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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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10 ANTHONY LONGO, individually Case No. SA 20-cv-00829-AB-RAO 11 and derivatively on behalf of TODOS 12 SANTOS SURF, INC., STIPULATED PROTECTIVE

ORDER1

13 v.

14 VINCENT LONGO, an individual;

FUTURE FIN SYSTEMS PTY LTD,

15 an Australian entity; and DOES 1 through 20, inclusive; 16 Defendants 17 -and- 18 TODOS SANTOS SURF, INC., a 19 California Corporation, Nominal Defendant 20

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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 27 1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 2 enter the following Stipulated Protective Order. The parties acknowledge that this 3 Order does not confer blanket protections on all disclosures or responses to 4 discovery and that the protection it affords from public disclosure and use extends 5 only to the limited information or items that are entitled to confidential treatment 6 under the applicable legal principles. 7 8 B. GOOD CAUSE STATEMENT 9 This action is likely to involve trade secrets, customer and pricing lists and 10 other valuable research, development, commercial, financial, technical and/or 11 proprietary information for which special protection from public disclosure and 12 from use for any purpose other than prosecution of this action is warranted. Such 13 confidential and proprietary materials and information consist of, among other 14 things, confidential business or financial information, information regarding 15 confidential business practices, or other confidential research, development, or 16 commercial information (including information implicating privacy rights of third 17 parties), information otherwise generally unavailable to the public, or which may be 18 privileged or otherwise protected from disclosure under state or federal statutes, 19 court rules, case decisions, or common law. Accordingly, to expedite the flow of 20 information, to facilitate the prompt resolution of disputes over confidentiality of 21 discovery materials, to adequately protect information the parties are entitled to keep 22 confidential, to ensure that the parties are permitted reasonable necessary uses of 23 such material in preparation for and in the conduct of trial, to address their handling 24 at the end of the litigation, and serve the ends of justice, a protective order for such 25 information is justified in this matter. It is the intent of the parties that information 26 will not be designated as confidential for tactical reasons and that nothing be so 27 designated without a good faith belief that it has been maintained in a confidential, 1 non-public manner, and there is good cause why it should not be part of the public 2 record of this case. 3 4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 5 The parties further acknowledge, as set forth in Section 12.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential information 7 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 8 and the standards that will be applied when a party seeks permission from the court 9 to file material under seal. 10 There is a strong presumption that the public has a right of access to judicial 11 proceedings and records in civil cases. In connection with non-dispositive motions, 12 good cause must be shown to support a filing under seal. See Kamakana v. City and 13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 15 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 16 require good cause showing), and a specific showing of good cause or compelling 17 reasons with proper evidentiary support and legal justification, must be made with 18 respect to Protected Material that a party seeks to file under seal. The parties’ mere 19 designation of Disclosure or Discovery Material as CONFIDENTIAL or HIGHLY 20 CONFIDENTIAL – ATTORNEYS’ EYES ONLY does not—without the 21 submission of competent evidence by declaration, establishing that the material 22 sought to be filed under seal qualifies as confidential, privileged, or otherwise 23 protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, then 25 compelling reasons, not only good cause, for the sealing must be shown, and the 26 relief sought shall be narrowly tailored to serve the specific interest to be protected. 27 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 1 under seal in connection with a dispositive motion or trial, the party seeking 2 protection must articulate compelling reasons, supported by specific facts and legal 3 justification, for the requested sealing order. Again, competent evidence supporting 4 the application to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. 7 If documents can be redacted, then a redacted version for public viewing, omitting 8 only the confidential, privileged, or otherwise protectable portions of the document 9 shall be filed. Any application that seeks to file documents under seal in their 10 entirety should include an explanation of why redaction is not feasible. 11 12 2. DEFINITIONS 13 2.1 Action: Anthony Longo v. Vincent Longo; Future Fin Systems Pty Ltd, 14 Case No. 20-cv-00829-AB-RAO. 15 2.2 Challenging Party: a Party or Non-Party that challenges the 16 designation of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for 19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 20 the Good Cause Statement. 21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 22 their support staff). 23 2.5 Designating Party: a Party or Non-Party that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 2.6 Disclosure or Discovery Material: all items or information, regardless 27 of the medium or manner in which it is generated, stored, or maintained (including, 1 generated in disclosures or responses to discovery in this matter. 2 2.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 an expert witness or as a consultant in this Action. 5 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 6 Information or Items: extremely sensitive confidential, or proprietary information or 7 tangible things, such as technical know-how and trade secrets, relating to: (1) 8 information relating to manufacturing processes or procedures with respect to 9 devices or other products that are commercially released or for which substantial 10 steps have been taken towards commercialization; or (2) information generated by 11 research and development activities.; or (3) information that otherwise derives 12 independent economic value, actual or potential, from not being generally known to 13 the public or to other persons who can obtain economic value from its disclosure or 14 use. The disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 15 ONLY” to another Party or Non-Party would create a substantial risk of serious 16 harm that could not be avoided by less restrictive means. 