joseph@farzamlaw.com 2 Henna H. Choi (SBN 306254) henna@farzamlaw.com 3 Giorgio O. Panagos (SBN 325892) giorgio@farzamlaw.com 4 JOSEPH FARZAM LAW FIRM A Professional Law Corporation 5 11766 Wilshire Blvd., Suite 280 6 Los Angeles, California 90025 Telephone: (310) 226-6890 7 Facsimile: (310) 226-6891 8 Attorneys for Plaintiff 9 MEESA BRADLEY 10 Nicole M. Shaffer (SBN 244366) nicole.shaffer@jacksonlewis.com 11 Stephanie M. Mavromatis (SBN 305235) 12 stephanie.mavromatis@jacksonlewis.com

JACKSON LEWIS P.C.

13 200 Spectrum Center Drive, Suite 500 14 Irvine, CA 92618 Telephone: (949) 885-1360 15 Facsimile: (949) 885-1380 16 Attorneys for Defendant 17

MAKE-UP ART COSMETICS INC.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

20 21 MEESA BRADLEY, an Individual, Case No. 2:20-cv-11670 PSG (ASx) 22 Plaintiff, PROTECTIVE ORDER 23 v. 24 Complaint Filed: July 24, 2020 25 MAKE-UP ART COSMETICS, INC. Date Removed: December 28, 2020 a Delaware Corporation; and DOES 1 Trial Date: December 14, 2021 26 through 20, inclusive, 27 Defendants. 28 IT IS HEREBY STIPULATED, by and between the Parties to the above- 2 captioned action through their respective counsel of record, that in order to facilitate 3 the exchange of information and documents which may be subject to confidentiality 4 limitations on disclosure due to federal laws, state laws, and privacy rights, the 5 Parties stipulate as follows: 6 1. A. PURPOSES AND LIMITATIONS 7 Discovery in this action is likely to involve production of confidential, 8 proprietary or private information for which special protection from public 9 disclosure and from use for any purpose other than prosecuting this litigation may 10 be warranted. This Stipulated Protective Order is intended to comply with the 11 California Medical Information Act (“CMIA”) and the Health Insurance Portability 12 and Accountability Act (“HIPAA”), which provides that a qualified protective order 13 may be issued by a court “with respect to protected health information.” (4.45 14 C.F.R. § 164.512(e)(1)(v).) Accordingly, the parties hereby stipulate to and jointly 15 petition the Court to enter the following Stipulated Protective Order. The parties 16 acknowledge that this Order does not confer blanket protections on all disclosures 17 or responses to discovery and that the protection it affords from public disclosure 18 and use extends only to the limited information or items that are entitled to 19 confidential treatment under the applicable legal principles. 20 B. GOOD CAUSE STATEMENT 21 The parties assert in support of their request that protection of the identified 22 categories of confidential information as listed in Section 2.3 is necessary because 23 this is an employment law action brought under the California Fair Employment and 24 Housing Act, California Government Code section 12940, et seq. This action is 25 likely to involve medical, psychiatric, personal and/or proprietary information for 26 which special protection from public disclosure and from use for any purpose other 27 than prosecution of this action is warranted. Such confidential and proprietary 28 materials and information consist of, among other things, confidential health information, psychiatric information, personal information, information implicating 2 privacy rights of third parties, and/or information otherwise generally unavailable to 3 the public, or which may be privileged or otherwise protected from disclosure under 4 state or federal statutes, court rules, case decisions, or common law. Accordingly, to 5 expedite the flow of information, to facilitate the prompt resolution of disputes over 6 confidentiality of discovery materials, to adequately protect information the parties 7 are entitled to keep confidential, to ensure that the parties are permitted reasonable 8 necessary uses of such material in preparation for and in the conduct of trial, to 9 address their handling at the end of the litigation, and serve the ends of justice, a 10 protective order for such information is justified in this matter. It is the intent of the 11 parties that information will not be designated as confidential for tactical reasons 12 and that nothing be so designated without a good faith belief that it has been 13 maintained in a confidential, non-public manner, and there is good cause why it 14 should not be part of the public record of this case. 15 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING 16 UNDER SEAL 17 The parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential information 19 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 20 and the standards that will be applied when a party seeks permission from the court 21 to file material under seal. 22 There is a strong presumption that the public has a right of access to judicial 23 proceedings and records in civil cases. In connection with non-dispositive motions, 24 good cause must be shown to support a filing under seal. See Kamakana v. City and 25 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 26 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 27 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 28 good cause showing), and a specific showing of good cause or compelling reasons with proper evidentiary support and legal justification, must be made with respect to 2 Protected Material that a party seeks to file under seal. The parties’ mere designation 3 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 4 submission of competent evidence by declaration, establishing that the material 5 sought to be filed under seal qualifies as confidential, privileged, or otherwise 6 protectable—constitute good cause. 