Anthony Sunseri v. Experian Information Solutions, Inc. et al

Filing 40

STIPULATED PROTECTIVE ORDER by Magistrate Judge Rozella A. Oliver re Stipulation for Protective Order 39 (dml)

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Jenna Dakroub, MN #0401650
(admitted pro hac vice)
Price Law Group, APC
8245 N. 85th Way
Scottsdale, AZ 85258
T: [phone]
F: [phone]
E: [e-mail]
Lauren Tegan Rodkey, Esq. (SBN: 275830)
Price Law Group, APC
6345 Balboa Boulevard, Suite 247
Encino, CA 91316
T: [phone]
F: [phone]
E: [e-mail]
Attorneys for Plaintiff,
Anthony Sunseri

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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Case No.: 2:20-cv-08932-DOC-RAO

ANTHONY SUNSERI,
Plaintiff,
v.
EXPERIAN INFORMATION
SOLUTIONS, INC.; and CREDIT
MANAGEMENT, LP

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STIPULATED PROTECTIVE
ORDER

Defendants.

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1.

A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,

proprietary or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may

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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

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enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles.

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B. GOOD CAUSE STATEMENT

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The parties seek protection for all confidential proprietary documents,

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testimony, transcripts and other materials in this action produced by any party or
non-party and the information contained therein.
The documents to be produced by Plaintiff and Defendant contain sensitive
personal information, such as social security number, date of birth, addresses, and

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phone numbers. Plaintiff will further be disclosing information regarding his

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financial and credit accounts. Plaintiff will be at risk from potential identity theft if

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his information were to get into the wrong hands. Further, in connection with the

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Action, Plaintiff likely will seek discovery or testimony regarding certain of

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Defendant’s confidential and proprietary trade secrets and other business

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information including, but not limited to, codes, computer systems, software and
processes used for credit reporting, and information derived therefrom.
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
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The parties further acknowledge, as set forth in Section 12.3, below, that this

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Stipulated Protective Order does not entitle them to file confidential information

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under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

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and the standards that will be applied when a party seeks permission from the court
to file material under seal.
There is a strong presumption that the public has a right of access to judicial
proceedings and records in civil cases. In connection with non-dispositive motions,

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good cause must be shown to support a filing under seal. See Kamakana v. City

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and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen.

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Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony

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Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective

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orders require good cause showing), and a specific showing of good cause or

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compelling reasons with proper evidentiary support and legal justification, must be

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made with respect to Protected Material that a party seeks to file under seal. The

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parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL

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does not—without the submission of competent evidence by declaration,

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establishing that the material sought to be filed under seal qualifies as confidential,

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privileged, or otherwise protectable—constitute good cause.

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Further, if a party requests sealing related to a dispositive motion or trial,

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then compelling reasons, not only good cause, for the sealing must be shown, and

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the relief sought shall be narrowly tailored to serve the specific interest to be
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protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.

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2010). For each item or type of information, document, or thing sought to be filed

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or introduced under seal in connection with a dispositive motion or trial, the party

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seeking protection must articulate compelling reasons, supported by specific facts

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and legal justification, for the requested sealing order. Again, competent evidence

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supporting the application to file documents under seal must be provided by

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declaration.
Any document that is not confidential, privileged, or otherwise protectable in

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its entirety will not be filed under seal if the confidential portions can be redacted.
If documents can be redacted, then a redacted version for public viewing, omitting

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only the confidential, privileged, or otherwise protectable portions of the document

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shall be filed. Any application that seeks to file documents under seal in their

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entirety should include an explanation of why redaction is not feasible.
2.

DEFINITIONS
2.1

Action: this pending lawsuit, entitled Anthony Sunseri v. Experian

Information Solutions, Inc., et al., Case No. 2:20-cv-08932-MCS-RAO.
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Challenging Party: a Party or Non-Party that challenges the

designation of information or items under this Order.
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“CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that qualify for
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protection under Federal Rule of Civil Procedure 26(c), and as specified above in

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the Good Cause Statement.

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“CONFIDENTIAL–ATTORNEYS’ EYES ONLY” Information or

Items: information (regardless of how it is generated, stored or maintained) or

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tangible things that qualify for protection under Federal Rule of Civil Procedure

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26(c), and as specified above in the Good Cause Statement, that a Designating Party

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believes in good faith that, despite the provisions of this Protective Order, there is a

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substantial risk of identifiable harm to the Designating Party if particular

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documents it designates as “CONFIDENTIAL” are disclosed to a Party or Non-

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Party.
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Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).
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Designating Party: a Party or Non-Party that designates information or

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items that it produces in disclosures or in responses to discovery as

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“CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY.”

