even stipulated protective 23 orders require good cause showing
How later courts described this case
- even stipulated protective 23 orders require good cause showing
Written by the judges who cited it.
The opinion
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9 UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
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STEPHANIE KUBACKI; Case No.: 2:25-cv-04877-CBM-MAR
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13 Plaintiffs, STIPULATED PROTECTIVE
ORDER AND [PROPOSED]
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vs. ORDER
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NEWREZ LLC, d/b/a
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SHELLPOINT MORTGAGE
17 SERVICING; EXPERIAN
INFORMATION SOLUTIONS,
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INC.; and DOES 1-10 inclusive,
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20 Defendants.
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24 IT IS HEREBY STIPULATED and agreed by Plaintiff Stephanie Kubacki
25 (“Plaintiff”) and Defendants Newrez, LLC dba Shellpoint Mortgage Servicing
26 (“Newrez”) and Experian Information Solutions, Inc. (“Experian”) (collectively
27 “Defendants”) (Plaintiff and Defendants are individually a “Party” and collectively
1 the “Parties”), through their undersigned counsel of record, that discovery,
2 disclosure, and use of specified private, privileged, proprietary, and/or confidential
3 information in this lawsuit entitled Kubacki v. Newrez LLC, et al., Central District of
4 California, Case No. 2:25-cv-04877-CBM-MAR (the “lawsuit” or “action”) shall be
5 had on the following terms:
6 1. PURPOSES AND LIMITATIONS
7 1.1 Disclosure and discovery activity in this action are likely to involve
8 production of confidential, proprietary, or private information for which special
9 protection from public disclosure and from use for any purpose other than prosecuting
10 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
11 petition the court to enter the following Stipulated Protective Order. The parties
12 acknowledge that this Order does not confer blanket protections on all disclosures or
13 responses to discovery and that the protection it affords from public disclosure and
14 use extends only to the limited information or items that are entitled to confidential
15 treatment under the applicable legal principles. The parties further acknowledge, as
16 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
17 them to file confidential information under seal; Local Civil Rule 79-5 sets forth the
18 procedures that must be followed and the standards applied when a party seeks
19 permission from the court to file material under seal.
20 1.2 This action is likely to involve trade secrets, customer and pricing lists
21 and other valuable research, development, commercial, financial, technical and/or
22 proprietary information for which special protection from public disclosure and from
23 use for any purpose other than prosecution of this action is warranted. Such
24 confidential and proprietary materials and information consist of, among other things,
25 confidential business or financial information, information regarding confidential
26 business practices, or other confidential research, development, or commercial
27 information (including information implicating privacy rights of third parties),
1 or otherwise protected from disclosure under state or federal statutes, court rules, case
2 decisions, or common law. Accordingly, to expedite the flow of information, to
3 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
4 to adequately protect information the parties are entitled to keep confidential, to
5 ensure that the parties are permitted reasonable necessary uses of such material in
6 preparation for and in the conduct of trial, to address their handling at the end of the
7 litigation, and serve the ends of justice, a protective order for such information is
8 justified in this matter. It is the intent of the parties that information will not be
9 designated as confidential for tactical reasons and that nothing be so designated
10 without a good faith belief that it has been maintained in a confidential, non-public
11 manner, and there is good cause why it should not be part of the public record of this
12 case.
13 1.3 The parties further acknowledge, as set forth in Section 12.3, below, that
14 this Stipulated Protective Order does not entitle them to file confidential information
15 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and
16 the standards that will be applied when a party seeks permission from the court to file
17 material under seal. There is a strong presumption that the public has a right of access
18 to judicial proceedings and records in civil cases. In connection with non-dispositive
19 motions, good cause must be shown to support a filing under seal. See Kamakana v.
20 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
21 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
22 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
23 orders require good cause showing), and a specific showing of good cause or
24 compelling reasons with proper evidentiary support and legal justification, must be
25 made with respect to Protected Material that a party seeks to file under seal. The
26 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
27 does not— without the submission of competent evidence by declaration, establishing
1 otherwise protectable—constitute good cause.
2 Further, if a party requests sealing related to a dispositive motion or trial, then
3 compelling reasons, not only good cause, for the sealing must be shown, and the relief
4 sought shall be narrowly tailored to serve the specific interest to be protected. See
5 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
6 or type of information, document, or thing sought to be filed or introduced under seal,
7 the party seeking protection must articulate compelling reasons, supported by specific
8 facts and legal justification, for the requested sealing order. Again, competent
9 evidence supporting the application to file documents under seal must be provided by
10 declaration.
