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IN THE UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 11 SHEFFIELD METALS CLEVELAND, ) CASE NO. 5:21-cv-02131-DMG-SP LLC, dba SHEFFIELD METALS ) 12 INTERNATIONAL, an Ohio ) Hon. Judge Dolly M. Gee corporation, ) Magistrate Judge: Sheri Pym 13 ) Courtroom: 8C 14 Plaintiffs, ) STIPULATED PROTECTIVE ) vs. ORDER 15 ) TIMOTHY MURPHY, an individual; ) 16 STACEY ROSE MURPHY, an ) individual; MAJESTIC METALS, a ) Trial Date: September 19, 2023 17 California corporation; and DOES 1 ) Complaint filed: December 22, 2021 through 100, inclusive, ) 18 ) Defendants. ) 19 dTIdMdOdTHY MURPHY, an individual; ) 20 STACEY ROSE MURPHY, an ) individual; and MAJESTIC METALS, a ) 21 California corporation, ) ) 22 Counter-Claimants, )

) 23 vs. ) 24 S LH LCE ,F dF bIE a L SD H EM FE FT IEA LL DS MCL EE TV AE LL S AND, ) ) 25 INTERNATIONAL, an Ohio ) corporation, ) 26 ) Counter-Defendant. ) 27 ) ) 1 Plaintiff SHEFFIELD METALS CLEVELAND, LLC, dba SHEFFIELD 2 METALS INTERNATIONAL (“Plaintiff”) and Defendants TIMOTHY 3 MURPHY, STACEY ROSE MURPHY, and MAJESTIC METALS 4 (“Defendants”) (collectively, the “Parties”), through their respective counsel, 5 hereby file this Stipulated Protective Order as set forth below. 6 1. A. PURPOSES AND LIMITATIONS 7 Discovery in this action is likely to involve production of confidential, 8 proprietary, or private information for which special protection from public 9 disclosure and from use for any purpose other than prosecuting this litigation 10 may be warranted. Accordingly, the parties hereby stipulate to and petition the 11 Court to enter the following Stipulated Protective Order. The parties 12 acknowledge that this Order does not confer blanket protections on all 13 disclosures or responses to discovery and that the protection it affords from 14 public disclosure and use extends only to the limited information or items that 15 are entitled to confidential treatment under the applicable legal principles. The 16 parties further acknowledge, as set forth in Section 12.3, below, that this Order 17 does not entitle them to file confidential information under seal. Rather, when 18 the parties seek permission from the court to file material under seal, the parties 19 must comply with Civil Local Rule 79-5 and with any pertinent orders of the 20 assigned District Judge and Magistrate Judge. 21 B. GOOD CAUSE STATEMENT 22 During the course of discovery it may be necessary to disclose certain 23 confidential information relating to the subject matter of this action. Such 24 confidential and proprietary materials and information consist of, among other 25 things, confidential business or financial information, information regarding 26 confidential business practices, or other confidential commercial information, 27 otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal statutes, court rules, 1 case decisions, or common law (such as financial information, including that of 2 third-parties). Accordingly, to expedite the flow of information, to facilitate the 3 prompt resolution of disputes over confidentiality of discovery materials, to 4 adequately protect information the parties are entitled to keep confidential, to 5 ensure that the parties are permitted reasonable necessary uses of such material 6 in preparation for and in the conduct of trial, to address their handling at the end 7 of the litigation, and serve the ends of justice, a protective order for such 8 information is justified in this matter. It is the intent of the parties that 9 information will not be designated as confidential for tactical reasons and that 10 nothing be so designated without a good faith belief that it has been maintained 11 in a confidential, non-public manner, and there is good cause why it should not 12 be part of the public record of this case. 13 Accordingly, the parties respectfully submit that there is good cause for 14 the entry of this Protective Order. 15 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 16 SEAL 17 The parties further acknowledge, as set forth in Section 12.3, below, that 18 this Stipulated Protective Order does not entitle them to file confidential 19 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 20 be followed and the standards that will be applied when a party seeks permission 21 from the court to file material under seal. 22 There is a strong presumption that the public has a right of access to 23 judicial proceedings and records in civil cases. In connection with non- 24 dispositive motions, good cause must be shown to support a filing under seal. 25 See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 26 2006); Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); 27 Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and a specific 1 showing of good cause or compelling reasons with proper evidentiary support 2 and legal justification, must be made with respect to Protected Material that a 3 party seeks to file under seal. The parties’ mere designation of Disclosure or 4 Discovery Material as CONFIDENTIAL does not—without the submission of 5 competent evidence by declaration, establishing that the material sought to be 6 filed under seal qualifies as confidential, privileged, or otherwise protectable— 7 constitute good cause. 8 Further, if a party requests sealing related to a dispositive motion or trial, 9 then compelling reasons, not only good cause, for the sealing must be shown, 10 and the relief sought shall be narrowly tailored to serve the specific interest to be 11 protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 12 2010). For each item or type of information, document, or thing sought to be 13 filed or introduced under seal in connection with a dispositive motion or trial, the 14 party seeking protection must articulate compelling reasons, supported by 15 specific facts and legal justification, for the requested sealing order. Again, 16 competent evidence supporting the application to file documents under seal must 17 be provided by declaration. 