1

2 3 4 5

UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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8 MAYRA ARANDA, Case No. 2:21-cv-03451-CBM-PD 9 Plaintiff,

10 v. STIPULATED PROTECTIVE

ORDER1

11 NISSAN MOTOR ACCEPTANCE

CORPORATION; EXPERIAN

12 INFORMATION SOLUTIONS, INC.; TRANS UNION LLC; and 13 EQUIFAX INFORMATION

SERVICES, LLC,

14 Defendant. 15

16 17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary, or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may be 21 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 22 the following Stipulated Protective Order. The parties acknowledge that this Order 23 does not confer blanket protections on all disclosures or responses to discovery and 24 that the protection it affords from public disclosure and use extends only to the 25 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 limited information or items that are entitled to confidential treatment under the 2 applicable legal principles. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, private financial information, or 5 company specific policies and procedure and/or proprietary information for which 6 special protection from public disclosure and from use for any purpose other than 7 prosecution of this action is warranted. Such confidential and proprietary materials 8 and information consist of, among other things, confidential business or financial 9 information, information regarding confidential business practices, or other 10 confidential research, development, or commercial information (including 11 information implicating privacy rights of third parties), information otherwise 12 generally unavailable to the public, or which may be privileged or otherwise 13 protected from disclosure under state or federal statutes, court rules, case decisions, 14 or common law. Accordingly, to expedite the flow of information, to facilitate the 15 prompt resolution of disputes over confidentiality of discovery materials, to 16 adequately protect information the parties are entitled to keep confidential, to ensure 17 that the parties are permitted reasonable necessary uses of such material in 18 preparation for and in the conduct of trial, to address their handling at the end of the 19 litigation, and serve the ends of justice, a protective order for such information is 20 justified in this matter. It is the intent of the parties that information will not be 21 designated as confidential for tactical reasons and that nothing be so designated 22 without a good faith belief that it has been maintained in a confidential, non-public 23 manner, and there is good cause why it should not be part of the public record of this 24 case. 25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 26 The parties further acknowledge, as set forth in section 12.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information 1 the standards that will be applied when a party seeks permission from the court to 2 file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 proceedings and records in civil cases. In connection with non-dispositive motions, 5 good cause must be shown to support a filing under seal. See Kamakana v. City and 6 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 7 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 8 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require 9 good cause showing), and a specific showing of good cause or compelling reasons 10 with proper evidentiary support and legal justification, must be made with respect to 11 Protected Material that a party seeks to file under seal. The parties’ mere designation 12 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 13 submission of competent evidence by declaration, establishing that the material 14 sought to be filed under seal qualifies as confidential, privileged, or otherwise 15 protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 compelling reasons, not only good cause, for the sealing must be shown, and the 18 relief sought shall be narrowly tailored to serve the specific interest to be protected. 19 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 20 item or type of information, document, or thing sought to be filed or introduced under 21 seal in connection with a dispositive motion or trial, the party seeking protection 22 must articulate compelling reasons, supported by specific facts and legal 23 justification, for the requested sealing order. Again, competent evidence supporting 24 the application to file documents under seal must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in 26 its entirety will not be filed under seal if the confidential portions can be redacted. If 27 documents can be redacted, then a redacted version for public viewing, omitting only 1 be filed. Any application that seeks to file documents under seal in their entirety 2 should include an explanation of why redaction is not feasible. 3 4 2. DEFINITIONS 5 2.1 Action: Aranda, Mayra v. Nissan Motor Acceptance Corporation, et al, 6 2 :21-cv-03451-CMD-PD. 7 2.2 Challenging Party: a Party or Non-Party that challenges the designation 8 of information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 10 how it is generated, stored or maintained) or tangible things that qualify for 11 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 12 Good Cause Statement. 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 14 their support staff). 15 2.5 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless 19 of the medium or manner in which it is generated, stored, or maintained (including, 20 among other things, testimony, transcripts, and tangible things), that are produced or 21 generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as 24 an expert witness or as a consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a Party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other outside 27 counsel. 1 other legal entity not named as a Party to this Action. 2 2.10 Outside Counsel of Record: attorneys who are not employees of a Party 3 to this Action but are retained to represent or advise a Party to this Action and have 4 appeared in this Action on behalf of that Party or are affiliated with a law firm which 5 has appeared on behalf of that Party, and includes support staff. 6 2.11 Party: any party to this Action as of the date of execution of this Order, 7 including all of its officers, directors, employees, consultants, retained experts, and 8 Outside Counsel of Record (and their support staffs). 9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 10 Discovery Material in this Action. 11 2.13 Professional Vendors: persons or entities that provide litigation support 12 services (e.g., photocopying, videotaping, translating, preparing exhibits or 13 demonstrations, and organizing, storing, or retrieving data in any form or medium) 14 and their employees and subcontractors. 