17 2.9 House Counsel: attorneys who are employees of a party to this Action. 18 House Counsel does not include Outside Counsel of Record or any other outside 19 counsel. 20 2.10 Non-Party: any natural person, partnership, corporation, association or 21 other legal entity not named as a Party to this action. 22 2.11 Outside Counsel of Record: attorneys who are not employees of a 23 party to this Action but are retained to represent or advise a party to this Action and 24 have appeared in this Action on behalf of that party or are affiliated with a law firm 25 that has appeared on behalf of that party, and includes support staff. 26 2.12 Party: any party to this Action, including all of its officers, directors, 27 employees, consultants, retained experts, and Outside Counsel of Record (and their 1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.14 Professional Vendors: persons or entities that provide litigation 4 support 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 2.15 Protected Material: any Disclosure or Discovery Material that is 8 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - 9 ATTORNEYS’ EYES ONLY.” 10 2.16 Receiving Party: a Party that receives Disclosure or Discovery 11 Material from a Producing Party. 12 13 3. SCOPE 14 The protections conferred by this Stipulation and Order cover not only 15 Protected Material (as defined above), but also (1) any information copied or 16 extracted from Protected Material; (2) all copies, excerpts, summaries, or 17 compilations of Protected Material; and (3) any testimony, conversations, or 18 presentations by Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 22 4. DURATION 23 Once a case proceeds to trial, information that was designated as 24 CONFIDENTIAL and/or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 25 ONLY or maintained pursuant to this protective order used or introduced as an 26 exhibit at trial becomes public and will be presumptively available to all members of 27 the public, including the press, unless compelling reasons supported by specific 1 trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for 2 sealing documents produced in discovery from “compelling reasons” standard when 3 merits-related documents are part of court record). Accordingly, the terms of this 4 protective order do not extend beyond the commencement of the trial. 5 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection under 9 this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items or oral or written 12 communications that qualify so that other portions of the material, documents, items 13 or communications for which protection is not warranted are not swept unjustifiably 14 within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating 19 Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or the legend 5 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter 6 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY legend”), to each 7 page that contains protected material. If only a portion of the material on a page 8 qualifies for protection, the Producing Party also must clearly identify the protected 9 portion(s) (e.g., by making appropriate markings in the margins). 10 A Party or Non-Party that makes original documents available for inspection 11 need not designate them for protection until after the inspecting Party has indicated 12 which documents it would like copied and produced. During the inspection and 13 before the designation, all of the material made available for inspection shall be 14 deemed “ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified 15 the documents it wants copied and produced, the Producing Party must determine 16 which documents, or portions thereof, qualify for protection under this Order. Then, 17 before producing the specified documents, the Producing Party must affix the 18 “CONFIDENTIAL legend” and/or the “HIGHLY CONFIDENTIAL – 19 ATTORNEYS’ EYES ONLY” legend, as appropriate, to each page that contains 20 Protected Material. If only a portion of the material on a page qualifies for 21 protection, the Producing Party also must clearly identify the protected portion(s) 22 (e.g., by making appropriate markings in the margins). 23 (b) for testimony given in depositions that the Designating Party identifies 24 the Disclosure or Discovery Material on the record, before the close of the 25 deposition all protected testimony. 26 (c) for information produced in some form other than documentary and 27 for any other tangible items, that the Producing Party affix in a prominent place on 1 “CONFIDENTIAL” legend and/or the “HIGHLY CONFIDENTIAL – 2 ATTORNEYS’ EYES ONLY” legend, as appropriate. If only a portion or portions 3 of the information warrants protection, the Producing Party, to the extent 4 practicable, shall identify the protected 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 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 The burden of persuasion in any such challenge proceeding shall be on 19 the Designating Party. Frivolous challenges, and those made for an improper 20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 21 parties) may expose the Challenging Party to sanctions. Likewise, a Designating 22 Party’s repeated over-designation of documents, thereby causing the Challenging 23 Party to repeatedly challenge such over-designations, may expose the Designating 24 Party to sanctions. Unless the Designating Party has waived or withdrawn the 25 confidentiality designation, all parties shall continue to afford the material in 26 question the level of protection to which it is entitled under the Producing Party’s 27 designation until the Court rules on the challenge. 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. Copies of “HIGHLY CONFIDENTIAL – 12 ATTORNEYS’ EYES ONLY” Information shall be maintained at the offices of 13 Plaintiff’s and Defendants’ respective Outside Counsel of Record in a secure 14 manner that ensures access is limited to the persons authorized under this Order. 