1 || Javier F. Garcia, Bar No. 296846 YGarciaperkinscalé.com 2 || PERKINS COIE LLP 1888 Century Park E., Suite 1700 3 || Los Angeles, California 90067-1721 Telephone: 310.788.9900 4 || Facsimile: 310.788.3399 5 || Attorneys for Defendants ‘ STERN BROTHERS & CO.

ALEXANDER KRAKOW + GLICK LLP

7 || Marvin E. Krakow (State Bar No. 81228) Amelia Alvarez (State Bar No. 310044) 8 || 1900 Avenue of the Stars, Suite 900 Los Angeles. California 90067 9 || T: 310 394 0888 | F: 310 394 0811 E: mkrakow@akgllp.com| E: 10 | aalvarez@akellp.com 11 || Attorneys for Plaintiff RICHARD DEPROSPO 12

UNITED STATES DISTRICT COURT

13

CENTRAL DISTRICT OF CALIFORNIA

14 15 RICHARD DEPROSPO, an Case No. 2:18-cv-10315 MWF(AGRx) 16 || individual, Assigned to the Hon. Michael W. 17 Plaintiff, Fitzgerald, Courtroom 5A 18 Vv. ORDER GRANTING STIPULATED

PROTECTIVE ORDER

19 || STERN BROTHERS & CO., a Missouri corporation, and Does 1-50, 20 || inclusive, State Complaint Filed: October 11, 2018 21 Defendants. Date of Removal: December 13, 2018 3 Trial Date: February 4, 2020

23 24 25 26 27 28

1 Pursuant to Fed. R. Civ. P. 26(c), the parties to this lawsuit, through 2 || undersigned counsel, jointly submit this Stipulated Protective Order to govern the 3 || handling of information and materials produced in the course of discovery or filed 4 || with the Court in this action. 5} 1. A. PURPOSES AND LIMITATIONS 6 Discovery in this action is likely to involve production of confidential, 7 || proprietary or private information for which special protection from public 8 || disclosure and from use for any purpose other than prosecuting this litigation may 9 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 10 || enter the following Stipulated Protective Order. The parties acknowledge that this 11 || Order does not confer blanket protections on all disclosures or responses to 12 || discovery and that the protection it affords from public disclosure and use extends 13 || only to the limited information or items that are entitled to confidential treatment 14 || under the applicable legal principles. 15 B. GOOD CAUSE STATEMENT 16 This action is likely to involve sensitive third-party personnel information, 17 || customer lists, and other valuable development, commercial, financial, technical 18 || and/or proprietary information for which special protection from public disclosure 19 || and from use for any purpose other than prosecution of this action is warranted. 20 || Such confidential and proprietary materials and information consist of, among other 21 || things, (a) confidential business or financial information, information regarding 22 || confidential business practices, or other confidential research, development, or 23 || commercial information (including information implicating privacy rights of third 24 || parties), (b) financial, compensation, employment, benefits, and tax documents 25 || belonging to plaintiff and non-parties to this litigation, (c) personnel information 26 || including disciplinary actions and performance ratings of non-parties to this 27 || litigation; (d) personal identifying information, including but not limited to the 28 || home addresses, telephone numbers, ages of past or present employees of 2.

1 || Defendant; and (e) information otherwise generally unavailable to the public, or 2 || which may be privileged or otherwise protected from disclosure under state or 3 || federal statutes, court rules, case decisions, or common law. 4 Accordingly, to expedite the flow of information, to facilitate the prompt 5 || resolution of disputes over confidentiality of discovery materials, to adequately 6 || protect information the parties are entitled to keep confidential, to ensure that the 7 || parties are permitted reasonable necessary uses of such material in preparation for 8 || and in the conduct of trial, to address their handling at the end of the litigation, and 9 || serve the ends of justice, a protective order for such information 1s justified in this 10 || matter. It is the intent of the parties that information will not be designated as 11 || confidential for tactical reasons and that nothing be so designated without a good 12 || faith belief that it has been maintained in a confidential, non-public manner, and 13 || there is good cause why it should not be part of the public record of this case. 14 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 15 SEAL 16 The parties further acknowledge, as set forth in Section 12.3, below, that this 17 || Stipulated Protective Order does not entitle them to file confidential information 18 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 19 || and the standards that will be applied when a party seeks permission from the court 20 || to file material under seal. 21 There 1s a strong presumption that the public has a right of access to judicial 22 || proceedings and records in civil cases. In connection with non-dispositive motions, 23 || good cause must be shown to support a filing under seal. See Kamakana □□□ City and 24 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 25 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 26 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 27 || require good cause showing), and a specific showing of good cause or compelling 28 || reasons with proper evidentiary support and legal justification, must be made with 3.

