Tommy T. Lor v. FCA US LLC

Opinion

1 EELmIaZilA: BemEcTnHu lVty.@ MeCfsNmUmLlaTwY. c(oSmB N 192455) 2 CHRISTOPHER J. WALDON (SBN 310179) Email: cwaldon@efsmmlaw.com 3 CHRISTINA M. TROTZ (SBN 354732) Email: ctrotz@efsmmlaw.com 4 EVANS FEARS SCHUTTERT MCNULTY MICKUS 1 Park Plaza, Suite 500 5 Irvine, CA 92614 Telephone: (949) 484-7488 6 Facsimile: (949) 966-0706 7 Attorneys for Defendant FCA US LLC 8

9 Tionna Carvalho (SBN 299010) tcarvalho@slpattorney.com 10 Elizabeth Larocque (SBN 219977) 11 elarocque@slpattorney.com STRATEGIC LEGAL PRACTICES 12 1888 Century Park East, 19th Floor 13 Los Angeles, CA 90067 Tel: (310) 929-4900 14 Facsimile: (310) 943-3838 15 emailservices@slpattorney.com 16 Attorneys for Plaintiff TOMMY T. LOR 17 UNITED STATES DISTRICT COURT 18 CENTRAL DISTRICT OF CALIFORNIA 19

