1 Adam P. KohSweeney (S.B. #229983) akohsweeney@omm.com 2 Kristin M. MacDonnell (S.B. #307124) kmacdonnell@omm.com 3

O’MELVENY & MYERS LLP

4 Two Embarcadero Center, 28th Floor San Francisco, California 94111-3823 5 Telephone: (415) 984-8700 Facsimile: (415) 984-8701 6

7 Attorneys for Defendant United Airlines, Inc. 8 *Additional counsel on following page 9

10

11 UNITED STATES DISTRICT COURT

12 CENTRAL DISTRICT OF CALIFORNIA

13

14 JOSE MEDINA, as an individual and Case No. 2:18-cv-07557-TJH-JC on behalf of all aggrieved employees, 15 Plaintiff, 16

STIPULATED PROTECTIVE

v. ORDER 17

18 UNITED AIRLINES, INC., a Delaware [CHANGES MADE BY COURT TO Corporation; and Does 1 through 100, PARAGRAPHS IVA, IVB, IXB, & 19 inclusive, XC]

20 Defendants. 21 22 23

24 1 Larry W. Lee, Esq. (SBN 228175)

DIVERSITY LAW GROUP

2 515 S. Figueroa St. Suite 1250 Los Angeles, CA 90071 3 Telephone: (213) 488-6555 4 Facsimile: (213) 488-6554 lwlee@diversitylaw.com 5 Edward W. Choi, Esq. (SBN 211334) 6

LAW OFFICES OF CHOI & ASSOCIATES

7 515 S. Figueroa St. Suite 1250 Los Angeles, CA 90071 8 Telephone: (213) 381-1515 Facsimile: (213) 465-4885 9 edward.choi@calaw.biz

10 William L. Marder, Esq. (SBN 170131) 11 POLARIS LAW GROUP 501 San Benito Street, Suite 200 12 Hollister, CA 95023 Telephone: (831) 531-4214 13 Facsimile: (831) 634-0333 14 Attorneys for Plaintiff 15 Jose Medina

16

17 18 19 20

21

22

23 24 1 I. PURPOSES AND LIMITATIONS 2 A. Discovery in this action is likely to involve production of 3 confidential, proprietary, or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this 5 litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 7 petition the Court to enter the following Stipulated Protective Order. The parties 8 acknowledge that this Order does not confer blanket protections on all disclosures 9 or responses to discovery and that the protection it affords from public disclosure 10 and use extends only to the limited information or items that are entitled to 11 confidential treatment under the applicable legal principles. The parties further 12 acknowledge, as set forth in Section XIII(C), below, that this Stipulated Protective 13 14 Order does not entitle them to file confidential information under seal; Civil Local 15 Rule 79-5 sets forth the procedures that must be followed and the standards that 16 will be applied when a party seeks permission from the Court to file material 17 under seal. 18

