1 S. YOUNG LIM (SBN126679

DAVID B. BLOOM (SBN 56573)

2 JAMES E. ADLER (SBN 75653)

PARK & LIM

3 3530 Wilshire Boulevard, Suite 1300 Los Angeles, CA 90010 4 Telephone: (213) 386-5595 Facsimile: (213) 384-7110 5 david@parkandlim.com james@parkandlim.com 6 Attorneys for Plaintiff, Jeereddi Enterprises, LLC 7

8

UNITED STATES DISTRICT COURT

9

FOR THE CENTRAL DISTRICT OF CALIFORNIA

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11 JEEREDDI ENTERPRISES, LLC, a ) CASE NO. 2:22-CV-1614-SSS-AFM 12 ) California limited liability company, ) STIPULATED PROTECTIVE 13 ) ) ORDER1 14 Plaintiff ) ) 15 vs. ) Date: June 6, 2023 ) Time: 10:00 a.m. 16 ) Courtroom: 780 VENKATA SUBASH BANDA, aka ) 17 SUBASH BANDA, an individual; and ) ) Discovery Cuttoff: June 13, 2023 18 LODESTAR HOLDINGS LLC, a ) ) Pretrial Conference: Oct. 20, 2023 Texas limited liability company, 19 ) Trial Date: Nov. 6, 2023 )

20 Defendants. ) ) 21 )

22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary or private information for which special protection from public 25 26

1 This Stipulated Protective Order is based substantially on the model protective 27 order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 28 1 disclosure and from use for any purpose other than prosecuting this litigation may 2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that 3 this Order does not confer blanket protections on all disclosures or responses to 4 discovery and that the protection it affords from public disclosure and use extends 5 only to the limited information or items that are entitled to confidential treatment 6 under the applicable legal principles. 7

B. GOOD CAUSE STATEMENT

8 This action, including but not limited to discovery relating to enforcement 9 of the Right to Attach Orders and Writs of attachment, and enforcement of any 10 judgment is likely to involve disclosure of private and confidential financial, 11 asset, and business information for which special protection from public 12 disclosure and from use for any purpose other than prosecution of this action or 13 enforcement of the attachments issued in this action or any judgment is 14 warranted. Accordingly, to expedite the flow of information, to facilitate the 15 prompt resolution of disputes over confidentiality of discovery materials, to 16 adequately protect information the parties are entitled to keep confidential, to 17 ensure that the parties are permitted reasonable necessary uses of such material 18 to address their handling at the end of the litigation, and serve the ends of justice, 19 a protective order for such information is justified in this matter. It is the intent of 20 the parties that information will not be designated as confidential for tactical 21 reasons and that nothing be so designated without a good faith belief that it has 22 been maintained in a confidential, non-public manner, and there is good cause 23 why it should not be part of the public record of this case. 24