7 Further, if a party requests sealing related to a dispositive motion or trial, then 8 compelling reasons, not only good cause, for the sealing must be shown, and the 9 relief sought shall be narrowly tailored to serve the specific interest to be protected. 10 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 11 each item or type of information, document, or thing sought to be filed or introduced 12 under seal in connection with a dispositive motion or trial, the party seeking 13 protection must articulate compelling reasons, supported by specific facts and legal 14 justification, for the requested sealing order. Again, competent evidence supporting 15 the application to file documents under seal must be provided by declaration. 16 Any document that is not confidential, privileged, or otherwise protectable in 17 its entirety will not be filed under seal if the confidential portions can be redacted. 18 If documents can be redacted, then a redacted version for public viewing, omitting 19 only the confidential, privileged, or otherwise protectable portions of the document, 20 shall be filed. Any application that seeks to file documents under seal in their entirety 21 should include an explanation of why redaction is not feasible. 22 2. DEFINITIONS 23 2.1 Action: this pending federal lawsuit entitled Meesa Bradley v. MAKE-UP 24 ART COSMETICS, INC. U.S.D.C. CACD Case No. 2:20-cv-11670-PSG (ASx). 25 2.2 Challenging Party: a Party or Non-Party that challenges the designation 26 of information or items under this Order. 27 2.3 “CONFIDENTIAL” Information or Items: As used in this Stipulated 28 Protective Order, “CONFIDENTIAL” Information is defined as information that the producing party designates in good faith has been previously maintained in a 2 confidential manner and should be protected from disclosure and use outside the 3 litigation because its disclosure and use is restricted by statute or could potentially 4 cause harm to the interests of disclosing party or nonparties. For purposes of this 5 Order, the parties will limit their designation of “CONFIDENTIAL” Information to 6 the following categories of information or documents: 7 • Any and all protected health information, including, but not limited to, 8 medical records, psychiatric records, treatment, health information, and 9 mental health information subject to the provisions of the CMIA and 10 HIPAA. 11 • Personnel files 12 • Pre- and post-employment medical screening documents 13 • Tax returns and other financial records 14 • Work restriction and/or workers’ compensation records 15 • Proprietary business records 16 • Trade secrets 17 • Records maintained in a complaint investigation 18 • Records whose disclosure is restricted or prohibited by statute 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or 22 items that it produces in disclosures or in responses to discovery as 23 “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless 25 of the medium or manner in which it is generated, stored, or maintained (including, 26 among other things, testimony, transcripts, and tangible things), that are produced 27 or generated in disclosures or responses to discovery in this matter. 28 /// 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent or advise a party to this Action and have 11 appeared in this Action on behalf of that party or are affiliated with a law firm that 12 has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or 2 compilations of Protected Material; and (3) any testimony, conversations, or 3 presentations by Parties or their Counsel that might reveal Protected Material. Any 4 use of Protected Material at trial shall be governed by the orders of the trial judge. 5 This Order does not govern the use of Protected Material at trial. 6 The Parties and all signatories to the Acknowledgment And Agreement To 7 Be Bound attached hereto as Exhibit A agree to be bound by this Stipulated 8 Protective Order pending its approval and entry by the Court. In the event that the 9 Court modifies this Stipulated Protective Order, or in the event that the Court enters 10 a different Protective Order, the Parties agree to be bound by this Stipulated 11 Protective Order until such time as the Court may enter such a different Protective 12 Order. It is the Parties’ intent to be bound by the terms of this Stipulated Protective 13 Order pending its entry so as to allow for immediate production of Protected 14 Materials under the terms herein. 15 4. DURATION 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 18 as an exhibit at trial becomes public and will be presumptively available to all 19 members of the public, including the press, unless compelling reasons supported by 20 specific factual findings to proceed otherwise are made to the trial judge in advance 21 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record). Accordingly, the 24 terms of this protective order do not extend beyond the commencement of the trial. 25 /// 26 /// 27 /// 28 // 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for 3 Protection. 