TAYLOR HANEY v. SERVICE FINANCE COMPANY, LLC

• Court: District Court, C.D. California
• Decided: October 24, 2025
• Docket: 5:25-cv-01338
• Status: Unknown

Opinion

1 KEMNITZER, BARRON & KRIEG, LLP KRISTIN KEMNITZER Bar No. 278946 2 ADAM J. MCNEILE Bar No. 280296 MALACHI J. HASWELL Bar No. 307729 3 KATHERINE SASS Bar No. 326185 1120 Mar West St., Ste. C-2 4 Tiburon, CA 94920 Telephone: (415) 632-1900 5 Facsimile: (415) 632-1901 kristin@kbklegal.com 6 adam@kbklegal.com kai@kbklegal.com 7 katie@kbklegal.com Attorneys for Plaintiff TAYLOR HANEY 8 David A. Berkley (Bar No. 260105) 9 Monique G. Matar (Bar No. 317145) WOMBLE BOND DICKINSON (US) LLP 10 400 Spectrum Center Drive, Suite 1700 Irvine, CA 92618 11 Telephone: (714) 557-3800 Facsimile: (714) 557-3347 12 Email: David.Berkley@wbd-us.com Email: Monique.Matar@wbd-us.com 13 Attorneys for Defendant 14 SERVICE FINANCE COMPANY, LLC

16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18 Taylor Haney 19 Case No.: 5:25−cv−01338−KK 20 Plaintiff(s), (SSCx) 21 v.

22 Service Finance Company STIPULATED PROTECTIVE ORDER1 23 Defendant(s). 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 is likely to 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 enter 7 the following Stipulated Protective Order. The parties acknowledge that 8 this Order does not confer blanket protections on all disclosures or 9 responses to discovery and that the protection it affords from public 10 disclosure and use extends only to the limited information or items that 11 are entitled to confidential treatment under the applicable legal 12 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/or 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 and 19 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 necessary 3 uses of such material in preparation for and in the conduct of trial, to 4 address their handling at the end of the litigation, and serve the ends of 5 justice, a protective order for such information is justified in this matter. 6 It is the intent of the parties that information will not be designated as 7 confidential for tactical reasons and that nothing be so designated without 8 a good faith belief that it has been maintained in a confidential, non-public 9 manner, and there is good cause why it should not be part of the public 10 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 non- 19 dispositive motions, good cause must be shown to support a filing under 20 seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 21 22 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 23 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 24 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 25 require good cause showing), and a specific showing of good cause or 26 compelling reasons with proper evidentiary support and legal 27 justification, must be made with respect to Protected Material that a 1 or Discovery Material as CONFIDENTIAL does not—without the 2 submission of competent evidence by declaration, establishing that the 3 material sought to be filed under seal qualifies as confidential, privileged, 4 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 must 7 be shown, and the relief sought shall be narrowly tailored to serve the 8 specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 605 9 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of information, 10 document, or thing sought to be filed or introduced under seal in 11 connection with a dispositive motion or trial, the party seeking protection 12 must articulate compelling reasons, supported by specific facts and legal 13 justification, for the requested sealing order. Again, competent evidence 14 supporting the application to file documents under seal must be provided 15 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: This pending federal lawsuit. 26 2.2 Challenging Party: a Party or Non-Party that challenges the 27 designation of information or items under this Order. 1 2.3 “CONFIDENTIAL” Information or Items: information 2 (regardless of how it is generated, stored or maintained) or tangible things 3 that qualify for protection under Rule 26(c) of the Federal Rules of Civil 4 Procedure, and as specified above in the Good Cause Statement. 5 2.4 Counsel: Outside Counsel of Record and House Counsel (as 6 well as their support staff). 7 2.5 Designating Party: a Party or Non-Party that designates 8 information or items that it produces in disclosures or in responses to 9 discovery as “CONFIDENTIAL.” 10 2.6 Disclosure or Discovery Material: all items or information, 11 regardless of the medium or manner in which it is generated, stored, or 12 maintained (including, among other things, testimony, transcripts, and 13 tangible things), that are produced or generated in disclosures or 14 responses to discovery in this matter. 15 2.7 Expert: a person with specialized knowledge or experience in a 16 matter pertinent to the litigation who has been retained by a Party or its 17 counsel to serve as an expert witness or as a consultant in this Action. 