11 Any document that is not confidential, privileged, or otherwise protectable in
12 its entirety will not be filed under seal if the confidential portions can be redacted. If
13 documents can be redacted, then a redacted version for public viewing, omitting only
14 the confidential, privileged, or otherwise protectable portions of the document, shall
15 be filed. Any application that seeks to file documents under seal in their entirety
16 should include an explanation of why redaction is not feasible.
17 2. DEFINITIONS
18 2.1 Challenging Party: a Party or Non-Party that challenges the designation
19 of information or items under this Order.
20 2.2 “CONFIDENTIAL” Information or Items: information (regardless of
21 how it is generated, stored or maintained) or tangible things that qualify for such
22 protection either under California law or the standards developed under Federal Rules
23 of Civil Procedure 26(c).
24 2.3 Counsel (without qualifier): Outside Counsel of Record and House
25 Counsel (as well as their support staff).
26 2.4 Designating Party: a Party or Non-Party that designates information or
27 items that it produces in disclosures or in responses to discovery as
1 2.5 Disclosure or Discovery Material: all items or information, regardless
2 of the medium or manner in which it is generated, stored, or maintained (including,
3 among other things, testimony, transcripts, and tangible things), that are produced or
4 generated in disclosures or responses to discovery in this matter.
5 2.6 Expert: a person with specialized knowledge or experience in a matter
6 pertinent to the litigation who has been retained by a Party or its counsel to serve as
7 an expert witness or as a consultant in this action.
8 2.7 House Counsel: attorneys who are employees of a party to this action.
9 House Counsel does not include Outside Counsel of Record or any other outside
10 counsel.
11 2.8 Non-Party: any natural person, partnership, corporation, association, or
12 other legal entity not named as a Party to this action.
13 2.9 Outside Counsel of Record: attorneys who are not employees of a party
14 to this action but are retained to represent or advise a party to this action and have
15 appeared in this action on behalf of that party or are affiliated with a law firm which
16 has appeared on behalf of that party.
17 2.10 Party: any party to this action, including all of its officers, directors,
18 employees, consultants, retained experts, and Outside Counsel of Record (and their
19 support staffs).
20 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
21 Discovery Material in this action.
22 2.12 Professional Vendors: persons or entities that provide litigation support
23 services (e.g., photocopying, videotaping, translating, preparing exhibits or
24 demonstrations, and organizing, storing, or retrieving data in any form or medium)
25 and their employees and subcontractors.
26 2.13 Protected Material: any Disclosure or Discovery Material that is
27 designated as “CONFIDENTIAL.”
1 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
2 from a Producing Party.
3 3. SCOPE
4 The protections conferred by this Stipulation and Order cover not only
5 Protected Material (as defined above), but also (1) any information copied or extracted
6 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
7 Protected Material; and (3) any testimony, conversations, or presentations by Parties
8 or their Counsel that might reveal Protected Material. However, the protections
9 conferred by this Stipulation and Order do not cover the following information: (a)
10 any information that is in the public domain at the time of disclosure to a Receiving
11 Party or becomes part of the public domain after its disclosure to a Receiving Party
12 as a result of publication not involving a violation of this Order, including becoming
13 part of the public record through trial or otherwise; and (b) any information known to
14 the Receiving Party prior to the disclosure or obtained by the Receiving Party after
15 the disclosure from a source who obtained the information lawfully and under no
16 obligation of confidentiality to the Designating Party.
17 4. DURATION
18 Even after final disposition of this litigation, the confidentiality obligations
19 imposed by this Stipulated Protective Order shall remain in effect until a Designating
20 Party agrees otherwise in writing or a court order otherwise directs. Final disposition
21 shall be deemed to be the later of (1) dismissal of all claims and defenses in this action,
22 with or without prejudice; and (2) final judgment herein after the completion and
23 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
24 including the time limits for filing any motions or applications for extension of time
25 pursuant to applicable law.
26 5. DESIGNATING PROTECTED MATERIAL
27 5.1 Exercise of Restraint and Care in Designating Material for Protection.
