Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page1lof15 Page ID #:1364

] 3 UNITED STATES DISTRICT COURT 4 CENTRAL DISTRICT OF CALIFORNIA ° JOSE VASQUEZ, individually and Case No. 2:21-cv-0693-FMO-ASx 6 on behalf of all those similarly CLASS ACTION 7 situated,

STIPULATED PROTECTIVE

8 Plaintiff, ORDER 9 Judge: Fernando M. Olguin 10 DRAPER AND KRAMER MORTGAGE CORP., Complaint filed: 9/22/2020 11 Trial Date: TBD Defendants, 12 13 4 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this

1 Order does not confer blanket protections on all disclosures or responses to

0 discovery and that the protection it affords from public disclosure and use extends

33 only to the limited information or items that are entitled to confidential treatment

oA under the applicable legal principles. The parties further acknowledge, as set forth in

35 Section 12.3, below, that this Stipulated Protective Order does not entitle them to

6 file confidential information under seal; Civil Local Rule 79-5 sets forth the

4 procedures that must be followed and the standards that will be applied when a party 3g seeks permission from the court to file material under seal.

TIMOTHY P. RUMDERGER

Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page2of15 Page ID #:1365

1 B. GOOD CAUSE STATEMENT This action is likely to involve putative class and collective action member 3 |lidentities and contact information, wage and hour data, or other valuable 4 commercial, financial, technical and/or proprietary information for which special > protection from public disclosure and from use for any purpose other than 6 prosecution of this action is warranted. Such confidential and proprietary materials 7 |land information consist of, among other things, confidential business or financial 8 information, information regarding confidential business practices, or other ? || confidential research, development, or commercial information (including 10" || information implicating privacy rights of third parties), information otherwise i generally unavailable to the public, or which may be privileged or otherwise V2 protected from disclosure under state or federal statutes, court rules, case decisions, '3 ll or common law. Accordingly, to expedite the flow of information, to facilitate the M4 prompt resolution of disputes over confidentiality of discovery materials, to 9 adequately protect information the parties are entitled to keep confidential, to ensure 16 that the parties are permitted reasonable necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of the 18 litigation, and serve the ends of justice, a protective order for such information is 9 justified in this matter. It is the intent of the parties that information will not be 20 designated as confidential for tactical reasons and that nothing be so designated 2! without a good faith belief that it has been maintained in a confidential, non-public 22 manner, and there is good cause why it should not be part of the public record of this °° case. 2. DEFINITIONS » 2.1 Action: This pending federal law suit, Jose Vasquez, individually and on *6 behalf of all those similarly situated, v. Draper and Kramer Mortgage Corp. or Case No. 2:21-cv-00693-FMO-AS. 28

TIMOTHY P. RUMDERGER

1339 Bay Street as0) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page3of15 Page ID #:1366

1 2.2 Challenging Party: A Party or Non-Party that challenges the designation 2 of information or items under this Order. 3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 4 how it is generated, stored or maintained) or tangible things that qualify for 5 protection under Federal Rule of Civil Procedure 26(c), and as specified 6 above in the Good Cause Statement. 7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 8 support staff). 9 2.5 Designating Party: a Party or Non-Party that designates information or 10 items that it produces in disclosures or in responses to discovery as 11 “CONFIDENTIAL.” 12 2.6 Disclosure or Discovery Material: all items or information, regardless of 13 the medium or manner in which it is generated, stored, or maintained 14 (including, among other things, testimony, transcripts, and tangible things), 15 that are produced or generated in disclosures or responses to discovery in this 16 matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to 19 serve as an expert witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other 22 outside counsel. 23 2.9 Non-Party: any natural person, partnership, corporation, association, or 24 other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees of a party 26 to this Action but are retained to represent or advise a party to this Action and 27 have appeared in this Action on behalf of that party or are affiliated with a 28

TIMOTHY P. RUMDERGER

1339 Bay Street as0) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page4of15 Page ID #:1367

1 law firm which has appeared on behalf of that party, and includes support 2 staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and 5 their support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or 1] medium) and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 7 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 ||Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 31 ||compilations of Protected Material; and (3) any testimony, conversations, or 39 ||presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 94 ||trial judge. This Order does not govern the use of Protected Material at trial. 25 4. DURATION *° Once a case proceeds to trial, all of the information that was designated as confidential or maintained pursuant to this protective order becomes public and will swore 1339 Bay Street as0) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page5of15 Page ID #:1368

