1 BOWMAN AND BROOKE LLP Brian Takahashi (SBN: 146505) 2 E-mail: brian.takahashi@bowmanandbrooke.com Theodore Dorenkamp III (SBN: 277004) 3 E-mail: theodore.dorenkampiii@bowmanandbrooke.com Bryan A. Reynolds (SBN: 296434) 4 E-mail: bryan.reynolds@bowmanandbrooke.com 970 West 190th Street, Suite 700 5 Torrance, California 90502 Tel No.: 310/ 768-3068 NOTE: CHANGES MADE BY THE COURT 6 Fax No.: 310/ 719-1019

7 Attorneys for Defendant

JAGUAR LAND ROVER NORTH AMERICA, LLC

8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA

11

12 NIKA HOSSEINALIZADEH ) CASE NO.: 2:19-cv-08624 SVW (JPRx) NOORI aka NIKA NOORI and ) 13 TOORAJ ) Assigned to: Hon. Stephen V. Wilson HAJIABDOLLAHTEHRANI, ) Magistrate: Hon. Jean P. Rosenbluth 14 ) Plaintiffs, ) DISCOVERY MATTER 15 ) STIPULATED PROTECTIVE vs. ) ORDER; [PROPOSED] ORDER 16 )

JAGUAR LAND ROVER NORTH )

