Heba Ahmed v. Trans Union Rental Screening Solutions Inc

• Court: District Court, C.D. California
• Decided: January 3, 2023
• Docket: 8:22-cv-00366
• Status: Unknown

Opinion

Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 1 of 16 Page ID #:231

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 HEBA AHMED, ) Case No.: 8:22-cv-00366-CJC-JDE 11 ) ) 12 Plaintiff, ) ) 13 ) v. ) STIPULATED PROTECTIVE ) 14 ) ORDER TRANS UNION RENTAL SCREENING ) 15 SOLUTIONS, INC. and RENTSPREE, ) ) 16 INC., ) 17 ) Defendants. ) 18 ) 19 AHMED AHMED, ) Case No. 8:22-cv-00367-CJC-JDE ) 20 ) Plaintiff, ) ) 21 ) v. ) 22 ) ) 23 TRANS UNION RENTAL SCREENING ) 24 SOLUTIONS, INC., et al., ) ) ) 25 Defendants. ) ) 26 27 Pursuant to the parties’ Stipulation and for good cause shown, the Court 28 finds and orders as follows. 1 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 2 of 16 Page ID #:232

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 pursuing this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 6 to enter the following Stipulated Protective Order. The parties acknowledge that 7 this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use 9 extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of 20 21 third parties), information otherwise generally unavailable to the public, or 22 which may be privileged or otherwise protected from disclosure under state or 23 federal statutes, court rules, case decisions, or common law. Accordingly, to 24 expedite the flow of information, to facilitate the prompt resolution of disputes 25 over confidentiality of discovery materials, to adequately protect information 26 the parties are entitled to keep confidential, to ensure that the parties are 27 permitted reasonable necessary uses of such material in preparation for and in 28 the conduct of trial, to address their handling at the end of the litigation, and 2 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 3 of 16 Page ID #:233

1 serve the ends of justice, a protective order for such information is justified in 2 this matter. It is the intent of the parties that information will not be designated 3 as confidential for tactical reasons and that nothing be so designated without a 4 good faith belief that it has been maintained in a confidential, non-public 5 manner, and there is good cause why it should not be part of the public record 6 of this case. 7 3. UNDER SEAL FILING PROCEDURE 8 The parties further acknowledge, as set forth in Section 14.3, below, that 9 this Stipulated Protective Order does not entitle them to file confidential 10 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 11 be followed and the standards that will be applied when a party seeks permission 12 from the court to file material under seal. There is a strong presumption that the 13 public has a right of access to judicial proceedings and records in civil cases. In 14 connection with non-dispositive motions, good cause must be shown to support 15 a filing under seal. See Kamakana v. City and County of Honolulu, 447 F.3d 16 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210- 17 11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 18 (E.D. Wis. 1999) (even stipulated protective orders require good cause 19 showing), and a specific showing of good cause or compelling reasons with 20 21 proper evidentiary support and legal justification, must be made with respect to 22 Protected Material that a party seeks to file under seal. The parties’ mere 23 designation of Disclosure or Discovery Material as CONFIDENTIAL does 24 not— without the submission of competent evidence by declaration, establishing 25 that the material sought to be filed under seal qualifies as confidential, 26 privileged, or otherwise protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, 28 then compelling reasons, not only good cause, for the sealing must be shown, 3 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 4 of 16 Page ID #:234

1 and the relief sought shall be narrowly tailored to serve the specific interest to be 2 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 3 2010). For each item or type of information, document, or thing sought to be 4 filed or introduced under seal, the party seeking protection must articulate 5 compelling reasons, supported by specific facts and legal justification, for the 6 requested sealing order. Again, competent evidence supporting the application 7 to file documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise 9 protectable in its entirety will not be filed under seal if the confidential portions 10 can be redacted. If documents can be redacted, then a redacted version for public 11 viewing, omitting only the confidential, privileged, or otherwise protectable 12 portions of the document, shall be filed. Any application that seeks to file 13 documents under seal in their entirety should include an explanation of why 14 redaction is not feasible. 15 4. DEFINITIONS 16 4.1 Action: Heba Ahmed v. Trans Union Rental Screening Solutions, Inc., et 17 al.; Case No. 8:22-cv-00366-CJC-JDE consolidated with Ahmed Ahmed v. Trans 18 19 Union Rental Screening Solutions, Inc., et al.; Case No. 8:22-cv-00367-CJC-JDE 20 4.2 Challenging Party: a Party or Non-Party that challenges the 21 designation of information or items under this Order. 22 4.3 “CONFIDENTIAL” Information or Items: information (regardless 23 of how it is generated, stored or maintained) or tangible things that qualify for 24 protection under Federal Rule of Civil Procedure 26(c), and as specified above 25 in the Good Cause Statement. 26 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 27 their support staff). 28 4 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 5 of 16 Page ID #:235

