Opinion

Court: District Court, C.D. California
Filed: Jan 8, 2026
Cited by: 0 cases
Authority: More cited than 38.2%

even stipulated 14 protective orders require good cause showing

How later courts described this case

even stipulated 14 protective orders require good cause showing

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

Case No. 2:25-cv-04799

5 SEAN LEONARD

6 Plaintiff,

STIPULATED PROTECTIVE

7 v. ORDER1

8 NAVY FEDERAL CREDIT

9 UNION; EARLY WARNING

SERVICES, LLC,

Defendants.

13 1. INTRODUCTION

1.1 Purposes and Limitations. Discovery in this action is likely to

involve production of confidential, proprietary, or private information for

which special protection from public disclosure and from use for any

purpose other than prosecuting this litigation may be warranted.

Accordingly, the parties hereby stipulate to and petition the court to

enter the following Stipulated Protective Order. The parties

acknowledge that this Order does not confer blanket protections on all

disclosures or responses to discovery and that the protection it affords

from public disclosure and use extends only to the limited information or

1 This Stipulated Protective Order is substantially based on the model

protective order provided under Magistrate Judge Stephanie S.

1 items that are entitled to confidential treatment under the applicable

2 legal principles.

3 1.2 Good Cause Statement. This action is likely to involve trade

4 secrets, customer and pricing lists and other valuable research,

5 development, commercial, financial, technical and/or proprietary

6 information for which special protection from public disclosure and from

7 use for any purpose other than prosecution of this action is warranted.

8 Such confidential and proprietary materials and information consist of,

among other things, confidential business or financial information,

information regarding confidential business practices, or other

confidential research, development, or commercial information (including

information implicating privacy rights of third parties), information

otherwise generally unavailable to the public, or which may be privileged

or otherwise protected from disclosure under state or federal statutes,

court rules, case decisions, or common law. Accordingly, to expedite the

flow of information, to facilitate the prompt resolution of disputes over

confidentiality of discovery materials, to adequately protect information

the parties are entitled to keep confidential, to ensure that the parties

are permitted reasonable necessary uses of such material in preparation

for and in the conduct of trial, to address their handling at the end of the

22 litigation, and serve the ends of justice, a protective order for such

23 information is justified in this matter. It is the intent of the parties that

24 information will not be designated as confidential for tactical reasons

25 and that nothing be so designated without a good faith belief that it has

26 been maintained in a confidential, non-public manner, and there is good

27 cause why it should not be part of the public record of this case.

1 1.3 Acknowledgment of Procedure for Filing Under Seal. The

2 parties further acknowledge, as set forth in Section 12.3, below, that this

3 Stipulated Protective Order does not entitle them to file confidential

4 information under seal; Local Rule 79-5 sets forth the procedures that

5 must be followed and the standards that will be applied when a party

6 seeks permission from the court to file material under seal.

7 There is a strong presumption that the public has a right of access

8 to judicial proceedings and records in civil cases. In connection with

non-dispositive motions, good cause must be shown to support a filing

under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

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

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

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

good cause or compelling reasons with proper evidentiary support and

legal justification, must be made with respect to Protected Material that

a party seeks to file under seal. The parties’ mere designation of

Disclosure or Discovery Material as “Confidential” or “Confidential-

Attorneys’ Eyes Only” does not—without the submission of competent

evidence by declaration, establishing that the material sought to be filed

22 under seal qualifies as confidential, privileged, or otherwise

23 protectable—constitute good cause.

24 Further, if a party requests sealing related to a dispositive motion

25 or trial, then compelling reasons, not only good cause, for the sealing

26 must be shown, and the relief sought shall be narrowly tailored to serve

27 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

1 information, document, or thing sought to be filed or introduced under

2 seal in connection with a dispositive motion or trial, the party seeking

3 protection must articulate compelling reasons, supported by specific

4 facts and legal justification, for the requested sealing order. Again,

5 competent evidence supporting the application to file documents under

6 seal must be provided by declaration.

7 Any document that is not confidential, privileged, or otherwise

8 protectable in 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 only the confidential, privileged, or

otherwise protectable portions of the document, shall be filed. Any

application that seeks to file documents under seal in their entirety

should include an explanation of why redaction is not feasible.

2. DEFINITIONS

2.1 Action: this pending federal lawsuit.

2.2 Challenging Party: a Party or Non-Party that challenges the

19 designation of information or items under this Order.

