Jesson Calloway v. Richman Property Services, Inc.

• Court: District Court, C.D. California
• Decided: September 24, 2024
• Docket: 2:24-cv-04232
• Status: Unknown

Opinion

2 UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA 4

5 JESSON CALLOWAY, Case No. 2:24-cv-04232-ODW- 6 JOSEPH GARCIA, SSC ANTOINETTE SPOLIANSKY, 7 ERIC LATTIMORE, SPENCER Hon. Stephanie S. Christensen 8 PASKACH, SAMBIDHAN

KHANIYA, and UPASANA 9 STIPULATED PROTECTIVE PANDEY, ORDER1 10 Plaintiff(s), 11 v. DISCOVERY MATTER 12 RICHMAN PROPERTY 13 SERVICES, INC. and DOES 1 14 through 10, 15 Defendant(s).

17 18 19 20 21 22 23 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action may 3 involve production of confidential, proprietary, or private information for 4 which special protection from public disclosure and from use for any 5 purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the court to 7 enter the following Stipulated Protective Order. The parties 8 acknowledge that this Order does not confer blanket protections on all 9 disclosures or responses to discovery and that the protection it affords 10 from public disclosure and use extends only to the limited information or 11 items that are entitled to confidential treatment under the applicable 12 legal principles. 13 1.2 Good Cause Statement. 14 This action is likely to involve trade secrets, customer and pricing 15 lists and other valuable research, development, commercial, financial, 16 technical and proprietary information for which special protection from 17 public disclosure and from use for any purpose other than prosecution of 18 this action is warranted. Such confidential and proprietary materials 19 and information consist of, among other things, confidential business or 20 financial information, information regarding confidential business 21 22 practices, or other confidential research, development, or commercial 23 information (including information implicating privacy rights of third 24 parties), information otherwise generally unavailable to the public, or 25 which may be privileged or otherwise protected from disclosure under 26 state or federal statutes, court rules, case decisions, or common law. 27 Accordingly, to expedite the flow of information, to facilitate the prompt 1 adequately protect information the parties are entitled to keep 2 confidential, to ensure that the parties are permitted reasonable 3 necessary uses of such material in preparation for and in the conduct of 4 trial, to address their handling at the end of the litigation, and serve the 5 ends of justice, a protective order for such information is justified in this 6 matter. It is the intent of the parties that information will not be 7 designated as confidential for tactical reasons and that nothing be so 8 designated without a good faith belief that it has been maintained in a 9 confidential, non-public manner, and there is good cause why it should 10 not be part of the public record of this case. 11 1.3 Acknowledgment of Procedure for Filing Under Seal. The 12 parties further acknowledge, as set forth in Section 12.3, below, that this 13 Stipulated Protective Order does not entitle them to file confidential 14 information under seal; Local Rule 79-5 sets forth the procedures that 15 must be followed and the standards that will be applied when a party 16 seeks permission from the court to file material under seal. 17 There is a strong presumption that the public has a right of access 18 to judicial proceedings and records in civil cases. In connection with 19 non-dispositive motions, good cause must be shown to support a filing 20 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 21 22 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 23 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 24 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 25 protective orders require good cause showing), and a specific showing of 26 good cause or compelling reasons with proper evidentiary support and 27 legal justification, must be made with respect to Protected Material that 1 Disclosure or Discovery Material as CONFIDENTIAL does not— 2 without the submission of competent evidence by declaration, 3 establishing that the material sought to be filed under seal qualifies as 4 confidential, privileged, or otherwise protectable—constitute good cause. 5 Further, if a party requests sealing related to a dispositive motion 6 or trial, then compelling reasons, not only good cause, for the sealing 7 must be shown, and the relief sought shall be narrowly tailored to serve 8 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 9 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 10 information, document, or thing sought to be filed or introduced under 11 seal in connection with a dispositive motion or trial, the party seeking 12 protection must articulate compelling reasons, supported by specific 13 facts and legal justification, for the requested sealing order. Again, 14 competent evidence supporting the application to file documents under 15 seal must be provided by declaration. 16 Any document that is not confidential, privileged, or otherwise 17 protectable in its entirety will not be filed under seal if the confidential 18 portions can be redacted. If documents can be redacted, then a redacted 19 version for public viewing, omitting only the confidential, privileged, or 20 otherwise protectable portions of the document, shall be filed. Any 21 22 application that seeks to file documents under seal in their entirety 23 should include an explanation of why redaction is not feasible. 