1 Order must take care to limit any such designation to specific material that qualifies
2 under the appropriate standards. The Designating Party must designate for protection
3 only those parts of material, documents, items, or oral or written communications that
4 qualify – so that other portions of the material, documents, items, or communications
5 for which protection is not warranted are not swept unjustifiably within the ambit of
6 this Stipulated Protective Order.
7 Mass, indiscriminate, or routinized designations are prohibited. Designations
8 that are shown to be clearly unjustified or that have been made for an improper
9 purpose (e.g., to unnecessarily encumber or retard the case development process or to
10 impose unnecessary expenses and burdens on other parties) expose the Designating
11 Party to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection, that Designating Party must
14 promptly notify all other Parties that it is withdrawing the mistaken designation.
15 5.2 Manner and Timing of Designations. Except as otherwise provided in
16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
18 under this Order must be clearly so designated before the material is disclosed or
19 produced.
20 Designation in conformity with this Order requires:
21 (a) for information in documentary form (e.g., paper or electronic documents,
22 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
23 Producing Party affix the legend “CONFIDENTIAL” to each page that contains
24 protected material. If only a portion or portions of the material on a page qualifies for
25 protection, the Producing Party also must clearly identify the protected portion(s)
26 (e.g., by making appropriate markings in the margins).
27 A Party or Non-Party that makes original documents or materials available for
1 indicated which material it would like copied and produced. During the inspection
2 and before the designation, all of the material made available for inspection shall be
3 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
4 it wants copied and produced, the Producing Party must determine which documents,
5 or portions thereof, qualify for protection under this Order. Then, before producing
6 the specified documents, the Producing Party must affix the “CONFIDENTIAL”
7 legend to each page that contains Protected Material. If only a portion or portions of
8 the material on a page qualifies for protection, the Producing Party also must clearly
9 identify the protected portion(s) (e.g., by making appropriate markings in the
10 margins).
11 (b) for testimony given in deposition or in other pretrial or trial proceedings,
12 that the Designating Party identify on the record, before the close of the deposition,
13 hearing, or other proceeding, or identify all protective testimony within 30 days
14 receipt of a certified transcript all protected testimony.
15 (c) for information produced in some form other than documentary and for any
16 other tangible items, that the Producing Party affix in a prominent place on the exterior
17 of the container or containers in which the information or item is stored the legend
18 “CONFIDENTIAL.” If only a portion or portions of the information or item warrant
19 protection, the Producing Party, to the extent practicable, shall identify the protected
20 portion(s).
21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
22 failure to designate qualified information or items does not, standing alone, waive the
23 Designating Party’s right to secure protection under this Stipulated Protective Order
24 for such material. Upon timely correction of a designation, the Receiving Party must
25 make reasonable efforts to assure that the material is treated in accordance with the
26 provisions of this Order.
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1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
3 designation of confidentiality at any time. Unless a prompt challenge to a Designating
4 Party’s confidentiality designation is necessary to avoid foreseeable, substantial
5 unfairness, unnecessary economic burdens, or a significant disruption or delay of the
6 litigation, a Party does not waive its right to challenge a confidentiality designation
7 by electing not to mount a challenge promptly after the original designation is
8 disclosed.
9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
10 resolution process by providing written notice of each designation it is challenging
11 and describing the basis for each challenge. To avoid ambiguity as to whether a
12 challenge has been made, the written notice must recite that the challenge to
13 confidentiality is being made in accordance with this specific paragraph of the
14 Protective Order. The parties shall attempt to resolve each challenge in good faith and
15 must begin the process by conferring directly (in voice to voice dialogue; other forms
16 of communication are not sufficient) within 14 days of the date of service of notice.
17 In conferring, the Challenging Party must explain the basis for its belief that the
18 confidentiality designation was not proper and must give the Designating Party an
19 opportunity to review the designated material, to reconsider the circumstances, and,
20 if no change in designation is offered, to explain the basis for the chosen designation.
21 A Challenging Party may proceed to the next stage of the challenge process only if it
22 has engaged in this meet and confer process first or establishes that the Designating
23 Party is unwilling to participate in the meet and confer process in a timely manner.
24 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without
25 court intervention, the Challenging Party may file a motion challenging a
26 confidentiality designation within 14 days of the parties agreeing that the meet and
27 confer process will not resolve their dispute, including a challenge to the designation
1 provision must be accompanied by a competent declaration affirming that the movant
2 has complied with the meet and confer requirements imposed by the preceding
3 paragraph.