1 4.5 Designating Party: a Party or Non-Party that designates 2 information or items that it produces in disclosures or in responses to discovery 3 as “CONFIDENTIAL.” 4 4.6 Disclosure or Discovery Material: all items or information, 5 regardless of the medium or manner in which it is generated, stored, or 6 maintained (including, among other things, testimony, transcripts, and tangible 7 things), that are produced or generated in disclosures or responses to discovery. 8 4.7 Expert: a person with specialized knowledge or experience in a 9 matter pertinent to the litigation who has been retained by a Party or its counsel 10 to serve as an expert witness or as a consultant in this Action. 11 4.8 House Counsel: attorneys who are employees of a party to this 12 Action. House Counsel does not include Outside Counsel of Record or any 13 other outside counsel. 14 4.9 Non-Party: any natural person, partnership, corporation, 15 association or other legal entity not named as a Party to this action. 16 4.10 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm 19 that has appeared on behalf of that party, and includes support staff. 20 21 4.11 Party: any party to this Action, including all of its officers, directors, 22 employees, consultants, retained experts, and Outside Counsel of Record (and 23 their support staffs). 24 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 4.13 Professional Vendors: persons or entities that provide litigation 27 support services (e.g., photocopying, videotaping, translating, preparing exhibits 28 5 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 6 of 16 Page ID #:236

1 or demonstrations, and organizing, storing, or retrieving data in any form or 2 medium) and their employees and subcontractors. 3 4.14 Protected Material: any Disclosure or Discovery Material that is 4 designated as “CONFIDENTIAL.” 5 4.15 Receiving Party: a Party that receives Disclosure or Discovery 6 Material from a Producing Party. 7 5. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or 10 extracted from Protected Material; (2) all copies, excerpts, summaries, or 11 compilations of Protected Material; and (3) any testimony, conversations, or 12 presentations by Parties or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of 14 the trial judge and other applicable authorities. This Order does not govern the 15 use of Protected Material at trial. 16 6. DURATION 17 Once a case proceeds to trial, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this protective order used or 19 introduced as an exhibit at trial becomes public and will be presumptively 20 21 available to all members of the public, including the press, unless compelling 22 reasons supported by specific factual findings to proceed otherwise are made to 23 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 24 (distinguishing “good cause” showing for sealing documents produced in 25 discovery from “compelling reasons” standard when merits-related documents 26 are part of court record). Accordingly, the terms of this protective order do not 27 extend beyond the commencement of the trial. 28 6 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 7 of 16 Page ID #:237

1 7. DESIGNATING PROTECTED MATERIAL 2 7.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for 4 protection under this Order must take care to limit any such designation to 5 specific material that qualifies under the appropriate standards. The Designating 6 Party must designate for protection only those parts of material, documents, 7 items or oral or written communications that qualify so that other portions of 8 the material, documents, items or communications for which protection is not 9 warranted are not swept unjustifiably within the ambit of this Order. 10 Mass, indiscriminate or routinized designations are prohibited. 11 Designations that are shown to be clearly unjustified or that have been made for 12 13 an improper purpose (e.g., to unnecessarily encumber the case development 14 process or to impose unnecessary expenses and burdens on other parties) may 15 expose the Designating Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items 17 that it designated for protection do not qualify for protection, that Designating 18 Party must promptly notify all other Parties that it is withdrawing the 19 inapplicable designation. 20 7.2 Manner and Timing of Designations. Except as otherwise provided 21 in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery 22 Material that qualifies for protection under this Order must be clearly so 23 designated before the material is disclosed or produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 proceedings), that the Producing Party affix at a minimum, the legend 28 7 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 8 of 16 Page ID #:238

1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 2 that contains protected material. If only a portion of the material on a page 3 qualifies for protection, the Producing Party also must clearly identify the 4 protected portion(s) (e.g., by making appropriate markings in the margins). 5 A Party or Non-Party that makes original documents available for 6 inspection need not designate them for protection until after the inspecting Party 7 has indicated which documents it would like copied and produced. During the 8 inspection and before the designation, all of the material made available for 9 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 10 identified the documents it wants copied and produced, the Producing Party 11 must determine which documents, or portions thereof, qualify for protection 12 under this Order. Then, before producing the specified documents, the 13 Producing Party must affix the “CONFIDENTIAL legend” to each page that 14 contains Protected Material. If only a portion of the material on a page qualifies 15 for protection, the Producing Party also must clearly identify the protected 16 portion(s) (e.g., by making appropriate markings in the margins). 17 (b) for testimony given in depositions that the Designating Party 18 identifies the Disclosure or Discovery Material on the record, before the close of 19 the deposition all protected testimony. 20 21 (c) for information produced in some form other than documentary 22 and for any other tangible items, that the Producing Party affix in a prominent 23 place on the exterior of the container or containers in which the information is 24 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 25 information warrants protection, the Producing Party, to the extent practicable, 26 shall identify the protected portion(s). 27 7.3 Inadvertent Failures to Designate. If timely corrected, an 28 inadvertent failure to designate qualified information or items does not, standing 8 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 9 of 16 Page ID #:239

