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9 10 UNITED STATES DISTRICT COURT 11

CENTRAL DISTRICT OF CALIFORNIA

12 13 LIAIGRE, INC., a Delaware Corporation, | Case No. 8:19-cv-01160-AG-KES Plaintiff, [Discovery Document: Referred to 15 |) y. Magistrate Judge Karen E. Scott] 16 || CALIFORNIA FURNITURE [PROPOSED] FIRST AMENDED COLLECTION, INC. d/b/a ROBERT STIPULATED PROTECTIVE □□□□□□ 17 || JAMES COLLECTION, a California Corporation; GINA B & COMPANY, 18 INC. , a California Corporation; and DOES 1g 110. Defendants. 21 22 Complaint Filed: June 11, 2019 23 Trial Date: None Set Zi 25 = r= 26 07 28

1 On stipulation of Plaintiff Liaigre, Inc. and Defendants California Furniture 2 | Collection, Inc. and Gina B & Company, Inc. (collectively, the “Parties”), the Court 3 || enters an Amended Protective Order in this matter as follows:

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 disclosure 8 || and from use for any purpose other than prosecuting this litigation may be warranted. 9 || Accordingly, the parties hereby stipulate to and petition the Court to enter the following 10 || Stipulated Protective Order. The parties acknowledge that this Order does not □□□□□□ 11 || blanket protections on all disclosures or responses to discovery and that the protection 11 12 || affords from public disclosure and use extends only to the limited information or items 13 || that are entitled to confidential treatment under the applicable legal principles. 14 B. GOOD CAUSE STATEMENT 15 This action is likely to involve trade secrets, furniture information, vendor 16 || information, supplier information, pricing information, cost information, and □□□□□ 17 || valuable proprietary information for which special protection from public disclosure 18 || and from use for any purpose other than prosecution of this action is warranted. Such 19 || confidential and proprietary materials and information consist of, among other things. 20 || sales summaries, pricing, internal business strategies, and other confidential business o1 21 || financial information, or information regarding confidential business practices. The 22 || confidential information at issue is generally unavailable to the public and may be 23 || privileged or otherwise protected from disclosure under state or federal statutes, court -24 | rules, case decisions, or common law. 25 Accordingly, to expedite the flow of information, to facilitate the prompt 26 || resolution of disputes over confidentiality of discovery materials, to adequately protect 27 || information the parties are entitled to keep confidential, to ensure that the parties are 28 || permitted reasonable necessary uses of such material in preparation for and in the

1 || conduct of trial, to address their handling at the end of the litigation, and serve the ends 2 || of justice, a protective order for such information is justified in this matter. It is the 3 | intent of the parties that information will not be designated as confidential for tactical 4 | reasons and that nothing be so designated without a good faith belief that it has beer 5 || maintained in a confidential, non-public manner, and there is good cause why it should 6 || not be part of the public record of this case. 7 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER

SEAL

9 The parties further acknowledge, as set forth in Section 12.3, below, that this 10 || Stipulated Protective Order does not entitle them to file confidential information unde 11 || seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 12 || standards that will be applied when a party seeks permission from the court to file 13 | material under seal. 14 There is a strong presumption that the public has a right of access to judicial 15 || proceedings and records in civil cases. In connection with non-dispositive motions. 16 || good cause must be shown to support a filing under seal. See Kamakana v. City ana 17 || County of Honolulu, 477 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 18 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.. 19 | 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 20 || cause showing), and a specific showing of good cause or compelling reasons with 21 || proper evidentiary support and legal justification, must be made with respect tc 22 || Protected Material that a party seeks to file under seal. The parties’ mere designation of 23 || Disclosure or Discovery Material as CONFIDENTIAL does not—without the -24 || submission of competent evidence by declaration, establishing that the material sought 25 be filed under seal qualifies as confidential, privileged, or otherwise protectable— 26 || constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, then 28 || compelling reasons, not only good cause, for the sealing must be shown, and the relief

