Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 1 of 16 Page ID #:273

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

11 GRASSROOTS PRODUCTIONS II, ) Case No.: 2:22-cv-05796 PA GJS(x) INC., a California corporation, ) 12 ) The Honorable Gail J. Standish 13 Plaintiff, ) Courtroom 640 ) 14 v. ) STIPULATED PROTECTIVE ORDER1 15 ) 16 PAULO EZEQUIEL LONDRA, an ) ACTION REMOVED: August 16, 2022 individual, and DOES 1 through 10, ) TRIAL DATE: July 18, 2023 17 inclusive, ) ) 18 Defendants. ) 19 ) ) 20 ________________________________ ) 21 ) ) 22 ) 23

AND RELATED COUNTERCLAIMS )

24 ) ) 25 ) 26 27 1 This Stipulated Protective Order is substantially based on the model protective order 28 provided under Magistrate Judge Gail J. Standish’s Procedures. Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 2 of 16 Page ID #:274

1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action includes claims for commissions as percentage of gross 13 compensation of a high-profile musical artist in connection with the artist’s endeavors 14 and activities in the entertainment industry. This action is therefore likely to involve 15 commercial, financial, and/or proprietary information for which special protection 16 from public disclosure and from use for any purpose other than prosecution of this 17 action is warranted. Such confidential and proprietary materials and information 18 consist of, among other things, confidential business or financial information, 19 information regarding confidential business practices, or other confidential 20 commercial information (including information implicating privacy rights of third 21 parties), information otherwise generally unavailable to the public, or which may be 22 privileged or otherwise protected from disclosure under state or federal statutes, court 23 rules, case decisions, or common law. Accordingly, to expedite the flow of 24 information, to facilitate the prompt resolution of disputes over confidentiality of 25 discovery materials, to adequately protect information the parties are entitled to keep 26 confidential, to ensure that the parties are permitted reasonable necessary uses of such 27 material in preparation for and in the conduct of trial, to address their handling at the 28 end of the litigation, and serve the ends of justice, a protective order for such 2 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 3 of 16 Page ID #:275

1 information is justified in this matter. It is the intent of the parties that information 2 will not be designated as confidential for tactical reasons and that nothing be so 3 designated without a good faith belief that it has been maintained in a confidential, 4 non-public manner, and there is good cause why it should not be part of the public 5 record of this case. 6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 Stipulated Protective Order does not entitle them to file confidential information 9 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 10 the standards that will be applied when a party seeks permission from the court to file 11 material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 proceedings and records in civil cases. In connection with non-dispositive motions, 14 good cause must be shown to support a filing under seal. See Kamakana v. City and 15 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 16 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 17 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 18 cause showing), and a specific showing of good cause or compelling reasons with 19 proper evidentiary support and legal justification, must be made with respect to 20 Protected Material that a party seeks to file under seal. The parties’ mere designation 21 of Disclosure or Discovery Material as CONFIDENTIAL does not – without the 22 submission of competent evidence by declaration, establishing that the material 23 sought to be filed under seal qualifies as confidential, privileged, or otherwise 24 protectable – constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 compelling reasons, not only good cause, for the sealing must be shown, and the relief 27 sought shall be narrowly tailored to serve the specific interest to be protected. See 28 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 3 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 4 of 16 Page ID #:276

1 item or type of information, document, or thing sought to be filed or introduced under 2 seal in connection with a dispositive motion or trial, the party seeking protection must 3 articulate compelling reasons, supported by specific facts and legal justification, for 4 the requested sealing order. Again, competent evidence supporting the application to 5 file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 its entirety will not be filed under seal if the confidential portions can be redacted. If 8 documents can be redacted, then a redacted version for public viewing, omitting only 9 the confidential, privileged, or otherwise protectable portions of the document, shall 10 be filed. Any application that seeks to file documents under seal in their entirety 11 should include an explanation of why redaction is not feasible. 12 2. DEFINITIONS 13 2.1 Action: This pending federal lawsuit, Case No.: 2:22-cv-05796-PA-GJS. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for protection 18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 19 Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless 26 of the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced or 28 generated in disclosures or responses to discovery in this matter. 4 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 5 of 16 Page ID #:277

1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, e-discovery and organizing, storing, or retrieving data in any form or 21 medium) and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 Protected Material (as defined above), but also (1) any information copied or extracted 28 5 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 6 of 16 Page ID #:278