15 2.14 Protected Material: any Disclosure or Discovery Material that is 16 designated as “CONFIDENTIAL.” Protected Material shall not include any 17 Disclosure or Discovery Material that shows on its face that it has been actually 18 published or otherwise disseminated to the public. 19 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 20 from a Producing Party. 21 22 3. SCOPE 23 The protections conferred by this Stipulation and Order cover not only 24 Protected Material (as defined above), but also (1) any information copied or 25 extracted from Protected Material; (2) all copies, excerpts, summaries, or 26 compilations of Protected Material; and (3) any testimony, conversations, or 27 presentations by Parties or their Counsel that might reveal Protected Material. 1 Any use of Protected Material at trial shall be governed by the orders of the 2 trial judge. This Order does not govern the use of Protected Material at trial. 3 This Order is made without prejudice to any Party’s right to seek additional or 4 further protection of any Disclosure or Discovery Material or to otherwise seek a 5 modification of this Order in any way, including, but not limited to, an order that 6 certain matter not be produced at all. 7 Nothing in this Order shall restrict or prevent a Producing Party’s own use or 8 disclosure of its own Protected Material for any purpose, and nothing in this Order 9 shall restrict or prevent any Producing Party from showing its own Protected 10 Material to any individual who prepared the Protected Material. 11 12 4. DURATION 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15 as an exhibit at trial becomes public and will be presumptively available to all 16 members of the public, including the press, unless compelling reasons supported by 17 specific factual findings to proceed otherwise are made to the trial judge in advance 18 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 standard when merits-related documents are part of court record). Accordingly, the 21 terms of this protective Order do not extend beyond the commencement of the trial 22 to any Disclosure or Discovery Material that was used or introduced as an exhibit at 23 trial. 24 Notwithstanding the preceding paragraph, this Order shall remain in effect 25 even after the termination of this Action, up through the earliest of either the 26 expiration of any rights to appeal or the conclusion of any related appellate 27 proceeding. This Court retains and shall have continuing jurisdiction over the Parties 1 and Receiving Parties of the Protected Material for enforcement of the provisions of 2 this Order following termination of this Action up through the earliest of either the 3 expiration of any rights to appeal or the conclusion of any related appellate 4 proceeding 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 protection only those parts of material, documents, items, or oral or written 11 communications that qualify so that other portions of the material, documents, items, 12 or communications for which protection is not warranted are not swept unjustifiably 13 within the ambit of this Order. 14 Mass, indiscriminate, or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating 18 Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., section 5.2(b) below), or as otherwise stipulated or ordered, 24 Disclosure or Discovery Material that qualifies for protection under this Order must 25 be clearly so designated before the material is disclosed or produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 1 proceedings), that the Producing Party affix at a minimum, the legend 2 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 3 contains protected material. If only a portion or portions of the material on a page 4 qualifies for protection, the Producing Party also must clearly identify the protected 5 portion(s) (e.g., by making appropriate markings in the margins). For electronic or 6 digital files being produced, the Producing Party may affix each viewable page or 7 image with the “CONFIDENTIAL” designation and mark the medium, container, 8 and/or communication in which the electronic or digital files were contained. 9 (b) A Party or Non-Party that makes original documents available for 10 inspection need not designate them for protection until after the inspecting Party has 11 indicated which documents it would like copied and produced. During the inspection 12 and before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must determine which 15 documents, or portions thereof, qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 18 portion or portions of the material on a page qualifies for protection, the Producing 19 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 20 markings in the margins). 21 (c) Where electronic or digital files and documents are produced in native 22 electronic format, such files and documents shall be marked as “CONFIDENTIAL” 23 by appending to the file names or designators information indicating that the file 24 contains Protected Material. When electronic or digital files or documents are printed 25 for use at a deposition, a Court proceeding, or for any other use in any manner 26 approved by this Order, the Party printing the files or documents shall mark the 27 printed copies with the appropriate designation set by the Designating Party. 1 the Disclosure or Discovery Material on the record, before the close of the deposition 2 all protected testimony. This provision shall not alter or modify any Designating 3 Party’s rights with respect the inadvertent failure to designate set forth herein, 4 including those provided in Section 5.3. 5 (e) for information produced in some form other than documentary and for 6 any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 “CONFIDENTIAL.” If only a portion or portions of the information warrants 9 protection, the Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. The inadvertent or unintentional 12 production or disclosure by a Party of Disclosure or Discovery Material containing 13 “CONFIDENTIAL” Information or Items but was not designated as 14 “CONFIDENTIAL,” despite the Producing Party’s reasonable efforts to prescreen 15 such Disclosure or Discovery Material prior to production, will not waive the 16 Producing Party’s right to designate all or a portion of the Disclosure or Discovery 17 material with the appropriate designation described herein provided that the 18 Producing Party notifies all Receiving Parties that such Disclosure or Discovery 19 Material should have been designated as “CONFIDENTIAL” within ten (10) court 20 days from the Producing Party’s discovery of the inadvertent or unintentional failure 21 to designate. The Producing Party shall thereafter reproduce the Protected Material 22 with the correct designation within five (5) court days upon its notification to the 23 Receiving Parties. Upon receipt of the Protected Material with the correct 24 designation, the Receiving Parties shall return or securely destroy, at Producing 25 Party’s option, all Disclosure or Discovery Material that was not properly 26 designated. 