II. GOOD CAUSE STATEMENT

19 A. This action is likely to involve sensitive information concerning 20 21 parties or nonparties which relates to personnel records (including, but not limited 22 to, employee’s contact information), payroll records, human resources processes, 23 business records, process, policies, or practices, operations, plans or apparatus, 24 1 identification of customers, and other commercial, financial, technical and/or 2 proprietary information for which special protection from public disclosure and 3 from use for any purpose other than prosecution of this action is warranted. Such 4 confidential and proprietary materials and information consist of, among other 5 things, confidential business or financial information, information regarding 6 7 confidential business practices, or other confidential research, development, or 8 commercial information (including information implicating privacy rights of third 9 parties), information otherwise generally unavailable to the public, or which may 10 be privileged or otherwise protected from disclosure under state or federal 11 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 12 flow of information, to facilitate the prompt resolution of disputes over 13 14 confidentiality of discovery materials, to adequately protect information the 15 parties are entitled to keep confidential, to ensure that the parties are permitted 16 reasonable necessary uses of such material in preparation for and in the conduct of 17 trial, to address their handling at the end of the litigation, and serve the ends of 18 justice, a protective order for such information is justified in this matter. It is the 19 intent of the parties that information will not be designated as confidential for 20 21 tactical reasons and that nothing be so designated without a good faith belief that 22 it has been maintained in a confidential, non-public manner, and there is good 23 cause why it should not be part of the public record of this case. 24 1 III. DEFINITIONS 2 A. Action: Jose Medina v. United Airlines, Inc., C.D. Cal. Case No. 3 2:18-cv-07557-TJH-JC. 4 B. Challenging Party: A Party or Non-Party that challenges the 5 designation of information or items under this Order. 6 7 C. “CONFIDENTIAL” Information or Items: Information (regardless 8 of how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 D. Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 14 E. Designating Party: A Party or Non-Party that designates information 15 or items that it produces in disclosures or in responses to discovery as 16 “CONFIDENTIAL.” 17 F. Disclosure or Discovery Material: All items or information, 18 regardless of the medium or manner in which it is generated, stored, or maintained 19 (including, among other things, testimony, transcripts, and tangible things), that 20 21 are produced or generated in disclosures or responses to discovery in this matter. 22 23 24 1 G. Expert: A person with specialized knowledge or experience in a 2 matter pertinent to the litigation who has been retained by a Party or its counsel to 3 serve as an expert witness or as a consultant in this Action. 4 H. House Counsel: Attorneys who are employees of a party to this 5 Action. House Counsel does not include Outside Counsel of Record or any other 6 7 outside counsel. 8 I. Non-Party: Any natural person, partnership, corporation, association, 9 or other legal entity not named as a Party to this action. 10 J. Outside Counsel of Record: Attorneys who are not employees of a 11 party to this Action but are retained to represent or advise a party to this Action 12 and have appeared in this Action on behalf of that party or are affiliated with a law 13 14 firm which has appeared on behalf of that party, and includes support staff. 15 K. Party: Any party to this Action, including all of its officers, 16 directors, employees, consultants, retained experts, and Outside Counsel of 17 Record (and their support staffs). 18 L. Producing Party: A Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 21 M. Professional Vendors: Persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing exhibits 23 24 1 or demonstrations, and organizing, storing, or retrieving data in any form or 2 medium) and their employees and subcontractors. 3 N. Protected Material: Any Disclosure or Discovery Material that is 4 designated as “CONFIDENTIAL.” 5 O. Receiving Party: A Party that receives Disclosure or Discovery 6 7 Material from a Producing Party. 8 IV. SCOPE 9 A. The protections conferred by this Stipulation and Order cover not 10 only Protected Material (as defined above), but also (1) any information copied or 11 extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 compilations of Protected Material; and (3) any deposition testimony, 13 14 conversations, or presentations by Parties or their Counsel that might reveal 15 Protected Material, other than during a court hearing or at trial. 16 B. Any use of Protected Material during a court hearing or at trial shall 17 be governed by the orders of the presiding judge. This Order does not govern the 18 use of Protected Material during a court hearing or at trial. 19

V. DURATION

20 21 A. Once a case proceeds to trial, all of the information that was 22 designated as confidential or maintained pursuant to this Protective Order 23 becomes public and will be presumptively available to all members of the public, 24 1 including the press, unless compelling reasons supported by specific factual 2 findings to proceed otherwise are made to the trial judge in advance of the trial. 3 See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 4 2006) (distinguishing “good cause” showing for sealing documents produced in 5 discovery from “compelling reasons” standard when merits-related documents are 6 7 part of court record). Accordingly, the terms of this Protective Order do not 8 extend beyond the commencement of the trial. 9 B. Even after final disposition of this litigation, the confidentiality 10 obligations imposed by this Order shall remain in effect until a Designating Party 11 agrees otherwise in writing or a court order otherwise directs. Final disposition 12 shall be deemed to be the later of (1) dismissal of all claims and defenses in this 13 14 Action, with or without prejudice; and (2) final judgment herein after the 15 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews 16 of this Action, including the time limits for filing any motions or applications for 17 extension of time pursuant to applicable law. 18