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Disclosure or Discovery Material: all items or information, regardless

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of the medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things) that are produced or

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generated in disclosures or responses to discovery in this matter.
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Expert: a person with specialized knowledge or experience in a matter

pertinent to the litigation who has been retained by a Party or its counsel to serve as
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an expert witness or as a consultant in this Action.

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2.9

House Counsel: attorneys who are employees of a party to this Action.

House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.10 Non-Party: any natural person, partnership, corporation, association or
other legal entity not named as a Party to this action.
2.11 Outside Counsel of Record: attorneys who are not employees of a

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party to this Action but are retained to represent or advise a party to this Action and

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have appeared in this Action on behalf of that party or are affiliated with a law firm

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that has appeared on behalf of that party, and includes support staff.
2.12 Party: any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.14 Professional Vendors: persons or entities that provide litigation

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support services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium)

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and their employees and subcontractors.
2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES
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ONLY.”

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2.16 Receiving Party: a Party that receives Disclosure or Discovery

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Material from a Producing Party.
3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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Protected Material (as defined above), but also (1) any information copied or

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extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the

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trial judge. This Order does not govern the use of Protected Material at trial.

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4.

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DURATION
Once a case proceeds to trial, information that was designated as

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“CONFIDENTIAL,” “CONFIDENTIAL–ATTORNEYS’ EYES ONLY,” or

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maintained pursuant to this Protective Order used or introduced as an exhibit at trial

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becomes public and will be presumptively available to all members of the public,

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including the press, unless compelling reasons supported by specific factual

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findings to proceed otherwise are made to the trial judge in advance of the trial. See

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Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing

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documents produced in discovery from “compelling reasons” standard when merits-

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related documents are part of court record). Accordingly, the terms of this
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Protective Order do not extend beyond the commencement of the trial as to

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Protected Material used at trial.

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Notwithstanding the foregoing, even after final disposition of this litigation,
the confidentiality obligations imposed by this Order will remain in effect until a

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Designating Party agrees otherwise in writing or a court order otherwise directs,

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and all Protected Material, including all documents designated as

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“CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY” and/or

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admitted as evidence at trial, shall be returned to the Designating Party as set forth

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in Paragraph 13 below. Final disposition will be deemed to be the later of

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(1) dismissal of all claims and defenses in this Action, with or without prejudice;

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and (2) final judgment herein after the completion and exhaustion of all appeals,

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rehearings, remands, trials, or reviews of this Action, including the time limits for

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filing any motions or applications for extension of time pursuant to applicable law.
5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items or oral or written

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communications that qualify so that other portions of the material, documents,

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items or communications for which protection is not warranted are not swept
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unjustifiably within the ambit of this Order.

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Mass, indiscriminate or routinized designations are prohibited. Designations
that are shown to be clearly unjustified or that have been made for an improper
purpose (e.g., to unnecessarily encumber the case development process or to

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impose unnecessary expenses and burdens on other parties) may expose the

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Designating Party to sanctions.

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If it comes to a Designating Party’s attention that information or items that it

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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under this Order must be clearly so designated before the material is disclosed or
produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic

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documents, but excluding transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix at a minimum, the legend

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“CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY”

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(hereinafter “CONFIDENTIAL legend”), to each page that contains Protected

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Material. If only a portion of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins).
A Party or Non-Party that makes original documents available for inspection
need not designate them for protection until after the inspecting Party has indicated

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which documents it would like copied and produced. During the inspection and

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before the designation, all of the material made available for inspection shall be

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deemed “CONFIDENTIAL.” After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must determine

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which documents, or portions thereof, qualify for protection under this Order.

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Then, before producing the specified documents, the Producing Party must affix the

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“CONFIDENTIAL legend” to each page that contains Protected Material. If only a

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portion of the material on a page qualifies for protection, the Producing Party also

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must clearly identify the protected portion(s) (e.g., by making appropriate markings
in the margins).
(b) for testimony given in depositions, that the Designating Party identifies
the Disclosure or Discovery Material on the record, before the close of the

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deposition all protected testimony, or within twenty-one (21) days from the date a

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deposition transcript is received by serving a notice to all Parties designating

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portions of the transcript as “CONFIDENTIAL” or “CONFIDENTIAL–

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ATTORNEYS’ EYES ONLY.” Until such time, all deposition testimony shall be

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treated as Protected Material. To the extent any designations are made on the
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record during the deposition, the Designating Party need not serve a notice re-

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designating those portions of the transcript as “CONFIDENTIAL” or

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“CONFIDENTIAL–ATTORNEYS’ EYES ONLY.”

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(c) for information produced in some form other than documentary and for

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any other tangible items, that the Producing Party affix in a prominent place on the

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exterior of the container or containers in which the information is stored the legend

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“CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY.” If

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only a portion or portions of the information warrants protection, the Producing

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Party, to the extent practicable, shall identify the protected portion(s).