27 1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 designation of confidentiality at any time that is consistent with the Court’s 3 Scheduling Order. Any Party or Non-Party shall not be obligated to challenge the 4 designation of Disclosure or Discovery Material under this Order at the time the 5 designation is made, and a failure to do so shall not preclude a subsequent challenge 6 thereto. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 resolution process under Local Rule 37 et seq. Any challenge shall particularly 9 identify the documents or information that the Challenging Party contends should 10 not be designated as “CONFIDENTIAL” and shall state the specific grounds for the 11 challenge and/or objection. The Parties may conduct the prefiling conference of 12 counsel telephonically or via a video platform. 13 6.3 The burden of persuasion in any such challenge proceeding shall be on 14 the Designating Party. Frivolous challenges, and those made for an improper purpose 15 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 16 expose the Challenging Party to sanctions. Unless the Designating Party has waived 17 or withdrawn the confidentiality designation, all Parties shall continue to afford the 18 material in question the level of protection to which it is entitled under the Producing 19 Party’s designation until the Court rules on the challenge. 20 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending, or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. Following the termination of this Action and the 27 earliest of either the expiration of any rights to appeal or the conclusion of any related 1 13 below (FINAL DISPOSITION). 2 Protected Material must be stored and maintained by a Receiving Party at a 3 location in the United States and in a secure manner that ensures that access is limited 4 to the persons authorized under this Order. 5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 6 otherwise ordered by the court or permitted in writing by the Designating Party, a 7 Receiving Party may disclose any information or item designated 8 “CONFIDENTIAL” only to: 9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 10 as Outside Counsel of Record’s paralegals and staff 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 the 13 Receiving Party to whom disclosure is reasonably necessary for this Action; 14 (c) Experts (as defined in this Order) of the Receiving Party to whom 15 disclosure is reasonably necessary for this Action provide that: (a) such Expert has 16 agreed to be bound by the provisions of this Order by signing a copy of the 17 “Acknowledgment and Agreement to Comply” (Exhibit A); 18 (d) the Court and its personnel and any juror or alternate juror; 19 (e) court reporters, stenographers, videographers, and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Comply” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 1 “Acknowledgment and Agreement to Comply” (Exhibit A), unless otherwise agreed 2 by the Designating Party or ordered by the Court. Pages of transcribed deposition 3 testimony or exhibits to depositions that reveal Protected Material may be separately 4 bound by the court reporter and may not be disclosed to anyone except as permitted 5 under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer, and their supporting personnel, 7 mutually agreed upon by any of the Parties engaged in settlement discussions. 8 (j) any other person with the prior written consent of the Producing Party. 9 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 11 IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification shall 16 include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order 18 to issue in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to this Protective Order. Such notification shall include a copy of 20 this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be pursued 22 by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served 24 with the subpoena or court order shall not produce any information designated in this 25 action as “CONFIDENTIAL” before a determination by the court from which the 26 subpoena or order issued, unless the Party has obtained the Designating Party’s 27 permission. The Designating Party shall bear the burden and expense of seeking 1 protection in that court of its Protected Material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED IN THIS LITIGATION 7 (a) The terms of this Order are applicable to information produced by a 8 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 9 produced by Non-Parties in connection with this Action is protected by the remedies 10 and relief provided by this Order. Nothing in these provisions should be construed 11 as prohibiting a Non-Party from seeking additional protections. 12 (b) In the event that a Party is required, by a valid discovery request, to 13 produce a Non-Party’s confidential information in its possession, and the Party is 14 subject to an agreement with the Non-Party not to produce the Non-Party’s 15 confidential information, then the Party shall: 16 (1) promptly notify in writing the Requesting Party and the Non-Party 17 that some or all of the information requested is subject to a confidentiality agreement 18 with a Non-Party; 19 (2) promptly provide the Non-Party with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), and a reasonably 21 specific description of the information requested; and 22 (3) make the information requested available for inspection by the 23 Non-Party, if requested. 24 (c) If the Non-Party fails to seek a protective order from this court within 25 14 calendar days of receiving the notice and accompanying information, the 26 Receiving Party may produce the Non-Party’s confidential information responsive 27 to the discovery request. If the Non-Party timely seeks a protective order, the 1 Receiving Party shall not produce any information in its possession or control that is 2 subject to the confidentiality agreement with the Non-Party before a determination 3 by the court. Absent a court order to the contrary, the Non-Party shall bear the burden 4 and expense of seeking protection in this court of its Protected Material. 5 6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 12 persons to whom unauthorized disclosures were made of all the terms of this Order, 13 and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Comply that is attached hereto as Exhibit A. Unauthorized or 15 inadvertence disclosure by the Receiving Party does not change the status of the 16 Protected Material or otherwise waive the Producing Party’s right to maintain the 17 “CONFIDENTIALITY” designation for such Protected Material. 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20