18 Any document that is not confidential, privileged, or otherwise protectable 19 in its entirety will not be filed under seal if the confidential portions can be 20 redacted. If documents can be redacted, then a redacted version for public 21 viewing, omitting only the confidential, privileged, or otherwise protectable 22 portions of the document shall be filed. Any application that seeks to file 23 documents under seal in their entirety should include an explanation of why 24 redaction is not feasible. 25 2. DEFINITIONS 26 2.1 Action: The instant action: Sheffield Metals Cleveland, LLC v. 27 Timothy Murphy, et al., Civil Action No. 5:21-cv-02131-DMG-SP. 2.2 Challenging Party: a Party or Non-Party that challenges the 1 designation of information or items under this Order. 2 2.3 “CONFIDENTIAL” Information or Items: information (regardless 3 of how it is generated, stored or maintained) or tangible things that qualify for 4 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 5 the Good Cause Statement. 6 2.4 Counsel: Counsel of Record and House Counsel (as well as their 7 support staff). 8 2.5 Designating Party: a Party or Non-Party that designates information 9 or items that it (or another Party or Non-Party produces) produces in disclosures 10 or in responses to discovery as “CONFIDENTIAL.” 11 2.6 Disclosure or Discovery Material: all items or information, 12 regardless of the medium or manner in which it is generated, stored, or 13 maintained (including, among other things, testimony, transcripts, and tangible 14 things), that are produced or generated in disclosures or responses to discovery in 15 this matter. 16 2.7 Expert: a person with specialized knowledge or experience in a 17 matter pertinent to the litigation who has been retained by a Party or its counsel 18 to serve as an expert witness or as a consultant in this Action. 19 2.8 House Counsel: attorneys who are employees of a party to this 20 Action. House Counsel does not include Outside Counsel of Record or any other 21 outside counsel. 22 2.9 Non-Party: any natural person, partnership, corporation, association, 23 or other legal entity not named as a Party to this action. 24 2.10 Outside Counsel of Record: attorneys who are not employees of a 25 party to this Action but are retained to represent or advise a party to this Action 26 and have appeared in this Action on behalf of that party or are affiliated with a 27 law firm which has appeared on behalf of that party, and includes support staff. 2.11 Party: any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, and Outside Counsel of Record (and 2 their support staffs). 3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 2.13 Professional Vendors: persons or entities that provide litigation 6 support services (e.g., photocopying, videotaping, translating, preparing exhibits 7 or demonstrations, and organizing, storing, or retrieving data in any form or 8 medium) and their employees and subcontractors. 9 2.14 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL.” 11 2.15 Receiving Party: a Party that receives Disclosure or Discovery 12 Material from a Producing Party. 13 3. SCOPE 14 The protections conferred by this Order cover not only Protected Material 15 (as defined above), but also (1) any information copied or extracted from 16 Protected Material; (2) all copies, excerpts, summaries, or compilations of 17 Protected Material; and (3) any testimony, conversations, or presentations by 18 Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 4. DURATION 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this protective order used or 24 introduced as an exhibit at trial becomes public and will be presumptively 25 available to all members of the public, including the press, unless compelling 26 reasons supported by specific factual findings to proceed otherwise are made to 27 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing documents produced in 1 discovery from “compelling reasons” standard when merits-related documents 2 are part of court record). Accordingly, the terms of this protective order do not 3 extend beyond the commencement of the trial. 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for 6 Protection. Each Party or Non-Party that designates information or items for 7 protection under this Order must take care to limit any such designation to 8 specific material that qualifies under the appropriate standards. The Designating 9 Party must designate for protection only those parts of material, documents, 10 items, or oral or written communications that qualify so that other portions of the 11 material, documents, items, or communications for which protection is not 12 warranted are not swept unjustifiably within the ambit of this Order. 13 Mass, indiscriminate, or routinized designations are prohibited. 14 Designations that are shown to be clearly unjustified or that have been made for 15 an improper purpose (e.g., to unnecessarily encumber the case development 16 process or to impose unnecessary expenses and burdens on other parties) may 17 expose the Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that 19 it designated for protection do not qualify for protection, that Designating Party 20 must promptly notify all other Parties that it is withdrawing the inapplicable 21 designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided 23 in this Order (see, e.g., second or third paragraphs of Section 5.2(a) below), or as 24 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies 25 for protection under this Order must be clearly so designated before the material 26 is disclosed or produced. 27 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic 1 documents, but excluding transcripts of depositions or other pretrial or trial 2 proceedings), that the Producing Party affix at a minimum, the legend 3 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 4 contains protected material. If only a portion or portions of the material on a 5 page qualifies for protection, the Producing Party also must clearly identify the 6 protected portion(s) (e.g., by making appropriate markings in the margins). 