Nicholas McArthur v. RELX INC. and LEXIS-NEXIS RISK SOLUTIONS FL INC.

• Court: District Court, C.D. California
• Decided: December 23, 2025
• Docket: 2:25-cv-06120
• Status: Unknown

Opinion

1 SEYFARTH SHAW LLP Ryan McCoy (SBN 276026) 2 rmccoy@seyfarth.com 3 Clara L. Rademacher (SBN 355494) crademacher@seyfarth.com 4 560 Mission Street, 31st Floor San Francisco, California 94105 5 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 6 7 Attorneys for Defendants RELX INC. and LEXIS-NEXIS RISK 8 SOLUTIONS FL INC. 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 NICHOLAS MCARTHUR, an individual, Case No. 2:25-cv-06120-SK 14 Plaintiff, STIPULATION AND PROPOSED PROTECTIVE ORDER 15 v. Date Action Filed: June 3, 2025 16 RELX INC., a Delaware Corporation, LEXIS-NEXIS RISK SOLUTIONS FL 17 INC., a Minnesota Corporation; and DOES 1 through 50, inclusive, 18 Defendants. 19 20 21 1. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, proprietary 23 or private information for which special protection from public disclosure and from use 24 for any purpose other than pursuing this litigation may be warranted. Accordingly, the 25 parties hereby stipulate to and petition the Court to enter the following Stipulated 26 Protective Order. The parties acknowledge that this Order does not confer blanket 27 protections on all disclosures or responses to discovery and that the protection it affords 28 1 from public disclosure and use extends only to the limited information or items that are 2 entitled to confidential treatment under the applicable legal principles. 3 2. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, customer and pricing lists and other 5 valuable research, development, commercial, financial, technical and/or proprietary 6 information for which special protection from public disclosure and from use for any 7 purpose other than prosecution of this action is warranted. Such confidential and 8 proprietary materials and information consist of, among other things, confidential 9 business or financial information, information regarding confidential business practices, 10 or other confidential research, development, or commercial information (including 11 information implicating privacy rights of third parties), information otherwise generally 12 unavailable to the public, or which may be privileged or otherwise protected from 13 disclosure under state or federal statutes, court rules, case decisions, or common law. 14 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 15 disputes over confidentiality of discovery materials, to adequately protect information the 16 parties are entitled to keep confidential, to ensure that the parties are permitted reasonable 17 necessary uses of such material in preparation for and in the conduct of trial, to address 18 their handling at the end of the litigation, and serve the ends of justice, a protective order 19 for such information is justified in this matter. It is the intent of the parties that 20 information will not be designated as confidential for tactical reasons and that nothing be 21 so designated without a good faith belief that it has been maintained in a confidential, 22 non-public manner, and there is good cause why it should not be part of the public record 23 of this case. 24 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 25 The parties further acknowledge, as set forth in Section 14.3, below, that this 26 Stipulated Protective Order does not entitle them to file confidential information under 27 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 28 standards that will be applied when a party seeks permission from the court to file 1 material under seal. There is a strong presumption that the public has a right of access to 2 judicial proceedings and records in civil cases. In connection with non-dispositive 3 motions, good cause must be shown to support a filing under seal. See Kamakana v. City 4 and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 5 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 6 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 7 cause showing), and a specific showing of good cause or compelling reasons with proper 8 evidentiary support and legal justification, must be made with respect to Protected 9 Material that a party seeks to file under seal. The parties’ mere designation of Disclosure 10 or Discovery Material as CONFIDENTIAL does not— without the submission of 11 competent evidence by declaration, establishing that the material sought to be filed under 12 seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 13 Further, if a party requests sealing related to a dispositive motion or trial, then 14 compelling reasons, not only good cause, for the sealing must be shown, and the relief 15 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 16 v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type 17 of information, document, or thing sought to be filed or introduced under seal, the party 18 seeking protection must articulate compelling reasons, supported by specific facts and 19 legal justification, for the requested sealing order. Again, competent evidence supporting 20 the application to file documents under seal must be provided by declaration. 21 Any document that is not confidential, privileged, or otherwise protectable in its 22 entirety will not be filed under seal if the confidential portions can be redacted. If 23 documents can be redacted, then a redacted version for public viewing, omitting only the 24 confidential, privileged, or otherwise protectable portions of the document, shall be filed. 25 Any application that seeks to file documents under seal in their entirety should include an 26 explanation of why redaction is not feasible. 27 28 1 4. DEFINITIONS 2 4.1 Action: Nicholas McArthur v. RELX INC., LEXIS-NEXIS RISK 3 SOLUTIONS, FL, United States District Court, Central District of California, Case No. 4 2:25-cv-06120-SK. 5 4.2 Challenging Party: a Party or Non-Party that challenges the designation of 6 information or items under this Order. 