C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER

25

SEAL

26 The parties further acknowledge, as set forth in Section 12.3, below, that 27 this Stipulated Protective Order does not entitle them to file confidential 28 1 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 2 be followed and the standards that will be applied when a party seeks permission from the court to file material under seal. 3 There is a strong presumption that the public has a right of access to 4 judicial proceedings and records in civil cases. In connection with non-dispositive 5 motions, good cause must be shown to support a filing under seal. See Kamakana 6 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 7 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 8 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 9 protective orders require good cause showing), and a specific showing of good 10 cause or compelling reasons with proper evidentiary support and legal 11 justification, must be made with respect to Protected Material that a party seeks to 12 file under seal. The parties’ mere designation of Disclosure or Discovery Material 13 as CONFIDENTIAL does not— without the submission of competent evidence 14 by declaration, establishing that the material sought to be filed under seal 15 qualifies as confidential, privileged, or otherwise protectable—constitute good 16 cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, 18 then compelling reasons, not only good cause, for the sealing must be shown, and 19 the relief sought shall be narrowly tailored to serve the specific interest to be 20 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 21 2010). For each item or type of information, document, or thing sought to be filed 22 or introduced under seal in connection with a dispositive motion or trial, the party 23 seeking protection must articulate compelling reasons, supported by specific facts 24 and legal justification, for the requested sealing order. Again, competent evidence 25 supporting the application to file documents under seal must be provided by 26 declaration. 27 Any document that is not confidential, privileged, or otherwise protectable 28 1 in its entirety will not be filed under seal if the confidential portions can be 2 redacted. If documents can be redacted, then a redacted version for public viewing, omitting only the confidential, privileged, or otherwise protectable 3 portions of the document, shall be filed. Any application that seeks to file 4 documents under seal in their entirety should include an explanation of why 5 redaction is not feasible. 6 2. DEFINITIONS 7 2.1 Action: the above entitled, pending federal lawsuit. 8 2.2 Challenging Party: a Party or Non-Party that challenges the 9 designation of information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless 11 of how it is generated, stored or maintained) or tangible things that qualify for 12 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information 17 or items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, 20 regardless of the medium or manner in which it is generated, stored, or 21 maintained (including among other things, testimony, transcripts, and tangible 22 things), that are produced or generated in disclosures or responses to discovery in 23 this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a 25 matter pertinent to the litigation who has been retained by a Party or its counsel to 26 serve as an expert witness or as a consultant in this Action. 27 2.8 House Counsel: attorneys who are employees of a party to this 28 1 Action. House Counsel does not include Outside Counsel of Record or any other 2 outside counsel. 2.9 Non-Party: any natural person, partnership, corporation, association 3 or other legal entity not named as a Party to this action. 4 2.10 Outside Counsel of Record: attorneys who are not employees of a 5 party to this Action but are retained to represent or advise a party to this Action 6 and have appeared in this Action on behalf of that party or are affiliated with a 7 law firm that has appeared on behalf of that party, and includes support staff. 8 2.11 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Outside Counsel of Record (and 10 their support staffs). 11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.13 Professional Vendors: persons or entities that provide litigation 14 support services (e.g., photocopying, videotaping, translating, preparing exhibits 15 or demonstrations, and organizing, storing, or retrieving data in any form or 16 medium) and their employees and subcontractors. 17 2.14 Protected Material: any Disclosure or Discovery Material that is 18 designated as “CONFIDENTIAL.” 19 2.15 Receiving Party: a Party that receives Disclosure or Discovery 20 Material from a Producing Party. 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the trial 28 1 judge. This Order does not govern the use of Protected Material at trial. 2 4. DURATION Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or 4 introduced as an exhibit at trial becomes public and will be presumptively 5 available to all members of the public, including the press, unless compelling 6 reasons supported by specific factual findings to proceed otherwise are made to 7 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 8 (distinguishing “good cause” showing for sealing documents produced in 9 discovery from “compelling reasons” standard when merits-related documents are 10 part of court record). Accordingly, the terms of this protective order do not extend 11 beyond the commencement of the trial. 12 Notwithstanding the foregoing, with respect to financial, asset, and 13 business documents relating to enforcement of the right to attach orders and writs 14 of attachment entered in this case, or enforcement of any judgment entered in this 15 case, neither this Order, nor the Action shall not be deemed to have terminated, or 16 disposed of, until such time as any judgment entered has been satisfied. 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for 19 Protection. Each Party or Non-Party that designates information or items for 20 protection under this Order must take care to limit any such designation to 21 specific material that qualifies under the appropriate standards. The Designating 22 Party must designate for protection only those parts of material, documents, items 23 or oral or written communications that qualify so that other portions of the 24 material, documents, items or communications for which protection is not 25 warranted are not swept unjustifiably within the ambit of this Order. 26 Mass, indiscriminate or routinized designations are prohibited. 27 Designations that are shown to be clearly unjustified or that have been made for 28 1 an improper purpose (e.g., to unnecessarily encumber the case development 2 process or to impose unnecessary expenses and burdens on other parties) may expose the Designating Party to sanctions. If it comes to a Designating Party’s 3 attention that information or items that it designated for protection do not qualify 4 for protection, that Designating Party must promptly notify all other Parties that it 5 is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided 7 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for 9 protection under this Order must be clearly so designated before the material is 10 disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other pretrial or trial 14 proceedings), that the Producing Party affix at a minimum, the legend 15 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 16 contains protected material. If only a portion of the material on a page qualifies 17 for protection, the Producing Party also must clearly identify the protected 18 portion(s) (e.g., by making appropriate markings in the margins). 19 A Party or Non-Party that makes original documents available for 20 inspection need not designate them for protection until after the inspecting Party 21 has indicated which documents it would like copied and produced. During the 22 inspection and before the designation, all of the material made available for 23 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 24 identified the documents it wants copied and produced, the Producing Party must 25 determine which documents, or portions thereof, qualify for protection under this 26 Order. Then, before producing the specified documents, the Producing Party must 27 affix the “CONFIDENTIAL legend” to each page that contains Protected 28 1 Material. If only a portion of the material on a page qualifies for protection, the 2 Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating Party 4 identifies the Disclosure or Discovery Material on the record, before the close of 5 the deposition all protected testimony. 6 (c) for information produced in some form other than documentary and 7 for any other tangible items, that the Producing Party affix in a prominent place 8 on the exterior of the container or containers in which the information is stored 9 the legend “CONFIDENTIAL.” If only a portion or portions of the information 10 warrants protection, the Producing Party, to the extent practicable, shall identify 11 the protected portion(s). 12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 13 failure to designate qualified information or items does not, standing alone, waive 14 the Designating Party’s right to secure protection under this Order for such 15 material. Upon timely correction of a designation, the Receiving Party must make 16 reasonable efforts to assure that the material is treated in accordance with the 17 provisions of this Order. 18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 20 designation of confidentiality at any time that is consistent with the Court’s 21 Scheduling Order. 22 6.2 Meet and Confer: The Challenging Party shall initiate the dispute 23 resolution process under Local Rule 37-1 et seq. 24 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 25 joint stipulation pursuant to Local Rule 37-2. 26 6.4 The burden of persuasion in any such challenge proceeding shall be 27 on the Designating Party. Frivolous challenges, and those made for an improper 28 1 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality designation, all parties shall 3 continue to afford the material in question the level of protection to which it is 4 entitled under the Producing Party’s designation until the Court rules on the 5 challenge. 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that 8 is disclosed or produced by another Party or by a Non-Party in connection with 9 this Action only for prosecuting, defending, attempting to settle this Action, for 10 the purpose of enforcing the right to attach orders and writs of attachment issued 11 in this Action, or enforcement of any judgment in this action. Such Protected 12 Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15

DISPOSITION).

16 Notwithstanding the foregoing, including with respect to compliance with 17 the provisions of section 13 below (FINAL DISPOSITION), with respect to 18 financial, asset, and business documents relating to enforcement of the right to 19 attach orders and writs of attachment entered in this case, or enforcement of any 20 judgment entered in this case, the Action shall not be deemed to have terminated, 21 or disposed of, until such time as any judgment entered in the Action has been 22 satisfied. 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 27 otherwise ordered by the court or permitted in writing by the Designating Party, a 28 1 Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: (a) the Receiving Party’s Outside Counsel of Record in this Action, as 3 well as employees of said Outside Counsel of Record to whom it is reasonably 4 necessary to disclose the information for this Action; 5 (b) the officers, directors, managers, members, and employees 6 (including House Counsel) of the Receiving Party to whom disclosure is 7 reasonably necessary for this Action; 8 (c) Experts (as defined in this Order) of the Receiving Party to whom 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (d) the court and its personnel; 12 (e) court reporters and their staff; 13 (f) professional jury or trial consultants, mock jurors, and Professional 14 Vendors to whom disclosure is reasonably necessary for this Action and who 15 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, witnesses, and attorneys for witnesses, in 19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 20 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 21 they will not be permitted to keep any confidential information unless they sign 22 them “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 23 otherwise agreed by the Designating Party or ordered by the court. Pages of 24 transcribed deposition testimony or exhibits to depositions that reveal Protected 25 Material may be separately bound by the court reporter and may not be disclosed 26 to anyone except as permitted under this Stipulated Protective Order; 27 (i) any mediator or settlement officer, and their supporting personnel, 28 1 mutually agreed upon by any of the parties engaged in settlement discussions; 2 (j) any levying officer and any other person lawfully executing process or other enforcement method with respect to the right to attach orders or writs of 3 attachment issued in the Action, or any judgment issued in the Action, for the 4 purpose of providing the information necessary for execution of process or other 5 enforcement method; 6 (k) Any attorney, lawyer, or other legal professional retained or 7 consulted with respect to enforcement of any judgment in that jurisdiction; and 8 (l) Any investigator for the purpose of locating additional assets of 9 Defendants, for the purpose of enforcing to the right to attach orders or writs of 10 attachment issued in the Action, or any judgment issued in the Action, provided 11 that scope of such investigations shall be limited to assets located within the 12 United States of America, unless and until a judgment has been entered in the 13 Action, and provided that the investigator has signed the “Acknowledgment and 14 Agreement to Be Bound” (Exhibit A). 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 16

IN OTHER LITIGATION

17 If a Party is served with a subpoena or a court order issued in other 18 litigation that compels disclosure of any information or items designated in this 19 Action as “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification 21 shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or 23 order to issue in the other litigation that some or all of the material covered by the 24 subpoena or order is subject to this Protective Order. Such notification shall 25 include a copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be 27 pursued by the Designating Party whose Protected Material may be affected. If 28 1 the Designating Party timely seeks a protective order, the Party served with the 2 subpoena or court order shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the court from which the 3 subpoena or order issued, unless the Party has obtained the Designating Party’s 4 permission. The Designating Party shall bear the burden and expense of seeking 5 protection in that court of its confidential material and nothing in these provisions 6 should be construed as authorizing or encouraging a Receiving Party in this 7 Action to disobey a lawful directive from another court. 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9

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.” Such 12 information produced by Non-Parties in connection with this litigation is 13 protected by the remedies and relief provided by this Order. Nothing in these 14 provisions should be construed as prohibiting a Non-Party from seeking 15 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 21 Party that some or all of the information requested is subject to a confidentiality 22 agreement 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 25 reasonably specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 Non-Party, if requested. 28 1 (c) If the Non-Party fails to seek a protective order from this court 2 within 14 days of receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential information 3 responsive to the discovery request. If the Non-Party timely seeks a protective 4 order, the Receiving Party shall not produce any information in its possession or 5 control that is subject to the confidentiality agreement with the Non-Party before 6 a determination by the court. Absent a court order to the contrary, the Non-Party 7 shall bear the burden and expense of seeking protection in this court of its 8 Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has 11 disclosed Protected Material to any person or in any circumstance not authorized 12 under this Stipulated Protective Order, the Receiving Party must immediately (a) 13 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 14 best efforts to retrieve all unauthorized copies of the Protected Material, (c) 15 inform the person or persons to whom unauthorized disclosures were made of all 16 the terms of this Order, and (d) request such person or persons to execute the 17 “Acknowledgment and Agreement to Be Bound” that is attached hereto as 18 Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20

PROTECTED MATERIAL

21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other 23 protection, the obligations of the Receiving Parties are those set forth in Federal 24 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 25 whatever procedure may be established in an e-discovery order that provides for 26 production without prior privilege review. Pursuant to Federal Rule of Evidence 27 502(d) and (e), insofar as the parties reach an agreement on the effect of 28 1 disclosure of a communication or information covered by the attorney-client 2 privilege or work product protection, the parties may incorporate their agreement in the stipulated protective order submitted to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of 5 any person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order, no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in 9 this Stipulated Protective Order. Similarly, no Party waives any right to object on 10 any ground to use in evidence of any of the material covered by this Protective 11 Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Local Civil Rule 79-5. Protected Material 14 may only be filed under seal pursuant to a court order authorizing the sealing of 15 the specific Protected Material at issue. If a Party’s request to file Protected 16 Material under seal is denied by the court, then the Receiving Party may file the 17 information in the public record unless otherwise instructed by the court. 18 13. FINAL DISPOSITION 19 After the final disposition of this Action, as defined in paragraph 4, and 20 7.1, above, within 60 days of a written request by the Designating Party, each 21 Receiving Party must return all Protected Material to the Producing Party or 22 destroy such material. As used in this subdivision, “all Protected Material” 23 includes all copies, abstracts, compilations, summaries, and any other format 24 reproducing or capturing any of the Protected Material. Whether the Protected 25 Material is returned or destroyed, the Receiving Party must submit a written 26 certification to the Producing Party (and, if not the same person or entity, to the 27 Designating Party) by the 60 day deadline that (1) identifies (by category, where 28 1 ||appropriate) all the Protected Material that was returned or destroyed and (2) 2 ||affirms that the Receiving Party has not retained any copies, abstracts, 3 || compilations, summaries or any other format reproducing or capturing any of the 4 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain 5 |}an archival copy of all pleadings, motion papers, trial, deposition, and hearing 6 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, 7 || expert reports, attorney work product, and consultant and expert work product, g ||even if such materials contain Protected Material. Any such archival copies that 9 || contain or constitute Protected Material remain subject to this Protective Order as 10 || set forth Section 4 (DURATION). 11 VIOLATION 12 || Any violation of this Order may be punished by appropriate measures including, 13 || without limitation, contempt proceedings and/or monetary sanctions. 14 |} DATED: June 7, 2023 PARK & LIM 15 By: _/S/S. Young Lim 16 Piaintiff Jeereddi Enterprises LLC 17 || DATED: June 7 , 2023 BARANOV & WITTENBERG, LLP By: /S/ Michael M. Baranov 21 LLC 22 53 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. ||DATED: 6/8/2023 25 |) Bey Maxk&-—— 27 || HON. ALEXANDER F. MacKINNON United States Magistrate Judge

□

STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, _____________________________ [print or type full name], of 3 _________________ [print or type full address], declare under penalty of perjury 4 that I have read in its entirety and understand the Stipulated Protective Order that 5 was issued by the United States District Court for the Central District of 6 California on [date] in the case of Jeereddi Enterprises, LLC v. Venkata Subash 7 Banda, Lodestar Holdings LLC, Case No. 22-cv-1614-SSS-AFM. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order 9 and I understand and acknowledge that failure to so comply could expose me to 10 sanctions and punishment in the nature of contempt. I solemnly promise that I 11 will not disclose in any manner any information or item that is subject to this 12 Stipulated Protective Order to any person or entity except in strict compliance 13 with the provisions of this Order. I further agree to submit to the jurisdiction of 14 the United States District Court for the Central District of California for enforcing 15 the terms of this Stipulated Protective Order, even if such enforcement 16 proceedings occur after termination of this action. I hereby appoint 17 __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection 20 with this action or any proceedings related to enforcement of this Stipulated 21 Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27 28