1 Cheryl L. O’Connor (State Bar No. 173897) coconnor@jonesday.com 2 JoeAl Akobian (State Bar No. 346801) jakobian@jonesday.com 3 Jones Day 3161 Michelson Drive, Suite 800 4 Irvine, California 92612.4408 Telephone: +1.949.851.3939 5 Facsimile: +1.949.553.7539

6 Attorneys for Defendant Experian Information Solutions, Inc. 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 Case No. CV 23-01572-SPG(PD) Karen Khachatryan et al. 12

Plaintiffs, DISCOVERY MATTER - 13

STIPULATED PROTECTIVE

v. ORDER1 14

Fair Collections and Outsourcing, Inc. 15 et al, 16 Defendants. 17

18 19

20 21 22 23 24 25 26

27 1 This Stipulated Protective Order is substantially based on the model protective 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 4 disclosure and from use for any purpose other than prosecuting this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this Order 7 does not confer blanket protections on all disclosures or responses to discovery and 8 that the protection it affords from public disclosure and use extends only to the 9 limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and from 15 use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of 26 such material in preparation for and in the conduct of trial, to address their handling 27 at the end of the litigation, and serve the ends of justice, a protective order for such 1 will not be designated as confidential for tactical reasons and that nothing be so 2 designated without a good faith belief that it has been maintained in a confidential, 3 non-public manner, and there is good cause why it should not be part of the public 4 record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 9 the standards that will be applied when a party seeks permission from the court to 10 file material under seal. 11 There is a strong presumption that the public has a right of access to judicial 12 proceedings and records in civil cases. In connection with non-dispositive motions, 13 good cause must be shown to support a filing under seal. See Kamakana v. City and 14 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 15 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 16 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 17 good cause showing), and a specific showing of good cause or compelling reasons 18 with proper evidentiary support and legal justification, must be made with respect to 19 Protected Material that a party seeks to file under seal. The parties’ mere designation 20 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 21 submission of competent evidence by declaration, establishing that the material 22 sought to be filed under seal qualifies as confidential, privileged, or otherwise 23 protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, then 25 compelling reasons, not only good cause, for the sealing must be shown, and the 26 relief sought shall be narrowly tailored to serve the specific interest to be protected. 27 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 1 seal in connection with a dispositive motion or trial, the party seeking protection 2 must articulate compelling reasons, supported by specific facts and legal 3 justification, for the requested sealing order. Again, competent evidence supporting 4 the application to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. If 7 documents can be redacted, then a redacted version for public viewing, omitting only 8 the confidential, privileged, or otherwise protectable portions of the document, shall 9 be filed. Any application that seeks to file documents under seal in their entirety 10 should include an explanation of why redaction is not feasible. 11 12 2. DEFINITIONS 13 2.1 Action: this pending federal law suit. 14 2.2 Challenging Party: a Party or Non-Party that challenges 15 the designation 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 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 19 Good Cause Statement. 20 2.4 “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” 21 Information or Items: “Confidential” Information as defined above that despite the 22 provisions of this protective order poses a substantial risk of identifiable harm to the 23 Producing Party if disclosed to non-parties in this action. 24 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 25 their support staff). 26 2.6 Designating Party: a Party or Non-Party that designates information or 27 items that it produces in disclosures or in responses to discovery as 1 ONLY.” 2 2.7 Disclosure or Discovery Material: all items or information, regardless 3 of the medium or manner in which it is generated, stored, or maintained (including, 4 among other things, testimony, transcripts, and tangible things), that are produced or 5 generated in disclosures or responses to discovery in this matter. 6 2.8 Expert: a person with specialized knowledge or experience in a matter 7 pertinent to the litigation who has been retained by a Party or its counsel to serve as 8 an expert witness or as a consultant in this Action. 9 2.9 House Counsel: attorneys who are employees of a party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 2.10 Non-Party: any natural person, partnership, corporation, association, or 13 other legal entity not named as a Party to this action. 14 2.11 Outside Counsel of Record: attorneys who are not employees of a party 15 to this Action but are retained to represent or advise a party to this Action and have 16 appeared in this Action on behalf of that party or are affiliated with a law firm which 17 has appeared on behalf of that party, and includes support staff. 18 2.12 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staffs). 21 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 22 Discovery Material in this Action. 