24 2. DEFINITIONS 25 2.1 Action: Calloway et al. v. Richman Property Services, Inc., 26 C.D. Cal. Case No. 2:24-cv-04232-ODW-SSC and Completo et al. v. 27 Richman Property Services, Inc., C.D. Cal. Case No. 2:24-cv-04233-ODW- 1 SSC. The parties further agree that this Stipulated Protective Order will 2 also apply to additional cases that Plaintiffs’ counsel has or will file 3 against Defendant relating to ICRAA. 4 2.2 Challenging Party: a Party or Non-Party that challenges the 5 designation of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information 7 (regardless of how it is generated, stored or maintained) or tangible 8 things that qualify for protection under Rule 26(c) of the Federal Rules of 9 Civil Procedure, and as specified above in the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and House Counsel (as 11 well as their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates 13 information or items that it produces in disclosures or in responses to 14 discovery as “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, 16 regardless of the medium or manner in which it is generated, stored, or 17 maintained (including, among other things, testimony, transcripts, and 18 tangible things), that are produced or generated in disclosures or 19 responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in 21 22 a matter pertinent to the litigation who has been retained by a Party or 23 its counsel to serve as an expert witness or as a consultant in this Action. 24 2.8 Final Disposition: the later of (1) dismissal of all claims and 25 defenses in this Action, with or without prejudice; and (2) final judgment 26 herein after the completion and exhaustion of all appeals, rehearings, 27 remands, trials, or reviews of this Action, including the time limits for 1 applicable law. 2 2.9 In-House Counsel: attorneys who are employees of a party to 3 this Action. In-House Counsel does not include Outside Counsel of 4 Record or any other outside counsel. 5 2.10 Non-Party: any natural person, partnership, corporation, 6 association, or other legal entity not named as a Party to this action. 7 2.11 Outside Counsel of Record: attorneys who are not employees 8 of a party to this Action but are retained to represent or advise a party to 9 this Action and have appeared in this Action on behalf of that party or 10 are affiliated with a law firm which has appeared on behalf of that party, 11 and includes support staff. 12 2.12 Party: any party to this Action, including all of its officers, 13 directors, employees, consultants, retained experts, and Outside Counsel 14 of Record (and their support staffs). 15 2.13 Producing Party: a Party or Non-Party that produces 16 Disclosure or Discovery Material in this Action. 17 2.14 Professional Vendors: persons or entities that provide 18 litigation- support services (e.g., photocopying, videotaping, translating, 19 preparing exhibits or demonstrations, and organizing, storing, or 20 retrieving data in any form or medium) and their employees and 21 22 subcontractors. 23 2.15 Protected Material: any Disclosure or Discovery Material that 24 is designated as “CONFIDENTIAL.” 25 2.16 Receiving Party: a Party that receives Disclosure or Discovery 26 Material from a Producing Party. 27 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not 3 only Protected Material (as defined above), but also (1) any information 4 copied or extracted from Protected Material; (2) all copies, excerpts, 5 summaries, or compilations of Protected Material; and (3) any 6 testimony, conversations, or presentations by Parties or their Counsel 7 that might reveal Protected Material. 8 Any use of Protected Material at trial shall be governed by the 9 orders of the trial judge. This Stipulated Protective Order does not 10 govern the use of Protected Material at trial. 11 3.1 Tenant’s File Exclusion: For the purposes of this Stipulated 12 Protective Order, Plaintiffs represent that all documents contained in 13 each individual Plaintiff Tenant’s file, including the entirety of their 14 rental application, their lease agreement, and any Investigative 15 Consumer Report prepared about each Plaintiff, do not contain 16 CONFIDENTIAL information relating to Plaintiffs. Defendant has 17 expressed concerns that such information may, among other reasons, 18 implicate the privacy rights of parties and third parties, and should be 19 designated as CONFIDENTIAL, but will produce such information 20 without designation pursuant to this representation by Plaintiffs. 21 22 Notwithstanding this section, the Parties agree that all public filings will 23 comply with Federal Rule of Civil Procedure 5.2. 24 4. TRIAL AND DURATION 25 The terms of this Stipulated Protective Order apply through Final 26 Disposition of the Action. 27 Once a case proceeds to trial, information that was designated as 1 Order and used or introduced as an exhibit at trial becomes public and 2 will be presumptively available to all members of the public, including 3 the press, unless compelling reasons supported by specific factual 4 findings to proceed otherwise are made to the trial judge in advance of 5 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 6 cause” showing for sealing documents produced in discovery from 7 “compelling reasons” standard when merits-related documents are part 8 of court record). Accordingly, for such materials, the terms of this 9 Stipulated Protective Order do not extend beyond the commencement of 10 the trial. 