VI. DESIGNATING PROTECTED MATERIAL

19 A. Exercise of Restraint and Care in Designating Material for Protection 20 21 1. Each Party or Non-Party that designates information or items for 22 protection under this Order must take care to limit any such designation to specific 23 material that qualifies under the appropriate standards. The Designating Party 24 1 must designate for protection only those parts of material, documents, items, or 2 oral or written communications that qualify so that other portions of the material, 3 documents, items, or communications for which protection is not warranted are 4 not swept unjustifiably within the ambit of this Order. 5 2. Mass, indiscriminate, or routinized designations are prohibited. 6 7 Designations that are shown to be clearly unjustified or that have been made for 8 an improper purpose (e.g., to unnecessarily encumber the case development 9 process or to impose unnecessary expenses and burdens on other parties) may 10 expose the Designating Party to sanctions. 11 3. If it comes to a Designating Party’s attention that information or 12 items that it designated for protection do not qualify for protection, that 13 14 Designating Party must promptly notify all other Parties that it is withdrawing the 15 inapplicable designation. 16 B. Manner and Timing of Designations 17 1. Except as otherwise provided in this Order (see, e.g., Section B(2)(b) 18 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material 19 that qualifies for protection under this Order must be clearly so designated before 20 21 the material is disclosed or produced. 22 23

24 1 2. Designation in conformity with this Order requires the following: 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 5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 6 7 contains protected material. If only a portion or portions of the material on a page 8 qualifies for protection, the Producing Party also must clearly identify the 9 protected portion(s) (e.g., by making appropriate markings in the margins). 10 b. A Party or Non-Party that makes original documents available for 11 inspection need not designate them for protection until after the inspecting Party 12 has indicated which documents it would like copied and produced. During the 13 14 inspection and before the designation, all of the material made available for 15 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 16 identified the documents it wants copied and produced, the Producing Party must 17 determine which documents, or portions thereof, qualify for protection under this 18 Order. Then, before producing the specified documents, the Producing Party must 19 affix the “CONFIDENTIAL legend” to each page that contains Protected 20 21 Material. If only a portion or portions of the material on a page qualifies for 22 protection, the Producing Party also must clearly identify the protected portion(s) 23 (e.g., by making appropriate markings in the margins). 24 1 c. For testimony given in depositions, that the Designating Party 2 identify the Disclosure or Discovery Material on the record, before the close of the 3 deposition all protected testimony. 4 d. For information produced in form other than document and for any 5 other tangible items, that the Producing Party affix in a prominent place on the 6 7 exterior of the container or containers in which the information is stored the 8 legend “CONFIDENTIAL.” If only a portion or portions of the information 9 warrants protection, the Producing Party, to the extent practicable, shall identify 10 the protected portion(s). 11 C. Inadvertent Failure to Designate 12 1. If timely corrected, an inadvertent failure to designate qualified 13 14 information or items does not, standing alone, waive the Designating Party’s right 15 to secure protection under this Order for such material. Upon timely correction of 16 a designation, the Receiving Party must make reasonable efforts to assure that the 17 material is treated in accordance with the provisions of this Order. 18

VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS

19 A. Timing of Challenges 20 21 1. Any party or Non-Party may challenge a designation of 22 confidentiality at any time that is consistent with the Court’s Scheduling Order. 23