7 A Party or Non-Party that makes original documents available for 8 inspection need not designate them for protection until after the inspecting Party 9 has indicated which documents it would like copied and produced. During the 10 inspection and before the designation, all of the material made available for 11 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 12 identified the documents it wants copied and produced, the Producing Party must 13 determine which documents, or portions thereof, qualify for protection under this 14 Order. Then, before producing the specified documents, the Producing Party 15 must affix the “CONFIDENTIAL legend” to each page that contains Protected 16 Material. If only a portion or portions of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) 18 (e.g., by making appropriate markings in the margins). 19 Should a Party wish to designate any Disclosure or Discovery Material 20 produced by another Party or Non-Party as “CONFIDENTIAL,” the Designating 21 Party shall, within ten (10) business days after the production to that Party, or the 22 date that the Parties receive notice that this Protective Order has been signed by 23 the Court, whichever is later (the “Effective Date”), provide written notice to 24 counsel of record for all Parties of the bates-numbers or number range or other 25 sufficiently definite description of the Documents, Testimony, or Information to 26 be designated “Confidential.” The Documents, Testimony, or Information shall 27 not be distributed to persons beyond those specified in Section 7.2, supra, until ten (10) business days after the production or the Effective Date, whichever is later, 1 to give Parties an opportunity to review and designate Documents, Testimony, or 2 Information as “Confidential” prior to further dissemination. 3 (b) for testimony given in depositions that the Designating Party identifies 4 on the record, before the close of the deposition as protected testimony. 5 (c) for information produced in some form other than documentary and 6 for any other tangible items, that the Producing Party affix in a prominent place 7 on the exterior of the container or containers in which the information is stored 8 the legend “CONFIDENTIAL.” If only a portion or portions of the information 9 warrants protection, the Producing Party, to the extent practicable, shall identify 10 the protected portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 12 failure to designate qualified information or items does not, standing alone, 13 waive the Designating Party’s right to secure protection under this Order for such 14 material. Upon timely correction of a designation, the Receiving Party must 15 make reasonable efforts to assure that the material is treated in accordance with 16 the provisions of this Order. 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 designation of confidentiality at any time that is consistent with the Court’s 20 Scheduling Order. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37-1 et seq. 23 6.3 The burden of persuasion in any such challenge proceeding shall be 24 on the Designating Party. Frivolous challenges, and those made for an improper 25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 26 parties) may expose the Challenging Party to sanctions. Unless the Designating 27 Party has waived or withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protection to which it is 1 entitled under the Producing Party’s designation until the Court rules on the 2 challenge 3 7. ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected Material that 5 is disclosed or produced by another Party or by a Non-Party in connection with 6 this Action only for prosecuting, defending, or attempting to settle this Action. 7 Such Protected Material may be disclosed only to the categories of persons and 8 under the conditions described in this Order. When the Action has been 9 terminated, a Receiving Party must comply with the provisions of Section 13 10 below. 11 Protected Material must be stored and maintained by a Receiving Party at 12 a location and in a secure manner that ensures that access is limited to the 13 persons authorized under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 15 otherwise ordered by the court or permitted in writing by the Designating Party, 16 a Receiving Party may disclose any information or item designated 17 “CONFIDENTIAL” only to: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 19 well as employees of said Outside Counsel of Record to whom it is reasonably 20 necessary to disclose the information for this Action; 21 (b) the officers, directors, and employees (including House Counsel) of 22 the Receiving Party to whom disclosure is reasonably necessary for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the court and its personnel; 27 (e) court reporters and their staff; (f) professional jury or trial consultants, mock jurors, and Professional 1 Vendors to whom disclosure is reasonably necessary for this Action and who 2 have 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 7 party requests that the witness sign the “Acknowledgment and Agreement to Be 8 Bound” form attached as Exhibit A hereto; and (2) they will not be permitted to 9 keep any confidential information unless they sign the “Acknowledgment and 10 Agreement to Be Bound” attached as Exhibit A, unless otherwise agreed by the 11 Designating Party or ordered by the court. Pages of transcribed deposition 12 testimony or exhibits to depositions that reveal Protected Material may be 13 separately bound by the court reporter and may not be disclosed to anyone 14 except as permitted under this Protective Order; and 15 (i) any mediator or settlement officer, and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 18 IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other 20 litigation that compels disclosure of any information or items designated in this 21 Action as “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification 23 shall include a copy of the subpoena or court order unless prohibited by law; 24 (b) promptly notify in writing the party who caused the subpoena or order 25 to issue in the other litigation that some or all of the material covered by the 26 subpoena or order is subject to this Protective Order. Such notification shall 27 include a copy of this Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 1 pursued by the Designating Party whose Protected Material may be affected. 