20 2.3 “Confidential Material”: information (regardless of how it is

21 generated, stored or maintained) or tangible things that qualify for

22 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and

23 as specified above in the Good Cause Statement.

24 2.4 “Confidential-Attorneys’ Eyes Only” information means

25 Confidential Material that falls within one or more of the following

26 categories:

1 a. Trade secrets information, including a formula, pattern,

2 compilation, program, device, method, technique, process, financial data,

3 or list of actual or potential customers or suppliers, that derives

4 independent economic value, actual or potential, from not being generally

5 known to, and not being readily ascertainable by proper means by, other

6 persons who can obtain economic value from its disclosure or use;

7 b. Highly sensitive financial, commercial, and marketing

8 information relating to the Parties’ respective products and/or business

9 activities.

10 2.5 “Confidential” information means all other Confidential

11 Material that does not constitute Confidential-Attorneys’ Eyes Only

12 information, including but not limited to:

(a) Research and development information;

(b) Information prohibited from disclosure by statute;

(d) Personal identity information;

(e) Income tax returns (including attached schedules and

forms, W-2 forms and 1099 forms); or

(f) Personnel or employment records of a person who is not

a Party to the case.

21 2.6 Counsel: Outside Counsel of Record and House Counsel (as

22 well as their support staff).

23 2.7 Designating Party: a Party or Non-Party that designates

24 information or items that it produces in disclosures or in responses to

25 discovery as “Confidential” or “Confidential-Attorneys’ Eyes Only.”

2.8 Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or

1 maintained (including, among other things, testimony, transcripts, and

2 tangible things), that are produced or generated in disclosures or

3 responses to discovery in this matter.

4 2.9 Expert: a person with specialized knowledge or experience in

5 a matter pertinent to the litigation who has been retained by a Party or

6 its counsel to serve as an expert witness or as a consultant in this Action.

7 2.10 Final Disposition: the later of (1) dismissal of all claims and

8 defenses in this Action, with or without prejudice; and (2) final judgment

herein after the completion and exhaustion of all appeals, rehearings,

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

filing any motions or applications for extension of time pursuant to

applicable law.

2.11 In-House Counsel: attorneys who are employees of a party to

this Action. In-House Counsel does not include Outside Counsel of

Record or any other outside counsel.

2.12 Non-Party: any natural person, partnership, corporation,

association, or other legal entity not named as a Party to this action.

2.13 Outside Counsel of Record: attorneys who are not employees

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

this Action and have appeared in this Action on behalf of that party or

22 are affiliated with a law firm which has appeared on behalf of that party,

23 and includes support staff.

24 2.14 Party: any party to this Action, including all of its officers,

25 directors, employees, consultants, retained experts, and Outside Counsel

26 of Record (and their support staffs).

27 2.15 Producing Party: a Party or Non-Party that produces

1 2.16 Professional Vendors: persons or entities that provide

2 litigation- support services (e.g., photocopying, videotaping, translating,

3 preparing exhibits or demonstrations, and organizing, storing, or

4 retrieving data in any form or medium) and their employees and

5 subcontractors.

6 2.17 Protected Material: any Disclosure or Discovery Material that

7 is designated as “Confidential” or “Confidential-Attorneys’ Eyes Only.”

2.18 Receiving Party: a Party that receives Disclosure or Discovery

Material from a Producing Party.

3. SCOPE

The protections conferred by this Stipulation and Order cover not

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

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

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

testimony, conversations, or presentations by Parties or their Counsel

that might reveal Protected Material.

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

20 orders of the trial judge. This Stipulated Protective Order does not

21 govern the use of Protected Material at trial.

23 4. TRIAL AND DURATION

The terms of this Stipulated Protective Order apply through Final

Disposition of the Action.

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

“Confidential” or “Confidential-Attorneys’ Eyes Only” or maintained

1 pursuant to this Stipulated Protective Order and used or introduced as

2 an exhibit at trial becomes public and will be presumptively available to

3 all members of the public, including the press, unless compelling

4 reasons supported by specific factual findings to proceed otherwise are

5 made to the trial judge in advance of the trial. See Kamakana, 447 F.3d

6 at 1180–81 (distinguishing “good cause” showing for sealing documents

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

8 related documents are part of court record). Accordingly, for such

materials, the terms of this Stipulated Protective Order do not extend

beyond the commencement of the trial.