24 1 B. Meet and Confer 2 1. The Challenging Party shall initiate the dispute resolution process 3 under Local Rule 37.1 et seq. 4 C. The burden of persuasion in any such challenge proceeding shall be 5 on the Designating Party. Frivolous challenges, and those made for an improper 6 7 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 8 parties) may expose the Challenging Party to sanctions. Unless the Designating 9 Party has waived or withdrawn the confidentiality designation, all parties shall 10 continue to afford the material in question the level of protection to which it is 11 entitled under the Producing Party’s designation until the Court rules on the 12 challenge. 13 14 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 15 A. Basic Principles 16 1. A Receiving Party may use Protected Material that is disclosed or 17 produced by another Party or by a Non-Party in connection with this Action only 18 for prosecuting, defending, or attempting to settle this Action. Such Protected 19 Material may be disclosed only to the categories of persons and under the 20 21 conditions described in this Order. When the Action has been terminated, a 22 Receiving Party must comply with the provisions of Section XIV below. 23 24 1 2. Protected Material must be stored and maintained by a Receiving 2 Party at a location and in a secure manner that ensures that access is limited to the 3 persons authorized under this Order. 4 B. Disclosure of “CONFIDENTIAL” Information or Items 5 1. Unless otherwise ordered by the Court or permitted in writing by the 6 7 Designating Party, a Receiving Party may disclose any information or item 8 designated “CONFIDENTIAL” only to: 9 a. The Receiving Party’s Outside Counsel of Record in this Action, as 10 well as employees of said Outside Counsel of Record to whom it is reasonably 11 necessary to disclose the information for this Action; 12 b. The officers, directors, and employees (including House Counsel) of 13 14 the Receiving Party to whom disclosure is reasonably necessary for this Action; 15 c. Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 d. The Court and its personnel; 19 e. Court reporters and their staff; 20 21 f. Professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary or this Action and who have 23 24 1 signed the “Acknowledgment and Agreement to be Bound” attached as Exhibit A 2 hereto; 3 g. The author or recipient of a document containing the information or a 4 custodian or other person who otherwise possessed or knew the information; 5 h. During their depositions, witnesses, and attorneys for witnesses, in 6 7 the Action to whom disclosure is reasonably necessary provided: (i) the deposing 8 party requests that the witness sign the “Acknowledgment and Agreement to Be 9 Bound;” and (ii) they will not be permitted to keep any confidential information 10 unless they sign the “Acknowledgment and Agreement to Be Bound,” unless 11 otherwise agreed by the Designating Party or ordered by the Court. Pages of 12 transcribed deposition testimony or exhibits to depositions that reveal Protected 13 14 Material may be separately bound by the court reporter and may not be disclosed 15 to anyone except as permitted under this Stipulated Protective Order; and 16 i. Any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions. 18 C. Under no circumstances will Plaintiff or his attorneys or agents share 19 Confidential Information with any labor union, collective bargaining agent, or 20 21 similar entity, or any employee, agent or affiliate thereof (individually and 22 collectively, “Labor Union”); provided, however, that in the event that Plaintiff 23 believes or contends that a Labor Union meets the definition of a Qualified 24 1 Person, Plaintiff may disclose Confidential Information to said Labor Union to the 2 extent that Plaintiff provides written notice to Defendant ten (10) business days 3 prior to the disclosure of the Confidential Information. Said written notice must 4 include a description, by reference to bates number or document name, of the 5 documents which Plaintiff intends to disclose. If Defendant objects to the 6 7 disclosure, Defendant shall notify Plaintiff in writing within five (5) business days 8 (after receipt of notice of intended disclosure from Plaintiff). If the parties’ 9 dispute cannot be resolved within five (5) business day after Defendant notifies 10 Plaintiff of their objection, Defendant will file a motion consistent with Section 11 VII herein. While any objection or motion is pending, the challenged Discovery 12 Material shall be treated as Confidential until the Court rules otherwise. 13 14 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 A. If a Party is served with a subpoena or a court order issued in other 17 litigation that compels disclosure of any information or items designated in this 18 Action as “CONFIDENTIAL,” that Party must: 19 1. Promptly notify in writing the Designating Party. Such notification 20 21 shall include a copy of the subpoena or court order; 22 2. Promptly notify in writing the party who caused the subpoena or 23 order to issue in the other litigation that some or all of the material covered by the 24 1 subpoena or order is subject to this Protective Order. Such notification shall 2 include a copy of this Stipulated Protective Order; and 3 3. Cooperate with respect to all reasonable procedures sought to be 4 pursued by the Designating Party whose Protected Material may be affected. 5 B. If the Designating Party timely seeks a protective order, the Party 6 7 served with the subpoena or court order shall not produce any information 8 designated in this action as “CONFIDENTIAL” before a determination by the 9 Court from which the subpoena or order issued, unless the Party has obtained the 10 Designating Party’s permission or unless otherwise required by the law or court 11 order. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material and nothing in these provisions 13 14 should be construed as authorizing or encouraging a Receiving Party in this 15 Action to disobey a lawful directive from another court. 16