20 TOMMY T. LOR, CASE NO: 2:24−cv−08216 WLH (SSCx)

21 Plaintiff, District Judge: Hon. Wesley L. Hsu Magistrate Judge: Hon. Stephanie S. 22 vs. Christensen

23 FCA US LLC; and DOES 1 to 10, STIPULATION AND PROTECTIVE inclusive, ORDER 24 Defendants. Superior Ct. Complaint Filed: 08/22/2024 25 Trial Date: 11/3/2025 26 27 28 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely 3 to involve production of confidential, proprietary, or private information 4 for 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/or proprietary information for which special protection 17 from public disclosure and from use for any purpose other than 18 prosecution of this action is warranted. Such confidential and 19 proprietary materials and information consist of, among other things, 20 confidential business or financial information, information regarding 21 confidential business practices, or other confidential research, 22 development, or commercial information (including information 23 implicating privacy rights of third parties), information otherwise 24 generally unavailable to the public, or which may be privileged or 25 otherwise protected from disclosure under state or federal statutes, 26 court rules, case decisions, or common law. Accordingly, to expedite the 27 flow of information, to facilitate the prompt resolution of disputes over 28 confidentiality of discovery materials, to adequately protect information 1 the parties are entitled to keep confidential, to ensure that the parties 2 are permitted reasonable necessary uses of such material in preparation 3 for and in the conduct of trial, to address their handling at the end of the 4 litigation, and serve the ends of justice, a protective order for such 5 information is justified in this matter. It is the intent of the parties that 6 information will not be designated as confidential for tactical reasons 7 and that nothing be so designated without a good faith belief that it has 8 been maintained in a confidential, non-public manner, and there is good 9 cause why it should not be part of the public record of this case. 10 1.3 Acknowledgment of Procedure for Filing Under Seal. The 11 parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential 13 information under seal; Local Rule 79-5 sets forth the procedures that 14 must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 There is a strong presumption that the public has a right of access 17 to judicial proceedings and records in civil cases. In connection with 18 non-dispositive motions, good cause must be shown to support a filing 19 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 20 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 21 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 22 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 23 protective orders require good cause showing), and a specific showing of 24 good cause or compelling reasons with proper evidentiary support and 25 legal justification, must be made with respect to Protected Material 26 that a party seeks to file under seal. The parties’ mere designation of 27 Disclosure or Discovery Material as CONFIDENTIAL does not— 28 without the submission of competent evidence by declaration, 1 establishing that the material sought to be filed under seal qualifies as 2 confidential, privileged, or otherwise protectable—constitute good 3 cause. 4 Further, if a party requests sealing related to a dispositive motion 5 or trial, then compelling reasons, not only good cause, for the sealing 6 must be shown, and the relief sought shall be narrowly tailored to serve 7 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 8 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 9 information, document, or thing sought to be filed or introduced under 10 seal in connection with a dispositive motion or trial, the party seeking 11 protection must articulate compelling reasons, supported by specific 12 facts and legal justification, for the requested sealing order. Again, 13 competent evidence supporting the application to file documents under 14 seal must be provided by declaration. 15 Any document that is not confidential, privileged, or otherwise 16 protectable in its entirety will not be filed under seal if the confidential 17 portions can be redacted. If documents can be redacted, then a 18 redacted version for public viewing, omitting only the confidential, 19 privileged, or otherwise protectable portions of the document, shall be 20 filed. Any application that seeks to file documents under seal in their 21 entirety should include an explanation of why redaction is not feasible. 22 2. DEFINITIONS 23 2.1 Action: this pending federal lawsuit]. 24 2.2 Challenging Party: a Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 2.3 “CONFIDENTIAL” Information or Items: information 27 (regardless of how it is generated, stored or maintained) or tangible 28 things that qualify for protection under Rule 26(c) of the Federal Rules 1 of Civil Procedure, and as specified above in the Good Cause Statement. 2 2.4 Counsel: Outside Counsel of Record and House Counsel (as 3 well as their support staff). 4 2.5 Designating Party: a Party or Non-Party that designates 5 information or items that it produces in disclosures or in responses to 6 discovery as “CONFIDENTIAL.” 7 2.6 Disclosure or Discovery Material: all items or information, 8 regardless of the medium or manner in which it is generated, stored, or 9 maintained (including, among other things, testimony, transcripts, and 10 tangible things), that are produced or generated in disclosures or 11 responses to discovery in this matter. 12 2.7 Expert: a person with specialized knowledge or experience in 13 a matter pertinent to the litigation who has been retained by a Party or 14 its counsel to serve as an expert witness or as a consultant in this 15 Action. 16 2.8 Final Disposition: the later of (1) dismissal of all claims and 17 defenses in this Action, with or without prejudice; and (2) final judgment 18 herein after the completion and exhaustion of all appeals, rehearings, 19 remands, trials, or reviews of this Action, including the time limits for 20 filing any motions or applications for extension of time pursuant to 21 applicable law. 22 2.9 In-House Counsel: attorneys who are employees of a party to 23 this Action. In-House Counsel does not include Outside Counsel of 24 Record or any other outside counsel. 25 2.10 Non-Party: any natural person, partnership, corporation, 26 association, or other legal entity not named as a Party to this action. 27 2.11 Outside Counsel of Record: attorneys who are not employees 28 of a party to this Action but are retained to represent or advise a party 1 to this Action and have appeared in this Action on behalf of that party or 2 are affiliated with a law firm which has appeared on behalf of that 3 party, and includes support staff. 4 2.12 Party: any party to this Action, including all of its officers, 5 directors, employees, consultants, retained experts, and Outside Counsel 6 of Record (and their support staffs). 