2 If the Designating Party timely seeks a protective order, the Party served 3 with the subpoena or court order shall not produce any information designated in 4 this action as “CONFIDENTIAL” before a determination by the court from 5 which the subpoena or order issued, unless the Party has obtained the 6 Designating Party’s permission, or unless otherwise required by the law or court 7 order. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these 9 provisions should be construed as authorizing or encouraging a Receiving Party 10 in this Action to disobey a lawful directive from another court. 11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a 14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such 15 information produced by Non-Parties in connection with this litigation is 16 protected by the remedies and relief provided by this Order. Nothing in these 17 provisions should be construed as prohibiting a Non-Party from seeking 18 additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 20 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- 24 Party that some or all of the information requested is subject to a confidentiality 25 agreement with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Protective 27 Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 1 (3) make the information requested available for inspection by the 2 Non-Party, if requested. 3 (c) If a 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 6 discovery request. If the Non-Party timely seeks a protective order, the 7 Receiving Party shall not produce any information in its possession or control 8 that is subject to the confidentiality agreement with the Non-Party because a 9 determined by the court. Absent a court order to the contrary, the Non-Party shall 10 bear the burden and expense of seeking protection in this court of its Protected 11 Material. 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has 14 disclosed Protected Material to any person or in any circumstance not authorized 15 under this Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best 17 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 18 the person or persons to whom unauthorized disclosures were made of all the 19 terms of this Order, and (d) request such person or persons to execute the 20 “Acknowledgment and Agreement to Be Bound” that is attached hereto as 21 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 26 protection, the obligations of the Receiving Parties are those set forth in Federal 27 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for 1 production without prior privilege review. Pursuant to Federal Rule of Evidence 2 502(d) and (e), insofar as the parties reach an agreement on the effect of 3 disclosure of a communication or information covered by the attorney-client 4 privilege or work product protection, the parties may incorporate their agreement 5 in the Stipulated Protective Order submitted to the Court. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of 8 any person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. No Party waives any right it 10 otherwise would have to object to disclosing or producing any information or 11 item on any ground not addressed in this Protective Order. Similarly, no Party 12 waives any right to object on any ground to use in evidence of any of the 13 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 and with any 16 pertinent orders of the assigned District Judge and Magistrate Judge. If a Party's 17 request to file Protected Material under seal is denied by the court, then the 18 Receiving Party may file the information in the public record unless otherwise 19 instructed by the court. 20 13. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in Section 4, within 60 22 days of a written request by the Designating Party, each Receiving Party must 23 return all Protected Material to the Producing Party or destroy such material. As 24 used in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of 26 the Protected Material. Whether the Protected Material is returned or destroyed, 27 the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day 1 deadline that (1) identifies (by category, where appropriate) all the Protected 2 Material that was returned or destroyed and (2) affirms that the Receiving Party 3 has not retained any copies, abstracts, compilations, summaries or any other 4 format reproducing or capturing any of the Protected Material. Notwithstanding 5 this provision, Counsel are entitled to retain an archival copy of all pleadings, 6 motion papers, trial, deposition, and hearing transcripts, legal memoranda, 7 correspondence, deposition and trial exhibits, expert reports, attorney work 8 product, and consultant and expert work product, even if such materials contain 9 Protected Material. Any such archival copies that contain or constitute Protected 10 Material remain subject to this Protective Order as set forth in Section 4. 11 14. Any violation of this Order may be punished by any and all appropriate 12 measures including, without limitation, contempt proceedings and/or monetary 13 sanctions. 14 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 Dated: March 22, 2023 HAIGHT BROWN & 17 BONESTEEL LLP 18

