1 | MARC E. MAYER (SBN 190969) memicumek on 2 ERBERG & KNUPP LLP 2049 Century Park East, 18th Floor 3 | Los Angeles, CA 90067-3120 Telephone: Gt%) 312-2000 4 | Facsimile: (310) 312-3100 5 | Attorneys for Defendants / Counterclaimants ‘ Interscope Records and Brianna Castro

MATTHEW M. HOESLY

7 See ee C 8 | 2424 S.E. Bristol Street, Suite 300 Newport Beach, CA 92660 9 | Telephone: (949) 936-0608 Facsimile: (415) 520-6593 Attorneys fo Plaintiff, Briana Cash 11 | Additional Plaintiff"s Counsel Listed on Signature Page 12

UNITED STATES DISTRICT COURT

1 ; CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION 14 BRIANA CASH, CASE NO. 2:22-cv-01900-ODW (MAA» 1 ° Plaintiff, Judge Otis D. Wright, II 16 y. STIPULATED 17 PROTECTIVE ORDER INTERSCOPE RECORDS, a division 1g | of UMG RECORDINGS, INC., a . Delaware corporation; and BRIANNA [Discovery Document: Referred to 19 | CASTRO, agistrate Judge Maria A. Audero] 20 Defendants. FAC Filed: July 21, 2022 21 _ CC Filed: Aug. 22, 2022 INTERSCOPE RECORDS, a division 22 | of U€MG RECORDINGS, INC., and Final Pretrial Conference: Sept. 18, 2023 BRIANNA CASTRO, Trial Date: Oct. 10, 2023 23 Counterclaimants, 24 V. 25

BRIANA CASH,

26 Counterclaim Defendant. 27 28

1)/1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 | proprietary, or private information for which special protection from public 4 | disclosure and from use for any purpose other than prosecuting this litigation may 5 | be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 | enter the following Stipulated Protective Order. The parties acknowledge that this 7 | Stipulated Protective Order does not confer blanket protections on all disclosures 8 | or responses to discovery and that the protection it affords from public disclosure 9 | and use extends only to the limited information or items that are entitled to 10 | confidential treatment under the applicable legal principles. The parties further 11 | acknowledge, as set forth in Section 13.3 below, that this Stipulated Protective 12 | Order does not entitle them to file confidential information under seal; Local Rule 13 | 79-5 sets forth the procedures that must be followed and the standards that will be 14 | applied when a party seeks permission from the Court to file material under seal. 15/2. GOOD CAUSE STATEMENT 16 This action is likely to involve trade secrets, personal, commercial, financial, 17 | technical and/or proprietary information for which special protection from public 18 | disclosure and from use for any purpose other than prosecution of this action is 19 | warranted. Such confidential and proprietary materials and information consist of, 20 | among other things, confidential business or financial information, information 21 | regarding confidential business practices, or other confidential research, 22 | development, or commercial information (including information implicating 23 | privacy rights of third parties), information otherwise generally unavailable to the 24 | public, or which may be privileged or otherwise protected from disclosure under 25 | state or federal statutes, court rules, case decisions, or common law. Accordingly, 26 | to expedite the flow of information, to facilitate the prompt resolution of disputes 27 | over confidentiality of discovery materials, to adequately protect information the 28 | parties are entitled to keep confidential, to ensure that the parties are permitted

1 | reasonable necessary uses of such material in preparation for and in the conduct of 2 | trial, to address their handling at the end of the litigation, and to serve the ends of 3 | justice, a protective order for such information is justified in this matter. It is the 4 | intent of the parties that information will not be designated as confidential for 5 | tactical reasons and that nothing be so designated without a good faith belief that it 6 | has been maintained in a confidential, non-public manner, and there is good cause 7 | why it should not be part of the public record of this case. 8/3. DEFINITIONS 9 3.1 Action: The above-captioned lawsuit. 10 3.2 Challenging Party: A Party or Nonparty that challenges the 11 | designation of information or items under this Stipulated Protective Order. 12 3.3 “CONFIDENTIAL” Information or Items: Information (regardless of 13 | how it is generated, stored or maintained) or tangible things that qualify for 14 | protection under Federal Rule of Civil Procedure 26(c), and as specified above in 15 | the Good Cause Statement. 16 3.4 Counsel: Outside Counsel of Record and In-House Counsel (as well 17 | as their support staff). 18 3.5. Designating Party: A Party or Nonparty that designates information or 19 | items that it produces in disclosures or in responses to discovery as 20 | “CONFIDENTIAL.” 21 3.6 Disclosure or Discovery Material: All items or information, regardless 22 | of the medium or manner in which it is generated, stored, or maintained (including, 23 | among other things, testimony, transcripts, and tangible things), that is produced or 24 | generated in disclosures or responses to discovery in this matter, 25 3.7 Expert: A person with specialized knowledge or experience in a 26 | matter pertinent to the litigation who has been retained by a Party or its counsel to 27 | serve as an expert witness or as a consultant in this Action. 28 Be

