parties) may expose the Challenging 5 Party to sanctions. Unless the Designating Party has waived or 6 7 withdrawn the confidentiality designation, all parties shall continue 8 to afford the material in question the level of protection to which it is 9 entitled under the Producing Party’s designation until the Court rules 10 on the challenge. 11

VIII. ACCESS TO AND USE OF PROTECTED MATERIAL

12 A. Basic Principles 13 14 1. A Receiving Party may use Protected Material that is 15 disclosed or produced by another Party or by a Non-Party in 16 connection with this Action only for prosecuting, defending, or 17 attempting to settle this Action. Such Protected Material may 18 be disclosed only to the categories of persons and under the 19 conditions described in this Order. When the Action has been 20 21 terminated, a Receiving Party must comply with the provisions 22 of Section XIV below. 23 24 12

STIPULATED PROTECTIVE ORDER

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1 2. Protected Material must be stored and maintained by a 2 Receiving Party at a location and in a secure manner that 3 ensures that access is limited to the persons authorized under 4 this Order. 5 B. Disclosure of “CONFIDENTIAL” Information or Items 6 7 1. Unless otherwise ordered by the Court or permitted in 8 writing by the Designating Party, a Receiving Party may 9 disclose any information or item designated 10 “CONFIDENTIAL” only to: 11 a. The Receiving Party’s Outside Counsel of Record in 12 this Action, as well as employees of said Outside Counsel 13 14 of Record to whom it is reasonably necessary to disclose 15 the information for this Action; 16 b. The officers, directors, and employees (including 17 House Counsel) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action; 19 c. Experts (as defined in this Order) of the Receiving 20 21 Party to whom disclosure is reasonably necessary for this 22 Action and who have signed the “Acknowledgment and 23 Agreement to Be Bound” (Exhibit A); 24 13

STIPULATED PROTECTIVE ORDER

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1 d. The Court and its personnel; 2 e. Court reporters and their staff; 3 f. Professional jury or trial consultants, mock jurors, 4 and Professional Vendors to whom disclosure is 5 reasonably necessary or this Action and who have signed 6 7 the “Acknowledgment and Agreement to be Bound” 8 attached as Exhibit A hereto; 9 g. The author or recipient of a document containing 10 the information or a custodian or other person who 11 otherwise possessed or knew the information; 12 h. During their depositions, witnesses, and attorneys 13 14 for witnesses, in the Action to whom disclosure is 15 reasonably necessary provided: (i) the deposing party 16 requests that the witness sign the “Acknowledgment and 17 Agreement to Be Bound;” and (ii) they will not be 18 permitted to keep any confidential information unless 19 they sign the “Acknowledgment and Agreement to Be 20 21 Bound,” unless otherwise agreed by the Designating 22 Party or ordered by the Court. Pages of transcribed 23 deposition testimony or exhibits to depositions that 24 14

STIPULATED PROTECTIVE ORDER

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1 reveal Protected Material may be separately bound by the 2 court reporter and may not be disclosed to anyone except 3 as permitted under this Stipulated Protective Order; and 4 i. Any mediator or settlement officer, and their 5 supporting personnel, mutually agreed upon by any of 6 7 the parties engaged in settlement discussions. 8 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED 9 PRODUCED IN OTHER LITIGATION 10 A. If a Party is served with a subpoena or a court order issued in 11 other litigation that compels disclosure of any information or items 12 designated in this Action as “CONFIDENTIAL,” that Party must: 13 14 1. Promptly notify in writing the Designating Party. Such 15 notification shall include a copy of the subpoena or court order; 16 2. Promptly notify in writing the party who caused the 17 subpoena or order to issue in the other litigation that some or 18 all of the material covered by the subpoena or order is subject 19 to this Protective Order. Such notification shall include a copy 20 21 of this Stipulated Protective Order; and 22 23 24 15

