Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 1 of 18 Page ID #:1151

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA

SOUTHERN DIVISION

3 4

TREVOR BAUER,

5 Case No. 8:22-cv-00868-JVS-ADSx 6 Plaintiff, Assigned for all purposes to the Hon. James V. Selna 7 v. 8

STIPULATED PROTECTIVE

LINDSEY C. HILL and NIRANJAN 9 ORDER

FRED THIAGARAJAH,

10 11 Defendants. 12 13 14 15 16 17 1. INTRODUCTION 18 1.1 PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary, or private information for which special protection from public disclosure 21 and from use for any purpose other than in connection with this litigation. 22 Accordingly, the parties hereby stipulate to and petition the Court to enter the 23 following Stipulated Protective Order. The parties acknowledge that this Stipulated 24 Protective Order does not confer blanket protections on all disclosures or responses 25 to discovery and that the protection it affords from public disclosure and use extends 26 only to the limited information or items that are entitled to confidential treatment 27 under the applicable legal principles. The parties further acknowledge, as set forth in 28 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 2 of 18 Page ID #:1152

1 Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 2 confidential information under seal. Civil Local Rule 79-5 sets forth the procedures 3 that must be followed and the standards that will be applied when a party seeks 4 permission from the court to file material under seal. 5 1.2 GOOD CAUSE STATEMENT 6 The Parties agree that good cause exists for the entry of this pretrial protective 7 order. Discovery may involve the production of personal and sensitive information, 8 financial records, personal communications and contact information, and health 9 records. 10 2. DEFINITIONS 11 2.1 Action: This pending federal lawsuit, Bauer v. Hill and Thiagarajah, 12 Case No. 22-cv-00868. 13 2.2 Challenging Party: A Party or Non-Party that challenges the designation 14 of information or items under this Order. 15 2.3 Confidential: Personal, sensitive, and non-public information which is in 16 the possession of a Designating Party and (a) visually depicts (i.e., photographs, 17 images, or videos) sexual acts or explicit nudity (i.e., naked breasts, buttocks, or 18 genitalia); (b) includes communications between a Party and any third-party to the 19 litigation that is sexual in nature; (c) includes protected medical information; (d) 20 private financial information; and/or (e) personally identifiable information, such as 21 addresses and social security numbers, and is designated by the Designating Party as 22 “CONFIDENTIAL.” 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 2 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 3 of 18 Page ID #:1153

1 2.6 Disclosure or Discovery Material: All items or information, regardless 2 of 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 7 an 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. 11 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 agents, consultants, 18 retained experts, and Outside Counsel of Record (and their support staffs). 19 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.13 Professional Vendors: Persons or entities that provide litigation support 22 services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 2.14 Protected Material: Any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 28 3 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 4 of 18 Page ID #:1154

1 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material from 2 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. 9 Any use of Protected Material at trial will be governed by the orders of the trial 10 judge. This Order does not govern the use of Protected Material at trial. 11 4. DURATION 12 Once a case proceeds to trial, all of the information that was designated as 13 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order becomes 14 public and will be presumptively available to all members of the public, including the 15 press, unless compelling reasons supported by specific factual findings to proceed 16 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City 17 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 18 “good cause” showing for sealing documents produced in discovery from 19 “compelling reasons” standard when merits-related documents are part of court 20 record). Accordingly, the terms of this Stipulated Protective Order do not extend 21 beyond the commencement of the trial. However, if this litigation is disposed without 22 a trial, the confidentiality obligations imposed by this Stipulated Protective Order will 23 remain in effect until a Designating Party agrees otherwise in writing or a court order 24 otherwise directs, and the parties will comply with section 13 below. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under this 28 4 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 5 of 18 Page ID #:1155

1 Order must take care to limit any such designation to specific material that qualifies 2 under the appropriate standards. The Designating Party must designate for protection 3 only those parts of material, documents, items, or oral or written communications that 4 qualify so that other portions of the material, documents, items, or communications 5 for which protection is not warranted are not swept unjustifiably within the ambit of 6 this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection 18 under this Stipulated Protective Order must be clearly so designated before the 19 material is disclosed or produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, 22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 23 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 24 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 25 portion or portions of the material on a page qualifies for protection, the Producing 26 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 27 markings in the margins). 28 5 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 6 of 18 Page ID #:1156