15 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 16 otherwise ordered by the court or permitted in writing by the Designating Party, a 17 Receiving Party may disclose any information or item designated 18 “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of 23 the Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel where disclosure is reasonably necessary 1 (e) court reporters and their staff where disclosure is reasonably necessary 2 for this Action; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, in the 9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 10 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 11 will not be permitted to keep any confidential information unless they sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may 15 be separately bound by the court reporter and may not be disclosed to anyone except 16 as permitted under this Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 (j) any other person with the prior written consent of the Designating Party 20 21 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 22 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 23 writing by the Designating Party, a Receiving Party may disclose any information or 24 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 25 to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, 27 as well as employees of said Outside Counsel of Record to whom it is reasonably 1 (b) Experts (as defined in this Order) of the Receiving Party to 2 whom disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (c) Professional Vendors (as defined in this Order) to whom 5 disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 7 (d) the court and its personnel where disclosure is reasonably 8 necessary for this Action; 9 (e) any other person with the prior written consent of the 10 Designating Party. 11 12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 13 IN OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation 15 that compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL” and/or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 17 ONLY,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification 19 shall include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order 21 to issue in the other litigation that some or all of the material covered by the 22 subpoena or order is subject to this Protective Order. Such notification shall include 23 a copy of this Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be 25 pursued 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 1 ATTORNEYS’ EYES ONLY,” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this Action 6 to disobey a lawful directive from another court. 7 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9 PRODUCED IN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced by a 11 Non-Party in this Action and designated as “CONFIDENTIAL” and/or “HIGHLY 12 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 13 Non-Parties in connection with this litigation is protected by the remedies and relief 14 provided by this Order. Nothing in these provisions should be construed as 15 prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and the Party is 18 subject to an agreement with the Non-Party not to produce the Non-Party’s 19 confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality 22 agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 Non-Party, if requested. 1 14 days of receiving the notice and accompanying information, the Receiving Party 2 may produce the Non-Party’s confidential information responsive to the discovery 3 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 4 not produce any information in its possession or control that is subject to the 5 confidentiality agreement with the Non-Party before a determination by the court. 6 Absent a court order to the contrary, the Non-Party shall bear the burden and 7 expense of seeking protection in this court of its Protected Material. 8 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A. 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 25 procedure may be established in an e-discovery order that provides for production 26 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 27 (e), insofar as the parties reach an agreement on the effect of disclosure of a 1 product protection, the parties may incorporate their agreement in the stipulated 2 protective order submitted to the court. 3 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order, no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in this 10 Stipulated Protective Order. Similarly, no Party waives any right to object on any 11 ground to use in evidence of any of the material covered by this Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under seal any 13 Protected Material must comply with Local Civil Rule 79-5. Protected Material 14 may only be filed under seal pursuant to a court order authorizing the sealing of the 15 specific Protected Material at issue. If a Party’s request to file Protected Material 16 under seal is denied by the court, then the Receiving Party may file the information 17 in the public record unless otherwise instructed by the court. 18 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 21 days of a written request by the Designating Party, each Receiving Party must return 22 all Protected Material to the Producing Party or destroy such material. As used in 23 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected 25 Material. Whether the Protected Material is returned or destroyed, the Receiving 26 Party must submit a written certification to the Producing Party (and, if not the same 27 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 1 destroyed and (2) affirms that the Receiving Party has not retained any copies, 2 abstracts, compilations, summaries or any other format reproducing or capturing any 3 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 4 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 5 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 6 reports, attorney work product, and consultant and expert work product, even if such 7 materials contain Protected Material. Any such archival copies that contain or 8 constitute Protected Material remain subject to this Protective Order as set forth in 9 Section 4 (DURATION). 10 // 11 // 12 // 13 // 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 1 || 14. VIOLATION 2 |} Any violation of this Order may be punished by appropriate measures including, 3 |} without limitation, contempt proceedings and/or monetary sanctions. 4 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 Dated: November 23, 2020 LEJEUNE LAW, P.C.

. By. CL ZS

CODY R. LEJEUNE

9 Attorneys for Plaintiff ANTHONY LONGO, individually and 10 derivatively on behalf of TODOS SANTOS

SURF, INC.

|| Dated: November 23,2020 | ROPERS MAJES KI PC 13 ; 14 2 ee Se By: ae 15 ANDREW S. HOLLINS

JAMES C. HILDEBRAND

16 ETHAN A. REIMERS Attomeys for Defendants 17 VINCENT LONGO and FUTURE FIN

SYSTEMS PTY LTD

18 19 99 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 09 DATED: November 25, 2020 3 || Rapelis, OL

HON. ROZELLA A. OLIVER

25 || United States Magistrate Judge 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Anthony Longo v. Vincent Longo; Future Fin Systems Pty 9 Ltd, Case No. 20-cv-00829-AB-RAO. I agree to comply with and to be bound by 10 all the terms of this Stipulated Protective Order and I understand and acknowledge 11 that failure to so comply could expose me to sanctions and punishment in the nature 12 of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person 14 or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27