1 3.8 In-House Counsel: Attorneys who are employees of a party to this 2 | Action. In-House Counsel does not include Outside Counsel of Record or any 3 | other outside counsel. 4 3.9 Nonparty: Any natural person, partnership, corporation, association, 5 | or other legal entity not named as a Party to this action. 6 3.10 Outside Counsel of Record: Attorneys who are not employees of a 7 | party to this Action but are retained to represent or advise a party to this Action 8 | and have appeared in this Action on behalf of that party or are affiliated with a law 9 | firm which has appeared on behalf of that party, and includes support staff. 10 3.11 Party: Any party to this Action, including all of its officers, directors, 11 | employees, consultants, retained experts, In-House Counsel, and Outside Counsel 12 | of Record (and their support staffs). 13 3.12 Producing Party: A Party or Nonparty that produces Disclosure or 14 | Discovery Material in this Action. 15 3.13 Professional Vendors: Persons or entities that provide litigation 16 | support services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 | demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 | and their employees and subcontractors. 19 3.14 Protected Material: Any Disclosure or Discovery Material that is 20 | designated as “CONFIDENTIAL.” 21 3.15 Receiving Party: A Party that receives Disclosure or Discovery 22 | Material from a Producing Party. 23|4. SCOPE 24 The protections conferred by this Stipulated Protective Order cover not only 25 | Protected Material, but also (1) any information copied or extracted from Protected 26 | Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 | Material; and (3) any testimony, conversations, or presentations by Parties or their 28 | 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 Stipulated Protective Order does not govern the use of Protected 3 | Material at trial. 4/5. DURATION 5 Once a case proceeds to trial, all of the information that was designated as 6 | confidential or maintained pursuant to this Stipulated Protective Order becomes 7 | public and presumptively will be available to all members of the public, including 8 | the press, unless compelling reasons supported by specific factual findings to 9 | proceed otherwise are made to the trial judge in advance of the trial. See 10 | Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir, 11 | 2006) (distinguishing “good cause” showing for sealing documents produced in 12 | discovery from “compelling reasons” standard when merits-related documents are 13 | part of court record). Accordingly, the terms of this Stipulated Protective Order do 14 | not extend beyond the commencement of the trial. 15/6. DESIGNATING PROTECTED MATERIAL 16 6.1 Exercise of Restraint and Care in Designating Material for Protection. 17 Each Party or Nonparty that designates information or items for protection 18 | under this Stipulated Protective Order must take care to limit any such designation 19 | to specific material that qualifies under the appropriate standards. The Designating 20 | Party must designate for protection only those parts of material, documents, items, 21 | or oral or written communications that qualify so that other portions of the 22 | material, documents, items, or communications for which protection is not 23 | warranted are not swept unjustifiably within the ambit of this Stipulated Protective 24 | Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations 26 | that are shown to be clearly unjustified or that have been made for an improper 27 | purpose (e.g., to unnecessarily encumber the case development process or to 28

1 | impose unnecessary expenses and burdens on other parties) may expose the 2 | Designating Party to sanctions. 3 6.2 Manner and Timing of Designations. 4 Except as otherwise provided in this Stipulated Protective Order (see, e.g., 5 | Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure or Discovery 6 | Material that qualifies for protection under this Stipulated Protective Order must be 7 | clearly so designated before the material is disclosed or produced. 8 Designation in conformity with this Stipulated Protective Order requires the 9 | following: 10 (a) For information in documentary form (e.g., paper or electronic 11 | documents, but excluding transcripts of depositions or other pretrial or trial 12 | proceedings), that the Producing Party affix at a minimum, the legend 13 | “CONFIDENTIAL” to each page that contains protected material. If only a portion 14 | or portions of the material on a page qualifies for protection, the Producing Party 15 | also must clearly identify the protected portion(s) (e.g., by making appropriate 16 | markings in the margins). 17 A Party or Nonparty that makes original documents available for inspection 18 | need not designate them for protection until after the inspecting Party has indicated 19 | which documents it would like copied and produced. During the inspection and 20 | before the designation, all of the material made available for inspection shall be 21 | deemed “CONFIDENTIAL.” After the inspecting Party has identified the 22 | documents it wants copied and produced, the Producing Party must determine 23 | which documents, or portions thereof, qualify for protection under this Stipulated 24 | Protective Order. Then, before producing the specified documents, the Producing 25 | Party must affix the legend “CONFIDENTIAL” to each page that contains 26 | Protected Material. If only a portion or portions of the material on a page qualifies 27 | for protection, the Producing Party also must clearly identify the protected 28 | portion(s) (e.g., by making appropriate markings in the margins).