STIPULATED PROTECTIVE ORDER

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1 3. Cooperate with respect to all reasonable procedures 2 sought to be pursued by the Designating Party whose Protected 3 Material may be affected. 4 B. If the Designating Party timely seeks a protective order, the 5 Party served with the subpoena or court order shall not produce any 6 7 information designated in this action as “CONFIDENTIAL” before a 8 determination by the Court from which the subpoena or order 9 issued, unless the Party has obtained the Designating Party’s 10 permission. The Designating Party shall bear the burden and 11 expense of seeking protection in that court of its confidential 12 material and nothing in these provisions should be construed as 13 14 authorizing or encouraging a Receiving Party in this Action to 15 disobey a lawful directive from another court. 16 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17

PRODUCED IN THIS LITIGATION

18 A. The terms of this Order are applicable to information produced 19 by a Non-Party in this Action and designated as “CONFIDENTIAL.” 20 21 Such information produced by Non-Parties in connection with this 22 litigation is protected by the remedies and relief provided by this 23 24 16

STIPULATED PROTECTIVE ORDER

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1 Order. Nothing in these provisions should be construed as 2 prohibiting a Non-Party from seeking additional protections. 3 B. In the event that a Party is required, by a valid discovery 4 request, to produce a Non-Party’s confidential information in its 5 possession, and the Party is subject to an agreement with the Non- 6 7 Party not to produce the Non-Party’s confidential information, then 8 the Party shall: 9 1. Promptly notify in writing the Requesting Party and the 10 Non-Party that some or all of the information requested is 11 subject to a confidentiality agreement with a Non-Party; 12 2. Promptly provide the Non-Party with a copy of the 13 14 Stipulated Protective Order in this Action, the relevant 15 discovery request(s), and a reasonably specific description of 16 the information requested; and 17 3. Make the information requested available for inspection 18 by the Non-Party, if requested. 19 C. If the Non-Party fails to seek a protective order from this court 20 21 within 14 days of receiving the notice and accompanying 22 information, the Receiving Party may produce the Non-Party’s 23 confidential information responsive to the discovery request. If the 24 17

STIPULATED PROTECTIVE ORDER

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1 Non-Party timely seeks a protective order, the Receiving Party shall 2 not produce any information in its possession or control that is 3 subject to the confidentiality agreement with the Non-Party before a 4 determination by the court. Absent a court order to the contrary, the 5 Non-Party shall bear the burden and expense of seeking protection 6 7 in this court of its Protected Material. 8 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED 9 MATERIAL 10 A. If a Receiving Party learns that, by inadvertence or otherwise, it 11 has disclosed Protected Material to any person or in any 12 circumstance not authorized under this Stipulated Protective Order, 13 14 the Receiving Party must immediately (1) notify in writing the 15 Designating Party of the unauthorized disclosures, (2) use its best 16 efforts to retrieve all unauthorized copies of the Protected Material, 17 (3) inform the person or persons to whom unauthorized disclosures 18 were made of all the terms of this Order, and (4) request such person 19 or persons to execute the “Acknowledgment and Agreement to be 20 21 Bound” that is attached hereto as Exhibit A. 22 23 24 18

STIPULATED PROTECTIVE ORDER

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1 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR 2 OTHERWISE PROTECTED MATERIAL 3 A. When a Producing Party gives notice to Receiving Parties that 4 certain inadvertently produced material is subject to a claim of 5 privilege or other protection, the obligations of the Receiving Parties 6 7 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 This provision is not intended to modify whatever procedure may be 9 established in an e-discovery order that provides for production 10 without prior privilege review. Pursuant to Federal Rule of Evidence 11 502(d) and (e), insofar as the parties reach an agreement on the 12 effect of disclosure of a communication or information covered by 13 14 the attorney-client privilege or work product protection, the parties 15 may incorporate their agreement in the Stipulated Protective Order 16 submitted to the Court. 17

XIII. MISCELLANEOUS

18 A. Right to Further Relief 19 1. Nothing in this Order abridges the right of any person to 20 21 seek its modification by the Court in the future. 22 B. Right to Assert Other Objections 23 24 19

