1 DOUGLAS HAN, CA Bar No. 232858 SHUNT TATAVOS-GHARAJEH, CA Bar No. 272164 2 DANIEL J. PARK, CA Bar No. 274973 AREEN BABAJANIAN, CA Bar No. 583307 3 JUSTICE LAW CORPORATION NOTE: CHANGES HAVE BEEN 751 North Fair Oaks Avenue, Suite 101 4 Pasadena, California 91103 MADE TO THIS DOCUMENT Telephone (818) 230-7502 5 Facsimile (818) 230-7502 See p. 6, line 9 6 Attorneys for Plaintiff 7 JACOB SCHUMACHER 8 EVAN R. MOSES, CA Bar No. 198099 9 evan.moses@ogletree.com

OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.

10 400 South Hope Street, Suite 1200 Los Angeles, CA 90071 11 Telephone: 213.239.9800 Facsimile: 213.239.9045 12 Attorneys for Defendant 13

GEORGIA-PACIFIC CORRUGATED LLC

14 Additional counsel below 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 JACOB SCHUMACHER, individually, Case No. 2:19-cv-08632-DMG (AFMx) and on behalf of other members of the 19 general public similarly situated, STIPULATED PROTECTIVE

ORDER1

20 Plaintiff, 21 v. Complaint Filed: September 5, 2019 22 Removal: October 7, 2019

GEORGIA-PACIFIC CORRUGATED

23 LLC, a Delaware Company and DOES 1 through 100, inclusive, 24 Defendant. 25 26 27 28 1 This Stipulated Protective Order is based substantially on the model protective order provided under 1 SARAH ZENEWICZ, CA Bar No. 258068 sarah.zenewicz@ogletree.com 2 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Steuart Tower, Suite 1300 3 One Market Plaza San Francisco, CA 94105 4 Telephone: 415.442.4810 Facsimile: 415.442.4870 5 6 Attorneys for Defendant