7 2.13 Producing Party: a Party or Non-Party that produces 8 Disclosure or Discovery Material in this Action. 9 2.14 Professional Vendors: persons or entities that provide 10 litigation- support services (e.g., photocopying, videotaping, translating, 11 preparing exhibits or demonstrations, and organizing, storing, or 12 retrieving data in any form or medium) and their employees and 13 subcontractors. 14 2.15 Protected Material: any Disclosure or Discovery Material 15 that is designated as “CONFIDENTIAL.” 16 2.16 Receiving Party: a Party that receives Disclosure or 17 Discovery Material from a Producing Party. 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not 20 only Protected Material (as defined above), but also (1) any information 21 copied or extracted from Protected Material; (2) all copies, excerpts, 22 summaries, or compilations of Protected Material; and (3) any 23 testimony, conversations, or presentations by Parties or their Counsel 24 that might reveal Protected Material. 25 Any use of Protected Material at trial shall be governed by the 26 orders of the trial judge. This Stipulated Protective Order does not 27 govern the use of Protected Material at trial. 28 / / / 1 4. TRIAL AND DURATION 2 The terms of this Stipulated Protective Order apply through Final 3 Disposition of the Action. 4 Once a case proceeds to trial, information that was designated as 5 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 6 Order and used or introduced as an exhibit at trial becomes public and 7 will be presumptively available to all members of the public, including 8 the press, unless compelling reasons supported by specific factual 9 findings to proceed otherwise are made to the trial judge in advance of 10 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 11 cause” showing for sealing documents produced in discovery from 12 “compelling reasons” standard when merits-related documents are part 13 of court record). Accordingly, for such materials, the terms of this 14 Stipulated Protective Order do not extend beyond the commencement of 15 the trial. 16 Even after Final Disposition of this litigation, the confidentiality 17 obligations imposed by this Stipulated Protective Order shall remain in 18 effect until a Designating Party agrees otherwise in writing or a court 19 order otherwise directs. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for 22 Protection. Each Party or Non-Party that designates information or 23 items for protection under this Order must take care to limit any such 24 designation to specific material that qualifies under the appropriate 25 standards. The Designating Party must designate for protection only 26 those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, 28 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 6 on 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 13 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 14 or 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 Designation in conformity with this Stipulated Protective Order 18 requires: 19 (a) for information in documentary form (e.g., paper or 20 electronic documents, but excluding transcripts of depositions or other 21 pretrial or trial proceedings), that the Producing Party affix at a 22 minimum, the legend “CONFIDENTIAL” to each page that contains 23 protected material. If only a portion or portions of the material on a 24 page qualifies for protection, the Producing Party also must clearly 25 identify the protected portion(s) (e.g., by making appropriate markings 26 in the margins). 27 A Party or Non-Party that makes original documents available for 28 inspection need not designate them for protection until after the 1 inspecting Party has indicated which documents it would like copied 2 and produced. During the inspection and before the designation, all of 3 the material made available for inspection shall be deemed 4 CONFIDENTIAL. After the inspecting Party has identified the 5 documents it wants copied and produced, the Producing Party must 6 determine which documents, or portions thereof, qualify for protection 7 under this Stipulated Protective Order. Then, before producing the 8 specified documents, the Producing Party must affix the 9 “CONFIDENTIAL” legend to each page that contains Protected 10 Material. If only a portion or portions of the material on a page 11 qualifies for protection, the Producing Party also must clearly identify 12 the protected portion(s) (e.g., by making appropriate markings in the 13 margins). 14 (b) for testimony given in depositions that the Designating 15 Party identify the Disclosure or Discovery Material on the record, before 16 the 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 20 in which the information is stored the “CONFIDENTIAL” legend. If 21 only a portion or portions of the information warrants protection, the 22 Producing Party, to the extent practicable, shall identify the protected 23 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 28 designation, the Receiving Party must make reasonable efforts to assure 1 that the material is treated in accordance with the provisions of this 2 Stipulated Protective Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may 5 challenge a designation of confidentiality at any time that is consistent 6 with the court’s Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party shall initiate the 8 dispute resolution process under Local Rule 37.1 et seq. and with 9 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 10 Discovery Motion Conference.”1 11 6.3 The burden of persuasion in any such challenge proceeding 12 shall be on the Designating Party. Frivolous challenges, and those 13 made for an improper purpose (e.g., to harass or impose unnecessary 14 expenses and burdens on other parties) may expose the Challenging 15 Party to sanctions. Unless the Designating Party has waived or 16 withdrawn the confidentiality designation, all parties shall continue to 17 afford the material in question the level of protection to which it is 18 entitled under the Producing Party’s designation until the court rules 19 on the challenge. 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected 22 Material that is disclosed or produced by another Party or by a Non- 23 Party in connection with this Action only for prosecuting, defending, or 24 attempting to settle this Action. Such Protected Material may be 25 disclosed only to the categories of persons and under the conditions 26 described in this Order. When the Action reaches a Final Disposition, a 27 1 Judge Christensen’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen. 