1 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 2 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 3 || without the submission of competent evidence by declaration, establishing that the 4 || material sought to be filed under seal qualifies as confidential, privileged, or 5 || otherwise protectable—constitute good cause. 6 Further, if a party requests sealing related to a dispositive motion or trial, 7 || then compelling reasons, not only good cause, for the sealing must be shown, and 8 || the relief sought shall be narrowly tailored to serve the specific interest to be 9 || protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 10 |} 2010). For each item or type of information, document, or thing sought to be filed 11 || or introduced under seal in connection with a dispositive motion or trial, the party 12 || seeking protection must articulate compelling reasons, supported by specific facts 13 || and legal justification, for the requested sealing order. Again, competent evidence 14 || supporting the application to file documents under seal must be provided by 15 || declaration. 16 Any document that is not confidential, privileged, or otherwise protectable in 17 || its entirety will not be filed under seal if the confidential or identifying 18 || portions/information can be redacted. If documents can be redacted, then a redacted 19 || version for public viewing, omitting only the confidential, privileged, or otherwise 20 || protectable portions of the document, shall be filed. Any application that seeks to 21 || file documents under seal in their entirety should include an explanation of why 22 || redaction is not feasible. 23 || 2. DEFINITIONS 24 2.1 Action: this pending federal lawsuit. 25 2.2 Challenging Party: a Party or Non-Party that challenges the designation 26 || of information or items under this Order. 27 4 /// 28 | /// 4.

1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 2 || how it is generated, stored or maintained) or tangible things that qualify for 3 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 4 || the Good Cause Statement. 5 2.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as 6 || their support staff). 7 2.5 Designating Party: a Party or Non-Party that designates information or 8 || items that it produces in disclosures or in responses to discovery as 9 || “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, regardless of 11 || the medium or manner in which it is generated, stored, or maintained (including, 12 || among other things, testimony, transcripts, and tangible things), that are produced 13 || or generated in disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter 15 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 16 || an expert witness or as a consultant in this Action. 17 2.8 In-House Counsel: attorneys who are employees of a party to this 18 || Action. In-House Counsel does not include Outside Counsel of Record or any other 19 || outside counsel. 20 2.9 Non-Party: any natural person, partnership, corporation, association or 21 || other legal entity not named as a Party to this action. 22 2.10 Outside Counsel of Record: attorneys who are not employees of a party 23 || to this Action but are retained to represent or advise a party to this Action and have 24 || appeared in this Action on behalf of that party or are affiliated with a law firm that 25 || has appeared on behalf of that party, and includes support staff. 26 2.11 Party: any party to this Action, including all of its officers, directors, 27 || employees, consultants, retained experts, and Outside Counsel of Record (and their 28 || support staffs). 5.

1 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 2 || Discovery Material in this Action. 3 2.13 Professional Vendors: persons or entities that provide litigation support 4 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 6 || and their employees and subcontractors. 7 2.14 Protected Material: any Disclosure or Discovery Material that is 8 || designated as “CONFIDENTIAL.” 9 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 10 || from a Producing Party. 11 |] 3. SCOPE 12 The protections conferred by this Stipulation and Order cover not only 13 || Protected Material (as defined above), but also (1) any information copied or 14 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 15 || compilations of Protected Material; and (3) any testimony, conversations, or 16 || presentations by Parties or their Counsel that might reveal Protected Material. 17 || Any use of Protected Material at trial shall be governed by the orders of the trial 18 || judge. This Order does not govern the use of Protected Material at trial. 19} 4. DURATION 20 Once a case proceeds to trial, information that was designated as 21 || CONFIDENTIAL or maintained pursuant to this protective order used or 22 || introduced as an exhibit at trial becomes public and will be presumptively available 23 || to all members of the public, including the press, unless compelling reasons 24 || supported by specific factual findings to proceed otherwise are made to the trial 25 || judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing 26 || “good cause” showing for sealing documents produced in discovery from 27 || “compelling reasons” standard when merits-related documents are part of court 28 6-

