Melissa Jefferson v. Justin Raisen et al

Filing 66

STIPULATED PROTECTIVE ORDER 65 by Magistrate Judge Maria A. Audero. [See document for details.] (es)

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1 2 3 4 5 6 Cynthia S. Arato (State Bar No. 156856) carato@shapiroarato.com SHAPIRO ARATO BACH LLP 500 Fifth Avenue, 40th Floor New York, New York 10110 Telephone: (212) 257-4880 Facsimile: (212) 202-6417 Attorneys for Plaintiff MELISSA JEFFERSON, p/k/a LIZZO 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 MELISSA JEFFERSON, professionally known as LIZZO, an individual, Plaintiff, 12 13 14 15 v. JUSTIN RAISEN, an individual, JEREMIAH RAISEN, an individual, HEAVY DUTY MUSIC PUBLISHING, YVES ROTHMAN, and DOES 1-10, 16 17 18 19 20 Defendants. JUSTIN RAISEN, an individual, JEREMIAH RAISEN, an individual, HEAVY DUTY LLC (erroneously sued as HEAVY DUTY MUSIC PUBLISHING), and JUSTIN “YVES” ROTHMAN, an individual, Counterclaimants, 21 22 23 24 25 26 27 28 Case No. 2:19 cv 09107 DMG MAA v. MELISSA JEFFERSON, professionally known as LIZZO, an individual, ERIC FREDERIC, an individual, JESSE ST. JOHN GELLER, an individual, STEVEN CHEUNG, an individual, and ROES 1-10 Counterdefendants. STIPULATED PROTECTIVE ORDER 1 1. 2 PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Stipulated Protective Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and 9 use extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. The parties further acknowledge, as 11 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Local Rule 79-5 sets forth the 13 procedures that must be followed and the standards that will be applied when a 14 party seeks permission from the Court to file material under seal. 15 16 17 2. GOOD CAUSE STATEMENT This action is likely to involve commercial, financial, and/or proprietary 18 information for which special protection from public disclosure and from use for 19 any purpose other than prosecution of this action is warranted. Such confidential 20 and proprietary materials and information consist of, among other things, 21 confidential business or financial information, confidential information and data 22 relating to the development and recording of various sound recordings, including 23 recordings that have not been commercially released, private correspondence and 24 documents of individuals active within the music and entertainment industry and 25 often subject to unwarranted tabloid attention. Accordingly, to expedite the flow of 26 information, to facilitate the prompt resolution of disputes over confidentiality of 27 discovery materials, to adequately protect information the parties are entitled to 28 keep confidential, to ensure that the parties are permitted reasonable necessary uses 2 1 of such material in preparation for and in the conduct of trial, to address their 2 handling at the end of the litigation, and to serve the ends of justice, a protective 3 order for such information is justified in this matter. It is the intent of the parties 4 that information will not be designated as confidential for tactical reasons and that 5 nothing be so designated without a good faith belief that it has been maintained in a 6 confidential, non-public manner, and there is good cause why it should not be part 7 of the public record of this case. 8 9 3. DEFINITIONS 10 3.1. Action: This pending federal lawsuit. 11 3.2. Challenging Party: A Party or Nonparty that challenges the 12 designation of information or items under this Stipulated Protective 13 Order. 14 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 15 how it is generated, stored or maintained) or tangible things that 16 qualify for protection under Federal Rule of Civil Procedure 26(c), and 17 as specified above in the Good Cause Statement. 18 3.4. 19 20 Counsel: Outside Counsel of Record and In-House Counsel (as well as their support staff). 3.5. Designating Party: A Party or Nonparty that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 3.6. Disclosure or Discovery Material: All items or information, regardless 24 of the medium or manner in which it is generated, stored, or 25 maintained (including, among other things, testimony, transcripts, and 26 tangible things), that is produced or generated in disclosures or 27 responses to discovery in this matter. 28 3.7. Expert: A person with specialized knowledge or experience in a 3 1 matter pertinent to the litigation who has been retained by a Party or its 2 counsel to serve as an expert witness or as a consultant in this Action. 3 3.8. In-House Counsel: Attorneys who are employees of a party to this 4 Action. In-House Counsel does not include Outside Counsel of 5 Record or any other outside counsel. 6 7 3.9. Nonparty: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 8 3.10. Outside Counsel of Record: Attorneys who are not employees of a 9 party to this Action but are retained to represent or advise a party to 10 this Action and have appeared in this Action on behalf of that party or 11 are affiliated with a law firm which has appeared on behalf of that 12 party, and includes support staff. 13 3.11. Party: Any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, In-House Counsel, and 15 Outside Counsel of Record (and their support staffs). 16 17 18 3.12. Producing Party: A Party or Nonparty that produces Disclosure or Discovery Material in this Action. 