17 AMERICA, LLC, a Delaware ) Limited Liability Company; TERRY ) 18 YORK MOTOR CARS, LTD., a ) California Corporation, dba LAND ) 19 ROVER ENCINO; and DOES 1 ) through 10, inclusive, ) 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 disclosure and from use for any purpose other than prosecuting this litigation may 26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 enter the following Stipulated Protective Order. The parties acknowledge that this 28 Order does not confer blanket protections on all disclosures or responses to 1 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the applicable legal principles. 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve trade secrets, customer information, and other 6 valuable research, development, commercial, financial, technical and/or proprietary 7 information for which special protection from public disclosure and from use for any 8 purpose other than prosecution of this action may be warranted. Such confidential 9 and proprietary materials and information consist of, among other things, 10 confidential business or financial information, information regarding confidential 11 business practices, or other confidential research, development, or commercial 12 information (including information implicating privacy rights of third parties), 13 information otherwise generally unavailable to the public, or which may be 14 privileged or otherwise protected from disclosure under state or federal statutes, 15 court rules, case decisions, or common law. Accordingly, to expedite the flow of 16 information, to facilitate the prompt resolution of disputes over confidentiality of 17 discovery materials, to adequately protect information the parties are entitled to keep 18 confidential, to ensure that the parties are permitted reasonable necessary uses of 19 such material in preparation for and in the conduct of trial, to address their handling 20 at the end of the litigation, and serve the ends of justice, a protective order for such 21 information is justified in this matter. It is the intent of the parties that information 22 will not be designated as confidential for tactical reasons and that nothing be so 23 designated without a good faith belief that it has been maintained in a confidential, 24 non-public manner, and there is good cause why it should not be part of the public 25 record of this case. 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 27 SEAL 28 The parties further acknowledge, as set forth in Section 12.3, below, that this 1 Stipulated Protective Order does not entitle them to file confidential information 2 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 3 and the standards that will be applied when a party seeks permission from the court 4 to file material under seal. 5 There is a strong presumption that the public has a right of access to judicial 6 proceedings and records in civil cases. In connection with non-dispositive motions, 7 good cause must be shown to support a filing under seal. See Kamakana v. City and 8 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 9 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 10 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 11 good cause showing), and a specific showing of good cause or compelling reasons 12 with proper evidentiary support and legal justification, must be made with respect to 13 Protected Material that a party seeks to file under seal. The parties' mere designation 14 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 15 submission of competent evidence by declaration, establishing that the material 16 sought to be filed under seal qualifies as confidential, privileged, or otherwise 17 protectable—constitute good cause. 18 Further, if a party requests sealing related to a dispositive motion or trial, then 19 compelling reasons, not only good cause, for the sealing must be shown, and the 20 relief sought shall be narrowly tailored to serve the specific interest to be protected. 21 See Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 22 each item or type of information, document, or thing sought to be filed or introduced 23 under seal in connection with a dispositive motion or trial, the party seeking 24 protection must articulate compelling reasons, supported by specific facts and legal 25 justification, for the requested sealing order. Again, competent evidence supporting 26 the application to file documents under seal must be provided by declaration. 27 Any document that is not confidential, privileged, or otherwise protectable in 28 its entirety will not be filed under seal if the confidential portions can be redacted. If 1 documents can be redacted, then a redacted version for public viewing, omitting only 2 the confidential, privileged, or otherwise protectable portions of the document, shall 3 be filed. Any application that seeks to file documents under seal in their entirety 4 should include an explanation of why redaction is not feasible. 5 2. DEFINITIONS 6 2.1 Action: Nika Hosseinalizadeh Noori aka Nika Noori and Tooraj 7 Hajiabdollahtehrani v. Jaguar Land Rover North America, LLC, et. al., United States 8 District Court — Central District, Case No. 2:19-cv-08624 SVW (SSx). 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 of information or items under this Order. 11 2.3 "CONFIDENTIAL" Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 16 their support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 "CONFIDENTIAL." 20 2.6 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 2.8 House Counsel: attorneys who are employees of a party to this Action. 28 House Counsel does not include Outside Counsel of Record or any other outside 1 counsel. 2 2.9 Non-Party: any natural person, partnership, corporation, association or 3 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 party 5 to this Action but are retained to represent or advise a party to this Action and have 6 appeared in this Action on behalf of that party or are affiliated with a law firm that 7 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 their 10 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 support 14 services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) 16 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 Material 20 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 28 trial judge. This Order does not govern the use of Protected Material at trial. 1 4. 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. 11 5. 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 5.2 Manner and Timing of Designations. Except as otherwise provided in this 1 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 2 or ordered, Disclosure or Discovery Material that qualifies for protection under this 3 Order must be clearly so designated before the material is disclosed or produced. 4 Designation in conformity with this Order requires: 5 (a) for information in documentary form (e.g., paper or electronic documents, 6 but excluding transcripts of depositions or other pretrial or trial proceedings), that 7 the Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter 8 "CONFIDENTIAL legend"), to each page that contains protected material. If only 9 a portion of the material on a page qualifies for protection, the Producing Party also 10 must clearly identify the protected portion(s) (e.g., by making appropriate markings 11 in the margins). 12 A Party or Non-Party that makes original documents available for inspection 13 need not designate them for protection until after the inspecting Party has indicated 14 which documents it would like copied and produced. During the inspection and 15 before the designation, all of the material made available for inspection shall be 16 deemed "CONFIDENTIAL." After the inspecting Party has identified the 17 documents it wants copied and produced, the Producing Party must determine which 18 documents, or portions thereof, qualify for protection under this Order. Then, before 19 producing the specified documents, the Producing Party must affix the 20 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a 21 portion of the material on a page qualifies for protection, the Producing Party also 22 must clearly identify the protected portion(s) (e.g., by making appropriate markings 23 in the margins). 24 (b) for testimony given in depositions that the Designating Party identifies the 25 Disclosure or Discovery Material on the record, before the close of the deposition 26 all protected testimony. 27 (c) for information produced in some form other than documentary and for 28 any other tangible items, that the Producing Party affix in a prominent place on the 1 exterior of the container or containers in which the information is stored the legend 2 "CONFIDENTIAL." If only a portion or portions of the information warrants 3 protection, the Producing Party, to the extent practicable, shall identify the protected 4 portion(s). 5 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 6 failure to designate qualified information or items does not, standing alone, waive 7 the Designating Party's right to secure protection under this Order for such material. 8 Upon timely correction of a designation, the Receiving Party must make reasonable 9 efforts to assure that the material is treated in accordance with the provisions of this 10 Order. 11 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court's 14 Scheduling Order. 15 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process under Local Rule 37-1 et seq. 17 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 18 joint stipulation pursuant to Local Rule 37-2. 19 6.4 The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the confidentiality designation, all parties shall 24 continue to afford the material in question the level of protection to which it is 25 entitled under the Producing Party's designation until the Court rules on the 26 challenge. 27 7. ACCESS TO AND USE OF PROTECTED MATERIAL 28 7.1 Basic Principles. A Receiving Party may use Protected Material that is 1 disclosed or produced by another Party or by a Non-Party in connection with this 2 Action only for prosecuting, defending or attempting to settle this Action. Such 3 Protected Material may be disclosed only to the categories of persons and under the 4 conditions described in this Order. When the Action has been terminated, a 5 Receiving Party must comply with the provisions of section 13 below (FINAL 6 DISPOSITION). 7 Protected Material must be stored and maintained by a Receiving Party at a 8 location and in a secure manner that ensures that access is limited to the persons 9 authorized under this Order. 10 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 11 otherwise ordered by the court or permitted in writing by the Designating Party, a 12 Receiving Party may disclose any information or item designated 13 "CONFIDENTIAL" only to: 14 (a) the Receiving Party's Outside Counsel of Record in this Action, as well as 15 employees of said Outside Counsel of Record to whom it is reasonably necessary to 16 disclose the information for this Action; 17 (b) the officers, directors, and employees (including House Counsel) of the 18 Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom 20 disclosure is reasonably necessary for this Action and who have signed the 21 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional 25 Vendors to whom disclosure is reasonably necessary for this Action and who have 26 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 28 custodian or other person who otherwise possessed or knew the information; 1 (h) during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 4 will not be permitted to keep any confidential information unless they sign the 5 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 6 agreed by the Designating Party or ordered by the court. Pages of transcribed 7 deposition testimony or exhibits to depositions that reveal Protected Material may 8 be separately bound by the court reporter and may not be disclosed to anyone except 9 as permitted under this Stipulated Protective Order; and 10 (i) any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions or 12 appointed by the Court. 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 14 IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this Action as 17 "CONFIDENTIAL," that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order unless prohibited by law; 20 (b) promptly notify in writing the party who caused the subpoena or order to 21 issue in the other litigation that some or all of the material covered by the subpoena 22 or order is subject to this Protective Order. Such notification shall include a copy of 23 this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued 25 by the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with 27 the subpoena or court order shall not produce any information designated in this 28 action as "CONFIDENTIAL" before a determination by the court from which the 1 subpoena or order issued, unless the Party has obtained the Designating Party's 2 permission. The Designating Party shall bear the burden and expense of seeking 3 protection in that court of its confidential material and nothing in these provisions 4 should be construed as authorizing or encouraging a Receiving Party in this Action 5 to disobey a lawful directive from another court. 6 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a 9 Non-Party in this Action and designated as "CONFIDENTIAL." Such information 10 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party's confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party's 16 confidential information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non- 18 Party that some or all of the information requested is subject to a confidentiality 19 agreement with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 specific description of the information requested; and 23 (3) make the information requested available for inspection by the 24 Non-Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 26 14 days of receiving the notice and accompanying information, the Receiving Party 27 may produce the Non-Party's confidential information responsive to the discovery 28 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 1 not produce any information in its possession or control that is subject to the 2 confidentiality agreement with the Non-Party before a determination by the court. 3 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 4 of seeking protection in this court of its Protected Material. 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 11 or persons to whom unauthorized disclosures were made of all the terms of this 12 Order, and (d) request such person or persons to execute the "Acknowledgment and 13 Agreement to Be Bound" that is attached hereto as Exhibit A. 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 20 may be established in an e-discovery order that provides for production without prior 21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 22 the parties reach an agreement on the effect of disclosure of a communication or 23 information covered by the attorney-client privilege or work product protection, the 24 parties may incorporate their agreement in the stipulated protective order submitted 25 to the court provided the Court so allows. 26 12. MISCELLANEOUS 27 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 person to seek its modification by the Court in the future. 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in this 4 Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 ground to use in evidence of any of the material covered by this Protective Order. 6 12.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 8 only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material at issue. If a Party's request to file Protected Material 10 under seal is denied by the court, then the Receiving Party may file the information 11 in the public record unless otherwise instructed by the court. Filing Protected 12 Material. A Party that seeks to file under seal any Protected Material must comply 13 with Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant 14 to a court order authorizing the sealing of the specific Protected Material at issue. If 15 a Party's request to file Protected Material under seal is denied by the court, then the 16 Receiving Party may file the information in the public record unless otherwise 17 instructed by the court. 18 13. FINAL DISPOSITION 19 After the final disposition of this Action, as defined in paragraph 4, within 60 20 days of a written request by the Designating Party, each Receiving Party must return 21 all Protected Material to the Producing Party or destroy such material. As used in 22 this subdivision, "all Protected Material" includes all copies, abstracts, compilations, 23 summaries, and any other format reproducing or capturing any of the Protected 24 Material. Whether the Protected Material is returned or destroyed, the Receiving 25 Party must submit a written certification to the Producing Party (and, if not the same 26 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 27 (by category, where appropriate) all the Protected Material that was returned or 28 destroyed and (2) affirms that the Receiving Party has not retained any copies, 1 || abstracts, compilations, summaries or any other format reproducing or capturing any 2 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 3 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 4 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 5 || reports, attorney work product, and consultant and expert work product, even if such 6 || materials contain Protected Material. Any such archival copies that contain or 7 || constitute Protected Material remain subject to this Protective Order as set forth in 8 || Section 4 (DURATION). 9 || 14. MIOLATION 10 Any violation of this Order may be punished by appropriate measures 11 || including, without limitation, contempt proceedings and/or monetary sanctions. 12 13 IT IS SO ORDERED. 14 fi Rrenhlutt~ 15 || Dated: March 30, 2020 16 United States Magistrate Tudge 17 18 19 20 21 22 23 24 25 26 27 28