7 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 8 is generated, stored or maintained) or tangible things that qualify for protection under 9 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 10 Statement. 11 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 12 support staff). 13 4.5 Designating Party: a Party or Non-Party that designates information or items 14 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 15 4.6 Disclosure or Discovery Material: all items or information, regardless of the 16 medium or manner in which it is generated, stored, or maintained (including, among 17 other things, testimony, transcripts, and tangible things), that are produced or generated in 18 disclosures or responses to discovery. 19 4.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 21 expert witness or as a consultant in this Action. 22 4.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside counsel. 24 4.9 Non-Party: any natural person, partnership, corporation, association or other 25 legal entity not named as a Party to this action. 26 4.10 Outside Counsel of Record: attorneys who are not employees of a party to 27 this Action but are retained to represent a party to this Action and have appeared in this 28 1 Action on behalf of that party or are affiliated with a law firm that has appeared on behalf 2 of that party, and includes support staff. 3 4.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 4.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 11 their employees and subcontractors. 12 4.14 Protected Material: any Disclosure or Discovery Material that is designated 13 as “CONFIDENTIAL.” 14 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 15 a Producing Party. 16 5. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected 18 Material (as defined above), but also (1) any information copied or extracted from 19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 20 Material; and (3) any testimony, conversations, or presentations by Parties or their 21 Counsel that might reveal Protected Material. 22 Any use of Protected Material at trial shall be governed by the orders of the trial 23 judge and other applicable authorities. This Order does not govern the use of Protected 24 Material at trial. 25 6. DURATION 26 Once a case proceeds to trial, information that was designated as 27 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 28 an exhibit at trial becomes public and will be presumptively available to all members of 1 the public, including the press, unless compelling reasons supported by specific factual 2 findings to proceed otherwise are made to the trial judge in advance of the trial. See 3 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 4 documents produced in discovery from “compelling reasons” standard when merits- 5 related documents are part of court record). Accordingly, the terms of this protective 6 order do not extend beyond the commencement of the trial. 7 7. DESIGNATING PROTECTED MATERIAL 8 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 9 Party or Non-Party that designates information or items for protection under this Order 10 must take care to limit any such designation to specific material that qualifies under the 11 appropriate standards. The Designating Party must designate for protection only those 12 parts of material, documents, items or oral or written communications that qualify so that 13 other portions of the material, documents, items or communications for which protection 14 is not warranted are not swept unjustifiably within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations that 16 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 17 to unnecessarily encumber the case development process or to impose unnecessary 18 expenses and burdens on other parties) may expose the Designating 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 7.2 Manner and Timing of Designations. Except as otherwise provided in this 23 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that 24 qualifies for protection under this Order must be clearly so designated before the material 25 is disclosed or produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 1 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 2 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 3 portion of the material on a page qualifies for protection, the Producing Party also must 4 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 5 margins). In the case of electronically stored information produced in native format, by 6 including “CONFIDENTIAL” in the file or directory name, or by affixing the 7 CONFIDENTIAL legend or to the media containing the Discovery Material (e.g., 8 CDROM, floppy disk, DVD, thumb drive). 9 A Party or Non-Party that makes original documents available for inspection need 10 not designate them for protection until after the inspecting Party has indicated which 11 documents it would like copied and produced. During the inspection and before the 12 designation, all of the material made available for inspection shall be deemed 13 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 14 copied and produced, the Producing Party must determine which documents, or portions 15 thereof, qualify for protection under this Order. Then, before producing the specified 16 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 17 that contains Protected Material. If only a portion of the material on a page qualifies for 18 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 19 by making appropriate markings in the margins). 20 (b) for testimony given in depositions or other pretrial proceedings: (1) 21 by a statement on the record, by counsel, at the time of such disclosure or before the close 22 of the deposition all protected testimony; or (ii) by written notice, sent to all Parties 23 within 30 days of receipt of the transcript of the deposition or other pretrial testimony; 24 provided that only those portions of the transcript designated as Protected Material shall 25 be deemed Protected Material. The Parties may modify this procedure for any particular 26 deposition or other pretrial testimony, through agreement on the record at such deposition 27 or testimony, without further order of the Court. 