3.13. Professional Vendors: Persons or entities that provide litigation 19 support services (e.g., photocopying, videotaping, translating, 20 preparing exhibits or demonstrations, and organizing, storing, or 21 retrieving data in any form or medium) and their employees and 22 subcontractors. 23 24 25 26 3.14. Protected Material: Any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 3.15. Receiving Party: A Party that receives Disclosure or Discovery Material from a Producing Party. 27 28 4 1 4. SCOPE 2 The protections conferred by this Stipulated Protective Order cover not only 3 Protected Material, but also (1) any information copied or extracted from Protected 4 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 5 and (3) any testimony, conversations, or presentations by Parties or their Counsel 6 that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Stipulated Protective Order does not govern the use of Protected 9 Material at trial. 10 11 12 5. DURATION Even after final disposition of this litigation, the confidentiality obligations 13 imposed by this Stipulated Protective Order shall remain in effect until a 14 Designating Party agrees otherwise in writing or a court order otherwise directs. 15 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 16 defenses in this Action, with or without prejudice; and (2) final judgment herein 17 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 18 reviews of this Action, including the time limits for filing any motions or 19 applications for extension of time pursuant to applicable law. 20 If this case proceeds to trial, however, all of the information that was 21 designated or maintained as confidential pursuant to this Stipulated Protective 22 Order and that is admitted into the trial record will become public and 23 presumptively will be available to all members of the public, including the press, 24 unless the Designating Party demonstrates the existence of compelling reasons for a 25 further protective order in a motion to the trial judge in advance of the trial. See 26 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 27 (distinguishing “good cause” showing for sealing documents produced in discovery 28 from “compelling reasons” standard when merits-related documents are part of 5 1 court record). 2 3 4 6. DESIGNATING PROTECTED MATERIAL 6.1. Exercise of Restraint and Care in Designating Material for Protection. 5 Each Party or Nonparty that designates information or items for 6 protection under this Stipulated Protective Order must take care to 7 limit any such designation to specific material that qualifies under the 8 appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items, or oral or 10 written communications that qualify so that other portions of the 11 material, documents, items, or communications for which protection is 12 not warranted are not swept unjustifiably within the ambit of this 13 Stipulated Protective Order. 14 Mass, indiscriminate, or routinized designations are prohibited. 15 Designations that are shown to be clearly unjustified or that have been 16 made for an improper purpose (e.g., to unnecessarily encumber the 17 case development process or to impose unnecessary expenses and 18 burdens on other parties) may expose the Designating Party to 19 sanctions. 20 6.2. Manner and Timing of Designations. 21 Except as otherwise provided in this Stipulated Protective Order 22 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 23 Disclosure or Discovery Material that qualifies for protection under 24 this Stipulated Protective Order must be clearly so designated before 25 the material is disclosed or produced. 26 Designation in conformity with this Stipulated Protective Order 27 requires the following: 28 (a) For information in documentary form (e.g., paper or electronic 6 1 documents, but excluding transcripts of depositions or other 2 pretrial or trial proceedings), that the Producing Party affix at a 3 minimum, the legend “CONFIDENTIAL” to each page that 4 contains protected material. If only a portion or portions of the 5 material on a page qualifies for protection, the Producing Party 6 also must clearly identify the protected portion(s) (e.g., by 7 making appropriate markings in the margins). 8 A Party or Nonparty that makes original documents 9 available for inspection need not designate them for protection 10 until after the inspecting Party has indicated which documents it 11 would like copied and produced. During the inspection and 12 before the designation, all of the material made available for 13 inspection shall be deemed “CONFIDENTIAL.” After the 14 inspecting Party has identified the documents it wants copied 15 and produced, the Producing Party must determine which 16 documents, or portions thereof, qualify for protection under this 17 Stipulated Protective Order. Then, before producing the 18 specified documents, the Producing Party must affix the legend 19 “CONFIDENTIAL” to each page that contains Protected 20 Material. If only a portion or portions of the material on a page 21 qualifies for protection, the Producing Party also must clearly 22 identify the protected portion(s) (e.g., by making appropriate 23 markings in the margins). 24 (b) For testimony given in depositions, that the Designating Party 25 identify the Disclosure or Discovery Material on the record, 26 before the close of the deposition, all protected testimony. 