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 17 to whom disclosure is reasonably necessary for this Action and who 18 have signed the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); 20 (d) to the court and its personnel; 21 (e) to court reporters and their staff; 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 28 knew the information; 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 10 separately bound by the court reporter and may not be disclosed to 11 anyone except 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 notification shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the 23 subpoena or order to issue in the other litigation that some or all of the 24 material covered by the subpoena or order is subject to this Protective 25 Order. Such notification shall include a copy of this Stipulated 26 Protective Order; and 27 (c) cooperate with respect to all reasonable procedures sought to 28 be pursued by the Designating Party whose Protected Material may be 1 affected. 2 If the Designating Party timely seeks a protective order, the 3 Party served with the subpoena or court order shall not produce any 4 information designated in this action as “CONFIDENTIAL” before a 5 determination by the court from which the subpoena or order issued, 6 unless the Party has obtained the Designating Party’s permission. The 7 Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these 9 provisions should be construed as authorizing or encouraging a 10 Receiving Party in this Action to disobey a lawful directive from 11 another court. 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 13 BE PRODUCED IN THIS LITIGATION 14 9.1 Application. The terms of this Stipulated Protective 15 Order are applicable to information produced by a Non-Party in 16 this Action and designated as “CONFIDENTIAL.” Such 17 information produced by Non-Parties in connection with this 18 litigation is protected by the remedies and relief provided by this 19 Order. Nothing in these provisions should be construed as 20 prohibiting a Non-Party from seeking additional protections. 21 9.2 Notification. In the event that a Party is required, by a 22 valid discovery request, to produce a Non-Party’s confidential 23 information in its possession, and the Party is subject to an 24 agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (a) promptly notify in writing the Requesting Party 27 and the Non-Party that some or all of the information 28 requested is subject to a confidentiality agreement with a 1 Non-Party; 2 (b) make the information requested available for 3 inspection by the Non-Party, if requested. 4 9.3 Conditions of Production. If the Non-Party fails to seek 5 a protective order from this court within 14 days of receiving the 6 notice and accompanying information, the Receiving Party may 7 produce the Non-Party’s confidential information responsive to the 8 discovery request. If the Non-Party timely seeks a protective 9 order, the Receiving Party shall not produce any information in its 10 possession or control that is subject to the confidentiality 11 agreement with the Non-Party before a determination by the court. 12 Absent a court order to the contrary, the Non-Party shall bear the 13 burden and expense of seeking protection in this court of its 14 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 the unauthorized disclosures, (b) use its best efforts to retrieve all 22 unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms 24 of this Order, and (d) request such person or persons to execute the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A) 26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 27 OTHERWISE PROTECTED MATERIAL 28 When a Producing Party gives notice to Receiving Parties that 1 certain inadvertently produced material is subject to a claim of 2 privilege or other protection, the obligations of the Receiving Parties 3 are those set forth in Rule 26(b)(5)(B) of the Federal Rules of Civil 4 Procedure. This provision is not intended to modify whatever 5 procedure may be established in an e-discovery order that provides for 6 production without prior privilege review. Pursuant to Rules 502(d) 7 and (e) of the Federal Rules of Evidence, insofar as the parties reach an 8 agreement on the effect of disclosure of a communication or information 9 covered by the attorney-client privilege or work product protection, the 10 parties may incorporate their agreement in the stipulated protective 11 order submitted to the court. 12 12. MISCELLANEOUS 13 12.1 Right to Further Relief. Nothing in this Stipulated 14 Protective Order abridges the right of any person to seek its 15 modification by the court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the 17 entry of this Stipulated Protective Order no Party waives any right it 18 otherwise would have to object to disclosing or producing any 19 information or item on any ground not addressed in this Stipulated 20 Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this 22 Stipulated Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under 24 seal any Protected Material must comply with Local Rule 79-5. 25 Protected Material may only be filed under seal pursuant to a court 26 order authorizing the sealing of the specific Protected Material at issue. 27 If a Party's request to file Protected Material under seal is denied by 28 the court, then the Receiving Party may file the information in the 1 public record unless otherwise instructed by the court. 2 13. FINAL DISPOSITION 3 After the Final Disposition of this Action, as defined in paragraph 4 4, within 60 days of a written request by the Designating Party, each 5 Receiving Party must return all Protected Material to the Producing 6 Party or destroy such material. As used in this subdivision, “all 7 Protected Material” includes all copies, abstracts, compilations, 8 summaries, and any other format reproducing or capturing any of the 9 Protected Material. Whether the Protected Material is returned or 10 destroyed, the Receiving Party must submit a written certification to 11 the Producing Party (and, if not the same person or entity, to the 12 Designating Party) by the 60 day deadline that (1) identifies (by 13 category, where appropriate) all the Protected Material that was 14 returned or destroyed and (2) affirms that the Receiving Party has not 15 retained any copies, abstracts, compilations, summaries or any other 16 format reproducing or capturing any of the Protected Material. 17 Notwithstanding this provision, Counsel is entitled to retain an 18 archival copy of all pleadings, motion papers, trial, deposition, and 19 hearing transcripts, legal memoranda, correspondence, deposition and 20 trial exhibits, expert reports, attorney work product, and consultant 21 and expert work product, even if such materials contain Protected 22 Material. Any such archival copies that contain or constitute Protected 23 Material remain subject to this Protective Order as set forth in Section 24 4. 25 26 27 28 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 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 9 DATED: June 2, 2025 __/s/ Elizabeth Larocque Elizabeth Larocque 10 Tionna Carvalho 1] Attorney(s) for Plaintiff(s) 12 1, | DATED: June 2, 2025 CO hldle—