23 2.14 Professional Vendors: persons or entities that provide litigation 24 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 2.15 Protected Material: any Disclosure or Discovery Material that is 1 ATTORNEY’S EYES ONLY.” 2 2.16 Receiving Party: a Party that receives Disclosure or Discovery 3 Material from a Producing Party. 4 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 Protected Material (as defined above), but also (1) any information copied or 8 extracted from Protected Material; (2) all copies, excerpts, summaries, or 9 compilations of Protected Material; and (3) any testimony, conversations, or 10 presentations by Parties or their Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial shall be governed by the orders of the 12 trial judge. This Order does not govern the use of Protected Material at trial. 13 14 4. DURATION 15 FINAL DISPOSITION of the action is defined as the conclusion of any 16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 17 has run. Except as set forth below, the terms of this protective order apply through 18 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 20 but will have to file a separate action for enforcement of the agreement once all 21 proceedings in this case are complete. 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 24 as an exhibit at trial becomes public and will be presumptively available to all 25 members of the public, including the press, unless compelling reasons supported by 26 specific factual findings to proceed otherwise are made to the trial judge in advance 27 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 1 showing for sealing documents produced in discovery from “compelling reasons” 2 standard when merits-related documents are part of court record). Accordingly, for 3 such materials, the terms of this protective order do not extend beyond the 4 commencement of the trial. 5 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, documents, items, 13 or communications for which protection is not warranted are not swept unjustifiably 14 within the ambit of this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and 11 before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 13 documents it wants copied and produced, the Producing Party must determine which 14 documents, or portions thereof, qualify for protection under this Order. Then, before 15 producing the specified documents, the Producing Party must affix the 16 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 portion or portions of the material on a page qualifies for protection, the Producing 18 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 19 markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identify 21 the Disclosure or Discovery Material on the record, before the close of the deposition 22 all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 protection, the Producing Party, to the extent practicable, shall identify the protected 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37.1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on 15 the Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 or withdrawn the confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the Court rules on the challenge. 21 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this 25 Action only for prosecuting, defending, or attempting to settle this Action. Such 26 Protected Material may be disclosed only to the categories of persons and under the 27 conditions described in this Order. When the Action has been terminated, a 1 Receiving Party must comply with the provisions of section 13 below (FINAL 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 as employees of said Outside Counsel of Record to whom it is reasonably necessary 12 to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may 4 be separately bound by the court reporter and may not be disclosed to anyone except 5 as permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 9 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 10 writing by the Designating party, a Receiving Party may disclose any information or 11 item designated “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” only 12 to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 14 well as employees of said Outside Counsel of Record to whom it is reasonably 15 necessary to disclose the information for this Action; 16 (b) Experts (as defined in this Order) of the Receiving Party to 17 whom disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (c) The Court and its personnel; 20 (d) The author or recipient of a document containing the information 21 or a custodian or other person who otherwise possessed or knew the information. 22 7.4 Documents produced pursuant to this Order shall not be made available 23 to any person designated in Subparagraph 7.2(c) or 7.3(b) unless he or she shall have 24 first read this Order, agreed to be bound by its terms, and signed the attached 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A). Counsel for any Party 26 providing any “Confidential” or “Attorney’s Eyes Only” documents or information 27 to a person signing a “Acknowledgment and Agreement to Be Bound” (Exhibit A) 1 California agent of the person signing the “Acknowledgment and Agreement to Be 2 Bound” for service of process in connection with this action or any proceedings 3 related to enforcement of this Stipulated Protective Order, and shall not provide any 4 such documents or information to such person until such Counsel has received a 5 signed “Acknowledgment and Agreement to Be Bound” from such person, shall 6 maintain a copy of any such “Acknowledgment and Agreement to Be Bound” until 7 the final disposition of the Action, and, after the final disposition of the Action, shall 8 provide a copy of any such “Acknowledgment and Agreement to Be Bound” to 9 Counsel for the Party whose “Confidential” or “Attorney’s Eyes Only” documents 10 or information was provided to such person. 11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 12