1 || record). Accordingly, the terms of this protective order do not extend beyond the 2 || commencement of the trial. 3} 5. DESIGNATING PROTECTED MATERIAL 4 5.1 Exercise of Restraint and Care in Designating Material for Protection. 5 || Each Party or Non-Party that designates information or items for protection under 6 || this Order must take care to limit any such designation to specific material that 7 || qualifies under the appropriate standards. The Designating Party must designate for 8 || protection only those parts of material, documents, items or oral or written 9 || communications that qualify so that other portions of the material, documents, 10 || items or communications for which protection is not warranted are not swept 11 || unjustifiably within the ambit of this Order. 12 Mass, indiscriminate or routinized designations are prohibited. Designations 13 || that are shown to be clearly unjustified or that have been made for an improper 14 || purpose (e.g., to unnecessarily encumber the case development process or to 15 || impose unnecessary expenses and burdens on other parties) may expose the 16 || Designating Party to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it 18 || designated for protection do not qualify for protection, that Designating Party must 19 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in 21 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 22 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 || under this Order must be clearly so designated before the material is disclosed or 24 || produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (e.g., paper or electronic 27 || documents, but excluding transcripts of depositions or other pretrial or trial 28 || proceedings), that the Producing Party affix at a minimum, the legend 7.

1 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 2 || contains protected material. If only a portion of the material on a page qualifies for 3 || protection, the Producing Party also must clearly identify the protected portion(s) 4 || (e.g., by making appropriate markings in the margins). 5 A Party or Non-Party that makes original documents available for inspection 6 || need not designate them for protection until after the inspecting Party has indicated 7 || which documents it would like copied and produced. During the inspection and 8 || before the designation, all of the material made available for inspection shall be 9 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 10 || documents it wants copied and produced, the Producing Party must determine 11 || which documents, or portions thereof, qualify for protection under this Order. 12 || Then, before producing the specified documents, the Producing Party must affix the 13 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 14 || portion of the material on a page qualifies for protection, the Producing Party also 15 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 16 || in the margins). 17 (b) for testimony given in depositions that the Designating Party 18 || identifies the Disclosure or Discovery Material on the record, before the close of 19 || the deposition all protected testimony. 20 (c) for information produced in some form other than documentary 21 || and for any other tangible items, that the Producing Party affix in a prominent place 22 || on the exterior of the container or containers in which the information is stored the 23 || legend “CONFIDENTIAL.” If only a portion or portions of the information 24 || warrants protection, the Producing Party, to the extent practicable, shall identify the 25 || protected portion(s). 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 || failure to designate qualified information or items does not, standing alone, waive 28 || the Designating Party’s right to secure protection under this Order for such

1 || material. Upon timely correction of a designation, the Receiving Party must make 2 || reasonable efforts to assure that the material is treated in accordance with the 3 || provisions of this Order. 4 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 6 || designation of confidentiality at any time that is consistent with the Court’s 7 || Scheduling Order. 8 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 9 || resolution process under Local Rule 37-1 et seq. 10 6.3 The burden of persuasion in any such challenge proceeding shall be on 11 || the Designating Party. Frivolous challenges, and those made for an improper 12 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 13 || parties) may expose the Challenging Party to sanctions. Unless the Designating 14 || Party has waived or withdrawn the confidentiality designation, all parties shall 15 || continue to afford the material in question the level of protection to which it is 16 || entitled under the Producing Party’s designation until the Court rules on the 17 || challenge. 18 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 20 || disclosed or produced by another Party or by a Non-Party in connection with this 21 || Action only for prosecuting, defending or attempting to settle this Action. Such 22 || Protected Material may be disclosed only to the categories of persons and under the 23 || conditions described in this Order. When the Action has been terminated, a 24 || Receiving Party must comply with the provisions of section 13 below (FINAL 25 || DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 || location and in a secure manner that ensures that access is limited to the persons 28 || authorized under this Order. 9.