1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and before 4 the designation, all of the material made available for inspection will be deemed 5 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or 7 portions thereof, qualify for protection under this Order. Then, before producing the 8 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 9 to each page that contains Protected Material. If only a portion or portions of the 10 material on a page qualifies for protection, the Producing Party also must clearly 11 identify the protected portion(s) (e.g., by making appropriate markings in the 12 margins). 13 (b) for testimony given in depositions that the Designating Party identify the 14 Disclosure or Discovery Material on the record, before the close of the deposition all 15 protected testimony. 16 (c) for information produced in some form other than documentary and for any 17 other tangible items, that the Producing Party affix in a prominent place on the exterior 18 of the container or containers in which the information is stored the legend 19 “CONFIDENTIAL.” If only a portion or portions of the information warrants 20 protection, the Producing Party, to the extent practicable, will identify the protected 21 portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Order for such material. 25 Upon timely correction of a designation, the Receiving Party must make reasonable 26 efforts to assure that the material is treated in accordance with the provisions of this 27 Order. 28 6 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 7 of 18 Page ID #:1157

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the applicable 4 scheduling order in this Action. 5 6.2 Meet and Confer. The Challenging Party will initiate the dispute 6 resolution process, and, if necessary, file a discovery motion under Local Rule 37.1 7 et seq. The Challenging Party shall provide to the Designating Party written notice of 8 its challenge, stating the reason(s) for the challenge. Within 10 days the Challenging 9 Party and the Designating Party shall schedule a time to meet and confer over the 10 challenge and the Challenging and Designating Parties shall try to resolve such 11 challenge in good faith and on informal basis. If neither the designation nor the 12 objection is withdrawn, the Designating Party shall become the moving party for 13 purposes of Local Rule 37-2 et seq. since it is their burden to establish the designated 14 document should remain confidential. The Designating Party shall serve on the 15 challenging party the Joint Stipulation within 10 days of the meet and confer, and 16 follow the process outlined in Local Rules 37-2 through 37-4. 17 6.3 The burden of persuasion in any such challenge proceeding will be on 18 the Designating Party. Frivolous challenges, and those made for an improper purpose 19 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 20 expose the Challenging Party to sanctions. Unless the Designating Party has waived 21 or withdrawn the confidentiality designation, all parties will continue to afford the 22 material in question the level of protection to which it is entitled under the Producing 23 Party’s designation until the Court rules on the challenge. 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only in connection with this Action. Such Protected Material may be disclosed 28 7 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 8 of 18 Page ID #:1158

1 only to the categories of persons and under the conditions described in this Order. 2 When the Action has been terminated, a Receiving Party must comply with the 3 applicable provisions of this Stipulated Protective Order. 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated 10 “CONFIDENTIAL” only to: 11 (a) the Receiving Party; 12 (b) the Receiving Party’s Outside Counsel of Record in this Action, as well 13 as employees of said Outside Counsel of Record to whom it is reasonably necessary 14 to disclose the information for this Action; 15 (c) the agents, employees, officers, directors, interpreters, translators, and 16 insurance claims handlers (including House Counsel) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (e) the Court and its personnel; 23 (f) court reporters and their staff; 24 (g) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 28 8 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 9 of 18 Page ID #:1159

1 (h) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (i) during their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may be 10 separately bound by the court reporter and may not be disclosed to anyone except as 11 permitted under this Stipulated Protective Order; and 12 (j) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 15 OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation 17 that compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification will 20 include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order 22 to issue in the other litigation that some or all of the material covered by the subpoena 23 or order is subject to this Protective Order. Such notification will include a copy of 24 this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be pursued 26 by the Designating Party whose Protected Material may be affected. 27 28 9 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 10 of 18 Page ID #:1160

1 If the Designating Party timely seeks a protective order, the Party served with 2 the subpoena or court order will not produce any information designated in this action 3 as “CONFIDENTIAL” before a determination by the court from which the subpoena 4 or order issued, unless the Party has obtained the Designating Party’s permission. The 5 Designating Party will bear the burden and expense of seeking protection in that court 6 of its confidential material and nothing in these provisions should be construed as 7 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 8 directive from another court. 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a 12 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 13 produced by Non-Parties in connection with this litigation is protected by the 14 remedies and relief provided by this Order. Nothing in these provisions should be 15 construed as prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and the Party is 18 subject to an agreement with the Non-Party not to produce the Non-Party’s 19 confidential information, then the Party will: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality agreement 22 with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 specific description of the information requested; and 26 (3) make the information requested available for inspection by the Non- 27 Party, if requested. 28 10 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 11 of 18 Page ID #:1161

1 (c) If the Non-Party fails to seek a protective order from this court within 2 14 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s confidential information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party will not 5 produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court. 7 Absent a court order to the contrary, the Non-Party will bear the burden and expense 8 of seeking protection in this court of its Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A. 18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, 22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 may be established in an e-discovery order that provides for production without prior 25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 26 parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the 28 11 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 12 of 18 Page ID #:1162