1 || sought shall be narrowly tailored to serve the specific interest to be protected. See 2 || Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 3 | or type of information, document, or thing sought to be filed or introduced under seal in 4 |}connection with a dispositive motion or trial, the party seeking protection must 5 || articulate compelling reasons, supported by specific facts and legal justification, for the 6 | requested sealing order. Again, competent evidence supporting the application to file 7 || documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in its 9 || entirety will not be filed under seal if the confidential portions can be redacted. If 10 || documents can be redacted, then a redacted version for public viewing, omitting only 11 || the confidential, privileged, or otherwise protectable portions of the document, shall be 12 || filed. Any application that seeks to file documents under seal in their entirety should 13 || include an explanation of why redaction is not feasible. 14 | 2. DEFINITIONS 15 2.1 Action: the above-captioned pending federal lawsuit entitled, Liaigre, Inc. 16 |} vy. California Furniture Collection, Inc., et al., No. 8:19-cv-01160-JAK-KES, in the 17 || United States District Court, Central District of California. 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 19 || information or items under this Order. 20 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how 21 || it is generated, stored or maintained) or tangible things that qualify for protection □□□□□ 22 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 23 || Statement. 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as thei 25 || support staff). = 26 2.5 Designating Party: a Party or Non-Party that designates information o1 27 || items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL’ 28 || or “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY.”

1 2.6 Disclosure or Discovery Material: all items or information, regardless of 2 || the medium or manner in which it is generated, stored, or maintained (including, among 3 | other things, testimony, transcripts, and tangible things), that are produced or generated 4 | in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a mattet 6 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 7 || expert witness or as a consultant in this Action. 8 2.8 “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY’ 9 || Information or Items: information (regardless of how it is generated, stored o1 10 || maintained) or tangible things that qualify for protection under Federal Rule of Civil 11 || Procedure 26(c), and as specified above in the Good Cause Statement for which 12 || disclosures to another party is likely to result in harm to the Designating Party. 13 2.9 House Counsel: attorneys who are employees of a party to this Action. 14 || House Counsel does not include Outside Counsel of Record or any other outside 15 || counsel. 16 2.10 Non-Party: any natural person, partnership, corporation, association, ot 17 || other legal entity not named as a Party to this action. 18 2.11 Outside Counsel of Record: attorneys who are not employees of a party tc 19 || this Action but are retained to represent or advise a party to this Action and have 20 || appeared in this Action on behalf of that party or are affiliated with a law firm that has 21 || appeared on behalf of that party, including support staff. 22 2.12 Party: any party to this Action, including all of its officers, directors. 23 || employees, consultants, retained experts, and Outside Counsel of Record (and theit -24 || support staffs). 25 2.13 Producing Party: a Party or Non-Party that produces Disclosure o1 26 || Discovery Material in this Action. 27 2.14 Professional Vendors: persons or entities that provide litigation support 28 services (e.g., photocopying, videotaping, translating, preparing exhibits ot

1 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and 2 || their employees and subcontractors. 3 2.15 Protected Material: any Disclosure or Discovery Material that is designated 4)as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES 5 | ONLY.” 6 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 7 || from a Producing Party. 8 || 3. SCOPE 9 The protections conferred by this Stipulation and Order cover not only Protected 10 || Material (as defined above), but also (1) any information copied or extracted from 11 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 12 || Material; and (3) any testimony, conversations, or presentations by Parties or thei 13 || Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the trial 15 || judge. This Order does not govern the use of Protected Material at trial. 16 | 4, DURATION 17 Once a case proceeds to trial, all of the court-filed information to be introduced 18 || that was previously designated as confidential or maintained pursuant to this protective 19 || order becomes public and will be presumptively available to all members of the public. 20 || including the press, unless compelling reasons supported by specific factual findings tc 21 || proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 22 || City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 23 || “good cause” showing for sealing documents produced in discovery from “compelling -24 ||reasons” standard when merits-related documents are part of court record). 25 || Accordingly, the terms of this protective order do not extend beyond the 26 || commencement of the trial. 27 Otherwise, even after final disposition of this litigation, the confidentiality 28 || obligations imposed by this Order shall remain in effect until a Designating Party agrees