19 By: /s/ William E. Ireland William E. Ireland 20 Bianca D. Falcon Attorneys for Plaintiff and Counter- 21 Defendant SHEFFIELD METALS CLEVELAND, LLC, dba 22 SHEFFIELD METALS INTERNATIONAL, an Ohio 23 corporation

24 /// 25 /// 26 /// 27 /// 1 Dated: March 22, 2023 GORDON REES SCULLY

MANSUKHANI, LLP

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3 By: /s/ Michael J. Dailey Craig J. Mariam 4 Michael J. Dailey Sonia X. Chen 5 Attorneys for Counter-Defendant Sheffield Metals Cleveland, LLC 6 dba Sheffield Metals International

7 Dated: March 21, 2023 NORRIS LAW GROUP, P.C. 8

9 By: /s/ Matthew J. Norris___________ Matthew J. Norris 10 Attorneys for Defendants and Counterclaimants Timothy Murphy, 11 Stacey Rose Murphy, and Majestic Metals 12

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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17 Dated: April 3, 2023 18 MAGISTRATE JUDGE SHERI PYM

UNITED STATES DISTRICT COURT

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21 22 23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full name] of ________________ 4 [print or type full address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California in the case of 7 Sheffield Metals Cleveland, LLC v. Timothy Murphy, et al., Civil Action No. 8 5:21-cv-02131-DMG-SP. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature 11 of contempt. I solemnly promise that I will not disclose any manner any 12 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 15 Court for the Central District of California for the purpose of enforcing the terms 16 of this Stipulated Protective Order, even if such enforcement proceedings occur 17 after termination of this action. I hereby appoint __________________________ 18 [print or type full name] of ___________________________________________ 19 [print or type full address and telephone number] as my California agent for 20 service of process in connection with this action or any proceedings related to the 21 enforcement of this Stipulated Protective Order. 22 23 Date: _______________________________ 24 City and State where sworn and signed: ________________________________ 25 26 Printed name: ______________________________________ 27 Signature: ________________________________________ 1 ATTESTATION [LOCAL RULE 5-4.3.4] 2 I, Michael J. Dailey, hereby attest that, pursuant to Local Rule 5- 3 4.3.4(a)(2)(i), all other signatories listed, and on whose behalf the filing is 4 submitted, concur in the filing’s content and have authorized the filing. 5 6 Dated: March 22, 2023 By: /s/ Michael J. Dailey_______ 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27