1 (b) 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 (c) For information produced in nondocumentary form, and for any 5 | other tangible items, that the Producing Party affix in a prominent place on the 6 | exterior of the container or containers in which the information is stored the legend 7 | “CONFIDENTIAL.” If only a portion or portions of the information warrants 8 | protection, the Producing Party, to the extent practicable, shall identify the 9 | protected portion(s). 10 6.3 Inadvertent Failure to Designate. 11 If timely corrected, an inadvertent failure to designate qualified information 12 | or items does not, standing alone, waive the Designating Party’s right to secure 13 | protection under this Stipulated Protective Order for such material. Upon timely 14 | correction of a designation, the Receiving Party must make reasonable efforts to 15 | assure that the material is treated in accordance with the provisions of this 16 | Stipulated Protective Order, 17|Z. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 7.1 Timing of Challenges. 19 Any Party or Nonparty may challenge a designation of confidentiality at any 20 | time that is consistent with the Court’s Scheduling Order, 21 Z2 Meet and Confer. 22 The Challenging Party shall initiate the dispute resolution process, which 23 | shall comply with Local Rule 37.1 et seg., and with Section 4 of Judge Audero’s 24 | Procedures (“Mandatory Telephonic Conference for Discovery Disputes”’).' 25 7.3 Burden of Persuasion. 26 27 28 | https" cacd uscourts.gov □□□□□□□□□□□□□□□□□□□□□□□

1 The burden of persuasion in any such challenge proceeding shall be on the 2 | Designating Party. Frivolous challenges, and those made for an improper purpose 3 | (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 | expose the Challenging Party to sanctions. Unless the Designating Party has 5 | waived or withdrawn the confidentiality designation, all parties shall continue to 6 | afford the material in question the level of protection to which it is entitled under 7 | the Producing Party’s designation until the Court rules on the challenge. 8|8. ACCESS TO AND USE OF PROTECTED MATERIALS 9 8.1 Basic Principles. 10 A Receiving Party may use Protected Material that is disclosed or produced 11 | by another Party or by a Nonparty in connection with this Action only for 12 | prosecuting, defending, or attempting to settle this Action. Such Protected Material 13 | may be disclosed only to the categories of persons and under the conditions 14 | described in this Stipulated Protective Order. When the Action reaches a final 15 | disposition, a Receiving Party must comply with the provisions of Section 14 16 | below. 17 Protected Material must be stored and maintained by a Receiving Party at a 18 | location and in a secure manner that ensures that access is limited to the persons 19 | authorized under this Stipulated Protective Order, 20 8.2 Disclosure of “CONFIDENTIAL” Information or Items. 21 Unless otherwise ordered by the Court or permitted in writing by the 22 | Designating Party, a Receiving Party may disclose any information or item 23 | designated “CONFIDENTIAL” only to: 24 (a) The Receiving Party’s Outside Counsel of Record, as well as 25 | employees of said Outside Counsel of Record to whom it is reasonably necessary 26 | to disclose the information for this Action; 27 28

1 (b) The officers, directors, and employees (including In-House 2 | Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 3 | this Action; 4 (c) Experts of the Receiving Party to whom disclosure is 5 | reasonably necessary for this Action and who have signed the “Acknowledgment 6 | and Agreement to Be Bound” (Exhibit A); 7 (d) The Court and its personnel; 8 (e) Court reporters and their staff; 9 (f) | Professional jury or trial consultants, mock jurors, and 10 | Professional Vendors to whom disclosure is reasonably necessary or this Action 11 | and who have signed the “Acknowledgment and Agreement to be Bound” (Exhibit 12 | A); 13 (g) The author or recipient of a document containing the 14 | information or a custodian or other person who otherwise possessed or knew the 15 | information; 16 (h) During their depositions, witnesses, and attorneys for witnesses, 17 | in the Action to whom disclosure is reasonably necessary provided: (1) the 18 | deposing party requests that the witness sign the “Acknowledgment and 19 | Agreement to Be Bound” (Exhibit A); and (i1) the witness will not be permitted to 20 | keep any confidential information unless they sign the “Acknowledgment and 21 | Agreement to Be Bound,” unless otherwise agreed by the Designating Party or 22 | ordered by the Court. Pages of transcribed deposition testimony or exhibits to 23 | depositions that reveal Protected Material may be separately bound by the court 24 | reporter and may not be disclosed to anyone except as permitted under this 25 | Stipulated Protective Order; and 26 (1) Any mediator or settlement officer, and their supporting 27 | personnel, mutually agreed upon by any of the parties engaged in settlement 28 | discussions. Qn