IN OTHER LITIGATION

13 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 17 ONLY” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order 21 to issue in the other litigation that some or all of the material covered by the subpoena 22 or order is subject to this Protective Order. Such notification shall include a copy of 23 this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued 25 by the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served 27 with the subpoena or court order shall not produce any information designated in this 1 EYES ONLY” before a determination by the court from which the subpoena or order 2 issued, unless the Party has obtained the Designating Party’s permission. The 3 Designating Party shall bear the burden and expense of seeking protection in that 4 court of its confidential material and nothing in these provisions should be construed 5 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 6 directive from another court. 7 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT 9 TO BE PRODUCED IN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced by a 11 Non-Party in this Action and designated as “CONFIDENTIAL,” or “HIGHLY 12 CONFIDENTIAL – ATTORNEY’S EYES ONLY.” Such information produced by 13 Non-Parties in connection with this litigation is protected by the remedies and relief 14 provided by this Order. Nothing in these provisions should be construed as 15 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 shall: 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 27 Non-Party, if requested. 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 shall 5 not 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 shall bear the burden and expense 8 of seeking protection in this court of its Protected Material. 9 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all the terms of this Order, 17 and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit A. 19 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21

PROTECTED MATERIAL

22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 26 may be established in an e-discovery order that provides for production without prior 27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 1 parties reach an agreement on the effect of disclosure of a communication or 2 information covered by the attorney-client privilege or work product protection, the 3 parties may incorporate their agreement in the stipulated protective order submitted 4 to the court. 5 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 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 days of a written request by the Designating Party, each Receiving Party must return 24 all Protected Material to the Producing Party or destroy such material. As used in 25 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected 27 Material. Whether the Protected Material is returned or destroyed, the Receiving 1 Party must submit a written certification to the Producing Party (and, if not the same 2 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 3 (by category, where appropriate) all the Protected Material that was returned or 4 destroyed and (2)affirms that the Receiving Party has not retained any copies, 5 abstracts, compilations, summaries or any other format reproducing or capturing any 6 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 7 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 8 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 9 reports, attorney work product, and consultant and expert work product, even if such 10 materials contain Protected Material. Any such archival copies that contain or 11 constitute Protected Material remain subject to this Protective Order as set forth in 12 Section 4 (DURATION). 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 14. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: May 24, 2023 8 9 LOKER LAW, APC 10 BY: /s/ Matthew Loker 11 Matthew Loker, Esq. 12 Attorneys for Plaintiffs 13

GORDON REES SCULLY MANSUKHANI, LLP

14 BY: /s/ Andrew M. Schwartz 15 Andrew M. Schwartz, Esq. 16 Attorneys for Defendant, Fair Collections and Outsourcing, Inc. 17

SEYFARTH SHAW, LLP

18 19 BY: /s/ Theodore Roethke 20 Theodore Roethke, Esq. Attorneys for Defendant, Equifax Information Services LLC 21 22

JONES DAY

23 24 BY: /s/ JoeAl Akobian JoeAl Akobian, Esq. 25 Attorneys for Defendant, Experian Information Solutions, Inc. 26 27

QUILLING SELANDER LOWNDS WINSLETT AND MOSER PC

3 || BY: /s/ Kyle E. Pietzrak 4 || Kyle E. Pietzrak ; Attorneys for Defendant, Trans Union LLC

6 7 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 || DATED: May 25, 2023 10 ll Piaticcca Donahue 12 || Patricia Donahue 3 United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of __________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to 9 be 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 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ________________________ [print or 19 type full name] of _________ [print or type full address and telephone number] as 20 my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22

23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25

26 Printed name: ____________________________________ 27