PROTECTED MATERIAL

21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 25 may be established in an e-discovery order that provides for production without prior 26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 27 parties reach an agreement on the effect of disclosure of a communication or 1 information covered by the attorney-client privilege or work product protection, the 2 parties may incorporate their agreement in the stipulated protective order submitted 3 to the court. 4 5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 ground to use in evidence of any of the material covered by this Protective Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 15 only be filed under seal pursuant to a court order authorizing the sealing of the 16 specific Protected Material at issue. If a Party's request to file Protected Material 17 under seal is denied by the court, then the Receiving Party may file the information 18 in the public record unless otherwise instructed by the court. 19 20 13. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in section 4, within 60 22 days of a written request by the Designating Party, each Receiving Party must return 23 all Protected Material to the Producing Party or destroy such material. As used in 24 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 summaries, and any other format reproducing or capturing any of the Protected 26 Material. Whether the Protected Material is returned or destroyed, the Receiving 27 Party must submit a written certification to the Producing Party (and, if not the same 1 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 2 (by category, where appropriate) all the Protected Material that was returned or 3 destroyed and (2) affirms that the Receiving Party has not retained any copies, 4 abstracts, compilations, summaries or any other format reproducing or capturing any 5 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 6 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 7 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 8 reports, attorney work product, and consultant and expert work product, even if such 9 materials contain Protected Material. Any such archival copies that contain or 10 constitute Protected Material remain subject to this Protective Order as set forth in 11 section 4 (DURATION). 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 14. VIOLATION 2 Any violation of this Order may be punished by any and all 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: December 16, 2021 8 /s/ Youssef H. Hammoud 9 Youssef H. Hammond, Esq.

PRICE LAW GROUP, APC

10 6345 Balboa Blvd. Suite 247 11 Encino, CA 91316 Tel: (818) 600-5596 12 Fax: (818) 600-5496 13 Email: youssef@pricelawgroup.com Attorneys for Plaintiff 14 Mayra Aranda 15 16 DATED December 16, 2021 17 /s/ Robert Im 18 Brian A. Paino (SBN 251243) Robert J. Im (SBN 299613) 19 McGLINCHEY STAFFORD 20 18201 Von Karman Avenue, Suite 350 Irvine, CA 92612 21 Tel: (949) 381-5900 22 Fax: (949) 271-4040 Email: bpaino@mcglinchey.com 23 rim@mcglinchey.com 24 Attorneys for Defendant Nissan Motor Acceptance Corporation 25

26

27 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 DATED: December 16, 2021 4

PATRICIA DONAHUE

5 _______________________________________

HONORABLE PATRICIA DONAHUE

6 United States Magistrate Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 SIGNATURE CERTIFICATION 2 Pursuant to L.R. 5-4.3.4(a)(2), I hereby certify that all other signatories listed, 3 on whose behalf this filing is submitted, concur with the contents of this filing, and 4 5 have authorized the filing. 6 DATED: December 16, 2021 By: /s/ Youssef H. Hammoud 7 Youssef H. Hammoud Attorneys for Plaintiff, 8 Mayra Aranda 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO COMPLY

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 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Aranda, Mayra v. Nissan Motor Acceptance Corporation; 8 Experian Information Solutions, Inc.; Trans Union LLC; and Equifax Information 9 Services, LLC 2:21-cv-03451-CBM-PD. I agree to comply with all the terms of the 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item 13 that is subject to the Stipulated Protective Order to any person or entity except in 14 strict compliance with the provisions of the 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 the 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ________________________ [print or 19 type full name] of _________ [print or type full address and telephone number] as 20 my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of the Stipulated Protective Order. 22

23 Date: __________________________

24 City and State where sworn and signed: _____________________________ 25 Printed name: ____________________________________ 26

27 Signature: ________________________________