4 Each Party or Non-Party that designates information or items for protection under 5 this Order must take care to limit any such designation to specific material that 6 qualifies under the appropriate standards. The Designating Party must designate for 7 protection only those parts of material, documents, items or oral or written 8 communications that qualify so that other portions of the material, documents, items 9 or communications for which protection is not warranted are not swept unjustifiably 10 within the ambit of this Order. Mass, indiscriminate or routinized designations are 11 prohibited. Designations that are shown to be clearly unjustified or that have been 12 made for an improper purpose (e.g., to unnecessarily encumber the case 13 development process or to impose unnecessary expenses and burdens on other 14 parties) may expose the Designating Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic documents, 25 but excluding transcripts of depositions or other pretrial or trial proceedings), that 26 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 27 “CONFIDENTIAL legend”), to each page that contains protected material. If only 28 a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings 2 in the margins). 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and 6 before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 8 documents it wants copied and produced, the Producing Party must determine which 9 documents, or portions thereof, qualify for protection under this Order. Then, before 10 producing the specified documents, the Producing Party must affix the 11 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 12 portion of the material on a page qualifies for protection, the Producing Party also 13 must clearly identify the protected portion(s) (e.g., by making appropriate markings 14 in the margins). 15 (b) for testimony given in depositions that the Designating Party identifies 16 the Disclosure or Discovery Material on the record, before the close of the deposition 17 all protected testimony. 18 (c) for information produced in some form other than documentary and for 19 any other tangible items, that the Producing Party affix in a prominent place on the 20 exterior of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL.” If only a portion or portions of the information warrants 22 protection, the Producing Party, to the extent practicable, shall identify the protected 23 portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 25 failure to designate qualified information or items does not, standing alone, waive 26 the Designating Party’s right to secure protection under this Stipulated Protective 27 Order for such material. Upon timely correction of a designation, the Receiving 28 Party must make reasonable efforts to assure that the material is treated in accordance with the provisions of this Stipulated Protective Order. 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 4 designation of confidentiality at any time that is consistent with the Court’s 5 Scheduling Order. 6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 7 resolution process under Local Rule 37-1 et seq. 8 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 9 joint stipulation pursuant to Local Rule 37-2. 10 6.4 Duty. The burden of persuasion in any such challenge proceeding shall 11 be on the Designating Party. Frivolous challenges, and those made for an improper 12 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 13 parties) may expose the Challenging Party to sanctions. Unless the Designating 14 Party has waived or withdrawn the confidentiality designation, all parties shall 15 continue to afford the material in question the level of protection to which it is 16 entitled under the Producing Party’s designation until the Court rules on the 17 challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 20 disclosed or produced by another Party or by a Non-Party in connection with this 21 Action only for prosecuting, defending or attempting to settle this Action. Such 22 Protected Material may be disclosed only to the categories of persons and under the 23 conditions described in this Order. When the Action has been terminated, a 24 Receiving Party must comply with the provisions of section 13 below (FINAL 25 DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 location and in a secure manner that ensures that access is limited to the persons 28 authorized under this Order. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 6 employees of said Outside Counsel of Record to whom it is reasonably necessary to 7 disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the court and its 13 personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or a 19 custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses, and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 23 not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 agreed by the Designating Party or ordered by the court. Pages of transcribed 26 deposition testimony or exhibits to depositions that reveal Protected Material may 27 be separately bound by the court reporter and may not be disclosed to anyone except 28 as permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 4 PRODUCED IN OTHER LITIGATION 5 If a Party is served with a subpoena or a court order issued in other litigation 6 that compels disclosure of any information or items designated in this Action as 7 “CONFIDENTIAL,” that Party must: 8 (a) promptly notify in writing the Designating Party. Such notification shall 9 include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the subpoena or order to 11 issue in the other litigation that some or all of the material covered by the subpoena 12 or order is subject to this Protective Order. Such notification shall include a copy of 13 this Stipulated Protective Order; and 14 (c) cooperate with respect to all reasonable procedures sought to be pursued 15 by the Designating Party whose Protected Material may be affected. 