4 The burden of persuasion in any such challenge proceeding shall be on the
5 Designating Party. Frivolous challenges, and those made for an improper purpose
6 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
7 expose the Challenging Party to sanctions. Unless the Designating Party has waived
8 the confidentiality designation by failing to file a motion to retain confidentiality as
9 described above, all parties shall continue to afford the material in question the level
10 of protection to which it is entitled under the Producing Party’s designation until the
11 court rules on the challenge.
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this case
15 only for prosecuting, defending, or attempting to settle this litigation. Such Protected
16 Material may be disclosed only to the categories of persons and under the conditions
17 described in this Order. When the litigation has been terminated, a Receiving Party
18 must comply with the provisions of section 13 below (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 location and in a secure manner that ensures that access is limited to the persons
21 authorized under this Stipulated Protective Order.
22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
23 otherwise ordered by the Court or permitted in writing by the Designating Party, a
24 Receiving Party may disclose any information or item designated
25 “CONFIDENTIAL” only to:
26 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as
27 employees of said Outside Counsel of Record to whom it is reasonably necessary to
1 (b) the officers, directors, and employees (including House Counsel) of the
2 Receiving Party to whom disclosure is reasonably necessary for this litigation);
3 (c) Experts (as defined in this Order) of the Receiving Party to whom
4 disclosure is reasonably necessary for this litigation and who have signed the
5 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A;
6 (d) the court, its personnel, and court reporters;
7 (e) court reporters and their staff, professional jury or trial consultants, mock
8 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
9 litigation and who have signed the “Acknowledgment and Agreement to Be Bound”
10 that is attached hereto as Exhibit A;
11 (f) during their depositions, witnesses in the action to whom disclosure is
12 reasonably necessary and who have signed the “Acknowledgment and Agreement to
13 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered
14 by the court. Pages of transcribed deposition testimony or exhibits to depositions that
15 reveal Protected Material must be separately bound by the court reporter and may not
16 be disclosed to anyone except as permitted under this Stipulated Protective Order.
17 (g) the author or recipient of a document containing the information or a
18 custodian or other person who otherwise possessed or knew the information.
19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
20 OTHER LITIGATION
21 If a Party is served with a subpoena or a court order issued in other litigation
22 that compels disclosure of any information or items designated in this action as
23 “CONFIDENTIAL” that Party must:
24 (a) promptly notify in writing the Designating Party. Such notification shall
25 include a copy of the subpoena or court order;
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1 (b) promptly notify in writing the party who caused the subpoena or order to
2 issue in the other litigation that some or all of the material covered by the subpoena
3 or order is subject to this Protective Order. Such notification shall include a copy of
4 this Stipulated Protective Order; and
5 (c) cooperate with respect to all reasonable procedures sought to be pursued
6 by the Designating Party whose Protected Material may be affected.
7 If the Designating Party timely seeks a protective order, the Party served with
8 the subpoena or court order shall not produce any information designated in this action
9 as “CONFIDENTIAL” before a determination by the court from which the subpoena
10 or order issued, unless the Party has obtained the Designating Party’s permission. The
11 Designating Party shall bear the burden and expense of seeking protection in that court
12 of its confidential material – and nothing in these provisions should be construed as
13 authorizing or encouraging a Receiving Party in this action to disobey a lawful
14 directive from another court.
15 9. NON-PARTY’S PROTECTED MATERIAL PRODUCED IN THIS
16 LITIGATION
17 (a) The terms of this Order are applicable to information produced by a Non-
18 Party in this action and designated as “CONFIDENTIAL.” Such information
19 produced by Non-Parties in connection with this litigation is protected by the
20 remedies and relief provided by this Stipulated Protective Order. Nothing in these
21 provisions should be construed as prohibiting a Non-Party from seeking additional
22 protections.
23 (b) In the event that a Party is required, by a valid discovery request, to produce
24 a Non-Party’s confidential information in its possession, and the Party is subject to an
25 agreement with the Non-Party not to produce the Non-Party’s confidential
26 information, then the Party shall:
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1 (1) promptly notify in writing the Requesting Party and the Non-Party
2 that some or all of the information requested is subject to a confidentiality
3 agreement with a Non-Party;
4 (2) promptly provide the Non-Party with a copy of the Stipulated
5 Protective Order in this litigation, the relevant discovery request(s), and a
6 reasonably specific description of the information requested; and
7 (3) make the information requested available for inspection by the
8 Non-Party.
9 (c) If the Non-Party fails to object or seek a protective order from this Court
10 within 14 days of receiving the notice and accompanying information, the Receiving
11 Party may produce the Non-Party’s confidential information responsive to the
12 discovery request. If the Non-Party timely seeks a protective order, the Receiving
13 Party shall not produce any information in its possession or control that is subject to
14 the confidentiality agreement with the Non-Party before a determination by the Court.