1 parties may incorporate their agreement in the stipulated protective order submitted 2 to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 13 only be filed under seal pursuant to a court order authorizing the sealing of the specific 14 Protected Material at issue. If a Party's request to file Protected Material under seal 15 is denied by the court, then the Receiving Party may file the information in the public 16 record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days of a written request by the Designating Party, each Receiving Party must return 20 all Protected Material to the Producing Party or destroy such material. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. Whether the Protected Material is returned or destroyed, the Receiving 24 Party must submit a written certification to the Producing Party (and, if not the same 25 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 26 (by category, where appropriate) all the Protected Material that was returned or 27 destroyed and (2) affirms that the Receiving Party has not retained any copies, 28 12 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 13 of 18 Page ID #:1163

1 abstracts, compilations, summaries or any other format reproducing or capturing any 2 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 3 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 4 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 5 reports, attorney work product, and consultant and expert work product, even if such 6 materials contain Protected Material. Any such archival copies that contain or 7 constitute Protected Material remain subject to this Protective Order as set forth in 8 Section 4 (DURATION). 9 14. Any willful violation of this Stipulated Protective Order may be 10 punished by civil or criminal contempt proceedings, financial or evidentiary 11 sanctions, reference to disciplinary authorities, or other appropriate action at the 12 discretion of the Court. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 14 of 18 Page ID #:1164

1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 4 DATED: September 9, 2022 /s/ Blair G. Brown 5 Blair G. Brown (admitted pro hac vice) Jon R. Fetterolf (admitted pro hac vice) 6 ZUCKERMAN SPAEDER LLP 1800 M Street, N.W., Suite 1000 7 Washington, D.C. 20036 Tel: (202) 778-1800 8 Fax: (202) 882-8106 bbrown@zuckerman.com 9 jfetterolf@zuckerman.com 10 Nell Z. Peyser (admitted pro hac vice)

ZUCKERMAN SPAEDER LLP

11 485 Madison Avenue, 10th Floor New York, NY 10022 12 (212) 704-9600 npeyser@zuckerman.com 13 Shawn Holley (Cal. Bar No. 136811) 14 Suann C. Maclsaac (Cal Bar No. 205659)

KINSELA WEITZMAN ISER KUMP

15 HOLLEY LLP 808 Wilshire Boulevard., 3rd Floor 16 Santa Monica, CA 90401 Tel: (310) 566-9800 17 Fax: (310) 566-9873 sholley@kwikhlaw.com 18 smacisaac@kwikhlaw.com 19 Attorneys for Plaintiff Trevor Bauer 20 21 WESIERSKI & ZUREK LLP 22 /s/ Michelle R. Prescott 23 24 Christopher P. Wesierski (Bar No. 086736) Michelle R. Prescott (Bar No. 262638) 25 Eileen Spadoni (Bar No. 133259) 26 Brett A. Smith (Bar No. 322707) 29 Orchard Road 27 Lake Forest, CA 92630 28 14 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 15 of 18 Page ID #:1165

Tel: (949) 975-1000 1 Fax: (949) 756-0517 2 cwesierski@wzllp.com mprescott@wzllp.com 3 espadoni@wzllp.com 4 bsmith@wzllp.com 5

FREEDMAN + TAITELMAN, LLP

6 /s/ Jesse A. Kaplan 7 8 Bryan J. Freedman (Bar No. 151990) Jesse A. Kaplan (Bar No. 197662) 9 1801 Century Park West, 5th Floor 10 Los Angeles, CA 90067 Tel: (310) 201-0005 11 Fax: (310) 201-0045 12 bfreedman@ftllp.com jkaplan@ftllp.com 13 14 Attorneys for Defendant Lindsey C. Hill 15 16

LEWIS BRISBOIS

17 BISGAARD & SMITH LLP 18 __/s/ David D. Samani________________ 19 Kenneth C. Feldman (Bar No. 130699) 20 David D. Samani (Bar. No. 280179) 21 633 West 5th Street, Suite 4000 22 Los Angeles, CA 90071 Tel: (213) 250-1800 23 Fax: (213) 250-7900 24 Ken.Feldman@lewisbrisbois.com David.Samani@lewisbrisbois.com 25 26 Attorneys for Defendant Niranjan Fred Thiagarajah 27 28 15 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 16 of 18 Page ID #:1166

1 ATTESTATION 2 Pursuant to Civil Local Rule 5-4.3.4(2)(i), I hereby attest that all other 3 signatories on behalf of whom this filing is submitted concur in the filing’s content 4 and have authorized the filing. 5 Dated: September 9, 2022 /s/ Nell Z. Peyser 6 Nell Z. Peyser 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 17 of 18 Page ID #:1167

1 2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 4 DATED:__ _ _0_9_/1_2_/_2_0_2_2___ ______/s_/_ A__u_tu_m__n_ D__. _S_p_a_e_th____________

HON. AUTUMN D. SPAETH

5 United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17 Case 8:22-cv-00868-JVS-ADS Document 51 Filed 09/12/22 Page 18 of 18 Page ID #:1168

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of 8 ___________ [insert case name and number]. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 18