18 2.8 Final Disposition: the later of (1) dismissal of all claims and 19 defenses in this Action, with or without prejudice; and (2) final judgment 20 herein after the completion and exhaustion of all appeals, rehearings, 21 22 remands, trials, or reviews of this Action, including the time limits for 23 filing any motions or applications for extension of time pursuant to 24 applicable law. 25 2.9 In-House Counsel: attorneys who are employees of a party to 26 this Action. In-House Counsel does not include Outside Counsel of Record 27 or any other outside counsel. 1 association, or other legal entity not named as a Party to this action. 2 2.11 Outside Counsel of Record: attorneys who are not employees of 3 a party to this Action but are retained to represent or advise a party to 4 this Action and have appeared in this Action on behalf of that party or are 5 affiliated with a law firm which has appeared on behalf of that party, and 6 includes support staff. 7 2.12 Party: any party to this Action, including all of its officers, 8 directors, employees, consultants, retained experts, and Outside Counsel 9 of Record (and their support staffs). 10 2.13 Producing Party: a Party or Non-Party that produces 11 Disclosure or Discovery Material in this Action. 12 2.14 Professional Vendors: persons or entities that provide 13 litigation- support services (e.g., photocopying, videotaping, translating, 14 preparing exhibits or demonstrations, and organizing, storing, or 15 retrieving data in any form or medium) and their employees and 16 subcontractors. 17 2.15 Protected Material: any Disclosure or Discovery Material that 18 is designated as “CONFIDENTIAL.” 19 2.16 Receiving Party: a Party that receives Disclosure or Discovery 20 Material from a Producing Party. 21 22 3. SCOPE 23 The protections conferred by this Stipulation and Order cover not 24 only Protected Material (as defined above), but also (1) any information 25 copied or extracted from Protected Material; (2) all copies, excerpts, 26 summaries, or compilations of Protected Material; and (3) any testimony, 27 conversations, or presentations by Parties or their Counsel that might 1 reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the 3 orders of the trial judge. This Stipulated Protective Order does not 4 govern the use of Protected Material at trial. 5 4. USE OF ANY ARTIFICAL INTELIGENCE (“AI”) PLATFORMS 6 The Parties acknowledge the inherent risks of sharing confidential 7 information with generative AI platforms (i.e., that platforms retain and 8 learn from the uploaded information). Accordingly, the Parties agree that 9 they are expressly prohibited from inputting any information produced 10 pursuant to this Stipulated Protective Order to any open Generative AI 11 platform, subject to this Section. 12 Specifically, any and all information or documentation produced by 13 any Party designated and properly marked as CONFIDENTIAL shall not 14 be submitted to any open Generative AI tool (e.g., ChatGPT) or any 15 substantially similar tool that is available to the public. Providing 16 information designated and properly marked as CONFIDENTIAL to an 17 open tool is considered disclosure to a third party and is strictly prohibited. 18 Before any Party receiving information designated as CONFIDENTIAL 19 submits such information to any closed Generative AI tool, the receiving 20 party shall ensure that the tool is not accessible to the public, is used in a 21 secure, controlled environment, and gives the receiving party the 22 capability to delete all such confidential information from the tool at the 23 close of the matter. The receiving Party will be responsible for destroying 24 such confidential produced information from such tools at the end of the 25 matter. 26 5. TRIAL AND DURATION 27 The terms of this Stipulated Protective Order apply through Final 1 Disposition of the Action. 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 4 Order and used or introduced as an exhibit at trial becomes public and 5 will be presumptively available to all members of the public, including 6 the press, unless compelling reasons supported by specific factual 7 findings to proceed otherwise are made to the trial judge in advance of 8 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 9 cause” showing for sealing documents produced in discovery from 10 “compelling reasons” standard when merits-related documents are part 11 of court record). Accordingly, for such materials, the terms of this 12 Stipulated Protective Order do not extend beyond the commencement of 13 the trial. 14 Even after Final Disposition of this litigation, the confidentiality 15 obligations imposed by this Stipulated Protective Order shall remain in 16 effect until a Designating Party agrees otherwise in writing or a court 17 18 order otherwise directs. 19 6. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for 21 Protection. Each Party or Non-Party that designates information or items 22 for protection under this Order must take care to limit any such 23 designation to specific material that qualifies under the appropriate 24 standards. The Designating Party must designate for protection only 25 those parts of material, documents, items, or oral or written 26 communications that qualify so that other portions of the material, 27 documents, items, or communications for which protection is not 1 warranted are not swept unjustifiably within the ambit of this Order. 