11 Even after Final Disposition of this litigation, the confidentiality 12 obligations imposed by this Stipulated Protective Order shall remain in 13 effect until a Designating Party agrees otherwise in writing or a court 14 order otherwise directs. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for 17 Protection. Each Party or Non-Party that designates information or 18 items for protection under this Order must take care to limit any such 19 designation to specific material that qualifies under the appropriate 20 standards. The Designating Party must designate for protection only 21 22 those parts of material, documents, items, or oral or written 23 communications that qualify so that other portions of the material, 24 documents, items, or communications for which protection is not 25 warranted are not swept unjustifiably within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. 27 Designations that are shown to be clearly unjustified or that have been 1 development process or to impose unnecessary expenses and burdens on 2 other parties) may expose the Designating Party to sanctions. 3 If it comes to a Designating Party’s attention that information or 4 items that it designated for protection do not qualify for protection, that 5 Designating Party must promptly notify all other Parties that it is 6 withdrawing the inapplicable designation. 7 5.2 Manner and Timing of Designations. Except as otherwise 8 provided in this Stipulated Protective Order (see, e.g., second paragraph 9 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 10 or Discovery Material that qualifies for protection under this Stipulated 11 Protective Order must be clearly so designated before the material is 12 disclosed or produced. 13 Designation in conformity with this Stipulated Protective Order 14 requires: 15 (a) for information in documentary form (e.g., paper or electronic 16 documents, but excluding transcripts of depositions or other pretrial or 17 trial proceedings), that the Producing Party affix at a minimum, the 18 legend “CONFIDENTIAL” to each page that contains protected 19 material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify 21 22 the protected portion(s) (e.g., by making appropriate markings in the 23 margins). 24 A Party or Non-Party that makes original documents available for 25 inspection need not designate them for protection until after the 26 inspecting Party has indicated which documents it would like copied 27 and produced. During the inspection and before the designation, all of 1 CONFIDENTIAL. After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must 3 determine which documents, or portions thereof, qualify for protection 4 under this Stipulated Protective Order. Then, before producing the 5 specified documents, the Producing Party must affix the 6 “CONFIDENTIAL” legend to each page that contains Protected 7 Material. If only a portion or portions of the material on a page 8 qualifies for protection, the Producing Party also must clearly identify 9 the protected portion(s) (e.g., by making appropriate markings in the 10 margins). 11 (b) for testimony given in depositions that the Designating Party 12 identify the Disclosure or Discovery Material on the record, before the 13 close of the deposition all protected testimony. 14 (c) for information produced in some form other than 15 documentary and for any other tangible items, that the Producing Party 16 affix in a prominent place on the exterior of the container or containers 17 in which the information is stored the “CONFIDENTIAL” legend. If only 18 a portion or portions of the information warrants protection, the 19 Producing Party, to the extent practicable, shall identify the protected 20 portion(s). 21 22 5.3 Inadvertent Failures to Designate. If timely corrected, an 23 inadvertent failure to designate qualified information or items does not, 24 standing alone, waive the Designating Party’s right to secure protection 25 under this Order for such material. Upon timely correction of a 26 designation, the Receiving Party must make reasonable efforts to assure 27 that the material is treated in accordance with the provisions of this 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may 3 challenge a designation of confidentiality at any time that is consistent 4 with the court’s Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the 6 dispute resolution process under Local Rule 37.1 et seq. and with 7 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 8 Discovery Motion Conference.”2 9 6.3 The burden of persuasion in any such challenge proceeding 10 shall be on the Designating Party. Frivolous challenges, and those 11 made for an improper purpose (e.g., to harass or impose unnecessary 12 expenses and burdens on other parties) may expose the Challenging 13 Party to sanctions. Unless the Designating Party has waived or 14 withdrawn the confidentiality designation, all parties shall continue to 15 afford the material in question the level of protection to which it is 16 entitled under the Producing Party’s designation until the court rules on 17 the challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected 20 Material that is disclosed or produced by another Party or by a Non- 21 22 Party in connection with this Action only for prosecuting, defending, or 23 attempting to settle this Action. Such Protected Material may be 24 disclosed only to the categories of persons and under the conditions 25 described in this Order. When the Action reaches a Final Disposition, a 26