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 Nika Hosseinalizadeh Noori aka Nika Noori and Tooraj 8 Hajiabdollahtehrani v. Jaguar Land Rover North America, LLC, et. al., United States 9 District Court — Central District, Case No. 2:19-cv-08624 SVW (JPRx). I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and 11 I understand and acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I will not disclose 13 in any manner any information or item that is subject to this Stipulated Protective 14 Order to any person or entity except in strict compliance with the provisions of this 15 Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for enforcing the terms of this Stipulated 18 Protective Order, even if such enforcement proceedings occur after termination of 19 this action. I hereby appoint __________________________ [print or type full 20 name] of _______________________________________ [print or type full address 21 and telephone number] as my California agent for service of process in connection 22 with this action or any proceedings related to enforcement of this Stipulated 23 Protective Order. 24 25 Date: ______________________________________ 26 City and State where sworn and signed: _________________________________ 27 Printed name: _______________________________ 28 Signature:_______________________________ 1 CERTIFICATE OF SERVICE 2 I hereby certify that on February 26, 2020, I filed the foregoing document 3 entitled STIPULATED PROTECTIVE ORDER; [PROPOSED] ORDER with 4 the clerk of court using the CM/ECF system, which will send a notice of electronic 5 filing to all counsel of record in this action. 6

7 /s/ Bryan A. Reynolds 8 Bryan A. Reynolds

9

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