2 Mass, indiscriminate, or routinized designations are prohibited. 3 Designations that are shown to be clearly unjustified or that have been 4 made for an improper purpose (e.g., to unnecessarily encumber the case 5 development process or to impose unnecessary expenses and burdens on 6 other parties) may expose the Designating Party to sanctions. 7 If it comes to a Designating Party’s attention that information or 8 items that it designated for protection do not qualify for protection, that 9 Designating Party must promptly notify all other Parties that it is 10 withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise 12 provided in this Stipulated Protective Order (see, e.g., second paragraph of 13 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 14 Discovery Material that qualifies for protection under this Stipulated 15 Protective Order must be clearly so designated before the material is 16 disclosed or produced. 17 18 Designation in conformity with this Stipulated Protective Order 19 requires: 20 (a) for information in documentary form (e.g., paper or electronic 21 documents, but excluding transcripts of depositions or other pretrial or 22 trial proceedings), that the Producing Party affix at a minimum, the 23 legend “CONFIDENTIAL” to each page that contains protected material. 24 If only a portion or portions of the material on a page qualifies for 25 protection, the Producing Party also must clearly identify the protected 26 portion(s) (e.g., by making appropriate markings in the margins). 27 A Party or Non-Party that makes original documents available for 1 inspection need not designate them for protection until after the 2 inspecting Party has indicated which documents it would like copied and 3 produced. During the inspection and before the designation, all of the 4 material made available for inspection shall be deemed 5 CONFIDENTIAL. After the inspecting Party has identified the 6 documents it wants copied and produced, the Producing Party must 7 determine which documents, or portions thereof, qualify for protection 8 under this Stipulated Protective Order. Then, before producing the 9 specified documents, the Producing Party must affix the 10 “CONFIDENTIAL” legend to each page that contains Protected Material. 11 If only a portion or portions of the material on a page qualifies for 12 protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party 15 identify the Disclosure or Discovery Material on the record, before the 16 close of the deposition all protected testimony. 17 (c) for information produced in some form other than 18 documentary and for any other tangible items, that the Producing Party 19 affix in a prominent place on the exterior of the container or containers in 20 which the information is stored the “CONFIDENTIAL” legend. If only a 21 22 portion or portions of the information warrants protection, the Producing 23 Party, to the extent practicable, shall identify the protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an 25 inadvertent failure to designate qualified information or items does not, 26 standing alone, waive the Designating Party’s right to secure protection 27 under this Order for such material. Upon timely correction of a 1 designation, the Receiving Party must make reasonable efforts to assure 2 that the material is treated in accordance with the provisions of this 3 Stipulated Protective Order. 4 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 7.1 Timing of Challenges. Any Party or Non-Party may challenge 6 a designation of confidentiality at any time that is consistent with the 7 court’s Scheduling Order. 8 7.2 Meet and Confer. The Challenging Party shall initiate the 9 dispute resolution process under Local Rule 37.1 et seq. and with Section 10 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-Discovery 11 Motion Conference.”2 12 7.3 The burden of persuasion in any such challenge proceeding 13 shall be on the Designating Party. Frivolous challenges, and those made 14 for an improper purpose (e.g., to harass or impose unnecessary expenses 15 and burdens on other parties) may expose the Challenging Party to 16 sanctions. Unless the Designating Party has waived or withdrawn the 17 18 confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under 20 the Producing Party’s designation until the court rules on the challenge. 21 8. ACCESS TO AND USE OF PROTECTED MATERIAL 22 8.1 Basic Principles. A Receiving Party may use Protected 23 Material that is disclosed or produced by another Party or by a Non-Party 24 in connection with this Action only for prosecuting, defending, or 25 attempting to settle this Action. Such Protected Material may be 26