27 2 Judge Christensen’s Procedures are available at 1 Receiving Party must comply with the provisions of section 13 below. 2 Protected Material must be stored and maintained by a Receiving 3 Party at a location and in a secure manner that ensures that access is 4 limited to the persons authorized under this Stipulated Protective 5 Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 7 Unless otherwise ordered by the court or permitted in writing by the 8 Designating Party, a Receiving Party may disclose any information or 9 item designated “CONFIDENTIAL” only: 10 (a) to the Receiving Party’s Outside Counsel of Record in this 11 Action, as well as employees of said Outside Counsel of Record to whom 12 it is reasonably necessary to disclose the information for this Action; 13 (b) to the officers, directors, and employees (including House 14 Counsel) of the Receiving Party to whom disclosure is reasonably 15 necessary for this Action; 16 (c) to Experts (as defined in this Order) of the Receiving Party to 17 whom disclosure is reasonably necessary for this Action and who have 18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) to the court and its personnel; 20 (e) to court reporters and their staff; 21 22 (f) to professional jury or trial consultants, mock jurors, and 23 Professional Vendors to whom disclosure is reasonably necessary for 24 this Action and who have signed the “Acknowledgment and Agreement 25 to Be Bound” (Exhibit A); 26 (g) to the author or recipient of a document containing the 27 information or a custodian or other person who otherwise possessed or 1 (h) during their depositions, to witnesses, and attorneys for 2 witnesses, in the Action to whom disclosure is reasonably necessary, 3 provided: (1) the deposing party requests that the witness sign the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 5 witness will not be permitted to keep any confidential information 6 unless they sign the “Acknowledgment and Agreement to Be Bound” 7 (Exhibit A), unless otherwise agreed by the Designating Party or 8 ordered by the court. Pages of transcribed deposition testimony or 9 exhibits to depositions that reveal Protected Material may be separately 10 bound by the court reporter and may not be disclosed to anyone except 11 as permitted under this Stipulated Protective Order; and 12 (i) to any mediator or settlement officer, and their supporting 13 personnel, mutually agreed upon by any of the parties engaged in 14 settlement discussions. 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 16 PRODUCED IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in 18 other litigation that compels disclosure of any information or items 19 designated in this Action as “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such 21 22 notification shall include a copy of the subpoena or court order; 23 (b) promptly notify in writing the party who caused the 24 subpoena or order to issue in the other litigation that some or all of the 25 material covered by the subpoena or order is subject to this Protective 26 Order. Such notification shall include a copy of this Stipulated 27 Protective Order; and 1 be pursued by the Designating Party whose Protected Material may be 2 affected. 3 If the Designating Party timely seeks a protective order, the 4 Party served with the subpoena or court order shall not produce any 5 information designated in this action as “CONFIDENTIAL” before a 6 determination by the court from which the subpoena or order issued, 7 unless the Party has obtained the Designating Party’s permission. The 8 Designating Party shall bear the burden and expense of seeking 9 protection in that court of its confidential material and nothing in these 10 provisions should be construed as authorizing or encouraging a 11 Receiving Party in this Action to disobey a lawful directive from another 12 court. 13 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 14 PRODUCED IN THIS LITIGATION 15 9.1 Application. The terms of this Stipulated Protective Order 16 are applicable to information produced by a Non-Party in this Action and 17 designated as “CONFIDENTIAL.” Such information produced by Non- 18 Parties in connection with this litigation is protected by the remedies 19 and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional 21 22 protections. 23 9.2 Notification. In the event that a Party is required, by a valid 24 discovery request, to produce a Non-Party’s confidential information in 25 its possession, and the Party is subject to an agreement with the Non- 26 Party not to produce the Non-Party’s confidential information, then the 27 Party shall: 1 Non-Party that some or all of the information requested is subject to a 2 confidentiality agreement with a Non-Party; 3 (b) make the information requested available for inspection by 4 the Non-Party, if requested. 5 9.3 Conditions of Production. If the Non-Party fails to seek a 6 protective order from this court within 14 days of receiving the notice 7 and accompanying information, the Receiving Party may produce the 8 Non-Party’s confidential information responsive to the discovery request. 9 If the Non-Party timely seeks a protective order, the Receiving Party 10 shall not produce any information in its possession or control that is 11 subject to the confidentiality agreement with the Non-Party before a 12 determination by the court. Absent a court order to the contrary, the 13 Non-Party shall bear the burden and expense of seeking protection in 14 this court of its Protected Material. 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 16 MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it 18 has disclosed Protected Material to any person or in any circumstance 19 not authorized under this Stipulated Protective Order, the Receiving 20 Party must immediately (a) notify in writing the Designating Party of 21 22 the unauthorized disclosures, (b) use its best efforts to retrieve all 23 unauthorized copies of the Protected Material, (c) inform the person or 24 persons to whom unauthorized disclosures were made of all the terms of 25 this Order, and (d) request such person or persons to execute the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 27 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 2 OTHERWISE PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that 4 certain inadvertently produced material is subject to a claim of privilege 5 or other protection, the obligations of the Receiving Parties are those set 6 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 7 provision is not intended to modify whatever procedure may be 8 established in an e-discovery order that provides for production without 9 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 10 Rules of Evidence, insofar as the parties reach an agreement on the 11 effect of disclosure of a communication or information covered by the 12 attorney-client privilege or work product protection, the parties may 13 incorporate their agreement in the stipulated protective order 14 submitted to the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Stipulated 17 Protective Order abridges the right of any person to seek its 18 modification by the court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry 20 of this Stipulated Protective Order no Party waives any right it 21 22 otherwise would have to object to disclosing or producing any 23 information or item on any ground not addressed in this Stipulated 24 Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this 26 Stipulated Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under 1 Protected Material may only be filed under seal pursuant to a court 2 order authorizing the sealing of the specific Protected Material at issue. 3 If a Party's request to file Protected Material under seal is denied by the 4 court, then the Receiving Party may file the information in the public 5 record unless otherwise instructed by the court. 6 13. FINAL DISPOSITION 7 After the Final Disposition of this Action, as defined in paragraph 8 4, within 60 days of a written request by the Designating Party, each 9 Receiving Party must return all Protected Material to the Producing 10 Party or destroy such material. As used in this subdivision, “all 11 Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the 13 Protected Material. Whether the Protected Material is returned or 14 destroyed, the Receiving Party must submit a written certification to 15 the Producing Party (and, if not the same person or entity, to the 16 Designating Party) by the 60 day deadline that (1) identifies (by 17 category, where appropriate) all the Protected Material that was 18 returned or destroyed and (2) affirms that the Receiving Party has not 19 retained any copies, abstracts, compilations, summaries or any other 20 format reproducing or capturing any of the Protected Material. 21 22 Notwithstanding this provision, Counsel is entitled to retain an archival 23 copy of all pleadings, motion papers, trial, deposition, and hearing 24 transcripts, legal memoranda, correspondence, deposition and trial 25 exhibits, expert reports, attorney work product, and consultant and 26 expert work product, even if such materials contain Protected Material. 27 Any such archival copies that contain or constitute Protected Material 1 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 by any and all appropriate measures including, without limitation, 4 contempt proceedings and/or monetary sanctions. 5 6 7 8