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5.3

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Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items does not, standing alone, waive

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the Designating Party’s right to secure protection under this Order for such

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material. Upon timely correction of a designation, the Receiving Party must make

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reasonable efforts to assure that the material is treated in accordance with the

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provisions of this Order.

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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges. Any Party or Non-Party may challenge a

designation of confidentiality at any time that is consistent with the Court’s
Scheduling Order.
6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Civil Rule 37.1 et seq.
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6.3

Joint Stipulation. Any challenge submitted to the Court shall be via a

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joint stipulation pursuant to Local Civil Rule 37-2.

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6.4

The burden of persuasion in any such challenge proceeding shall be on

the Designating Party. Frivolous challenges, and those made for an improper

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties shall

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continue to afford the material in question the level of protection to which it is

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entitled under the Producing Party’s designation until the Court rules on the

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challenge.
7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

disclosed or produced by another Party or by a Non-Party in connection with this

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Action only for prosecuting, defending or attempting to settle this Action. Such

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Protected Material may be disclosed only to the categories of persons and under the

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conditions described in this Order. When the Action has been terminated, a

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Receiving Party must comply with the provisions of section 13 below (FINAL

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DISPOSITION).

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.
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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the Designating Party, a

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Receiving Party may disclose any information or item designated

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“CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
as employees of said Outside Counsel of Record to whom it is reasonably necessary
to disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;

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(c) Experts (as defined in this Order) of the Receiving Party to whom
disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(d) the court and its personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party

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requests that the witness sign the “Acknowledgment and Agreement to Be Bound”

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(Exhibit A); and (2) they will not be permitted to keep any confidential information

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unless otherwise agreed by the Designating Party or ordered by the court. Pages of

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transcribed deposition testimony or exhibits to depositions that reveal Protected

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Material may be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Stipulated Protective Order;

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(i) any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the parties engaged in settlement discussions; and

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(j) present or former employees of the Producing Party in connection with
their depositions in this action (provided that no former employees shall be shown
documents prepared after the date of his or her departure).

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7.3

Disclosure of “CONFIDENTIAL–ATTORNEYS’ EYES ONLY”

Information or Items. Unless otherwise ordered by the court or permitted in writing
by the Designating Party, a Receiving Party may disclose any information or item

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designated “CONFIDENTIAL–ATTORNEYS’ EYES ONLY” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
as employees of said Outside Counsel of Record to whom it is reasonably necessary

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to disclose the information for this Action and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(b) Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary for this Action and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(c) the court and its personnel;

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(d) court reporters and their staff to whom disclosure is reasonably necessary

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for this Action and who have signed the “Acknowledgment and Agreement to Be
Bound” (Exhibit A); and
(e) the author or recipient of a document containing the information or a

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custodian or other person who otherwise possessed or knew the information.

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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation

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that compels disclosure of any information or items designated in this Action as

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“CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES ONLY,” that

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Party must:
(a) 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 to

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issue in the other litigation that some or all of the material covered by the subpoena

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or order is subject to this Protective Order. Such notification shall include a copy

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of this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be pursued

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by the Designating Party whose Protected Material may be affected.

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this

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action as “CONFIDENTIAL” or “CONFIDENTIAL–ATTORNEYS’ EYES

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ONLY” before a determination by the court from which the subpoena or order

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issued, unless the Party has obtained the Designating Party’s permission. The

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Designating Party shall bear the burden and expense of seeking protection in that

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court of its confidential material and nothing in these provisions should be

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construed as authorizing or encouraging a Receiving Party in this Action to disobey

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a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a Non-

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Party in this Action and designated as “CONFIDENTIAL” or “CONFIDENTIAL–
ATTORNEYS’ EYES ONLY.” Such information produced by Non-Parties in
connection with this litigation is protected by the remedies and relief provided by

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this Order. Nothing in these provisions should be construed as prohibiting a NonParty from seeking additional protections.

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(b) In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the Non-Party
that some or all of the information requested is subject to a confidentiality
agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Stipulated
Protective Order in this Action, the relevant discovery request(s), and a
reasonably specific description of the information requested; and
(3) make the information requested available for inspection by the
Non-Party, if requested.
(c) If the Non-Party fails to seek a protective order from this court within 14
days of receiving the notice and accompanying information, the Receiving Party
may produce the Non-Party’s confidential information responsive to the discovery

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request. If the Non-Party timely seeks a protective order, the Receiving Party shall

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not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Non-Party before a determination by the court.