27 2 Judge Christensen’s Procedures are available at 1 disclosed only to the categories of persons and under the conditions 2 described in this Order. When the Action reaches a Final Disposition, a 3 Receiving Party must comply with the provisions of section 13 below. 4 Protected Material must be stored and maintained by a Receiving 5 Party at a location and in a secure manner that ensures that access is 6 limited to the persons authorized under this Stipulated Protective Order. 7 8.2 Disclosure of “CONFIDENTIAL” Information or Items. 8 Unless otherwise ordered by the court or permitted in writing by the 9 Designating Party, a Receiving Party may disclose any information or 10 item designated “CONFIDENTIAL” only: 11 (a) to the Receiving Party’s Outside Counsel of Record in this 12 Action, as well as employees of said Outside Counsel of Record to whom 13 it is reasonably necessary to disclose the information for this Action; 14 (b) to the officers, directors, and employees (including House 15 Counsel) of the Receiving Party to whom disclosure is reasonably 16 necessary for this Action; 17 (c) to Experts (as defined in this Order) of the Receiving Party to 18 whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) to the court and its personnel; 21 22 (e) to court reporters and their staff; 23 (f) to professional jury or trial consultants, mock jurors, and 24 Professional Vendors to whom disclosure is reasonably necessary for this 25 Action and who have signed the “Acknowledgment and Agreement to Be 26 Bound” (Exhibit A); 27 (g) to the author or recipient of a document containing the 1 knew the information; 2 (h) during their depositions, to witnesses, and attorneys for 3 witnesses, in the Action to whom disclosure is reasonably necessary, 4 provided: (1) the deposing party requests that the witness sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 6 witness will not be permitted to keep any confidential information unless 7 they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 8 unless otherwise agreed by the Designating Party or ordered by the court. 9 Pages of transcribed deposition testimony or exhibits to depositions that 10 reveal Protected Material may be separately bound by the court reporter 11 and may not be disclosed to anyone except as permitted under this 12 Stipulated Protective Order; and 13 (i) to any mediator or settlement officer, and their supporting 14 personnel, mutually agreed upon by any of the parties engaged in 15 settlement discussions. 16 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 17 PRODUCED IN OTHER LITIGATION 18 19 If a Party is served with a subpoena or a court order issued in other 20 litigation that compels disclosure of any information or items designated 21 in this Action as “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such 23 notification shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena 25 or order to issue in the other litigation that some or all of the material 26 covered by the subpoena or order is subject to this Protective Order. Such 27 notification shall include a copy of this Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to 2 be pursued by the Designating Party whose Protected Material may be 3 affected. 4 If the Designating Party timely seeks a protective order, the 5 Party served with the subpoena or court order shall not produce any 6 information designated in this action as “CONFIDENTIAL” before a 7 determination by the court from which the subpoena or order issued, 8 unless the Party has obtained the Designating Party’s permission. The 9 Designating Party shall bear the burden and expense of seeking 10 protection in that court of its confidential material and nothing in these 11 provisions should be construed as authorizing or encouraging a Receiving 12 Party in this Action to disobey a lawful directive from another court. 13 10. 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 are 16 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 and 19 relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 22 9.2 Notification. In the event that a Party is required, by a valid 23 discovery request, to produce a Non-Party’s confidential information in its 24 possession, and the Party is subject to an agreement with the Non-Party 25 not to produce the Non-Party’s confidential information, then the Party 26 shall: 27 (a) promptly notify in writing the Requesting Party and the Non- 1 confidentiality agreement with a Non-Party; 2 (b) make the information requested available for inspection by 3 the Non-Party, if requested. 4 9.3 Conditions of Production. If the Non-Party fails to seek a 5 protective order from this court within 14 days of receiving the notice and 6 accompanying information, the Receiving Party may produce the Non- 7 Party’s confidential information responsive to the discovery request. If the 8 Non-Party timely seeks a protective order, the Receiving Party shall not 9 produce any information in its possession or control that is subject to the 10 confidentiality agreement with the Non-Party before a determination by 11 the court. Absent a court order to the contrary, the Non-Party shall bear 12 the burden and expense of seeking protection in this court of its Protected 13 Material. 