Even after Final Disposition of this litigation, the confidentiality

obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

order otherwise directs.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for

19 Protection. Each Party or Non-Party that designates information or

20 items for protection under this Order must take care to limit any such

21 designation to specific material that qualifies under the appropriate

22 standards. The Designating Party must designate for protection only

23 those parts of material, documents, items, or oral or written

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

25 documents, items, or communications for which protection is not

26 warranted are not swept unjustifiably within the ambit of this Order.

27 Mass, indiscriminate, or routinized designations are prohibited.

1 Designations that are shown to be clearly unjustified or that have been

2 made for an improper purpose (e.g., to unnecessarily encumber the case

3 development process or to impose unnecessary expenses and burdens on

4 other parties) may expose the Designating Party to sanctions.

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

6 items that it designated for protection do not qualify for protection, that

7 Designating Party must promptly notify all other Parties that it is

8 withdrawing the inapplicable designation.

5.2 Manner and Timing of Designations. Except as otherwise

provided in this Stipulated Protective Order (see, e.g., second paragraph

of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

or Discovery Material that qualifies for protection under this Stipulated

Protective Order must be clearly so designated before the material is

disclosed or produced.

Designation in conformity with this Stipulated Protective Order

requires:

18 (a) for information in documentary form (e.g., paper or electronic

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

20 trial proceedings), that the Producing Party affix at a minimum, the

21 legend “Confidential” or “Confidential-Attorneys’ Eyes Only” to each

22 page that contains protected material. If only a portion or portions of

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

24 must clearly identify the protected portion(s) (e.g., by making

25 appropriate markings in the margins).

26 A Party or Non-Party that makes original documents available for

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 Confidential

4 or Confidential-Attorneys’ Eyes Only. After the inspecting Party has

5 identified the documents it wants copied and produced, the Producing

6 Party must determine which documents, or portions thereof, qualify for

7 protection under this Stipulated Protective Order. Then, before

8 producing the specified documents, the Producing Party must affix the

“Confidential” or “Confidential-Attorneys’ Eyes Only” legend to each

page that contains Protected Material. If only a portion or portions of

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

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

identify the Disclosure or Discovery Material on the record, before the

close of the deposition all protected testimony.

documentary and for any other tangible items, that the Producing Party

affix in a prominent place on the exterior of the container or containers

in which the information is stored the “Confidential” or “Confidential-

22 Attorneys’ Eyes Only” legend. If only a portion or portions of the

23 information warrants protection, the Producing Party, to the extent

24 practicable, shall identify the protected portion(s).

25 5.3 Inadvertent Failures to Designate. If timely corrected, an

26 inadvertent failure to designate qualified information or items does not,

standing alone, waive the Designating Party’s right to secure protection

1 under this Order for such material. Upon timely correction of a

2 designation, the Receiving Party must make reasonable efforts to assure

3 that the material is treated in accordance with the provisions of this

4 Stipulated Protective Order.

6 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 Rule 37.1 et seq. and with

Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

Discovery Motion Conference.”2

6.3 The burden of persuasion in any such challenge proceeding

shall be on the Designating Party. Frivolous challenges, and those

made for an improper purpose (e.g., to harass or impose unnecessary

expenses and burdens on other parties) may expose the Challenging

19 Party to sanctions. Unless the Designating Party has waived or

20 withdrawn the confidentiality designation, all parties shall continue to

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

22 entitled under the Producing Party’s designation until the court rules on

23 the challenge.

24 //

25 //

2 Judge Christensen’s Procedures are available at

1 7. ACCESS TO AND USE OF PROTECTED MATERIAL

2 7.1 Basic Principles. A Receiving Party may use Protected

3 Material that is disclosed or produced by another Party or by a Non-

4 Party in connection with this Action only for prosecuting, defending, or

attempting to settle this Action. Such Protected Material may be

disclosed only to the categories of persons and under the conditions

described in this Order. When the Action reaches a Final Disposition, a

Receiving Party must comply with the provisions of section 13 below.

Protected Material must be stored and maintained by a Receiving

Party at a location and in a secure manner that ensures that access is

limited to the persons authorized under this Stipulated Protective

Order.