1/9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 | that compels disclosure of any information or items designated in this Action as 5 | “CONFIDENTIAL,” that Party must: 6 (a) Promptly notify in writing the Designating Party. Such 7 | notification shall include a copy of the subpoena or court order; 8 (b) Promptly notify in writing the party who caused the subpoena 9 | or order to issue in the other litigation that some or all of the material covered by 10 | the subpoena or order is subject to this Stipulated Protective Order. Such 11 | notification shall include a copy of this Stipulated Protective Order; and 12 (c) Cooperate with respect to all reasonable procedures sought to 13 | be pursued by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 | with the subpoena or court order shall not produce any information designated in 16 | this action as “CONFIDENTIAL” before a determination by the Court from which 17 | the subpoena or order issued, unless the Party has obtained the Designating Party’s 18 | permission. The Designating Party shall bear the burden and expense of seeking 19 | protection in that court of its confidential material and nothing in these provisions 20 | should be construed as authorizing or encouraging a Receiving Party in this Action 21 | to disobey a lawful directive from another court. 22|}10. ANONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 10.1 Application. 25 The terms of this Stipulated Protective Order are applicable to information 26 | produced by a Nonparty in this Action and designated as “CONFIDENTIAL.” 27 | Such information produced by Nonparties in connection with this litigation is 28 | protected by the remedies and relief provided by this Stipulated Protective Order, Qn

1 | Nothing in these provisions should be construed as prohibiting a Nonparty from 2 | seeking additional protections. 3 10.2 Notification. 4 In the event that a Party is required, by a valid discovery request, to produce 5 | a Nonparty’s confidential information in its possession, and the Party is subject to 6 | an agreement with the Nonparty not to produce the Nonparty’s confidential 7 | information, then the Party shall: 8 (a) Promptly notify in writing the Requesting Party and the 9 | Nonparty that some or all of the information requested is subject to a 10 | confidentiality agreement with a Nonparty; 11 (b) Promptly provide the Nonparty with a copy of the Stipulated 12 | Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 | specific description of the information requested; and 14 (c) Make the information requested available for inspection by the 15 | Nonparty, if requested. 16 10.3 Conditions of Production. 17 If the Nonparty fails to seek a protective order from this Court within 18 | fourteen (14) days after receiving the notice and accompanying information, the 19 | Receiving Party may produce the Nonparty’s confidential information responsive 20 | to the discovery request. If the Nonparty timely seeks a protective order, the 21 | Receiving Party shall not produce any information in its possession or control that 22 | is subject to the confidentiality agreement with the Nonparty before a 23 | determination by the Court. Absent a court order to the contrary, the Nonparty 24 | shall bear the burden and expense of seeking protection in this Court of its 25 | Protected Material.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

27 If a Receiving Party learns that, by inadvertence or otherwise, it has 28 | disclosed Protected Material to any person or in any circumstance not authorized 11

1 | under this Stipulated Protective Order, the Receiving Party immediately must (1) 2 | notify in writing the Designating Party of the unauthorized disclosures, (2) use its 3 | best efforts to retrieve all unauthorized copies of the Protected Material, (3) inform 4 | the person or persons to whom unauthorized disclosures were made of all the terms 5 | of this Stipulated Protective Order, and (4) request such person or persons to 6 | execute the “Acknowledgment and Agreement to be Bound” (Exhibit A). 7|12. INADVERTENT PRODUCTION OF PRIVILEGED OR 8 OTHERWISE PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 | inadvertently produced material is subject to a claim of privilege or other 11 | protection, the obligations of the Receiving Parties are those set forth in Federal 12 | Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 13 | whatever procedure may be established in an e-discovery order that provides for 14 | production without prior privilege review. Pursuant to Federal Rule of Evidence 15 | 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 16 | of a communication or information covered by the attorney-client privilege or 17 | work product protection, the parties may incorporate their agreement in the 18 | Stipulated Protective Order submitted to the Court. 19/13. MISCELLANEOUS 20 13.1 Right to Further Relief. 21 Nothing in this Stipulated Protective Order abridges the right of any person 22 | to seek its modification by the Court in the future. 23 13.2 Right to Assert Other Objections. 24 By stipulating to the entry of this Stipulated Protective Order, no Party 25 | waives any right it otherwise would have to object to disclosing or producing any 26 | information or item on any ground not addressed in this Stipulated Protective 27 | Order. Similarly, no Party waives any right to object on any ground to use in 28 | evidence of any of the material covered by this Stipulated Protective Order, Dn