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Absent a court order to the contrary, the Non-Party shall bear the burden and

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expense of seeking protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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writing the Designating Party of the unauthorized disclosures, (b) use its best

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efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the

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person or persons to whom unauthorized disclosures were made of all the terms of

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this Order, and (d) request such person or persons to execute the “Acknowledgment

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and Agreement to Be Bound” that is attached hereto as Exhibit A.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other

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protection, the obligations of the Receiving Parties are those set forth in Federal

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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

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whatever procedure may be established in an e-discovery order that provides for

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production without prior privilege review. Pursuant to Federal Rule of Evidence

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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

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of a communication or information covered by the attorney-client privilege or work

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product protection, the parties may incorporate their agreement in the stipulated

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protective order submitted to the court.
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12.

MISCELLANEOUS

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12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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person to seek its modification by the Court in the future.

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12.2 Right to Assert Other Objections. By stipulating to the entry of this

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Protective Order, no Party waives any right it otherwise would have to object to

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disclosing or producing any information or item on any ground not addressed in

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this Stipulated Protective Order. Similarly, no Party waives any right to object on

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any ground to use in evidence of any of the material covered by this Protective

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Order.

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12.3 Filing Protected Material. A Party that seeks to file under seal any

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Protected Material must comply with Local Civil Rule 79-5. Protected Material

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may only be filed under seal pursuant to a court order authorizing the sealing of the

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specific Protected Material at issue. If a Party’s request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information

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in the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60

days of a written request by the Designating Party, each Receiving Party must
return all Protected Material to the Producing Party or destroy such material. As

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used in this subdivision, “all Protected Material” includes all copies, abstracts,

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compilations, summaries, and any other format reproducing or capturing any of the
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Protected Material. Whether the Protected Material is returned or destroyed, the

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Receiving Party must submit a written certification to the Producing Party (and, if

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not the same person or entity, to the Designating Party) by the 60 day deadline that

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(1) identifies (by category, where appropriate) all the Protected Material that was

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returned or destroyed and (2) affirms that the Receiving Party has not retained any

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copies, abstracts, compilations, summaries or any other format reproducing or

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capturing any of the Protected Material. Notwithstanding this provision, Counsel

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are entitled to retain an archival copy of all pleadings, motion papers, trial,

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deposition, and hearing transcripts, legal memoranda, correspondence, deposition

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and trial exhibits, expert reports, attorney work product, and consultant and expert

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work product, even if such materials contain Protected Material. Any such archival

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copies that contain or constitute Protected Material remain subject to this Protective

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Order as set forth in Section 4 (DURATION).
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14.

VIOLATION

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Any violation of this Order may be punished by appropriate measures including,

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without limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: February 17, 2021

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Lauren Tegan Rodkey, (SBN: 275830)
Price Law Group, APC
6345 Balboa Boulevard, Suite 247
Encino, CA 91316
T: [phone]
E: [e-mail]
Attorneys for Plaintiff, Anthony Sunseri

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DATED: February 17, 2021

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By: s/ Jenna Dakroub
Jenna Dakroub, MN #0401650
(admitted pro hac vice)
Price Law Group, APC
8245 N. 85th Way
Scottsdale, AZ 85258
T: [phone]
E: [e-mail]

By: s/ Jennifer Sun
Jennifer Sun
JONES DAY
Counsel for Defendant
Experian Information Solutions, Inc.

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: February 17, 2021

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_____________________________________
HON. ROZELLA A. OLIVER
United States Magistrate Judge

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SIGNATURE CERTIFICATION 

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Pursuant to L.R. 5-4.3.4(a)(2), I hereby certify that all other signatories listed,

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on whose behalf this filing is submitted, concur with the contents of this filing and

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have authorized the filing.  
By: s/ Jenna Dakroub
Jenna Dakroub, MN #0401650
(admitted pro hac vice)
Price Law Group, APC
8245 N. 85th Way
Scottsdale, AZ 85258
T: [phone]
F: [phone]
E: [e-mail]

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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [print or type full name], of
_________________ [print or type full address], declare under penalty of perjury

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that I have read in its entirety and understand the Stipulated Protective Order that was

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issued by the United States District Court for the Central District of California on

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_________________ [date] in the case of Anthony Sunseri v. Experian Information

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Solutions, Inc., et al., Case No.: 2:20-cv-08932-MCS-RAO. I agree to comply with

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and to be bound by all the terms of this Stipulated Protective Order and I understand

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and acknowledge that failure to so comply could expose me to sanctions and

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punishment in the nature of contempt. I solemnly promise that I will not disclose in

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any manner any information or item that is subject to this Stipulated Protective Order

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to any person or entity except in strict compliance with the provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for enforcing the terms of this Stipulated

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Protective Order, even if such enforcement proceedings occur after termination of

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this action. I hereby appoint __________________________ [print or type full

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name] of _______________________________________ [print or type full address

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and telephone number] as my California agent for service of process in connection

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with this action or any proceedings related to enforcement of this Stipulated

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Protective Order.
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Date: ______________________________________

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City and State where sworn and signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________

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