1 || otherwise in writing or a court order otherwise directs. Final disposition shall be 2 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with o1 3 | without prejudice; and (2) final judgment herein after the completion and exhaustion of 4 | all appeals, rehearings, remands, trials, or reviews of this Action, including the time 5 | limits for filing any motions or applications for extension of time pursuant to applicable 6 || law. 715. DESIGNATING PROTECTED MATERIAL 8 5.1 Exercise _of Restraint_and Care in Designating Material for Protection 9 | Each Party or Non-Party that designates information or items for protection under this 10 || Order must take care to limit any such designation to specific material that qualifies 11 || under the appropriate standards. The Designating Party must designate for protection 12 || only those parts of material, documents, items, or oral or written communications that 13 || qualify so that other portions of the material, documents, items, or communications □□□ 14 || which protection is not warranted are not swept unjustifiably within the ambit of this 15 || Order. 16 Mass, indiscriminate, or routinized designations are prohibited. Designations that 17 || are shown to be clearly unjustified or that have been made for an improper purpose 18 || (e.g., to unnecessarily encumber the case development process or to impose 19 || unnecessary expenses and burdens on other parties) may expose the Designating Party 20 || to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 || designated for protection do not qualify for protection, that Designating Party must 23 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2 Manner and Timing of Designations. Except as otherwise provided in this 25 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated o1 26 || ordered, Disclosure or Discovery Material that qualifies for protection under this Ordet 27 || must be clearly so designated before the material is disclosed or produced. 28

1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic 3 |documents, but excluding transcripts of depositions or other pretrial or trial 4 | proceedings), that the Producing Party affix, at a minimum, the legend 5S | “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES ONLY’ 6 | (hereinafter “CONFIDENTIAL legend”), to each page that contains protected material. 7 only a portion or portions of the material on a page qualifies for protection, the 8 || Producing Party also must clearly identify the protected portion(s) (e.g., by making 9 | 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 before 13 || the designation, all of the material made available for inspection shall be deemed 14 | “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES ONLY.’ 15 || After the inspecting Party has identified the documents it wants copied and produced. 16 | the Producing Party must determine which documents, or portions thereof, qualify for 17 || protection under this Order. Then, before producing the specified documents, the 18 || Producing Party must affix the “CONFIDENTIAL legend” to each page that contains 19 || Protected Material. If only a portion or portions of the material on a page qualifies for 20 || protection, the Producing Party also must clearly identify the protected portion(s) (e.g.. 21 || by making appropriate markings in the margins). 22 (b) for testimony given in depositions that the Designating Party 23 identify the Disclosure or Discovery Material on the record, before the close of the -24 || deposition, of all protected testimony designated as Protected Material. Alternatively. 25 || the Designating Party may, within a reasonable time not to exceed twenty-one (21) 26 || days, after the deposition transcript is delivered to the Designating Party, provide to all 27 || counsel written notice identifying the specific portion (by page and line numbers) that 28

1 || the Designating Party seeks to protect, and all parties to the litigation will mark the 2 || pages with the appropriate legends. 3 (c) for information produced in some form other than documentary and 4 | for any other tangible items, that the Producing Party affix in a prominent place on the 5 exterior of the container or containers in which the information is stored the □□□□□□ 6 | “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “ATTORNEY EYES ONLY.’ 7 | If only a portion or portions of the information warrants protection, the Producing Party. 8 || to the extent practicable, shall identify the protected portion(s). 9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 10 || failure to designate qualified information or items does not, standing alone, waive the 11 || Designating Party’s right to secure protection under this Order for such material. Upon 12 || timely correction of a designation, the Receiving Party must make reasonable efforts tc 13 || assure that the material is treated in accordance with the provisions of this Order. 14 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 16 || designation of confidentiality at any time that is consistent with the Court’s Scheduling 17 || Order. 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 19 || resolution process under Local Rule 37.1, et seq. Any discovery motion must strictly 20 || comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 21 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 22 || stipulation pursuant to Local Rule 37-2. 23 6.4 Burden. The burden of persuasion in any such challenge proceeding shal be on the Designating Party. Frivolous challenges, and those made for an impropet 25 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) = 26 may expose the Challenging Party to sanctions. Unless the Designating Party has 27 || waived or withdrawn the confidentiality designation, all parties shall continue to afford 28