Christopher J. Waldon 15 Attorney for Defendant 16 17 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 >, | DATED: June 2, 2025 2 STEPHANIE S. CHRISTENSEN 33 United States Magistrate Judge 24 25 26 27 28 -17-

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 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 contempt. I solemnly promise that I will not disclose in any manner 14 any information or item that is subject to this Stipulated Protective 15 Order to any person or entity except in strict compliance with the 16 provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States 18 District Court for the Central District of California for the purpose of 19 enforcing the terms of this Stipulated Protective Order, even if such 20 enforcement proceedings occur after termination of this action. I 21 hereby appoint ________________________ [print or type full name] 22 of _________ [print or type full address and telephone number] 23 as my California agent for service of process in connection with this 24 action or any proceedings related to enforcement of this Stipulated 25 Protective Order. 26 27 28 1 2 Date: ___________________________ 3 City and State where sworn and 4 signed: ___________________________ 5 Printed name: ___________________________ 6 Signature: ___________________________

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 | CERTIFICATE OF SERVICE 2 I am employed in the County of Orange, State of California. I am over the age of 18 and nota party to the within action; my business address is | Park Plaza, 3 | Suite 500, Irvine, CA 92614. 4 On June 2, 2025, I served, in the manner indicated below, the foregoing 5 document described as: 6 STIPULATION AND PROTECTIVE ORDER 7 | on the interested parties in this action as follows: 8 BY ELECTRONIC TRANSMISSION: Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via ? NEF and hyperlink to the document. On June 2, 2025, I checked the CM/ECF docket for this proceeding and determined that the following 10 person(s) are on the Electronic Mail Notice List to receive NE transmission at the email address(es) stated below.

12 || Tionna Carvalho (SBN 299010) Attorneys for Plaintiff tcarvalho@slpattorney.com TOMMY T. LOR 13 || Elizabeth Larocque (SBN 219977) 14 || clarocque@slpattorney.com STRATEGIC LEGAL PRACTICES 15 || 1888 Century Park East, 19th Floor 16 || Los Angeles, CA 90067 Tel: (310) 929-4900 17 || Facsimile: (310) 943-3838 1g ||_emailservices@slpattorney.com 19 | Ed (F EDERAL) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. 20 I declare under penalty of petjury under the laws of the State of California 21 | that the above is true and correct. Executed on June 2, 2025 at Irvine, California. 22 23 24 25 26 27 Jacquelerfe Zambrano 28 - 20 -