GEORGIA-PACIFIC CORRUGATED LLC

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 B. GOOD CAUSE STATEMENT 12 Good cause exists for the entry of this Stipulated Protective Order as follows: 13 (a) In this action, plaintiff Jacob Schumacher (“Plaintiff”) asserts the following 14 causes of action against defendant Georgia-Pacific Corrugated LLC (“Defendant”) on 15 behalf of himself and all current and former non-exempt employees in California 16 during the period September 5, 2015, through the present: (1) Violation of California 17 Labor Code - §§ 510, 1194, and 1198 (Unpaid Overtime); (2) Violation of California 18 Labor Code §§ 226.7 and 512(a) (Unpaid Meal Period Premiums); (3) Violation of 19 California Labor Code § 226.7 (Unpaid Rest Period Premiums); (4) Violation of 20 California. Labor Code §§ 201 and 202 (Final Wages Not Timely Paid); (5) Violation 21 of California Labor Code § 226(a) (Non-Compliant Wage Statements); (6) Violation 22 of California Business & Professions Code § 17200, et seq. 23 (b) Based on the nature of this case, the allegations asserted by Plaintiff, and the 24 discovery requests already received in this action, the documents, materials, and other 25 information to be exchanged in discovery may reveal private, confidential, and/or 26 proprietary information of the putative class members and Defendant’s business 27 policies and practices. Such materials, to the extent they are discoverable in this action, 28 could reveal confidential information concerning: putative class members’ financial 1 information, putative class members’ contact information, putative class members’ 2 personnel information, Defendant’s employment practices, Defendant’s business 3 operations, Defendant’s finances, Defendant’s clients, Defendant’s employees, and 4 information otherwise generally unavailable to the public, or which may be privileged 5 or otherwise protected from disclosure under state or federal statutes, court rules, case 6 decisions, or common law. 7 (c) Due to the nature of the information described herein, putative class 8 members’ interests in their privacy and Defendant’s business interests may suffer harm 9 if such information is disclosed publicly. Potential harm that may result from the 10 public disclosure of such information may include, but is not limited to, loss of 11 privacy, economic losses, loss of competitive advantages, and diminution of good- 12 will. Accordingly, to expedite the flow of information, to facilitate the prompt 13 resolution of disputes over confidentiality of discovery materials, to adequately protect 14 information the parties are entitled to keep confidential, to ensure that the parties are 15 permitted reasonable necessary uses of such material in preparation for and in the 16 conduct of trial, to address their handling at the end of the litigation, and serve the ends 17 of justice, a protective order for such information is justified in this matter. It is the 18 intent of the parties that information will not be designated as confidential for tactical 19 reasons and that nothing be so designated without a good faith belief that it has been 20 maintained in a confidential, non-public manner, and there is good cause why it should 21 not be part of the public record of this case. 22 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 23 SEAL 24 The parties further acknowledge, as set forth in Section 12.3, below, that this 25 Stipulated Protective Order does not entitle them to file confidential information under 26 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 27 standards that will be applied when a party seeks permission from the court to file 28 material under seal. 1 There is a strong presumption that the public has a right of access to judicial 2 proceedings and records in civil cases. In connection with non-dispositive motions, 3 good cause must be shown to support a filing under seal. See Kamakana v. City and 4 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 5 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 6 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 7 cause showing), and a specific showing of good cause or compelling reasons with 8 proper evidentiary support and legal justification, must be made with respect to 9 Protected Material that a party seeks to file under seal. The parties’ mere designation 10 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 11 submission of competent evidence by declaration, establishing that the material sought 12 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 13 constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the relief 16 sought shall be narrowly tailored to serve the specific interest to be protected. See 17 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 18 or type of information, document, or thing sought to be filed or introduced under seal 19 in connection with a dispositive motion or trial, the party seeking protection must 20 articulate compelling reasons, supported by specific facts and legal justification, for 21 the requested sealing order. Again, competent evidence supporting the application to 22 file documents under seal must be provided by declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in 24 its entirety will not be filed under seal if the confidential portions can be redacted. If 25 documents can be redacted, then a redacted version for public viewing, omitting only 26 the confidential, privileged, or otherwise protectable portions of the document, shall 27 be filed. Any application that seeks to file documents under seal in their entirety should 28 include an explanation of why redaction is not feasible. 1 2. DEFINITIONS 2 2.1 Action:Schumacher v. Georgia-Pacific Corrugated LLC, Case No. 2:19- 3 cv-08632-DMG (AFMx). 4 2.2 Challenging Party: a Party or Non-Party that challenges the designation 5 of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for protection 8 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 9 Statement. 10 2.4 Counsel: Outside Counsel of Record and In House Counsel (as well as 11 their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, regardless of 16 the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association or 26 other legal entity not named as a Party to this Action. 27 2.10 Outside Counsel of Record: attorneys who are not employees of a party 28 to this Action but are retained to represent or advise a party to this Action and have 1 appeared in this Action on behalf of that party or are affiliated with a law firm that has 2 appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 11 their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only Protected 19 Material (as defined above), but also (1) any information copied or extracted from 20 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 21 Material; and (3) any testimony, conversations, or presentations by Parties or their 22 Counsel that might reveal Protected Material. 23 Anyuse of Protected Material at trial shall be governed by the orders of the trial 24 judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 Once a case proceeds to trial, information that was designated as 28 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 1 as an exhibit at trial becomes public and will be presumptively available to all 2 members of the public, including the press, unless compelling reasons supported by 3 specific factual findings to proceed otherwise are made to the trial judge in advance of 4 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing 5 for sealing documents produced in discovery from “compelling reasons” standard 6 when merits-related documents are part of court record). Accordingly, the terms of 7 this protective order do not extend beyond the commencement of the trial as to any 8 information that was designated as CONFIDENTIAL or maintained pursuant to this 9 protective order and used or introduced as an exhibit at trial. 10 Unless and until this case proceeds to trial, the confidentiality obligations 11 imposed by this Order shall remain in effect until a Designating Party agrees otherwise 12 in writing or a court order otherwise directs. 13 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. 16 Each Party or Non-Party that designates information or items for protection under this 17 Order must take care to limit any such designation to specific material that qualifies 18 under the appropriate standards. The Designating Party must designate for protection 19 only those parts of material, documents, items or oral or written communications that 20 qualify so that other portions of the material, documents, items or communications for 21 which protection is not warranted are not swept unjustifiably within the ambit of this 22 Order. 23 Mass, indiscriminate or routinized designations are prohibited. Designations 24 that are shown to be clearly unjustified or that have been made for an improper purpose 25 (e.g., to unnecessarily encumber the case development process or to impose 26 unnecessary expenses and burdens on other parties) may expose the Designating Party 27 to sanctions. 28 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 14 contains protected material. If only a portion of the material on a page qualifies for 15 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 16 by making appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and before 20 the designation, all of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 22 copied and produced, the Producing Party must determine which documents, or 23 portions thereof, qualify for protection under this Order. Then, before producing the 24 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 25 to each page that contains Protected Material. If only a portion of the material on a 26 page qualifies for protection, the Producing Party also must clearly identify the 27 protected portion(s) (e.g., by making appropriate markings in the margins) 28 1 (b) for testimony given in depositions that the Designating Party identifies 2 the Disclosure or Discovery Material on the record, before the close of the deposition 3 all protected testimony. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent place on the 6 exterior of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information warrants 8 protection, the Producing Party, to the extent practicable, shall identify the protected 9 portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 Designating Party’s right to secure protection under this Order for such material. Upon 13 timely correction of a designation, the Receiving Party must make reasonable efforts 14 to assure that the material is treated in accordance with the provisions of this Order. 15 16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s Scheduling 19 Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 21 resolution process under Local Rule 37-1 et seq. 22 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 23 stipulation pursuant to Local Rule 37-2. 24 6.4 The burden of persuasion in any such challenge proceeding shall be on 25 the Designating Party. Frivolous challenges, and those made for an improper purpose 26 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 27 expose the Challenging Party to sanctions. Unless the Designating Party has waived 28 or withdrawn the confidentiality designation, all parties shall continue to afford the 1 material in question the level of protection to which it is entitled under the Producing 2 Party’s designation until the Court rules on the challenge. 3 4 7. ACCESS TO AND USE OF PROTECTED MATERIAL 5 7.1 Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a Receiving 10 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at a 12 location and in a secure manner that ensures that access is limited to the persons 13 authorized under this Order. 14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 15 otherwise ordered by the court or permitted in writing by the Designating Party, a 16 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 17 only to: 18 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 19 as employees of said Outside Counsel of Record to whom it is reasonably necessary 20 to disclose the information for this Action; 21 (b) the officers, directors, and employees (including In House Counsel) of 22 the Receiving Party to whom disclosure is reasonably necessary for this Action; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (d) the court and its personnel; 27 (e) court reporters and their staff; 28 1 (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 agreed 11 by the Designating Party or ordered by the court. Pages of transcribed deposition 12 testimony or exhibits to depositions that reveal Protected Material may be separately 13 bound by the court reporter and may not be disclosed to anyone except as permitted 14 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 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 19 OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation 21 that compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order 26 to issue in the other litigation that some or all of the material covered by the subpoena 27 or order is subject to this Protective Order. Such notification shall include a copy of 28 this Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to be pursued 2 by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with 4 the subpoena or court order shall not produce any information designated in this action 5 as “CONFIDENTIAL” before a determination by the court from which the subpoena 6 or order issued, unless the Party has obtained the Designating Party’s permission. The 7 Designating Party shall bear the burden and expense of seeking protection in that court 8 of its confidential material and nothing in these provisions should be construed as 9 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 10 directive from another court. 11 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a 15 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 16 produced by Non-Parties in connection with this litigation is protected by the remedies 17 and relief provided by this Order. Nothing in these provisions should be construed as 18 prohibiting a Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 20 produce a Non-Party’s confidential information in its possession, and the Party is 21 subject to an agreement with the Non-Party not to produce the Non-Party’s 22 confidential information, then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non-Party 24 that some or all of the information requested is subject to a confidentiality agreement 25 with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 Protective Order in this Action, the relevant discovery request(s), and a reasonably 28 specific description of the information requested; and 1 (3) make the information requested available for inspection by the Non- 2 Party, if requested. 3 (c) If the 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 not 7 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 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 16 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 17 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of this Order, 19 and (d) request such person or persons to execute the “Acknowledgment and 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 28 may be established in an e-discovery order that provides for production without prior 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted to 5 the court. 6 7 12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order, no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the specific 18 Protected Material at issue. If a Party’s request to file Protected Material under seal is 19 denied by the court, then the Receiving Party may file the information in the public 20 record unless otherwise instructed by the court. 21 22 13. FINAL DISPOSITION 23 After the final disposition of this Action, as defined in paragraph 4, within 60 24 days of a written request by the Designating Party, each Receiving Party must return 25 all Protected Material to the Producing Party or destroy such material. As used in this 26 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the Protected 28 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 1 must submit a written certification to the Producing Party (and, if not the same person 2 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 3 category, where appropriate) all the Protected Material that was returned or destroyed 4 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 5 compilations, summaries or any other format reproducing or capturing any of the 6 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 7 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 8 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 9 attorney work product, and consultant and expert work product, even if such materials 10 contain Protected Material. Any such archival copies that contain or constitute 11 Protected Material remain subject to this Protective Order as set forth in Section 4 12 (DURATION). 13 14 14. VIOLATION 15 Any violation of this Order may be punished by appropriate measures including, 16 without limitation, contempt proceedings and/or monetary sanctions. 17 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 19 20 DATED: April 3, 2020 OGLETREE, DEAKINS, NASH, SMOAK &