STIPULATED PROTECTIVE ORDER

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1 1. By stipulating to the entry of this Protective Order, no 2 Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground 4 not addressed in this Stipulated Protective Order. Similarly, no 5 Party waives any right to object on any ground to use in 6 7 evidence of any of the material covered by this Protective 8 Order. 9 C. Filing Protected Material 10 1. A Party that seeks to file under seal any Protected 11 Material must comply with Civil Local Rule 79-5. Protected 12 Material may only be filed under seal pursuant to a court order 13 14 authorizing the sealing of the specific Protected Material at 15 issue. If a Party's request to file Protected Material under seal 16 is denied by the Court, then the Receiving Party may file the 17 information in the public record unless otherwise instructed by 18 the Court. 20 21 A. After the final disposition of this Action, as defined in Section 22 V, within sixty (60) days of a written request by the Designating 23 Party, each Receiving Party must return all Protected Material to the 24 20

STIPULATED PROTECTIVE ORDER

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1 Producing Party or destroy such material. As used in this 2 subdivision, “all Protected Material” includes all copies, abstracts, 3 compilations, summaries, and any other format reproducing or 4 capturing any of the Protected Material. Whether the Protected 5 Material is returned or destroyed, the Receiving Party must submit a 6 7 written certification to the Producing Party (and, if not the same 8 person or entity, to the Designating Party) by the 60 day deadline 9 that (1) identifies (by category, where appropriate) all the Protected 10 Material that was returned or destroyed and (2) affirms that the 11 Receiving Party has not retained any copies, abstracts, compilations, 12 summaries or any other format reproducing or capturing any of the 13 14 Protected Material. Notwithstanding this provision, Counsel are 15 entitled to retain an archival copy of all pleadings, motion papers, 16 trial, deposition, and hearing transcripts, legal memoranda, 17 correspondence, deposition and trial exhibits, expert reports, 18 attorney work product, and consultant and expert work product, 19 even if such materials contain Protected Material. Any such archival 20 21 copies that contain or constitute Protected Material remain subject 22 to this Protective Order as set forth in Section V. 23 24 21

STIPULATED PROTECTIVE ORDER

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1 B. — Any violation of this Order may be punished by any and all 2 appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 5 7 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated:_May 26, 2022 /s/ Todd M. Friedman 9 Todd M. Friedman 10 Attorneys for Plaintiffs

11 Dated: May 26, 2022 /s/ Hassan Elrakabawy 12 Attorneys for Defendants 13 14 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 15 Galex< - Marmot Dated: May 31, 2022 16 HONORABLE PAUL L. ABRAMS 17 United States Magistrate Judge 18 19 20 21 29 23 24 22

STIPULATED PROTECTIVEORDER.

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1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

3 I, [print or type full name], of 4 [print or type full address], declare under penalty of 5 perjury that I have read in its entirety and understand the Stipulated 6 7 Protective Order that was issue by the United States District Court for the 8 Central District of California on [DATE] in the case of 9 [insert formal name of the case and the number and initials 10 assigned to it by the Court]. I agree to comply with and to be bound by all 11 the terms of this Stipulated Protective Order and I understand and 12 acknowledge that failure to so comply could expose me to sanctions and 13 14 punishment in the nature of contempt. I solemnly promise that I will not 15 disclose in any manner any information or item that is subject to this 16 Stipulated Protective Order to any person or entity except in strict 17 compliance with the provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 21 enforcing the terms of this Stipulated Protective Order, even if such 22 enforcement proceedings occur after termination of this action. I hereby 23 appoint [print or type full name] of 24 23

STIPULATED PROTECTIVE ORDER

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1 [print or type full address and telephone number] as my 2 California agent for service of process in connection with this action or any 3 proceedings related to enforcement of this Stipulated Protective Order. 4 Date: 5 City and State where sworn and signed: 6 7 Printed Name: 8 Signature: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 24

STIPULATED PROTECTIVE ORDER