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

1 (g) the author or recipient of a document containing the information or a 2 || custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in 4 || the Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 6 | be permitted to keep any confidential information unless they sign _ the 7 | “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 8 || by the Designating Party or ordered by the Court. Pages of transcribed deposition 9 | testimony or exhibits to depositions that reveal Protected Material may be separately 10 || bound by the court reporter and may not be disclosed to anyone except as permitted 11 || under this Stipulated Protective Order; and 12 (i) any mediator or settlement officer, and their supporting personnel. 13 || mutually agreed upon by any of the parties engaged in settlement discussions. 14 7.3. Disclosure of “HIGHLY CONFIDENTIAL” or “ATTORNEY’S EYES 15 || ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 16 || writing by the Designating Party, a Receiving Party may disclose any information o1 17 | item designated “HIGHLY CONFIDENTIAL” or “ATTORNEY EYES ONLY” only 18 || 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) Experts (as defined in this Order) of the Receiving Party to whom 23 || disclosure is reasonably necessary for this Action and who have signed the -24 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (c) the court and its personnel; = 26 (d) court reporters and their staff; 27 28

1 (e) 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 (f) the author or recipient of a document containing the information or a 5 || custodian or other person who otherwise possessed or knew the information; and 6 (g) any mediator or settlement officer, and their supporting personnel. 7 || mutually agreed upon by any of the parties engaged in settlement discussions; and 8 (h) while the Receiving Party only access any Information designated as 9 | “HIGHLY CONFIDENTIAL” or “ATTORNEYS EYES ONLY” as described above. 10 || the parties may separately agree in writing to redact Information designated as 11 | “HIGHLY CONFIDENTIAL” or “ATTORNEYS EYES ONLY” so □□□□ said 12 || Information may be designated as “CONFIDENTIAL” in its redacted form, to allow the 13 || Receiving Party to have information necessary for evaluating litigation strategy in this 14 || Action. 1S || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 16 IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation that 18 compels disclosure of any information or items designated in this Action as 19 | “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL” or “ATTORNEYS EYES ONLY,” 20 || that Party must: 21 (a) promptly notify in writing the Designating Party. Such notification shall 22 || include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the subpoena or order tc -24 || issue in the other litigation that some or all of the material covered by the subpoena o1 25 || order is subject to this Protective Order. Such notification shall include a copy of this 26 || Stipulated Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to be pursued 28 || by the Designating Party whose Protected Material may be affected.

1 If the Designating Party timely seeks a protective order, the Party served with the 2 || subpoena or court order shall not produce any information designated in this action as 3 | “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL” or “ATTORNEYS EYES ONLY,’ 4 || before a determination by the court from which the subpoena or order issued, unless the 5 || Party has obtained the Designating Party’s permission. The Designating Party shall beat 6 | the burden and expense of seeking protection in that court of its confidential material 7 | and nothing in these provisions should be construed as authorizing or encouraging □ 8 || Receiving Party in this Action to disobey a lawful directive from another court. 99. A__NON-PARTY’S PROTECTED MATERIAL SOUGHT TO _ BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- 12 ||Party in this Action and designated as “CONFIDENTIAL,” “HIGHLY 13 | CONFIDENTIAL” or “ATTORNEYS EYES ONLY.” Such information produced by 14 || Non-Parties in connection with this litigation is protected by the remedies and relief 15 || provided by this Order. Nothing in these provisions should be construed as prohibiting a 16 || Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, tc 18 || produce a Non-Party’s confidential information in its possession, and the Party is 19 || subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 20 || information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non-Party 22 || that some or all of the information requested is subject to a confidentiality agreement 23 || with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 || specific description of the information requested; and 27 (3) make the information requested available for inspection by the Non- 28 || Party, if requested.