7.2 Disclosure of “Confidential” 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 designated “Confidential” only:

18 (a) to the Receiving Party’s Outside Counsel of Record in this

19 Action, as well as employees of said Outside Counsel of Record to whom

20 it is reasonably necessary to disclose the information for this Action;

21 (b) to the officers, directors, and employees (including House

22 Counsel) of the Receiving Party to whom disclosure is reasonably

23 necessary for this Action;

24 (c) to Experts (as defined in this Order) of the Receiving Party to

25 whom disclosure is reasonably necessary for this Action and who have

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

(d) to the court and its personnel;

1 (e) to court reporters and their staff;

2 (f) to professional jury or trial consultants, mock jurors, and

3 Professional Vendors to whom disclosure is reasonably necessary for

4 this Action and who have signed the “Acknowledgment and Agreement

5 to Be Bound” (Exhibit A);

6 (g) to the author or recipient of a document containing the

7 information or a custodian or other person who otherwise possessed or

8 knew the information;

(h) during their depositions, to witnesses, and attorneys for

witnesses, in the Action to whom disclosure is reasonably necessary,

provided: (1) the deposing party requests that the witness sign the

“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

witness will not be permitted to keep any confidential information

unless they sign the “Acknowledgment and Agreement to Be Bound”

(Exhibit A), unless otherwise agreed by the Designating Party or

ordered by the court. Pages of transcribed deposition testimony or

exhibits to depositions that reveal Protected Material may be separately

bound by the court reporter and may not be disclosed to anyone except

as permitted under this Stipulated Protective Order; and

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

22 personnel, mutually agreed upon by any of the parties engaged in

23 settlement discussions.

24 7.3 Disclosure of “Confidential-Attorneys’ Eyes Only”

25 Information or Items: Unless otherwise ordered by the Court or

26 permitted in writing by the Designating Party, a Receiving Party may

27 only disclose any information or item designated “Confidential-

1 (a) the Receiving Party’s Outside Counsel of Record in this

2 Action, as well as employees of said Outside Counsel of Record to whom

3 it is reasonably necessary to disclose the information for this Action;

4 (b) the Receiving Party’s House Counsel;

5 (c) Experts (as defined in this Order) of the Receiving Party to

6 whom disclosure is reasonably necessary for this Action and who have

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

8 (d) the Court and its personnel;

(e) court reporters and their staff;

(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” (Ex. A);

(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) any mediator or settlement officer who may be utilized in

connection with this Action, and their supporting personnel, mutually

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

and

22 (i) any other person that the Designating Party agrees to in

23 writing.

24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

25 PRODUCED IN OTHER LITIGATION

26 If a Party is served with a subpoena or a court order issued in

27 other litigation that compels disclosure of any information or items

1 designated in this Action as “Confidential” or “Confidential-Attorneys’

2 Eyes Only,” that Party must:

3 (a) promptly notify in writing the Designating Party. Such

4 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 issue in the other litigation that some or all of the

material covered by the subpoena or order is subject to this Protective

Order. Such notification shall include a copy of this Stipulated

Protective Order; and

be pursued by the Designating Party whose Protected Material may be

affected.

If the Designating Party timely seeks a protective order, the

Party served with the subpoena or court order shall not produce any

information designated in this action as “Confidential” or “Confidential-

Attorneys’ Eyes Only” before a determination by the court from which

18 the subpoena or order issued, unless the Party has obtained the

19 Designating Party’s permission. The Designating Party shall bear the

20 burden and expense of seeking protection in that court of its confidential

21 material and nothing in these provisions should be construed as

22 authorizing or encouraging a Receiving Party in this Action to disobey a

23 lawful directive from another court.

25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

26 PRODUCED IN THIS LITIGATION

27 9.1 Application. The terms of this Stipulated Protective Order

1 are applicable to information produced by a Non-Party in this Action and

2 designated as “Confidential” or “Confidential-Attorneys’ Eyes Only.”

3 Such information produced by Non-Parties in connection with this

4 litigation is protected by the remedies and relief provided by this Order.

5 Nothing in these provisions should be construed as prohibiting a Non-

6 Party from seeking additional protections.

7 9.2 Notification. In the event that a Party is required, by a valid

8 discovery request, to produce a Non-Party’s confidential information in

its possession, and the Party is subject to an agreement with the Non-

Party not to produce the Non-Party’s confidential information, then the

Party shall:

(a) 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;

(b) make the information requested available for inspection by

the Non-Party, if requested.

9.3 Conditions of Production. 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 request.

22 If the Non-Party timely seeks a protective order, the Receiving Party

23 shall not produce any information in its possession or control that is

24 subject to the confidentiality agreement with the Non-Party before a

25 determination by the court. Absent a court order to the contrary, the

26 Non-Party shall bear the burden and expense of seeking protection in

27 this court of its Protected Material.

1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED

2 MATERIAL

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

4 has disclosed Protected Material to any person or in any circumstance

not authorized under this Stipulated Protective Order, the Receiving

Party must immediately (a) notify in writing the Designating Party of

the unauthorized disclosures, (b) use its best efforts to retrieve all

unauthorized copies of the Protected Material, (c) inform the person or

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

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

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

11. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

16 When a Producing Party gives notice to Receiving Parties that

17 certain inadvertently produced material is subject to a claim of privilege

18 or other protection, the obligations of the Receiving Parties are those set

19 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

20 provision is not intended to modify whatever procedure may be

established in an e-discovery order that provides for production without

prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

Rules of Evidence, insofar as the parties reach an agreement on the

effect of disclosure of a communication or information covered by the

attorney-client privilege or work product protection, the parties may

incorporate their agreement in the stipulated protective order

submitted to the court.

2 12. MISCELLANEOUS

3 12.1 Right to Further Relief. Nothing in this Stipulated

4 Protective Order abridges the right of any person to seek its

modification by the court in the future.

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

of this Stipulated Protective Order no Party waives any right it

otherwise would have to object to disclosing or producing any

information or item on any ground not addressed in this Stipulated

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

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

Stipulated Protective Order.

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

seal any Protected Material must comply with Local Rule 79-5.

Protected Material may only be filed under seal pursuant to a court

order authorizing the sealing of the specific Protected Material at issue.

If a Party's request to file Protected Material under seal is denied by the

19 court, then the Receiving Party may file the information in the public

20 record unless otherwise instructed by the court.

22 13. FINAL DISPOSITION

23 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 used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations,

1 summaries, and any other format reproducing or capturing any of the

2 Protected Material. Whether the Protected Material is returned or

3 destroyed, the Receiving Party must submit a written certification to

4 the Producing Party (and, if not the same person or entity, to the

5 Designating Party) by the 60 day deadline that (1) identifies (by

6 category, where appropriate) all the Protected Material that was

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

8 retained any copies, abstracts, compilations, summaries or any other

format reproducing or capturing any of the Protected Material.

Notwithstanding this provision, Counsel is entitled to retain an archival

copy of all pleadings, motion papers, trial, deposition, and hearing

transcripts, legal memoranda, correspondence, deposition and trial

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

expert work product, even if such materials contain Protected Material.

Any such archival copies that contain or constitute Protected Material

remain subject to this Protective Order as set forth in Section 4.

18 //

19 //

24 //

25 //

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.

6 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

g || Dated: January 7, 2026 KAZEROUNI LAW GROUP, APC

? By: /s/ Gor Antonyan, Esq.

10 Gor Antonyan, Esq.

Attorneys for Plaintiff

12 || Dated: January 7, 2026 TROUTMAN PEPPER LOCKE LLP

By: /s/ Jacob Kozaczuk, Esq.

14 Jacob Kozaczuk, Esq.

15 Attorneys for Defendant Navy

16 Federal Credit Union

17 || Dated: January 7, 2026 TROUTMAN PEPPER LOCKE LLP

8 By: /s/ Katalina Baumann, Esq.

19 Katalina Baumann, Esq.

0 Attorneys for Defendant Early

Warning Services LLC

|| FOR GOOD CAUSE SHOWN, IT IS SO O RED.

STEPHANIE 8. CHRISTENSEN

26 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

penalty of perjury that I have read in its entirety and understand the

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

case of Sean Leonard v. Navy Federal Credit Union et al.; Case No.

2:25-cv-04799-MRA-SSC. I agree to comply with and to be bound by all

the terms of this Stipulated Protective Order and I understand and

acknowledge that failure to so comply could expose me to sanctions

and punishment in the nature of contempt. I solemnly promise that I

14 will not disclose in any manner any information or item that is subject

15 to this Stipulated Protective Order to any person or entity except in

16 strict compliance with the 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] as

1 my California agent for service of process in connection with this action

2 or any proceedings related to enforcement of this Stipulated Protective

3 Order.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

8 Printed name: ___________________________

Signature: ___________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.