28 1 (c) for information produced in some form other than documentary and 2 for any other tangible items, that the Producing Party affix in a prominent place on the 3 exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 5 the Producing Party, to the extent practicable, shall identify the protected portion(s). 6 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 7 to designate qualified information or items does not, standing alone, waive the 8 Designating Party’s right to secure protection under this Order for such material. Upon 9 timely correction of a designation, the Receiving Party must make reasonable efforts to 10 assure that the material is treated in accordance with the provisions of this Order. 11 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation 13 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 14 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 15 process under Local Rule 37-1 et seq. 16 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint 17 stipulation pursuant to Local Rule 37-2. 18 8.4 The burden of persuasion in any such challenge proceeding shall be on the 19 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to 20 harass or impose unnecessary expenses and burdens on other parties) may expose the 21 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 22 the confidentiality designation, all parties shall continue to afford the material in question 23 the level of protection to which it is entitled under the Producing Party’s designation until 24 the Court rules on the challenge. 25 9. ACCESS TO AND USE OF PROTECTED MATERIAL 26 9.1 Basic Principles. A Receiving Party may use Protected Material that is 27 disclosed or produced by another Party or by a Non-Party in connection with this Action 28 only for prosecuting, defending or attempting to settle this Action. Such Protected 1 Material may be disclosed only to the categories of persons and under the conditions 2 described in this Order. When the Action has been terminated, a Receiving Party must 3 comply with the provisions of section 15 below (FINAL DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 10 only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 12 well as employees of said Outside Counsel of Record to whom it is reasonably necessary 13 to disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of 15 the Receiving Party to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 23 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided that the witness sign the 28 form attached as Exhibit A hereto, unless otherwise agreed by the Designating Party or 1 ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions 2 that reveal Protected Material may be separately bound by the court reporter and may not 3 be disclosed to anyone except as permitted under this Stipulated Protective Order; and 4 (i) any mediators or settlement officers and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement discussions and who 6 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 7 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 8 IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation that 10 compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification 13 shall include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or order 15 to issue in the other litigation that some or all of the material covered by the subpoena or 16 order is subject to this Protective Order. Such notification shall include a copy of this 17 Stipulated Protective Order; and 18 (c) cooperate with respect to all reasonable procedures sought to be 19 pursued by the Designating Party whose Protected Material may be affected. If the 20 Designating Party timely seeks a protective order, the Party served with the subpoena or 21 court order shall not produce any information designated in this action as 22 “CONFIDENTIAL” before a determination by the court from which the subpoena or 23 order issued, unless the Party has obtained the Designating Party’s permission. The 24 Designating Party shall bear the burden and expense of seeking protection in that court of 25 its confidential material and nothing in these provisions should be construed as 26 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 27 from another court. 28 1 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a 4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the remedies 6 and relief provided by this Order. Nothing in these provisions should be construed as 7 prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is subject 10 to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 (3) make the information requested available for inspection by the Non- 19 Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 21 14 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery request. If 23 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 24 information in its possession or control that is subject to the confidentiality agreement 25 with the Non-Party before a determination by the court. Absent a court order to the 26 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 27 court of its Protected Material. 28 1 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 8 such person or persons to execute the “Acknowledgment an Agreement to Be Bound” 9 attached hereto as Exhibit A. 10 13. PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 11 MATERIAL 12 The production or disclosure of communications, documents, or information 13 protected by the attorney-client privilege, work product doctrine, or any other privilege 14 (“Privileged Material”), whether inadvertent or otherwise, is not a waiver of any privilege 15 or other protection from discovery in this case or in any other federal or state proceeding. 