27 28 (c) For information produced in nondocumentary form, and for any other tangible items, that the Producing Party affix in a 7 1 prominent place on the exterior of the container or containers in 2 which the information is stored the legend “CONFIDENTIAL.” 3 If only a portion or portions of the information warrants 4 protection, the Producing Party, to the extent practicable, shall 5 identify the protected portion(s). 6 6.3. 7 Inadvertent Failure to Designate. If timely corrected, an inadvertent failure to designate qualified 8 information or items does not, standing alone, waive the Designating 9 Party’s right to secure protection under this Stipulated Protective Order 10 for such material. Upon timely correction of a designation, the 11 Receiving Party must make reasonable efforts to assure that the 12 material is treated in accordance with the provisions of this Stipulated 13 Protective Order. 14 15 7. 16 CHALLENGING CONFIDENTIALITY DESIGNATIONS 7.1. Timing of Challenges. 17 Any Party or Nonparty may challenge a designation of 18 confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 7.2. 21 Meet and Confer. The Challenging Party shall initiate the dispute resolution 22 process, which shall comply with Local Rule 37.1 et seq., and with 23 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic 24 Conference for Discovery Disputes”).1 25 7.3. Burden of Persuasion. 26 27 28 1 Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-maria-audero. 8 1 The burden of persuasion in any such challenge proceeding shall 2 be on the Designating Party. Frivolous challenges, and those made for 3 an improper purpose (e.g., to harass or impose unnecessary expenses 4 and burdens on other parties) may expose the Challenging Party to 5 sanctions. Unless the Designating Party has waived or withdrawn the 6 confidentiality designation, all parties shall continue to afford the 7 material in question the level of protection to which it is entitled under 8 the Producing Party’s designation until the Court rules on the 9 challenge. 10 11 12 8. ACCESS TO AND USE OF PROTECTED MATERIALS 8.1. 13 Basic Principles. A Receiving Party may use Protected Material that is disclosed 14 or produced by another Party or by a Nonparty in connection with this 15 Action only for prosecuting, defending, or attempting to settle this 16 Action. Such Protected Material may be disclosed only to the 17 categories of persons and under the conditions described in this 18 Stipulated Protective Order. When the Action reaches a final 19 disposition, a Receiving Party must comply with the provisions of 20 Section 14 below. 21 Protected Material must be stored and maintained by a 22 Receiving Party at a location and in a secure manner that ensures that 23 access is limited to the persons authorized under this Stipulated 24 Protective Order. 25 26 8.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the Court or permitted in writing 27 by the Designating Party, a Receiving Party may disclose any 28 information or item designated “CONFIDENTIAL” only to: 9 1 (a) The Receiving Party’s Outside Counsel of Record, as well as 2 employees of said Outside Counsel of Record to whom it is 3 reasonably necessary to disclose the information for this Action; 4 (b) The officers, directors, and employees (including In-House 5 Counsel) of the Receiving Party to whom disclosure is 6 reasonably necessary for this Action; 7 (c) Experts of the Receiving Party to whom disclosure is reasonably 8 necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (d) The Court and its personnel; 11 (e) Court reporters and their staff; 12 (f) Professional jury or trial consultants, mock jurors, and 13 Professional Vendors to whom disclosure is reasonably 14 necessary or this Action and who have signed the 15 “Acknowledgment and Agreement to be Bound” (Exhibit A); 16 (g) The author or recipient of a document containing the 17 information or a custodian or other person who otherwise 18 possessed or knew the information; 19 (h) During their depositions, witnesses, and attorneys for witnesses, 20 in the Action to whom disclosure is reasonably necessary 21 provided: (i) the deposing party requests that the witness sign 22 the “Acknowledgment and Agreement to Be Bound” (Exhibit 23 A); and (ii) the witness will not be permitted to keep any 24 confidential information unless they sign the “Acknowledgment 25 and Agreement to Be Bound,” unless otherwise agreed by the 26 Designating Party or ordered by the Court. Pages of transcribed 27 deposition testimony or exhibits to depositions that reveal 28 Protected Material may be separately bound by the court 10 1 reporter and may not be disclosed to anyone except as permitted 2 under this Stipulated Protective Order; and 3 (i) Any mediator or settlement officer, and their supporting 4 personnel, mutually agreed upon by any of the parties engaged 5 in settlement discussions. 6 7 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 8 PRODUCED IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 that compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 (a) 13 14 Promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (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 16 by the subpoena or order is subject to this Stipulated Protective Order. 