1 ||be presumptively available to all members of the public, including the press, unless 2 ||compelling reasons supported by specific factual findings to proceed otherwise are 3 ||made to the trial judge in advance of the trial. See Kamakana v. City and County of 4 || Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 5 ||showing for sealing documents produced in discovery from “compelling reasons” 6 ||standard when merits-related documents are part of court record). Accordingly, the 7 ||terms of this protective order do not extend beyond the commencement of the trial. 8 5. DESIGNATING PROTECTED MATERIAL 9 5.1 Exercise of Restraint and Care in Designating Material for Protection 10 Each Party or Non-Party that designates information or items for protection 11 ||under this Order must take care to limit any such designation to specific material 12 ||that qualifies under the appropriate standards. The Designating Party must designate 13 ||for protection only those parts of material, documents, items, or oral or written 14 |}communications that qualify so that other portions of the material, documents, 15 ||items, or communications for which protection is not warranted are not swept 16 |/unjustifiably within the ambit of this Order. 17 Mass, indiscriminate, or routinized designations are prohibited. Designations 18 ||that are shown to be clearly unjustified or that have been made for an improper 19 || purpose (e.g., to unnecessarily encumber the case development process or to impose 20 □□ unnecessary expenses and burdens on other parties) may expose the Designating 21 ||Party to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it 23 ||designated for protection do not qualify for protection, that Designating Party must 24 |!promptly notify all other Parties that it is withdrawing the inapplicable designation. 25 26 5.2 Manner and Timing of Designations. Except as otherwise provided in 27 ||this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 28 ||stipulated or ordered, Disclosure or Discovery Material that qualifies for protection as0) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page6of15 Page ID #:1369

1 |{under this Order must be clearly so designated before the material is disclosed or 2 ||produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, 5 ||but excluding transcripts of depositions or other pretrial or trial proceedings), that 6 ||the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 7 ||“CONFIDENTIAL legend”), to each page that contains protected material. If only a 8 ||portion or portions of the material on a page qualifies for protection, the Producing 9 ||Party also must clearly identify the protected portion(s) (e.g., by making appropriate 10 ||markings in the margins). 1] A Party or Non-Party that makes original documents available for inspection 12 ||need not designate them for protection until after the inspecting Party has indicated 13 which documents it would like copied and produced. During the inspection and 14 ||before the designation, all of the material made available for inspection shall be 15 ||deemed “CONFIDENTIAL.” After the inspecting Party has identified the 16 ||documents it wants copied and produced, the Producing Party must determine which 17 |/documents, or portions thereof, qualify for protection under this Order. Then, before 18 || producing the specified documents, the Producing Party must affix the 19 ||“CONFIDENTIAL legend” to each page that contains Protected Material. If only a 20 □□ portion or portions of the material on a page qualifies for protection, the Producing 21 |!Party also must clearly identify the protected portion(s) (e.g., by making appropriate 22 ||markings in the margins). 23 (b) for testimony given in depositions that the Designating Party identify the 24 |!Disclosure or Discovery Material on the record, before the close of the deposition all 25 || protected testimony. 26 (c) for information produced in some form other than documentary and for 27 |\any other tangible items, that the Producing Party affix in a prominent place on the 28

TIMOTHY P. RUMDERGER

Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 7of15 Page ID #:1370

1 ||exterior of the container or containers in which the information is stored the legend 2 ||“CONFIDENTIAL.” If only a portion or portions of the information warrants 3 || protection, the Producing Party, to the extent practicable, shall identify the protected 4 ||portion(s). 5 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 6 ||failure to designate qualified information or items does not, standing alone, waive 7 ||the Designating Party’s right to secure protection under this Order for such material. 8 ||Upon timely correction of a designation, the Receiving Party must make reasonable 9 ||efforts to assure that the material is treated in accordance with the provisions of this 10 }|Order. 11 □ 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

4 designation of confidentiality at any time that is consistent with the Court’s

15 Scheduling Order.

6 6.2 Meet and Confer. The Challenging Party shall initiate the informal v7 dispute resolution process set forth in the Court's Procedures and Schedules. see 18 http://www.cacd.uscourts.gov/honorable-alka-sagar 19 6.3 The burden of persuasion in any such challenge proceeding shall be on 50 the Designating Party. Frivolous challenges, and those made for an improper 51 ||Purpose (e.g., to harass or impose unnecessary expenses and burdens on other > parties) may expose the Challenging Party to sanctions. Unless the Designating 73 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 95 entitled under the Producing Party’s designation until the Court rules on the 26 challenge. 27 28