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 || otherwise ordered by the court or permitted in writing by the Designating Party, a 3 || Receiving Party may disclose any information or item designated 4 || “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, 6 || as well as employees of said Outside Counsel of Record to whom it is reasonably 7 || necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House 9 || Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 10 || Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to 12 || whom disclosure is reasonably necessary for this Action and who have signed the 13 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff; 16 (f) professional jury or trial consultants, mock jurors, and 17 || Professional Vendors to whom disclosure is reasonably necessary for this Action 18 || and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 19 || A); 20 (g) 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 (h) during their depositions, witnesses, and attorneys for witnesses, 23 || in the Action to whom disclosure is reasonably necessary provided: (1) the 24 || deposing party requests that the witness sign the form attached as Exhibit | hereto; 25 || and (2) they will not be permitted to keep any confidential information unless they 26 || sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 27 || otherwise agreed by the Designating Party or ordered by the court. Pages of 28 || transcribed deposition testimony or exhibits to depositions that reveal Protected -10-

1 || Material may be separately bound by the court reporter and may not be disclosed to 2 || anyone except as permitted under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting 4 || personnel, mutually agreed upon by any of the parties engaged in settlement 5 || discussions. 6 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 7 IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation 9 || that compels disclosure of any information or items designated in this Action as 10 || “CONFIDENTIAL,” that Party must: 11 (a) promptly notify in writing the Designating Party. Such 12 || notification shall include a copy of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or 14 || order to issue in the other litigation that some or all of the material covered by the 15 || subpoena or order is subject to this Protective Order. Such notification shall include 16 || acopy of this Stipulated Protective Order; and 17 (c) | cooperate with respect to all reasonable procedures sought to be 18 || pursued by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party 20 || served with the subpoena or court order shall not produce any information 21 || designated in this action as “CONFIDENTIAL” before a determination by the court 22 || from which the subpoena or order issued, unless the Party has obtained the 23 || Designating Party’s permission. The Designating Party shall bear the burden and 24 || expense of seeking protection in that court of its confidential material and nothing 25 || in these provisions should be construed as authorizing or encouraging a Receiving 26 || Party in this Action to disobey a lawful directive from another court. 27 /// 28 | /// 11-

1 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced 4 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 5 || information produced by Non-Parties in connection with this litigation is protected 6 || by the remedies and relief provided by this Order. Nothing in these provisions 7 || should be construed as prohibiting a Non-Party from seeking additional protections. 8 (b) Inthe event that a Party is required, by a valid discovery 9 || request, to produce a Non-Party’s confidential information in its possession, and the 10 || Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 11 || confidential information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the 13 || Non-Party that some or all of the information requested is subject to a 14 || confidentiality agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the 16 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a 17 || reasonably specific description of the information requested; and 18 (3) make the information requested available for inspection 19 || by the Non-Party, if requested. 20 (c) Ifthe Non-Party fails to seek a protective order from this court within 21 || 14 days of receiving the notice and accompanying information, the Receiving Party 22 || may produce the Non-Party’s confidential information responsive to the discovery 23 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 || not produce any information in its possession or control that is subject to the 25 || confidentiality agreement with the Non-Party before a determination by the court. 26 || Absent a court order to the contrary, the Non-Party shall bear the burden and 27 || expense of seeking protection in this court of its Protected Material. 28 | /// -12-

1 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 || Protected Material to any person or in any circumstance not authorized under this 4 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 || writing the Designating Party of the unauthorized disclosures, (b) use its best 6 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 7 || person or persons to whom unauthorized disclosures were made of all the terms of 8 || this Order, and (d) request such person or persons to execute the “Acknowledgment 9 || and Agreement to Be Bound” that is attached hereto as Exhibit A. 10} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 || inadvertently produced material is subject to a claim of privilege or other 14 || protection, the obligations of the Receiving Parties are those set forth in Federal 15 |) Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 16 || whatever procedure may be established in an e-discovery order that provides for 17 || production without prior privilege review. Pursuant to Federal Rule of Evidence 18 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 19 || of acommunication or information covered by the attorney-client privilege or 20 || work product protection, the parties may incorporate their agreement in the 21 || stipulated protective order submitted to the court. 22 |} 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 || person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 || Protective Order, no Party waives any right it otherwise would have to object to 27 || disclosing or producing any information or item on any ground not addressed in 28 || this Stipulated Protective Order. Similarly, no Party waives any right to object on -13-