17 Such notification shall include a copy of this Stipulated Protective 18 Order; and 19 (c) Cooperate with respect to all reasonable procedures sought to be 20 pursued by the Designating Party whose Protected Material may be 21 affected. 22 If the Designating Party timely seeks a protective order, the Party served with 23 the subpoena or court order shall not produce any information designated in this 24 action as “CONFIDENTIAL” before a determination by the Court from which the 25 subpoena or order issued, unless the Party has obtained the Designating Party’s 26 permission. The Designating Party shall bear the burden and expense of seeking 27 protection in that court of its confidential material and nothing in these provisions 28 should be construed as authorizing or encouraging a Receiving Party in this Action 11 1 to disobey a lawful directive from another court. 2 3 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 10.1. Application. 6 The terms of this Stipulated Protective Order are applicable to 7 information produced by a Nonparty in this Action and designated as 8 “CONFIDENTIAL.” Such information produced by Nonparties in 9 connection with this litigation is protected by the remedies and relief 10 provided by this Stipulated Protective Order. Nothing in these 11 provisions should be construed as prohibiting a Nonparty from seeking 12 additional protections. 13 10.2. Notification. 14 In the event that a Party is required, by a valid discovery 15 request, to produce a Nonparty’s confidential information in its 16 possession, and the Party is subject to an agreement with the Nonparty 17 not to produce the Nonparty’s confidential information, then the Party 18 shall: 19 (a) Promptly notify in writing the Requesting Party and the 20 Nonparty that some or all of the information requested is subject 21 to a confidentiality agreement with a Nonparty; 22 (b) Promptly provide the Nonparty with a copy of the Stipulated 23 Protective Order in this Action, the relevant discovery 24 request(s), and a reasonably specific description of the 25 information requested; and 26 27 28 (c) Make the information requested available for inspection by the Nonparty, if requested. 10.3. Conditions of Production. 12 1 If the Nonparty fails to seek a protective order from this Court 2 within fourteen (14) days after receiving the notice and accompanying 3 information, the Receiving Party may produce the Nonparty’s 4 confidential information responsive to the discovery request. If the 5 Nonparty timely seeks a protective order, the Receiving Party shall not 6 produce any information in its possession or control that is subject to 7 the confidentiality agreement with the Nonparty before a 8 determination by the Court. Absent a court order to the contrary, the 9 Nonparty shall bear the burden and expense of seeking protection in 10 this Court of its Protected Material. 11 12 11. 13 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 16 writing the Designating Party of the unauthorized disclosures, (2) use its best 17 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 18 person or persons to whom unauthorized disclosures were made of all the terms of 19 this Stipulated Protective Order, and (4) request such person or persons to execute 20 the “Acknowledgment and Agreement to be Bound” (Exhibit A). 21 22 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 In this litigation, if a Party or Nonparty (“Disclosing Party”) inadvertently 25 discloses information that is subject to a claim of attorney-client privilege or work 26 product protection (“Inadvertently Disclosed Information”), such disclosure shall 27 not constitute or be deemed a waiver or forfeiture of any claim of privilege or work 28 13 1 product protection with respect to the Inadvertently Disclosed Information or its 2 related subject matter in this litigation or in any other court or legal proceeding. 3 4 5 (a) If at any time the Disclosing Party discovers that it has disclosed Inadvertently Disclosed Information, it shall, as soon as practicable: 6 Notify all parties in writing of the inadvertent disclosure. 7 Identify all Inadvertently Disclosed Information. 8 9 10 (b) Upon receiving the Disclosing Party's notice, each Receiving Party shall within seven business days: 11 Return, destroy, sequester, or delete all copies of the Inadvertently 12 Disclosed Information. 13 Take reasonable steps to retrieve the Inadvertently Disclosed 14 Information if it was disseminated by the receiving party prior to 15 such notification. 16 Provide a certification of counsel that all such information has been 17 returned, destroyed, sequestered, or deleted. 18 19 (c) Even if the Receiving Party objects (or intends to object) to the Disclosing 20 Party's privilege or protection claim, it shall refrain from any further use, 21 disclosure, or dissemination of the Inadvertently Disclosed Information in 22 any way (including, but not limited to, using the information at 23 depositions or trial) until the Court rules on the privileged or protected 24 status of the Inadvertently Disclosed Information. The Disclosing Party 25 must preserve the Inadvertently Disclosed Information until either: 26 All receiving parties concede that it is privileged or protected. 27 The Court resolves any disputes as to whether the Inadvertently 28 Disclosed Information is privileged or protected. 