1 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 2 Protected Material; and (3) any testimony, conversations, or presentations by Parties 3 or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Order does not govern the use of Protected Material at trial. 6 4. DURATION 7 FINAL DISPOSITION of the action is defined as the conclusion of any 8 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 9 has run. Except as set forth below, the terms of this protective order apply through 10 FINAL DISPOSITION of the action. The parties may stipulate that they will be 11 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 12 but will have to file a separate action for enforcement of the agreement once all 13 proceedings in this case are complete. 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 16 as an exhibit at trial becomes public and will be presumptively available to all 17 members of the public, including the press, unless compelling reasons supported by 18 specific factual findings to proceed otherwise are made to the trial judge in advance 19 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 20 showing for sealing documents produced in discovery from “compelling reasons” 21 standard when merits-related documents are part of court record). Accordingly, for 22 such materials, the terms of this protective order do not extend beyond the 23 commencement of the trial. 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under this 27 Order must take care to limit any such designation to specific material that qualifies 28 under the appropriate standards. The Designating Party must designate for protection 6 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 7 of 16 Page ID #:279

1 only those parts of material, documents, items or oral or written communications that 2 qualify so that other portions of the material, documents, items or communications 3 for which protection is not warranted are not swept unjustifiably within the ambit of 4 this Order. 5 Mass, indiscriminate or routinized designations are prohibited. Designations 6 that are shown to be clearly unjustified or that have been made for an improper 7 purpose (e.g., to unnecessarily encumber the case development process or to impose 8 unnecessary expenses and burdens on other parties) may expose the Designating Party 9 to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 designated for protection do not qualify for protection, that Designating Party must 12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 under this Order must be clearly so designated before the material is disclosed or 17 produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum, the legend 22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 23 contains protected material. If only a portion of the material on a page qualifies for 24 protection, the Producing Party also must clearly identify the protected portion(s) 25 (e.g., by making appropriate markings in the margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 28 which documents it would like copied and produced. During the inspection and 7 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 8 of 16 Page ID #:280

1 before the designation, all of the material made available for inspection shall be 2 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 3 it wants copied and produced, the Producing Party must determine which documents, 4 or portions thereof, qualify for protection under this Order. Then, before producing 5 the specified documents, the Producing Party must affix the “CONFIDENTIAL 6 legend” to each page that contains Protected Material. If only a portion of the material 7 on a page qualifies for protection, the Producing Party also must clearly identify the 8 protected portion(s) (e.g., by making appropriate markings in the margins). 9 (b) for testimony given in depositions that the Designating Party 10 identifies the Disclosure or Discovery Material on the record, before the close of the 11 deposition all protected testimony. 12 (c) for information produced in some form other than documentary and 13 for any other tangible items, that the Producing Party affix in a prominent place on 14 the exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive the 20 Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 9 of 16 Page ID #:281

1 resolution process under Local Rule 37.1 et seq. 2 6.3 The burden of persuasion in any such challenge proceeding shall be on 3 the Designating Party. Frivolous challenges, and those made for an improper purpose 4 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 5 expose the Challenging Party to sanctions. Unless the Designating Party has waived 6 or withdrawn the confidentiality designation, all parties shall continue to afford the 7 material in question the level of protection to which it is entitled under the Producing 8 Party’s designation until the Court rules on the challenge. 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 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized 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 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 24 well as employees of said Outside Counsel of Record to whom it is reasonably 25 necessary to disclose the information for this Action; 26 (b) the officers, directors, employees, agents and representatives of the 27 Receiving Party to whom disclosure is reasonably necessary for this Action; 28 (c) Experts (as defined in this Order) of the Receiving Party to whom 9 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 10 of 16 Page ID #:282

1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the Court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the information or 9 a custodian or other person who otherwise possessed or knew the information; 10 (h) during their depositions, witnesses, and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 13 not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 15 agreed by the Designating Party or ordered by the court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal Protected Material may be 17 separately bound by the court reporter and may not be disclosed to anyone except as 18 permitted under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 22 OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification 27 shall include a copy of the subpoena or court order; 28 (b) promptly notify in writing the party who caused the subpoena or 10 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 11 of 16 Page ID #:283