X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

17

PRODUCED IN THIS LITIGATION

18 A. The terms of this Order are applicable to information produced by a 19 Non-Party in this Action and designated as “CONFIDENTIAL.” Such 20 21 information produced by Non-Parties in connection with this litigation is protected 22 by the remedies and relief provided by this Order. Nothing in these provisions 23 24 1 should be construed as prohibiting a Non-Party from seeking additional 2 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 7 confidential information, then the Party shall: 8 1. Promptly notify in writing the Requesting Party and the Non-Party 9 that some or all of the information requested is subject to a confidentiality 10 agreement with a Non-Party; 11 2. Promptly provide the Non-Party with a copy of the Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 14 specific description of the information requested; and 15 3. Make the information requested available for inspection by the Non- 16 Party, if requested. 17 C. If the Non-Party fails to seek a protective order from this court 18 within 14 days of receiving the notice and accompanying information, the 19 Receiving Party may produce the Non-Party’s confidential information responsive 20 21 to the discovery request. If the Non-Party timely seeks a protective order, the 22 Receiving Party shall not produce any information in its possession or control that 23 is subject to the confidentiality agreement with the Non-Party before a 24 1 determination by the court unless otherwise required by the law or court order. 2 Absent a court order to the contrary, the Non-Party shall bear the burden and 3 expense of seeking protection in this court of its Protected Material. 4

XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

5 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 6 7 disclosed Protected Material to any person or in any circumstance not authorized 8 under this Stipulated Protective Order, the Receiving Party must immediately (1) 9 notify in writing the Designating Party of the unauthorized disclosures, (2) use its 10 best efforts to retrieve all unauthorized copies of the Protected Material, (3) 11 inform the person or persons to whom unauthorized disclosures were made of all 12 the terms of this Order, and (4) request such person or persons to execute the 13 14 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit 15 A. 16

XII. INADVERTENT PRODUCTION OF PRIVILEGED OR

17

OTHERWISE PROTECTED MATERIAL

18 A. When a Producing Party gives notice to Receiving Parties that certain 19 inadvertently produced material is subject to a claim of privilege or other 20 21 protection, the obligations of the Receiving Parties are those set forth in Federal 22 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 23 whatever procedure may be established in an e-discovery order that provides for 24 1 production without prior privilege review. Pursuant to Federal Rule of Evidence 2 502(d) and (e), insofar as the parties reach an agreement on the effect of 3 disclosure of a communication or information covered by the attorney-client 4 privilege or work product protection, the parties may incorporate their agreement 5 in the Stipulated Protective Order submitted to the Court. 6 7 XIII. MISCELLANEOUS 8 A. Right to Further Relief 9 1. Nothing in this Order abridges the right of any person to seek its 10 modification by the Court in the future. 11 B. Right to Assert Other Objections 12 1. By stipulating to the entry of this Protective Order, no Party waives 13 14 any right it otherwise would have to object to disclosing or producing any 15 information or item on any ground not addressed in this Stipulated Protective 16 Order. Similarly, no Party waives any right to object on any ground to use in 17 evidence of any of the material covered by this Protective Order. 18 C. Filing Protected Material 19 1. A Party that seeks to file under seal any Protected Material must 20 21 comply with Civil Local Rule 79-5. Protected Material may only be filed under 22 seal pursuant to a court order authorizing the sealing of the specific Protected 23 Material at issue. If a Party's request to file Protected Material under seal is 24 1 denied by the Court, then the Receiving Party may file the information in the 2 public record unless otherwise instructed by the Court. 4 A. After the final disposition of this Action, as defined in Section V, 5 within sixty (60) days of a written request by the Designating Party, each 6 7 Receiving Party must return all Protected Material to the Producing Party or 8 destroy such material. As used in this subdivision, “all Protected Material” 9 includes all copies, abstracts, compilations, summaries, and any other format 10 reproducing or capturing any of the Protected Material. Whether the Protected 11 Material is returned or destroyed, the Receiving Party must submit a written 12 certification to the Producing Party (and, if not the same person or entity, to the 13 14 Designating Party) by the 60 day deadline that (1) identifies (by category, where 15 appropriate) all the Protected Material that was returned or destroyed and (2) 16 affirms that the Receiving Party has not retained any copies, abstracts, 17 compilations, summaries or any other format reproducing or capturing any of the 18 Protected Material. Notwithstanding this provision, Counsel are entitled to retain 19 an archival copy of all pleadings, motion papers, trial, deposition, and hearing 20 21 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 22 reports, attorney work product, and consultant and expert work product, even if 23 such materials contain Protected Material. Any such archival copies that contain 24 1 or constitute Protected Material remain subject to this Protective Order as set forth 2 in Section V. 3 B. Any violation of this Order may be punished by any and all 4 appropriate measures including, without limitation, contempt proceedings and/or 5 monetary sanctions. 6 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 Dated: October 13, 2021 /s/ Larry Lee 9 By: Larry Lee