1 alone, waive the Designating Party’s right to secure protection under this Order 2 for such material. Upon timely correction of a designation, the Receiving Party 3 must make reasonable efforts to assure that the material is treated in accordance 4 with the provisions of this Order. 5 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 7 designation of confidentiality at any time that is consistent with the Court’s 8 Scheduling Order. 9 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 10 resolution process under Local Rule 37-1 et seq. 11 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 12 joint stipulation pursuant to Local Rule 37-2. 13 8.4 The burden of persuasion in any such challenge proceeding shall be 14 on the Designating Party. Frivolous challenges, and those made for an 15 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 16 on other parties) may expose the Challenging Party to sanctions. Unless the 17 Designating Party has waived or withdrawn the confidentiality designation, all 18 parties shall continue to afford the material in question the level of protection 19 to which it is entitled under the Producing Party’s designation until the Court 20 21 rules on the challenge. 22 9. ACCESS TO AND USE OF PROTECTED MATERIAL 23 9.1 Basic Principles. A Receiving Party may use Protected Material that 24 is disclosed or produced by another Party or by a Non-Party in connection 25 with this Action only for prosecuting, defending or attempting to settle this 26 Action. Such Protected Material may be disclosed only to the categories of 27 persons and under the conditions described in this Order. When the Action has 28 9 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 10 of 16 Page ID #:240

1 been terminated, a Receiving Party must comply with the provisions of section 2 15 below (FINAL DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party 4 at a location and in a secure manner that ensures that access is limited to the 5 persons authorized under this Order. 6 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating 8 Party, a Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this 11 Action, as well as employees of said Outside Counsel of Record to whom it is 12 reasonably necessary to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House 14 Counsel) of the Receiving Party to whom disclosure is reasonably necessary 15 for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to 17 whom disclosure is reasonably necessary for this Action and who have signed 18 the “Acknowledgment and Agreement to Comply” (Exhibit A); 19 (d) the court and its personnel; 20 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and 23 Professional Vendors to whom disclosure is reasonably necessary for this 24 Action and who have signed the “Acknowledgment and Agreement to 25 Comply” (Exhibit A); 26 (g) the author or recipient of a document containing the 27 information or a custodian or other person who otherwise possessed or knew 28 the information; 10 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 11 of 16 Page ID #:241

1 (h) during their depositions, witnesses, and attorneys for witnesses, 2 in the Action to whom disclosure is reasonably necessary provided: (1) the 3 deposing party requests that the witness sign the form attached as Exhibit A 4 hereto; and (2) they will not be permitted to keep any confidential information 5 unless they sign the “Acknowledgment and Agreement to Comply” (Exhibit 6 A), unless otherwise agreed by the Designating Party or ordered by the court. 7 Pages of transcribed deposition testimony or exhibits to depositions that reveal 8 Protected Material may be separately bound by the court reporter and may not 9 be disclosed to anyone except as permitted under this Stipulated Protective 10 Order; and 11 (i) any mediators or settlement officers and their supporting 12 personnel, mutually agreed upon by any of the parties engaged in settlement 13 discussions. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 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 (a) promptly notify in writing the Designating Party. Such 20 notification shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or 22 order to issue in the other litigation that some or all of the material covered by 23 the subpoena or order is subject to this Protective Order. Such notification shall 24 include a copy of this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 27 pursued by the Designating Party whose Protected Material may be affected. If 28 the Designating Party timely seeks a protective order, the Party served with the 11 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 12 of 16 Page ID #:242

1 subpoena or court order shall not produce any information designated in this 2 action as “CONFIDENTIAL” before a determination by the court from which 3 the subpoena or order issued, unless the Party has obtained the Designating 4 Party’s permission. The Designating Party shall bear the burden and expense of 5 seeking protection in that court of its confidential material and nothing in these 6 provisions should be construed as authorizing or encouraging a Receiving Party 7 in this Action to disobey a lawful directive from another court. 8 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 9 BE PRODUCED IN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced 11 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 12 information produced by Non-Parties in connection with this litigation is 13 protected by the remedies and relief provided by this Order. Nothing in these 14 provisions should be construed as prohibiting a Non-Party from seeking 15 additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, 17 to produce a Non-Party’s confidential information in its possession, and the 18 Party is subject to an agreement with the Non-Party not to produce the Non- 19 Party’s confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non- 21 Party that some or all of the information requested is subject to a confidentiality 22 agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), and a 25 reasonably specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 Non-Party, if requested. 28 12 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 13 of 16 Page ID #:243