16 Regardless of the steps taken to prevent disclosure, if a Party produces information that it 17 discovers, or in good faith later asserts, to be privileged or otherwise protected from 18 disclosure, the production of that information will not constitute a waiver of any 19 applicable privileges or other protection, and the Receiving Party may not argue that the 20 Producing Party failed to take reasonable steps to prevent production of the privileged or 21 protected materials. 22 When a producing party gives notice to receiving parties that certain produced 23 material is subject to a claim of privilege or other protection, the obligations of the 24 receiving parties include those set forth in Federal Rule of Civil Procedure 26(b)(5)(B), 25 and encompass all later created excerpts, summaries, compilations, and other documents 26 or records that include, communicate or reveal the information claimed to be privileged 27 or protected. 28 1 The receiving party may object to the producing party’s designation of disclosed 2 information as Privileged Material by providing written notice of such objection within 3 seven days of its receipt of a written demand for the return of the disclosed Privileged 4 Material. The Parties must meet and confer in good faith in an attempt to resolve any 5 dispute regarding the designation of information as Privileged Material. If the Parties are 6 unable to resolve any such dispute, the issue shall be resolved by the Court after an in 7 camera review of the disclosed Privileged Material. Pending resolution of any such 8 dispute by the Court, the receiving party shall not review and shall not use the disclosed 9 Privileged Material in any respect. This Order shall be interpreted to provide the 10 maximum protection allowed by law. 11 14. MISCELLANEOUS 12 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 13 person to seek its modification by the Court in the future. 14 14.2 Right to Assert Other Objections. By stipulating to the entry of this 15 Protective Order, no Party waives any right it otherwise would have to object to 16 disclosing or producing any information or item on any ground not addressed in this 17 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 18 to use in evidence of any of the material covered by this Protective Order. 19 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected 20 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 21 under seal pursuant to a court order authorizing the sealing of the specific Protected 22 Material. If a Party’s request to file Protected Material under seal is denied by the court, 23 then the Receiving Party may file the information in the public record unless otherwise 24 instructed by the court. 25 14.4 Effective Upon Execution of the Parties. The Parties agree to be bound by 26 the terms of this Stipulation pending the entry by the Court of this Stipulation, and any 27 violation of its terms shall be subject to the same sanctions and penalties as if this 28 Stipulation had been entered by the Court. 1 14.5 Deadlines. Any deadlines herein may be extended by written agreement of 2 ||the parties without further Court approval. 3 15. FINAL DISPOSITION 4 After the final disposition of this Action, as defined in paragraph 6, within 60 days 5 a written request by the Designating Party, each Receiving Party must return all 6 ||Protected Material to the Producing Party or destroy such material. As used in this 7 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 8 ||summaries, and any other format reproducing or capturing any of the Protected Material. 9 || Whether the Protected Material is returned or destroyed, the Receiving Party must submit 10 written certification to the Producing Party (and, if not the same person or entity, to the 11 || Designating Party) by the 60-day deadline that (1) identifies (by category, where 12 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 13 Receiving Party has not retained any copies, abstracts, compilations, summaries or 14 other format reproducing or capturing any of the Protected Material. Notwithstanding 15. provision, Counsel are entitled to retain an archival copy of all pleadings, motion 16 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 17 deposition and trial exhibits, expert reports, attorney work product, and consultant and 18 ||expert work product, even if such materials contain Protected Material. Any such archival 19 copies that contain or constitute Protected Material remain subject to this Protective 20 || Order as set forth in Section 6 (DURATION). 21 16. VIOLATION 22 Any violation of this Order may be punished by appropriate measures including, 23 || without limitation, contempt proceedings and/or monetary sanctions. 24 |/ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

(Tl Kates 26 ||DATED: 12/23/2025 FF = Attorneys for Plaintiff

28 14

1 ||DATED: _December 23, 2025 /s/ Ryan McCo 5 Attorneys for Defendant

3 4 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

: DATED:_December 23, 2025 _

8 STEVEKIM 9 United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that I 5 have read in its entirety and understand the Stipulated Protective Order that was issued by 6 the United States District Court for the Central District of California on __________ in 7 the case of Nicholas McArthur v. RELX Inc., et al., Case No. 2:25-cv-06120-SK. I agree 8 to comply with and to be bound by all the terms of this Stipulated Protective Order and I 9 understand and acknowledge that failure to so comply could expose me to sanctions and 10 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 11 manner any information or item that is subject to this Stipulated Protective Order to any 12 person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District 14 Court for the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this action or 20 any proceedings related to enforcement of this Stipulated Protective Order. 21 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________ 28