10 Larry W. Lee, Esq. (SBN 228175) 11 DIVERSITY LAW GROUP 515 S. Figueroa St. Suite 1250 12 Los Angeles, CA 90071 Telephone: (213) 488-6555 13 Facsimile: (213) 488-6554 14 lwlee@diversitylaw.com

15 Edward W. Choi, Esq. (SBN 211334)

LAW OFFICES OF CHOI &

16

ASSOCIATES

515 S. Figueroa St. Suite 1250 17 Los Angeles, CA 90071 18 Telephone: (213) 381-1515 Facsimile: (213) 465-4885 19 edward.choi@calaw.biz

20 William L. Marder, Esq. (SBN 170131) 21 POLARIS LAW GROUP 501 San Benito Street, Suite 200 22 Hollister, CA 95023 Telephone: (831) 531-4214 23 Facsimile: (831) 634-0333

24 1 Attorneys for Plaintiff Jose Medina 2

3 Dated: October 13, 2021 /s/ Adam P. KohSweeney 4 By: Adam P. KohSweeney

5 Adam P. KohSweeney (S.B. #229983) akohsweeney@omm.com 6 Kristin M. MacDonnell (S.B. #307124) 7 kmacdonnell@omm.com

O’MELVENY & MYERS LLP

8 Two Embarcadero Center, 28th Floor San Francisco, California 94111-3823 9 Telephone: (415) 984-8700 Facsimile: (415) 984-8701 10

11 Attorneys for Defendant United Airlines, Inc. 12

13

ATTESTATION

14 Pursuant to Local Rule 5-4.3.4 regarding signatures, I attest that I have 15 obtained the concurrence in the filing of this document from all signatories. 16 By: /s/ Adam P. KohSweeney 17 Adam P. KohSweeney 18 Attorney for Defendant United Airlines, Inc.

19

20

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21

22 Dated: October 20, 2021 /s/ Hon. Jacqueline Chooljian 23 United States Magistrate Judge

24 1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

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 7 was issue by the United States District Court for the Central District of California 8 on October 20, 2021 in the case of Jose Medina v. United Airlines, Inc., C.D. Cal. 9 Case No. 2:18-cv-07557-TJH-JC. I agree to comply with and to be bound by all 10 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 12 nature of contempt. I solemnly promise that I will not disclose in any manner any 13 14 information or item that is subject to this Stipulated Protective Order to any 15 person or entity except in strict compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District 17 Court for the Central District of California for the purpose of enforcing the terms 18 of this Stipulated Protective Order, even if such enforcement proceedings occur 19 after termination of this action. I hereby appoint 20 21 [print or type full name] of [print or type full 22 address and telephone number] as my California agent for service of process in 23 24 1 connection with this action or any proceedings related to enforcement of this 2 Stipulated Protective Order. 3

4 Date: 5 City and State where sworn and signed: 6 7 Printed Name: 8 Signature: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24