14 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it 16 has disclosed Protected Material to any person or in any circumstance not 17 18 authorized under this Stipulated Protective Order, the Receiving Party 19 must immediately (a) notify in writing the Designating Party of the 20 unauthorized disclosures, (b) use its best efforts to retrieve all 21 unauthorized copies of the Protected Material, (c) inform the person or 22 persons to whom unauthorized disclosures were made of all the terms of 23 this Order, and (d) request such person or persons to execute the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 25 12. INADVERTENT PRODUCTION OF PRIVILEGED OR 26 OTHERWISE PROTECTED MATERIAL 27 1 certain inadvertently produced material is subject to a claim of privilege 2 or other protection, the obligations of the Receiving Parties are those set 3 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 4 provision is not intended to modify whatever procedure may be 5 established in an e-discovery order that provides for production without 6 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 7 Rules of Evidence, insofar as the parties reach an agreement on the effect 8 of disclosure of a communication or information covered by the attorney- 9 client privilege or work product protection, the parties may incorporate 10 their agreement in the stipulated protective order submitted to the court. 11 13. MISCELLANEOUS 12 13.1 Right to Further Relief. Nothing in this Stipulated Protective 13 Order abridges the right of any person to seek its modification by the 14 court in the future. 15 13.2 Right to Assert Other Objections. By stipulating to the entry 16 of this Stipulated Protective Order no Party waives any right it otherwise 17 18 would have to object to disclosing or producing any information or item 19 on any ground not addressed in this Stipulated Protective Order. 20 Similarly, no Party waives any right to object on any ground to use in 21 evidence of any of the material covered by this Stipulated Protective 22 Order. 23 13.3 Filing Protected Material. A Party that seeks to file under 24 seal any Protected Material must comply with Local Rule 79-5. Protected 25 Material may only be filed under seal pursuant to a court order 26 authorizing the sealing of the specific Protected Material at issue. If a 27 Party's request to file Protected Material under seal is denied by the 1 court, then the Receiving Party may file the information in the public 2 record unless otherwise instructed by the court. 3 14. FINAL DISPOSITION 4 After the Final Disposition of this Action, as defined in paragraph 5 4, within 60 days of a written request by the Designating Party, each 6 Receiving Party must return all Protected Material to the Producing 7 Party or destroy such material. As used in this subdivision, “all Protected 8 Material” includes all copies, abstracts, compilations, summaries, and 9 any other format reproducing or capturing any of the Protected Material. 10 Whether the Protected Material is returned or destroyed, the Receiving 11 Party must submit a written certification to the Producing Party (and, if 12 not the same person or entity, to the Designating Party) by the 60 day 13 deadline that (1) identifies (by category, where appropriate) all the 14 Protected Material that was returned or destroyed and (2) affirms that 15 the Receiving Party has not retained any copies, abstracts, compilations, 16 summaries or any other format reproducing or capturing any of the 17 18 Protected Material. Notwithstanding this provision, Counsel is entitled 19 to retain an archival copy of all pleadings, motion papers, trial, 20 deposition, and hearing transcripts, legal memoranda, correspondence, 21 deposition and trial exhibits, expert reports, attorney work product, and 22 consultant and expert work product, even if such materials contain 23 Protected Material. Any such archival copies that contain or constitute 24 Protected Material remain subject to this Protective Order as set forth in 25 Section 4. 26 15. VIOLATION 27 Any violation of this Stipulated Protective Order may be punished 1 || by any and all appropriate measures including, without limitation, 2 || contempt proceedings and/or monetary sanctions. 3 4 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: October 10, 2025 KEMNITZER, BARRON & KRIEG, LLP 7 8 By: /s/ Kristin Kemnitzer 9 KRISTIN KEMNITZER Attorneys for Plaintiff 10 1] Dated: October 10, 2025 WOMBLE BOND DICKINSON (US) LLP 12 13 By: /s/ David A. Berkley 14 DAVID A. BERKLEY MONIQUE G. MATAR I5 Attorneys for Defendant 16 SERVICE FINANCE COMPANY, INC 17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 ZA DATED: October 24, 2025 21 STEPHANIE 8. CHRISTENSEN 22 United States Magistrate Judge 23 24 25 26 27 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 case of __________ [insert formal name of the case and the 9 number and initials assigned to it by the court]. I agree to 10 comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so 12 comply could expose me to sanctions and punishment in the nature of 13 14 contempt. I solemnly promise that I will not disclose in any manner 15 any information or item that is subject to this Stipulated Protective 16 Order to any person or entity except in strict compliance with the 17 provisions of this Order. 18 I further agree to submit to the jurisdiction of the United States 19 District Court for the Central District of California for the purpose of 20 enforcing the terms of this Stipulated Protective Order, even if such 21 enforcement proceedings occur after termination of this action. I 22 hereby appoint ________________________ [print or type full name] 23 of _________ [print or type full address and telephone number] as 24 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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