1 13.3 Filing Protected Material. 2 A Party that seeks to file under seal any Protected Material must comply 3 | with Local Rule 79-5. Protected Material may only be filed under seal pursuant to 4 | acourt order authorizing the sealing of the specific Protected Material at issue. If a 5 | Party's request to file Protected Material under seal is denied by the Court, then the 6 | Receiving Party may file the information in the public record unless otherwise 7 | instructed by the Court. 8/14. FINAL DISPOSITION 9 After the final disposition of this Action, within sixty (60) days of a written 10 | request by the Designating Party, each Receiving Party must return all Protected 11 | Material to the Producing Party or destroy such material. As used in this 12 | subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 | summaries, and any other format reproducing or capturing any of the Protected 14 | Material. Whether the Protected Material is returned or destroyed, the Receiving 15 | Party must submit a written certification to the Producing Party (and, if not the 16 | same person or entity, to the Designating Party) by the 60-day deadline that (1) 17 | identifies (by category, where appropriate) all the Protected Material that was 18 | returned or destroyed and (2) affirms that the Receiving Party has not retained any 19 | copies, abstracts, compilations, summaries or any other format reproducing or 20 | capturing any of the Protected Material. Notwithstanding this provision, Counsel is 21 | entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 22 | and hearing transcripts; legal memoranda; correspondence; deposition and trial 23 | exhibits; expert reports; attorney work product; and consultant and expert work 24 | product, even if such materials contain Protected Material. Any such archival 25 | copies that contain or constitute Protected Material remain subject to this 26 | Stipulated Protective Order as set forth in Section 5. 27 28 13

VIOLATION

2 Any violation of this Stipulated Order may be punished by any and all 3 | appropriate measures including, without limitation, contempt proceedings and/or 4 | monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. \DATED: March 1, 2023 MATTHEW M. HOESLY g DHILLON LAW GROUP INC. 9 By: /s/ Matthew M. Hoesly Matthew M. Hoesly (SBN. 289593) 10 Nitoy P. Singh (SBN: 265005) Ronald D. Coleman (pro hac vice) 11 Attorneys for Plaintiff and Counterclaim Defendant Briana Cash 12 13 14 DATED: March 1, 2023 MARC E. MAYER 15 MITCHELL SILBERBERG & KNUPP LLP 16 By: /s/ Marc E. Mayer Marc E. Mayer (SBN 190969) 17 Attorneys for Defendants and Counterclaimants UMG Recordings, Inc. 18 and Brianna Castro 19 20 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 ( W ui 22 | Dated: | March 2, 2023 73 Hon. Maria A. Audero United States Magistrate Judge 24 25 26 27 28 14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I 5 | have read in its entirety and understand the Stipulated Protective Order that was 6 | issued by the United States District Court for the Central District of California on 7 [date] in the case of Briana Cash v. Interscope Geffen 8 | 4 and M Records et al, 22-cv-01900-ODW-MAA (C.D. Cal. 2022). I agree to 9 | comply with and to be bound by all the terms of this Stipulated Protective Order, 10 | and I understand and acknowledge that failure to so comply could expose me to 11 | sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 | not disclose in any manner any information or item that is subject to this Stipulated 13 | Protective Order to any person or entity except in strict compliance with the 14 | provisions of this Stipulated Protective Order. 15 I further agree to submit to the jurisdiction of the United States District 16 | Court for the Central District of California for the purpose of enforcing the terms 17 | of this Stipulated Protective Order, even if such enforcement proceedings occur 18 | after termination of this action. I hereby appoint 19 | [full name] of [address and telephone 20 | number] as my California agent for service of process in connection with this 21 | action or any proceedings related to enforcement of this Stipulated Protective 22 | Order. 23 Signature: 25 | Printed Name: 26 | Date: 27 | City and State Where Sworn and Signed: 28

1 Attestation Regarding Signatures 2 I, Marc E. Mayer, attest that all signatories listed, and on whose behalf the 3 | filing is submitted, concur in the filing’s content and have authorized the filing. 4 5 6 | DATED: March 1, 2023 Is) Mare E. Maver 7 Marc E. Mayer 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 YG