1 || any ground to use in evidence of any of the material covered by this Protective 2 || Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 5 || may only be filed under seal pursuant to a court order authorizing the sealing of the 6 || specific Protected Material at issue. If a Party’s request to file Protected Material 7 || under seal is denied by the court, then the Receiving Party may file the information 8 || in the public record unless otherwise instructed by the court. The parties agree to 9 || meet and confer to determine if non-material information can be redacted to protect 10 || the identity of third parties which would allow for the filing of sensitive third party 11 || information (1.e., redact names and addresses). 12 | 13. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 4, within 60 14 || days of a written request by the Designating Party, each Receiving Party must 15 return all Protected Material to the Producing Party or destroy such material. As 16 || used in this subdivision, “all Protected Material” includes all copies, abstracts, 17 || compilations, summaries, and any other format reproducing or capturing any of the 18 || Protected Material. Whether the Protected Material is returned or destroyed, the 19 || Receiving Party must submit a written certification to the Producing Party (and, if 20 || not the same person or entity, to the Designating Party) by the 60 day deadline that 21 || (1) identifies (by category, where appropriate) all the Protected Material that was 22 || returned or destroyed and (2) affirms that the Receiving Party has not retained any 23 || copies, abstracts, compilations, summaries or any other format reproducing or 24 || capturing any of the Protected Material. Notwithstanding this provision, Counsel 25 || are entitled to retain an archival copy of all pleadings, motion papers, trial, 26 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition 27 || and trial exhibits, expert reports, attorney work product, and consultant and expert 28 || work product, even if such materials contain Protected Material. Any such archival 14-

1 || copies that contain or constitute Protected Material remain subject to this Protective 2 || Order. 3 || 14. VIOLATION 4 Any violation of this Order may be punished by appropriate measures 5 || including, without limitation, contempt proceedings and/or monetary sanctions. 6 7 8 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 9 || DATED: October 10, 2019 10 | Chew h “Keen, 12 | Alicia G. Rosenberg 3 United States Magistrate Judge

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -15-

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 5 || of perjury that I have read in its entirety and understand the Stipulated Protective 6 || Order that was issued by the United States District Court for the Central District of 7 || California on [date] in the case of DeProspo v. Stern Brothers, Case No. 2:18-cv- 8 || 10315 MWF(AGRx). I agree to comply with and to be bound by all the terms of 9 || this Stipulated Protective Order and I understand and acknowledge that failure to so 10 || comply could expose me to sanctions and punishment in the nature of contempt. I 11 || solemnly promise that I will not disclose in any manner any information or item 12 || that is subject to this Stipulated Protective Order to any person or entity except in 13 || strict compliance with the provisions of this Order. 14 | I further agree to submit to the jurisdiction of the United States District Court for 15 || the Central District of California for enforcing the terms of this Stipulated 16 || Protective Order, even if such enforcement proceedings occur after termination of 17 || this action. 18 || [hereby appoint [print or type full name] of [print 19 || or type full address and telephone number] as my California agent for service of 20 || process in connection with this action or any proceedings related to enforcement of 21 || this Stipulated Protective Order. 22 || Date: 23 || City and State where sworn and signed: 24 || Printed name: 25 26 || Signature: 27 28 -16-

1 PROOF OF SERVICE 2 I, Melanie L. Duncan, declare: 3 I am a citizen of the United States and employed in Los Angeles County, 4 | California. I am over the age of eighteen years and not a party to the within-entitled 5 || action. My business address is 1888 Century Park E., Suite 1700, Los Angeles, 6 || California 90067-1721. On October 9, 2019, I served a copy of the within 7 || document(s): [PROPOSED] ORDER GRANTING STIPULATED PROTECTIVE ORDER by placing the document(s) listed above in a sealed envelope with postage 9 thereon fully prepaid, in the United States mail at Los Angeles, California 10 addressed as set forth below. []_ by placing the document(s) listed above in a sealed FedX envelope, affixing a pre-paid air bill, causing it to be delivered to a FedX agent for delivery. 12 []_ by transmitting via e-mail or electronic transmission the document(s) listed 13 above to the person(s) at the e-mail address(es) set forth below. 14 Amelia Alvarez, Esq. 15 Marvin Krakow, Esq. Alexander Krakow & Glick LLP 16 1900 Avenue of the Stars, Suite 900 7 Los Angeles, CA 90067-4310 Ig I am readily familiar with the firm’s practice of collection and processing 19 correspondence for mailing. Under that practice it would be deposited with the

30 U.S. Postal Service on that same day with postage thereon fully prepaid in the

51 ordinary course of business. I am aware that on motion of the party served, service

9 is presumed invalid if postal cancellation date or postage meter date is more than

53 one day after date of deposit for mailing in affidavit.

54 I declare that I am employed in the office of a member of the bar of this court

at whose direction the service was made.

6 Executed on October 9, 2019, at Los Angeles, California.

27 28 Melanie L. Duncan 17 PROOF OF SERVICE