14 1 2 (d) Within seven business days of the notification that the Receiving Party 3 returned, destroyed, sequestered, or deleted the Inadvertently Disclosed 4 Information, the Disclosing Party shall produce a privilege log with 5 respect to the Inadvertently Disclosed Information. 6 7 (e) A party that objects to a claim of privilege or work product protection 8 with respect to the Inadvertently Disclosed Information may seek an 9 Order from the Court pursuant to Local Civil Rule 37 compelling 10 production of the Inadvertently Disclosed Information. To the extent 11 necessary, the motion shall be filed under seal pursuant to the Court's 12 rules governing under seal filing. The Disclosing Party bears the burden 13 of establishing the privileged or protected nature of any Inadvertently 14 Disclosed Information. Nothing in this Order shall limit the right to 15 request an in camera review of the Inadvertently Disclosed Information. 16 17 18 19 20 21 22 13. MISCELLANEOUS 13.1. Right to Further Relief. Nothing in this Stipulated Protective Order abridges the right of any person to seek its modification by the Court in the future. 13.2. Right to Assert Other Objections. By stipulating to the entry of this Stipulated Protective Order, no 23 Party waives any right it otherwise would have to object to disclosing 24 or producing any information or item on any ground not addressed in 25 this Stipulated Protective Order. Similarly, no Party waives any right 26 to object on any ground to use in evidence of any of the material 27 covered by this Stipulated Protective Order. 28 15 1 13.3. Filing Protected Material. 2 A Party that seeks to file under seal any Protected Material must 3 comply with Local Rule 79-5. Protected Material may only be filed 4 under seal pursuant to a court order authorizing the sealing of the 5 specific Protected Material at issue. If a Party's request to file 6 Protected Material under seal is denied by the Court, then the 7 Receiving Party may file the information in the public record unless 8 otherwise instructed by the Court. 9 10 11 14. FINAL DISPOSITION After the final disposition of this Action, within sixty (60) days of a written 12 request by the Designating Party, each Receiving Party must return all Protected 13 Material to the Producing Party or destroy such material. As used in this 14 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 15 summaries, and any other format reproducing or capturing any of the Protected 16 Material. Whether the Protected Material is returned or destroyed, the Receiving 17 Party must submit a written certification to the Producing Party (and, if not the 18 same person or entity, to the Designating Party) by the 60-day deadline that 19 (1) identifies (by category, where appropriate) all the Protected Material that was 20 returned or destroyed and (2) affirms that the Receiving Party has not retained any 21 copies, abstracts, compilations, summaries or any other format reproducing or 22 capturing any of the Protected Material. Notwithstanding this provision, Counsel is 23 entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 24 and hearing transcripts; legal memoranda; correspondence; deposition and trial 25 exhibits; expert reports; attorney work product; and consultant and expert work 26 product, even if such materials contain Protected Material. Any such archival 27 copies that contain or constitute Protected Material remain subject to this Stipulated 28 Protective Order as set forth in Section 5. 16 1 2 15. VIOLATION Any violation of this Stipulated Order may be punished by any and all 3 appropriate measures including, without limitation, contempt proceedings and/or 4 monetary sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 Dated: October 13, 2020 /s/ Cynthia S. Arato Cynthia S. Arato (State Bar No. 156856) SHAPIRO ARATO BACH LLP 500 Fifth Avenue, 40th Floor New York, NY 10110 Tel: (212) 257-4880 Fax: (212) 202-6417 carato@shapiroarato.com 9 10 11 12 13 Attorneys for Plaintiff and Counterclaim Defendant MELISSA JEFFERSON, p/k/a LIZZO 14 15 16 17 Dated: October 13, 2020 /s/ Allen Secretov Allen Secretov (State Bar No. 301655) KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP 808 Wilshire Boulevard, 3rd Floor Santa Monica, CA 90401 Tel: (310) 566-9800 Fax: (310) 566-9850 asecretov@kwikalaw.com 18 19 20 21 22 Attorneys for Defendants and Counterclaimants JUSTIN RAISEN, JEREMIAH RAISEN, HEAVY DUTY LLC, and JUSTIN “YVES” ROTHMAN 23 24 25 26 27 28 17 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 Dated: 10/14/20 Maria A. Audero United States Magistrate Judge 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, 4 [full name], of [address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on 7 [date] in the case of Jefferson v. Raisen, et al., 19-cv-9107. I agree to comply with 8 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 10 and punishment in the nature of contempt. I solemnly promise that I will not 11 disclose in any manner any information or item that is subject to this Stipulated 12 Protective Order to any person or entity except in strict compliance with the 13 provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint 18 of 19 as my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. [full name] [address and telephone number] 21 22 Signature: 23 Printed Name: 24 Date: 25 City and State Where Sworn and Signed: 26 27 28 19

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