STEWART, P.C.

21 22 23 By: /s/ Sarah Zenewicz

EVAN R. R. MOSES

24 SARAH ZENEWICZ Attorneys for Defendant 25 GEORGIA-PACIFIC CORRUGATED LLC 26 27 28 1 DATED: April 3, 2020 JUSTICE LAW CORPORATION 2 3 A By: /s/ Douglas Han

DOUGLAS HAN

5 SHUNT TATAVOS-GHARAJEH

DANIEL J. PARK

6 AREEN BABAJANIAN Attorneys for Plaintiff 7 JACOB SCHUMACHER 8 9 ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-4.3.4 10 I, Sarah Zenewicz, attest that concurrence in the filing of this Stipulated 11 || Protective Order pursuant to Local Rule 5-4.3.4 has been obtained from the other 12 || Signatories. DATED: April 3, 2020 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 14 By: /s/Sarah Zenewicz 15 SARAH ZENEWICZ 16 17

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

18 19

DATED: 4/3/2020

20 »| Ceey Mle f&-——~ 22 HON. ALEXANDER F. MacKINNON 23 || United States Magistrate Judge 24 25 26 27 28 15 Cace No 2:190-cv-02622_-DMCG (AEMy)

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 5 under penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on [date] in the case of [insert formal name of the case and 8 the number and initials assigned to it by the court]. I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any person 13 or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for enforcing the terms of this Stipulated 16 Protective Order, even if such enforcement proceedings occur after termination of this 17 action. 18 I hereby appoint [print or type full name] of [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: 23 City and State where sworn and signed: 24 25 Printed name: 26 27 Signature: 28 1 42089382.3 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28