1 order to issue in the other litigation that some or all of the material covered by the 2 subpoena or order is subject to this Protective Order. Such notification shall include 3 a copy of this Stipulated Protective Order; and 4 (c) cooperate with respect to all reasonable procedures sought to be 5 pursued by the Designating Party whose Protected Material may be affected. 6 If the Designating Party timely seeks a protective order, the Party served with 7 the subpoena or court order shall not produce any information designated in this action 8 as “CONFIDENTIAL” before a determination by the court from which the subpoena 9 or order issued, unless the Party has obtained the Designating Party’s permission. The 10 Designating Party shall bear the burden and expense of seeking protection in that court 11 of its confidential material and nothing in these provisions should be construed as 12 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 13 directive from another court. 14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a 17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non- 26 Party that some or all of the information requested is subject to a confidentiality 27 agreement with a Non-Party; 28 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 12 of 16 Page ID #:284

1 Protective Order in this Action, the relevant discovery request(s), and a reasonably 2 specific description of the information requested; and 3 (3) make the information requested available for inspection by the 4 Non-Party, if requested. 5 (c) If the Non-Party fails to seek a protective order from this court within 6 14 days of receiving the notice and accompanying information, the Receiving Party 7 may produce the Non-Party’s confidential information responsive to the discovery 8 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 9 not produce any information in its possession or control that is subject to the 10 confidentiality agreement with the Non-Party before a determination by the court. 11 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 12 of seeking protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 19 persons to whom unauthorized disclosures were made of all the terms of this Order, 20 and (d) request such person or persons to execute the “Acknowledgment and 21 Agreement to Be Bound” that is attached hereto as Exhibit A. 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 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 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 28 procedure may be established in an e-discovery order that provides for production 12 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 13 of 16 Page ID #:285

1 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 2 (e), insofar as the parties reach an agreement on the effect of disclosure of a 3 communication or information covered by the attorney-client privilege or work 4 product protection, the parties may incorporate their agreement in the stipulated 5 protective order submitted 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 Local Civil Rule 79-5. Protected Material may 16 only be filed under seal pursuant to a court order authorizing the sealing of the specific 17 Protected Material at issue. If a Party’s request to file Protected Material under seal 18 is denied by the court, then the Receiving Party may file the information in the public 19 record unless otherwise instructed by the court. 20 13. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 4, within 60 22 days of a written request by the Designating Party, each Receiving Party must return 23 all Protected Material to the Producing Party or destroy such material. As used in this 24 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected 26 Material. Whether the Protected Material is returned or destroyed, the Receiving 27 Party must submit a written certification to the Producing Party (and, if not the same 28 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 13 Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 14 of 16 Page ID #:286

1 (by category, where appropriate) all the Protected Material that was returned or 2 destroyed and (2) affirms that the Receiving Party has not retained any copies, 3 abstracts, compilations, summaries or any other format reproducing or capturing any 4 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 5 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 6 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 7 reports, attorney work product, and consultant and expert work product, even if such 8 materials contain Protected Material. Any such archival copies that contain or 9 constitute Protected Material remain subject to this Protective Order as set forth in 10 Section 4 (DURATION). 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 14 Case |P:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 15o0f16 Page ID #:287

1 || 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 |) including, without limitation, contempt proceedings and/or monetary sanctions. 4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 || DATED: January 10, 2023 Respectfully submitted,

SINGH, SINGH & TRAUBEN, LLP

8 MICHAEL A. TRAUBEN By: _ /s/ Michael A. Trauben 10 Michael A. Trauben 11 Attorneys for Plaintiff/Counter-Defendant 12 GRASSROOTS PRODUCTIONS II, INC. 13 || DATED: January 10, 2023 Respectfully submitted, 14

PRYOR CASHMAN LLP

15 James G. Sammataro 16 Benjamin S. Akley 17 By: /s/ 18 Attorneys for Defendant/Counterclaimant 19 PAULO EZEQUIEL LONDRA 20 21 22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 || DATED: January 11, 2023 ya 26

HON. GAIL J. STANDISH

27 || United States Magistrate Judge 28 15

Case 2:22-cv-05796-PA-GJS Document 25 Filed 01/11/23 Page 16 of 16 Page ID #:288

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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4 I, _____________________________ [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 Grassroots Productions II, Inc. v. Paulo 9 Ezequiel Londra, Case No.: 2:22-cv-05796 PA GJS(x). I agree to comply with and 10 to be bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint __________________________ [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 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 16