15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
16 of seeking protection in this court of its Protected Material.
17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
19 Protected Material to any person or in any circumstance not authorized under this
20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
23 persons to whom unauthorized disclosures were made of all the terms of this Order,
24 and (d) request such person or persons to execute the “Acknowledgment and
25 Agreement to Be Bound” that is attached hereto as Exhibit A.
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1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
2 PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other protection,
5 Receiving Parties must promptly return, sequester, or destroy the specified
6 information and any copies it has, must not use or disclose the information until the
7 claim is resolved, must take reasonable steps to retrieve the information if the party
8 disclosed it before being notified, and may promptly present the information to the
9 Court under seal for a determination of the claim. The Receiving Party must preserve
10 the information until the claim is resolved. This provision is not intended to modify
11 whatever procedure may be established in an e-discovery order that provides for
12 production without prior privilege review.
13 12. MISCELLANEOUS
14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
15 person to seek its modification by the court in the future.
16 12.2 Right to Assert Other Objections. By stipulating to the entry of this
17 Protective Order no Party waives any right it otherwise would have to object to
18 disclosing or producing any information or item on any ground not addressed in this
19 Stipulated Protective Order. Similarly, no Party waives any right to object on any
20 ground to use in evidence of any of the material covered by this Protective Order.
21 12.3 Filing Protected Material. Without written permission from the
22 Designating Party or a court order secured after appropriate notice to all interested
23 persons, a Party may not file in the public record in this action any Protected Material.
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1 13. FINAL DISPOSITION
2 Within 60 days after the final disposition of this action, as defined in paragraph
3 4, each Receiving Party must return all Protected Material to the Producing Party or
4 destroy such material. As used in this subdivision, “all Protected Material” includes
5 all copies, abstracts, compilations, summaries, and any other format reproducing or
6 capturing any of the Protected Material. Whether the Protected Material is returned
7 or destroyed, the Receiving Party must submit a written certification to the Producing
8 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
9 deadline that (1) identifies (by category, where appropriate) all the Protected Material
10 that was returned or destroyed and (2) affirms that the Receiving Party has not
11 retained any copies, abstracts, compilations, summaries or any other format
12 reproducing or capturing any of the Protected Material. Notwithstanding this
13 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
14 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
15 deposition and trial exhibits, expert reports, attorney work product, and consultant
16 and expert work product, even if such materials contain Protected Material. Any such
17 archival copies that contain or constitute Protected Material remain subject to this
18 Protective Order as set forth in Section 4 (DURATION).
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1/}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
December 17, 2025
4||| HOUSER LLP LAW OFFICES OF TODD M.
FRIEDMAN, P.C.
/s/ Timothy A. Schneider
6 ||| Timothy A. Schneider /s/ Todd Friedman
Attorneys for Defendant, Newrez, Todd Friedman
711) LLC dba Shellpoint Mortgage Attorneys for Plaintiff, Stephanie
g ||| Servicing Kubacki
? ||| TROUTMAN PEPPER LOCKE
||| LLP
IT Ryan A. Lewis
□□□ Ryan A. Lewis
Attorneys for Defendant, Experian
taformation Solutions, Inc.
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6 IT IS SO ORDERED.
17|| Dated: 1/26/2026
18 HON. MARGO A. ROCCONI
United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, ____________________________________(print or type full name), of
4 _____________________________ (print or type full
5 address), declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court, Central District of California on ________________, 2025 in the case
8 of Kubacki v. Newrez LLC, et al., Central District of California, Case No. 2:25-cv-
9 04877-CBM-MAR, I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court,
16 Central District of California for the purpose of enforcing the terms of this Stipulated
17 Protective Order, even if such enforcement proceedings occur after termination of this
18 action.
19 I hereby appoint (print or type full name) of _________________ (print or type
20 full address and telephone number) as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 City and State where sworn and signed:
24
25 Printed name:
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27 Signature: