l NOTE: CHANGES MADE BY THE COURT 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 10 11 ID CHARLES D. STAPHOLZ, CASE NO.: 2:19-cev-02194-DSF-PLAx Plaintiff, District Judge: Dale S. Fischer 13 Magistrate fudge: Paul L. Abrams

VS.

14

JAGUAR LAND ROVER NORTH

15 | AMERICA. LLC, a Limited ORDER RE STIPULATED Liability Company; and DOES 1 PROTECTIVE ORDER 16 || through 100, inclusive, 17 Defendants. 18 19 20 Having considered the papers, and finding that good cause exists, the Parties’ 21 || Stipulated Protective Order is granted as modified. 22 IT IS SO ORDERED. 23 24 SakKx. Mamet 25 || Dated: October 3, 2019

PAUL L. ABRAMS

26 United States Magistrate Judge 27 28

ADCANY,. 1 naan UnRAM ANA IRAND □□

SO,

1 || BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505) 2 || E-mail: Brian. Takahashi@bowmanandbrooke.com Dy Theodore Dorenkamp III (SBN: 277004) Oe 3 || E-mail: Theodore.Dorenkam IH @bowmanandbrooke.com “Lon Bryan A. Reynolds (SBN: 2064 ) “O05 4 || E-mail: Bryan.Re nolds@bowmanandbrooke. com □□□□ 970 West 190th Street, uite 700 □□□ 5 || Torrance, California 90502 Tel No.: 310/768-3068 6 || Fax No.: 310/ 719-1019 7 Attomeys for Defendant 3 JAGUAR LAND ROVER NORTH AMERICA, LLC 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA — WESTERN DIVISION 11 CHARLES D. STAPHOLZ, CASE NO.: 2:19-cv-02194-DSF-PLAx Plaintiff, District Judge: Dale S. Fischer 13 Magistrate Judge: Paul L. Abrams

VS.

14 STIPULATED PROTECTIVE

JAGUAR LAND ROVER NORTH ORDER; [PROPOSED] ORDER

15 | AMERICA, LLC, a Limited Liability Company; and DOES 1 16 || through 100, inclusive, 17 Defendants. 18 19

A. PURPOSES AND LIMITATIONS

21 Discovery in this action is likely to involve production of confidential, 22 || proprietary or private information for which special protection from public 23 || disclosure and from use for any purpose other than prosecuting this litigation may 24 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 || enter the following Stipulated Protective Order. The parties acknowledge that this 26 || Order does not confer blanket protections on all disclosures or responses to 27 || discovery and that the protection it affords from public disclosure and use extends 28 || only to the limited information or items that are entitled to confidential treatment

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1 || under the applicable legal principles. 2 B. GOOD CAUSE STATEMENT 3 This action is likely to involve trade secrets, customer information, and other 4 || valuable research, development, commercial, financial, technical and/or proprietary 5 || information for which special protection from public disclosure and from use for any 6 || purpose other than prosecution of this action is warranted. Such confidential and 7 || proprietary materials and information consist of, among other things, confidential 8 || business or financial information, information regarding confidential business 9 || practices, or other confidential research, development, or commercial information 10 | (including information implicating privacy rights of third parties), information 11 || otherwise generally unavailable to the public, or which may be privileged or 12 || otherwise protected from disclosure under state or federal statutes, court rules, case 13 || decisions, or common law. Accordingly, to expedite the flow of information, to 14 || facilitate the prompt resolution of disputes over confidentiality of discovery 15 || materials, to adequately protect information the parties are entitled to keep 16 || confidential, to ensure that the parties are permitted reasonable necessary uses of 17 || such material in preparation for and in the conduct of trial, to address their handling 18 || at the end of the litigation, and serve the ends of justice, a protective order for such 19 || information is justified in this matter. It is the intent of the parties that information 20 || will not be designated as confidential for tactical reasons and that nothing be so 21 || designated without a good faith belief that it has been maintained in a confidential, 22 || non-public manner, and there is good cause why it should not be part of the public 23 || record of this case.

ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

25 The parties further acknowledge, as set forth in Section 12.3, below, that this 26 || Stipulated Protective Order does not entitle them to file confidential information 27 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 28 || and the standards that will be applied when a party seeks permission from the court

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1 || to file material under seal. 2 There is a strong presumption that the public has a right of access to judicial 3 || proceedings and records in civil cases. In connection with non-dispositive motions, 4 || good cause must be shown to support a filing under seal. See Kamakana v. City and 5 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 6 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 7 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 8 || good cause showing), and a specific showing of good cause or compelling reasons 9 || with proper evidentiary support and legal justification, must be made with respect to 10 || Protected Material that a party seeks to file under seal. The parties’ mere designation 11 || of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 12 |} submission of competent evidence by declaration, establishing that the material 13 || sought to be filed under seal qualifies as confidential, privileged, or otherwise 14 || protectable—constitute good cause. 15 Further, if a party requests sealing related to a dispositive motion or trial, then 16 || compelling reasons, not only good cause, for the sealing must be shown, and the 17 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 18 || See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 19 || each item or type of information, document, or thing sought to be filed or introduced 20 || under seal in connection with a dispositive motion or trial, the party seeking 21 || protection must articulate compelling reasons, supported by specific facts and legal 22 || justification, for the requested sealing order. Again, competent evidence supporting 23 || the application to file documents under seal must be provided by declaration. 24 Any document that is not confidential, privileged, or otherwise protectable in 25 || its entirety will not be filed under seal if the confidential portions can be redacted. If 26 || documents can be redacted, then a redacted version for public viewing, omitting only 27 || the confidential, privileged, or otherwise protectable portions of the document, shall 28 || be filed. Any application that seeks to file documents under seal in their entirety

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1 || should include an explanation of why redaction is not feasible.

DEFINITIONS

3 2.1 Action: Charles D. Stapholz v. Jaguar Land Rover North America, 4 || LLC, et. al., United States District Court — Central District, Western Division Case 5 || No. 2:19-cv-02194-DSF-PLAx. 6 2.2 Challenging Party: a Party or Non-Party that challenges the designation 7 || of information or items under this Order. 8 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 9 || how it is generated, stored or maintained) or tangible things that qualify for 10 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 || the Good Cause Statement. 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 13 || their support staff). 14 2.5 Designating Party: a Party or Non-Party that designates information or 15 || items that it produces in disclosures or in responses to discovery as 16 || “CONFIDENTIAL.” 17 2.6 Disclosure or Discovery Material: all items or information, regardless 18 || of the medium or manner in which it is generated, stored, or maintained (including, 19 || among other things, testimony, transcripts, and tangible things), that are produced or 20 || generated in disclosures or responses to discovery in this matter. 21 2.7 Expert: a person with specialized knowledge or experience in a matter 22 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 23 || an expert witness or as a consultant in this Action. 24 2.8 House Counsel: attorneys who are employees of a party to this Action. 25 || House Counsel does not include Outside Counsel of Record or any other outside 26 || counsel. 27 /// 28 || ///

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1 2.9 Non-Party: any natural person, partnership, corporation, association 2 || or other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a party 4 || to this Action but are retained to represent or advise a party to this Action and have 5 || appeared in this Action on behalf of that party or are affiliated with a law firm that 6 || has appeared on behalf of that party, and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 || employees, consultants, retained experts, and Outside Counsel of Record (and their 9 || support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 || Discovery Material in this Action. 12 2.13. Professional Vendors: persons or entities that provide litigation support 13 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 || and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 || designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 |; from a Producing Party. 20 ||3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 || Protected Material (as defined above), but also (1) any information copied or 23 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 || compilations of Protected Material; and (3) any testimony, conversations, or 25 || presentations by Parties or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 || trial judge. This Order does not govern the use of Protected Material at trial. 28 ///

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DURATION

2 Once a case proceeds to trial, information that was designated as 3 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 || as an exhibit at trial becomes public and will be presumptively available to all 5 || members of the public, including the press, unless compelling reasons supported by 6 || specific factual findings to proceed otherwise are made to the trial judge in advance 7 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 8 || showing for sealing documents produced in discovery from “compelling reasons” 9 || standard when merits-related documents are part of court record). Accordingly, the 10 || terms of this protective order do not extend beyond the commencement of the trial.

DESIGNATING PROTECTED MATERIAL

12 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 || Each Party or Non-Party that designates information or items for protection under 14 || this Order must take care to limit any such designation to specific material that 15 || qualifies under the appropriate standards. The Designating Party must designate for 16 || protection only those parts of material, documents, items or oral or written 17 || communications that qualify so that other portions of the material, documents, items 18 || or communications for which protection is not warranted are not swept unjustifiably 19 || within the ambit of this Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations 21 || that are shown to be clearly unjustified or that have been made for an improper 22 || purpose (e.g., to unnecessarily encumber the case development process or to impose 23 || unnecessary expenses and burdens on other parties) may expose the Designating 24 || Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 || designated for protection do not qualify for protection, that Designating Party must 27 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 || ///

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1 5.2 Manner and Timing of Designations. Except as otherwise provided in this 2 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 3 || or ordered, Disclosure or Discovery Material that qualifies for protection under this 4 || Order must be clearly so designated before the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic documents, 7 || but excluding transcripts of depositions or other pretrial or trial proceedings), that 8 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 9 || “CONFIDENTIAL legend”), to each page that contains protected material. If only 10 |] a portion of the material on a page qualifies for protection, the Producing Party also 11 |] must clearly identify the protected portion(s) (e.g., by making appropriate markings 12 || in the margins). 13 A Party or Non-Party that makes original documents available for inspection 14 || need not designate them for protection until after the inspecting Party has indicated 15 || which documents it would like copied and produced. During the inspection and 16 || before the designation, all of the material made available for inspection shall be 17 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 18 || documents it wants copied and produced, the Producing Party must determine which 19 || documents, or portions thereof, qualify for protection under this Order. Then, before 20 || producing the specified documents, the Producing Party must affix the 21 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 22 || portion of the material on a page qualifies for protection, the Producing Party also 23 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 24 || in the margins). 25 (b) for testimony given in depositions that the Designating Party identifies the 26 || Disclosure or Discovery Material on the record, before the close of the deposition 27 || all protected testimony. 28 (c) for information produced in some form other than documentary and for

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] || any other tangible items, that the Producing Party affix in a prominent place on the 2 || exterior of the container or containers in which the information is stored the legend 3 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 4 || protection, the Producing Party, to the extent practicable, shall identify the protected 5 |} portion(s). 6 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 || failure to designate qualified information or items does not, standing alone, waive 8 || the Designating Party’s right to secure protection under this Order for such material. 9 || Upon timely correction of a designation, the Receiving Party must make reasonable 10 || efforts to assure that the material is treated in accordance with the provisions of this 11 || Order. 12 CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 || designation of confidentiality at any time that is consistent with the Court’s 15 || Scheduling Order. 16 6.2 Meet_and Confer. The Challenging Party shall initiate the dispute 17 || resolution process under Local Rule 37-1 et seq. 18 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 19 || joint stipulation pursuant to Local Rule 37-2. 20 6.4 The burden of persuasion in any such challenge proceeding shall be on 21 || the Designating Party. Frivolous challenges, and those made for an improper 22 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 23 || parties) may expose the Challenging Party to sanctions. Unless the Designating 24 || Party has waived or withdrawn the confidentiality designation, all parties shall 25 || continue to afford the material in question the level of protection to which it is 26 || entitled under the Producing Party’s designation until the Court rules on the 27 || challenge. 28 | ///

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1 ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 || disclosed or produced by another Party or by a Non-Party in connection with this 4 || Action only for prosecuting, defending or attempting to settle this Action. Such 5 || Protected Material may be disclosed only to the categories of persons and under the 6 || conditions described in this Order. When the Action has been terminated, a 7 || Receiving Party must comply with the provisions of section 13 below (FINAL 8 || DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 || location and in a secure manner that ensures that access is limited to the persons 11 || authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 || otherwise ordered by the court or permitted in writing by the Designating Party, a 14 || Receiving Party may disclose any information or item designated 15 || “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 17 || employees of said Outside Counsel of Record to whom it is reasonably necessary to 18 || disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this 21 || Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 || disclosure is reasonably necessary for this Action and who have signed the 24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 /// 28 | ///

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l (f) professional jury or trial consultants, mock jurors, and Professional 2 || Vendors to whom disclosure is reasonably necessary for this Action and who have 3 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 || custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 9 || not be permitted to keep any confidential information unless they sign the 10 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 || agreed by the Designating Party or ordered by the court. Pages of transcribed 12 || deposition testimony or exhibits to depositions that reveal Protected Material may 13 || be separately bound by the court reporter and may not be disclosed to anyone except 14 || as permitted under this Stipulated 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 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 litigation 20 || that compels disclosure of any information or items designated in this Action as 21 || “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification shall 23 || include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order to 25 || issue in the other litigation that some or all of the material covered by the subpoena 26 || or order is subject to this Protective Order. Such notification shall include a copy of 27 || this Stipulated Protective Order; and 28 (c) cooperate with respect to all reasonable procedures sought to be pursued

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1 || by the Designating Party whose Protected Material may be affected. 2 If the Designating Party timely seeks a protective order, the Party served with 3 || the subpoena or court order shall not produce any information designated in this 4 || action as “CONFIDENTIAL.” before a determination by the court from which the 5 || subpoena or order issued, unless the Party has obtained the Designating Party’s 6 || permission. The Designating Party shall bear the burden and expense of seeking 7 || protection in that court of its confidential material and nothing in these provisions 8 || should be construed as authorizing or encouraging a Receiving Party in this Action 9 || to disobey a lawful directive from another court.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 14 || produced by Non-Parties in connection with this litigation is protected by the 15 || remedies and relief provided by this Order. Nothing in these provisions should be 16 || construed as prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 || produce a Non-Party’s confidential information in its possession, and the Party is 19 || subject to an agreement with the Non-Party not to produce the Non-Party’s 20 || confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non- 22 || Party that some or all of the information requested is subject to a confidentiality 23 || agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 || specific description of the information requested; and /// 28 ///

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1 (3) make the information requested available for inspection by the 2 || Non-Party, if requested. 3 (c) Ifthe Non-Party fails to seek a protective order from this court within 4 || 14 days of receiving the notice and accompanying information, the Receiving Party 5 || may produce the Non-Party’s confidential information responsive to the discovery 6 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 7 || not produce any information in its possession or control that is subject to the 8 || confidentiality agreement with the Non-Party before a determination by the court. 9 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 10 || of seeking protection in this court of its Protected Material. 11 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 || Protected Material to any person or in any circumstance not authorized under this 14 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person 17 || or persons to whom unauthorized disclosures were made of all the terms of this 18 || Order, and (d) request such person or persons to execute the “Acknowledgment and 19 || Agreement to Be Bound” that is attached hereto as Exhibit A. 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 28 || the parties reach an agreement on the effect of disclosure of a communication or

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1 || information covered by the attorney-client privilege or work product protection, the 2 || parties may incorporate their agreement in the stipulated protective order submitted 3 || to the court. 4}}12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 || person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 || Protective Order, no Party waives any right it otherwise would have to object to 9 || disclosing or producing any information or item on any ground not addressed in this 10 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 || ground to use in evidence of any of the material covered by this Protective 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 may 14 || only be filed under seal pursuant to a court order authorizing the sealing of the 15 || specific Protected Material at issue. If a Party’s request to file Protected Material 16 || under seal is denied by the court, then the Receiving Party may file the information 17 || in the public record unless otherwise instructed by the court. Filing—Protected’ 18 || Materiel. A-Party-thatsecks to-fite-under-seatany Protected-Materiat must-eompty □□□ 19 || with boeat Civit Rute 79-5. Protected ivfatertatmay-onty-be-fitedunderseal-pursuant 20 || te-a-eourt-erder-authorizing the seahng of the specific Protected Matertatat issue. tt 21 22 23 || enstructed-by-the court— 24 || 13. FINAL DISPOSITION 25 After the final disposition of this Action, as defined in paragraph 4, within 60 26 || days of a written request by the Designating Party, each Receiving Party must return 27 || all Protected Material to the Producing Party or destroy such material. As used in 28 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

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I || summaries, and any other format reproducing or capturing any of the Protected 2 || Material. Whether the Protected Material is returned or destroyed, the Receiving 3 |] Party must submit a written certification to the Producing Party (and, if not the same 4 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 5 || (by category, where appropriate) all the Protected Material that was returned or 6 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 7 || abstracts, compilations, summaries or any other format reproducing or capturing any 8 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 9 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 10 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 11 || reports, attorney work product, and consultant and expert work product, even if such 12 || materials contain Protected Material. Any such archival copies that contain or 13 |] constitute Protected Material remain subject to this Protective Order as set forth in 14 || Section 4 (DURATION). 15 || /// 16 /// 17} /// 18 |) /// 19 || /// 20 || /// 21 /// 22 || /// 23 /// 24 || /// 25 /// 26 |} /// 27 | /// 28 | ///

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14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 || DATED: October 2, 2019 THE LAW OFFICE OF ROBERT L. STARR 8 9 By: /s/Robert L. Starr 10 Robert L. Starr Adam M. Rose _ . Attorneys for Plaintiff 1 CHARLES D. STAPHOLZ 12 13 || DATED: October 2, 2019 BOWMAN AND BROOKE LLP 14 15 By: /s/ Bryan S. Reynolds Brian Takahashi 16 Theodore Dorenkamp III Bryan Reynolds 17 Attorneys for Defendant

JAGUAR LAND ROVER NORTH

18 AMERICA, LLC 19 20 21 22 23 24 25 26 27 28

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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 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 Charles D. Stapholz v. Jaguar Land Rover North America, 8 || LLC, et. al., United States District Court — Central District, Western Division Case 9 || No. 2:19-cv-02194-DSF-PLAx. I agree to comply with and to be bound by all the 10 || terms of this Stipulated Protective Order and I understand and acknowledge that 11 || failure to so comply could expose me to sanctions and punishment in the nature of 12 || contempt. I solemnly promise that I will not disclose in any manner any information 13 || or item that is subject to this Stipulated Protective Order to any person or entity 14 || except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 || Protective Order, even if such enforcement proceedings occur after termination of 18 || this action. I hereby appoint [print or type full 19 || name] of [print or type full address 20 || and telephone number] as my California agent for service of process in connection 21 || with this action or any proceedings related to enforcement of this Stipulated 22 || Protective Order. 23 24 || Date: 25 || City and State where sworn and signed: 26 || Printed name: 27 || Signature: 28

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