21 22 23 24 25 26 27 1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 DATED: September 23, LITIGATION ADVOCACY GROUP 4 2024 /s/ Glenn A. Murphy 5 Glenn A. Murphy 6 Attorneys for Plaintiffs 7 DATED: September 23, BROD LAW FIRM, P.C. 8 2024 ? /s/ Gregory J. Brod 10 Gregory J. Brod 11 Attorneys for Plaintiffs 12 DATED: September 23, MANATT, PHELPS & PHILLIPS, LLP 13 2024 14 By: _/s/ Benjamin E. Strauss Is Robert H. Platt 16 Benjamin E. Strauss Attorneys for Defendant RICHMAN PROPERTY SERVICES, 18 INC. 19 SIGNATURE ATTESTATION 20 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Benjamin E. Strauss, attest 21 that all other signatories listed, and on whose behalf this filing is 22 submitted, concur in the filing’s content and have authorized the filing. 23 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 29 DATED: September 24, 2024 LZ ~ STEPHANIE 8S. CHRISTENSEN 27 United States Magistrate Judge 28

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 5 penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the 8 cases of Calloway et al. v. Richman Property Services, Inc., Case No. 9 2:24-cv-04232-ODW-SSC and Completo et al. v. Richman Property 10 Services, Inc., Case No. 2:24-cv-04233-ODW-SSC. I agree to comply 11 with and to be bound by all the terms of this Stipulated Protective 12 Order and I understand and acknowledge that failure to so comply 13 14 could expose me to sanctions and punishment in the nature of 15 contempt. I solemnly promise that I will not disclose in any manner 16 any information or item that is subject to this Stipulated Protective 17 Order to any person or entity except in strict compliance with the 18 provisions of this Order. 19 I further agree to submit to the jurisdiction of the United States 20 District Court for the Central District of California for the purpose of 21 enforcing the terms of this Stipulated Protective Order, even if such 22 enforcement proceedings occur after termination of this action. I 23 hereby appoint ________________________ [print or type full name] 24 of _________ [print or type full address and telephone number] as 25 26 27 1 my California agent for service of process in connection with this action 2 or any proceedings related to enforcement of this Stipulated Protective 3 Order. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10

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