1 (c) If the Non-Party fails to seek a protective order from this Court within 14 2 || days of receiving the notice and accompanying information, the Receiving Party may 3 | produce the Non-Party’s confidential information responsive to the discovery request. If 4 || the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 5 || information in its possession or control that is subject to the confidentiality agreement 6 | with the Non-Party before a determination by the Court. Absent a court order to the 7 | contrary, the Non-Party shall bear the burden and expense of seeking protection in this 8 | Court of its Protected Material. 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 writing 13 || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 14 || all unauthorized copies of the Protected Material, (c) inform the person or persons tc 15 || whom unauthorized disclosures were made of all the terms of this Order, and (d) 16 || request such person or persons to execute the “Acknowledgment and Agreement to Be 17 || Bound” that is attached hereto as Exhibit A. 18/11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 || inadvertently produced material is subject to a claim of privilege or other protection, the 22 || obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure -24 || may be established in an e-discovery order that provides for production without priot 25 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the = 26 parties reach an agreement on the effect of disclosure of a communication o1 27 || information covered by the attorney-client privilege or work product protection, the 28

1 || parties may incorporate their agreement in the stipulated protective order submitted tc 2 | the Court.

MISCELLANEOUS

4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 || person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 || Protective Order, no Party waives any right it otherwise would have to object tc 8 || disclosing or producing any information or item on any ground not addressed in this 9 | Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 || ground to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 13 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 14 || Protected Material at issue; good cause must be shown in the request to file under seal. 15 || If 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 6C 20 || days of a written request by the Designating Party, each Receiving Party must return all 21 || Protected Material to the Producing Party or destroy such material. As used in this 22 || 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 Party 25 || must submit a written certification to the Producing Party (and, if not the same person = 26 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 27 || category, where appropriate) all the Protected Material that was returned or destroyed 28 and (2) affirms that the Receiving Party has not retained any copies, abstracts.

1 || compilations, summaries or any other format reproducing or capturing any of the 2 Protected Material. Notwithstanding this provision, counsel are entitled to retain an 3 | archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts. 4 | legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 5 || work product, and consultant and expert work product, even if such materials contain 6 || Protected Material. Any such archival copies that contain or constitute Protected 7 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 8 | 14. VIOLATION 9 Any violation of this Order may be punished by any and all appropriate measures 10 || including, without limitation, contempt proceedings and/or monetary sanctions. 11 12 ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD 13 14 || Dated: December 18, 2020 By: Dy nam & cot I United Stace Magistrate ludge 16 1 i i 20

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, [print full name]. 5 || of [print full address]. 6 | declare under penalty of perjury that I have read in its entirety and understand the 7 || Stipulated Protective Order that was issued by the United States District Court for the 8 || Central District of California in the case of Liaigre, Inc. v. California Furniture 9 | Collection, Inc., et al., No. 8:19-cv-01160-JAK-KES. I agree to comply with and to be 10 || bound by all of the terms of this Stipulated Protective Order and I understand and 11 || acknowledge that failure to so comply could expose me to sanctions and punishment in 12 || the nature 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 o1 14 || 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 16 | the Central District of California for the purpose of enforcing the terms of this 17 || Stipulated Protective Order, even if such enforcement proceedings occur aftet 18 | termination of this action. 19 I hereby appoint [print full name] 20 || of [print full address and 21 || telephone number] as my California agent for service of process in connection with this 22 || action or any proceedings related to enforcement of this Stipulated Protective Order. 23 Date: Z, 25 || City and State where sworn and signed: 26 || Printed name: 27 | Signature: 28