1 (c) If the Non-Party fails to seek a protective order from this court 2 within 14 days of receiving the notice and accompanying information, the 3 Receiving Party may produce the Non-Party’s confidential information 4 responsive to the discovery request. If the Non-Party timely seeks a protective 5 order, the Receiving Party shall not produce any information in its possession 6 or control that is subject to the confidentiality agreement with the Non-Party 7 before a determination by the court. Absent a court order to the contrary, the 8 Non-Party shall bear the burden and expense of seeking protection in this court 9 of its Protected Material. 10 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 11 MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has 12 13 disclosed Protected Material to any person or in any circumstance not 14 authorized under this Stipulated Protective Order, the Receiving Party must 15 immediately (a) notify in writing the Designating Party of the unauthorized 16 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 17 Protected Material, (c) inform the person or persons to whom unauthorized 18 disclosures were made of all the terms of this Order, and (d) request such person 19 or persons to execute the “Acknowledgment and Agreement to Comply” 20 attached hereto as Exhibit A. 21 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 22 OTHERWISE PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other 25 protection, the obligations of the Receiving Parties are those set forth in Federal 26 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 27 whatever procedure may be established in an e-discovery order that provides for 28 production without prior privilege review. Pursuant to Federal Rule of Evidence 13 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page 14 of 16 Page ID #:244

1 502(d) and (e), insofar as the parties reach an agreement on the effect of 2 disclosure of a communication or information covered by the attorney-client 3 privilege or work product protection, the parties may incorporate their 4 agreement in the stipulated protective order submitted to the court. 5 14. MISCELLANEOUS 6 14.1 Right to Further Relief. Nothing in this Order abridges the right of 7 any person to seek its modification by the Court in the future. 8 14.2 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 11 in this Stipulated Protective Order. Similarly, no Party waives any right to object 12 on any ground to use in evidence of any of the material covered by this 13 Protective Order. 14 14.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Local Civil Rule 79-5. Protected Material 16 may only be filed under seal pursuant to a court order authorizing the sealing of 17 the specific Protected Material. If a Party’s request to file Protected Material 18 under seal is denied by the court, then the Receiving Party may file the 19 information in the public record unless otherwise instructed by the court. 20 21 15. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 6, within 23 60 days of a written request by the Designating Party, each Receiving Party must 24 return all Protected Material to the Producing Party or destroy such material. 25 As used in this subdivision, “all Protected Material” includes all copies, 26 abstracts, compilations, summaries, and any other format reproducing or 27 capturing any of the Protected Material. Whether the Protected Material is 28 returned or destroyed, the Receiving Party must submit a written certification to 14 Case 8:22-cv-00366-CJC-JDE Document 43 Filed 01/03/23 Page15o0f16 Page ID #:245

I ||the Producing Party (and, if not the same person or entity, to the Designating 2 || Party) by the 60-day deadline that (1) identifies (by category, where appropriate) 3 | all the Protected Material that was returned or destroyed and (2) affirms that the 4 || Receiving Party has not retained any copies, abstracts, compilations, summaries > any other format reproducing or capturing any of the Protected Material. 6 Notwithstanding this provision, Counsel are entitled to retain an archival copy ” |i of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 8 memoranda, correspondence, deposition and trial exhibits, expert reports, ° attorney work product, and consultant and expert work product, even if such 0 materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in Section 6 (DURATION). 4 16. VIOLATION

5 Any violation of this Order may be punished by appropriate measures 16 including, without limitation, contempt proceedings and/or monetary 17 || Sanctions. 18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 30 DATED: January 03, 2023 Hf te 21 tbr. 7 39 esr ND. EARLY : nited States Magistrate Judge 23 24 25 26 27 28 15

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1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO COMPLY 2 I, _____________________________ [print or type full name], of 3 _________________ [print or type full address], declare under penalty of perjury 4 that I have read in its entirety and understand the Stipulated Protective Order that 5 was issued by the United States District Court for the Central District of California 6 7 on December 30, 2022, in the case of Heba Ahmed v. Trans Union Rental Screening 8 Solutions, Inc., et al.; Case No. 8:22-cv-00366-CJC-JDE consolidated with Ahmed 9 Ahmed v. Trans Union Rental Screening Solutions, Inc., et al.; Case No. 8:22-cv- 10 00367-CJC-JDE. I agree to comply with all the terms of this Stipulated Protective 11 Order and I understand and acknowledge that failure to so comply could expose me 12 to sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. I further agree to submit to the jurisdiction of the United 16 States District Court for the Central District of California for enforcing the terms of 17 this Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print 19 or type full name] of _______________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28 16