TIMOTHY P. RUMDERGER

Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 8of15 Page ID #:1371

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

TIMOTHY P. RUMDERGER

Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page9of15 Page ID #:1372

1 || Vendors to whom disclosure is reasonably necessary for this Action and who have 2 ||signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (g) the author or recipient of a document containing the information or a 4 ||custodian or other person who otherwise possessed or knew the information; 5 (h) during their depositions, witnesses, and attorneys for witnesses, in the 6 ||Action to whom disclosure is reasonably necessary provided: (1) the deposing party 7 ||requests that the witness sign the form attached as Exhibit A hereto; and (2) they 8 || will not be permitted to keep any confidential information unless they sign the 9 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 10 ||agreed by the Designating Party or ordered by the court. Pages of transcribed 11 ||deposition testimony or exhibits to depositions that reveal Protected Material may 12 ||be separately bound by the court reporter and may not be disclosed to anyone except 13 ||as permitted under this Stipulated Protective Order; and 14 (1) any mediator or settlement officer, and their supporting personnel, 15 |/mutually agreed upon by any of the parties engaged in settlement discussions. 16 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 8 PRODUCED IN OTHER LITIGATION

19 If a Party is served with a subpoena or a court order issued in other litigation 29 ||that compels disclosure of any information or items designated in this Action as 21 || “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification shall 23 ||include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order to 25 |{1ssue in the other litigation that some or all of the material covered by the subpoena 26 |{or order is subject to this Protective Order. Such notification shall include a copy of 27 ||this Stipulated Protective Order; and 28

TIMOTHY P. RUMDERGER

Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page 10o0f15 Page ID #:1373

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

14 (a) The terms of this Order are applicable to information produced by a Non- 15 || Party in this Action and designated as “CONFIDENTIAL.” Such information 16 ||produced by Non-Parties in connection with this litigation is protected by the 17. |}/remedies and relief provided by this Order. Nothing in these provisions should be 1g |}construed as prohibiting a Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 29 ||produce a Non-Party’s confidential information in its possession, and the Party is 21 ||subject to an agreement with the Non-Party not to produce the Non-Party’s 22 ||confidential information, then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non-Party that 24 ||some or all of the information requested is subject to a confidentiality agreement 25 || with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 27 Order in this Action, the relevant discovery request(s), and a reasonably specific

28 description of the information requested; and TIMOTHY P. RUMBERGER 10 Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page11o0f15 Page ID #:1374

1 (3) make the information requested available for inspection by the Non-Party, 2 {lif requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 4 |\days of receiving the notice and accompanying information, the Receiving Party 5 ||may produce the Non-Party’s confidential information responsive to the discovery 6 ||request. If the Non-Party timely seeks a protective order, the Receiving Party shall 7 ||not produce any information in its possession or control that is subject to the 8 ||confidentiality agreement with the Non-Party before a determination by the court. 9 □□ Absent a court order to the contrary, the Non-Party shall bear the burden and 10 |/expense of seeking protection in this court of its Protected Material. 11 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 ||Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 ||to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 ||persons to whom unauthorized disclosures were made of all the terms of this Order, 19 ||and (d) request such person or persons to execute the “Acknowledgment and 20 ||Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. NADVERTENT PRODUCTION OF PRIVILEGED OR 33 OTHERWISE PROTECTED MATERIAL

74 When a Producing Party gives notice to Receiving Parties that certain 5 |}inadvertently produced material is subject to a claim of privilege or other protection, 26 ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 _ ||Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 4g ||may be established in an e-discovery order that provides for production without TIMOTHY P. RUMDERGER tI Sana Cat STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page12o0f15 Page ID #:1375

1 ||prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 2 |{as the parties reach an agreement on the effect of disclosure of a communication or 3 {information covered by the attorney-client privilege or work product protection, the 4 ||parties may incorporate their agreement in the stipulated protective order submitted 5 ||to the court. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 ||person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 || Protective Order no Party waives any right it otherwise would have to object to 11 |/disclosing or producing any information or item on any ground not addressed in this 12 ||Stipulated Protective Order. Similarly, no Party waives any right to object on any 13 || ground to use in evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 ||Protected Material must comply with Civil Local Rule 79-5. Protected Material may 16 |/only be filed under seal pursuant to a court order authorizing the sealing of the 17 □□ specific Protected Material at issue. If a Party's request to file Protected Material 18 |/under seal is denied by the court, then the Receiving Party may file the information 19 |\in the public record unless otherwise instructed by the court. 20 13. FINAL DISPOSITION 21 |) As an initial matter, Plaintiff Vasquez and his counsel acknowledge that they were 22 ||provided with contact information belonging to all putative collective action 23 ||members as a result of the Court’s order granting them permission to send a notice 24 |/of collective action. Plaintiff Vasquez and his counsel acknowledge and agree that, 25 within 5 business days of executing this stipulated protective order, they will destroy 26 |/the contact information, whether maintained in electronic or physical form, 27 28 TIMOTHY P. RUMDERGER 12 1339 Bay Street Sensi) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page130f15 Page ID #:1376

1 ||concerning any putative collective action member who did not opt into the FLSA 2 |{collective or is not a Rule 23 putative class member. 3 In addition to the aforementioned representation, after the final disposition of 4 ||this Action, as defined in paragraph 4, within 60 days of a written request by the 5 ||Designating Party, each Receiving Party must return all Protected Material to the 6 ||Producing Party or destroy such material. As used in this subdivision, “all Protected 7 Material” includes all copies, abstracts, compilations, summaries, and any other 8 ||format reproducing or capturing any of the Protected Material. Whether the 9 ||Protected Material is returned or destroyed, the Receiving Party must submit a 10 || written certification to the Producing Party (and, if not the same person or entity, to 11 ||the Designating Party) by the 60 day deadline that (1) identifies (by category, where 12 ||appropriate) all the Protected Material that was returned or destroyed and (2)affirms 13 ||that the Receiving Party has not retained any copies, abstracts, compilations, 14 |!summaries or any other format reproducing or capturing any of the Protected 15 ||Material. Notwithstanding this provision, Counsel are entitled to retain an archival 16 |Ilcopy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 17 |}memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 18 |) work product, and consultant and expert work product, even if such materials 19 ||contain Protected Material. Any such archival copies that contain or 20 |/constitute Protected Material remain subject to this Protective Order as set forth in 21 |)/Section 4 (DURATION). 22 14. Any violation of this Order may be punished by any and all appropriate 23 ||measures including, without limitation, contempt proceedings and/or monetary 24 sanctions. 25 *° IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 27 28 TIMOTHY P. RUMDERGER 13 1339 Bay Street as0) 841-3500 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page14o0f15 Page ID #:1377

] 5 Counsel for Defendant Draper & Kramer Mortgage Corp. Dated: June 2022 = 5 McDERMOTT WILL & EMERY LLP ‘ Ronald J. Holland, Esq. Christopher A. Braham, Esq. 7 Brian Casillas, Esq. 10 Counsel for Plaintiff and Class Counsel for all Conditionally Certified Class Members 11 12 Dated: June 23, 2022 13 Timothy P. Rumberger, Es 4 Kevin R. Allen, Esq. 15 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 ||Dated: 06/28/2022 /S/ 20 Honorable Alka Sagar United States Magistrate Judge 21 22 23 24 25 26 27 28 TIMOTHY > CuMEeROER 1 4 “ens 84100 STIPULATED PROTECTIVE ORDER

Case 2:21-cv-00693-FMO-AS Document 94 Filed 06/28/22 Page15o0f15 Page ID #:1378

1 EXHIBIT A 5 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print 5 |]or type full address], declare under penalty of perjury that I have read in its entirety 6 ||and understand the Stipulated Protective Order that was issue by the United States 7 || District Court for the Central District of California on in the case of 8 ||Jose Vasquez, individually and on behalf of all those similarly situated, v. Draper 9 ||and Kramer Mortgage Corp. Case No. 2:21-cv-00693-FMO-AS. I agree to 10 ||comply with and to be bound by all the terms of this Stipulated Protective Order and 11 |/I understand and acknowledge that failure to so comply could expose me to 12 ||sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 |/not disclose in any manner any information or item that is subject to this Stipulated 14 ||Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 || for the Central District of California for the purpose of enforcing the terms of this 18 || Stipulated Protective Order, even if such enforcement proceedings occur after 19 ||termination of this action. I hereby appoint [print or type 20 |! full name] of [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 || Date: 25 ||City and State where sworn and signed: 26 Printed Name: 27 28 Signature: TIMOTHY P. RUMDERGER 15 Sana Cat STIPULATED PROTECTIVE ORDER