16 If the Designating Party timely seeks a protective order, the Party served with 17 the subpoena or court order shall not produce any information designated in this 18 action as “CONFIDENTIAL” before a determination by the court from which the 19 subpoena or order issued, unless the Party has obtained the Designating Party’s 20 permission. The Designating Party shall bear the burden and expense of seeking 21 protection in that court of its confidential material and nothing in these provisions 22 should be construed as authorizing or encouraging a Receiving Party in this Action 23 to disobey a lawful directive from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 (a) The terms of this Order are applicable to information produced by a Non- 27 Party in this Action and designated as “CONFIDENTIAL.” Such information 28 produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party that 8 some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 11 Order in this Action, the relevant discovery request(s), and a reasonably specific 12 description of the information requested; and 13 (3) make the information requested available for inspection by the Non-Party, 14 if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 14 16 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 28 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the terms of this 2 Order, and (d) request such person or persons to execute the “Acknowledgment and 3 Agreement to Be Bound” that is attached hereto as Exhibit A. 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 5 OTHERWISE PROTECTED MATERIAL 6 When a Producing Party gives notice to Receiving Parties that certain 7 inadvertently produced material is subject to a claim of privilege or other protection, 8 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 9 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 10 may be established in an e-discovery order that provides for production without prior 11 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 12 parties reach an agreement on the effect of disclosure of a communication or 13 information covered by the attorney-client privilege or work product protection, the 14 parties may incorporate their agreement in the stipulated protective order submitted 15 to the court. 16 12. MISCELLANEOUS 17 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 18 person to seek its modification by the Court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry of this 20 Protective Order, no Party waives any right it otherwise would have to object to 21 disclosing or producing any information or item on any ground not addressed in this 22 Stipulated Protective Order. Similarly, no Party waives any right to object on any 23 ground to use in evidence of any of the material covered by this Protective Order. 24 12.3 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 26 only be filed under seal pursuant to a court order authorizing the sealing of the 27 specific Protected Material at issue. If a Party’s request to file Protected Material 28 under seal is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. 2 13. FINAL DISPOSITION 3 After the final disposition of this Action, as defined in paragraph 4, within 60 4 days of a written request by the Designating Party, each Receiving Party must return 5 all Protected Material to the Producing Party or destroy such material. As used in 6 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 7 summaries, and any other format reproducing or capturing any of the Protected 8 Material. Whether the Protected Material is returned or destroyed, the Receiving 9 Party must submit a written certification to the Producing Party (and, if not the same 10 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 11 (by category, where appropriate) all the Protected Material that was returned or 12 destroyed and (2) affirms that the Receiving Party has not retained any copies, 13 abstracts, compilations, summaries or any other format reproducing or capturing any 14 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 15 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 16 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 17 reports, attorney work product, and consultant and expert work product, even if such 18 materials contain Protected Material. Any such archival copies that contain or 19 constitute Protected Material remain subject to this Protective Order as set forth in 20 Section 4. 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: August 13, 2021 8 9 /s/ Henna H. Choi 10

JOSEPH FARZAM LAW FIRM

11 Joseph S. Farzam, Esq. 12 Henna H. Choi, Esq. Giorgio O. Panagos, Esq. 13 Attorneys for Plaintiff 14 MEESA BRADLEY 15 DATED: August 13, 2021 16 17 /s/ Nicole M. Shaffer

JACKSON LEWIS P.C.

18 Nicole M. Shaffer, Esq. 19 Stephanie M. Mavromatis, Esq. Attorneys for Defendant 20

MAKE-UP ART COSMETICS, INC.

21 22

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

23 DATED: __A__u_g_u_s_t _2_7_, _2_0_2_1_________ 24 25 26 ________/_ s_ /_ S_a_g_a_r______________________ Honorable Alka Sagar 27 United States Magistrate Judge 28

EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on ______________ in the case of Meesa Bradley v. MAKE-UP ART COSMETICS, 8 INC. U.S.D.C. CACD Case No. 2:20-cv-11670-PSG (ASx). I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and I understand 10 and acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in 12 any manner any information or item that is subject to this Stipulated Protective Order 13 to any person 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 for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [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 Signature: _______________________________ 27 28