The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
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12 MUHAMAD AWADALLAH
13 Plaintiff, Case No. 2:26-cv-01822-MEMF-AJR
14 v. [PROPOSED] STIPULATED
PROTECTIVE ORDER
15 EXPERIAN INFORMATION
SOLUTIONS, INC., TRANS UNION,
16 LLC, and GOLDMAN SACHS BANK,
USA,
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Defendants.
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20 1. GENERAL
21 1.1 Purposes and Limitations. Discovery in this action is likely to involve
22 production of confidential, proprietary, or private information for which special
23 protection from public disclosure and from use for any purpose other than
24 prosecuting this litigation may be warranted. Accordingly, the parties hereby
25 stipulate to and petition the Court to enter the following Stipulated Protective Order.
26 The parties acknowledge that this Order does not confer blanket protections on all
27 disclosures or responses to discovery and that the protection it affords from public
28 disclosure and use extends only to the limited information or items that are entitled
1 to confidential treatment under the applicable legal principles. The parties further
2 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
3 does not entitle them to file confidential information under seal; Civil Local Rule 79-
4 5 sets forth the procedures that must be followed and the standards that will be
5 applied when a Party seeks permission from the court to file material under seal.
6 1.2 Good Cause Statement. This action is likely to involve trade secrets,
7 internally developed policies and procedures, confidential logs and business records,
8 customer personal information and other valuable research, commercial, financial,
9 technical and/or proprietary information for which special protection from public
10 disclosure and from use for any purpose other than prosecution of this action is
11 warranted. Such confidential and proprietary materials and information consist of,
12 among other things, confidential business or financial information (including
13 documentation related to customer data, consumer credit accounts and credit reports,
14 as well as records of proprietary bank operations, policies, and procedures),
15 information regarding confidential business practices, or other confidential research,
16 development, or commercial information (including information implicating privacy
17 rights of third parties), information otherwise generally unavailable to the public, or
18 which may be privileged or otherwise protected from disclosure under state or federal
19 statutes, court rules, case decisions, or common law. Accordingly, to expedite the
20 flow of information, to facilitate the prompt resolution of disputes over
21 confidentiality of discovery materials, to adequately protect information the parties
22 are entitled to keep confidential, to ensure that the parties are permitted reasonable
23 necessary uses of such material in preparation for and in the conduct of trial, to
24 address their handling at the end of the litigation, and serve the ends of justice, a
25 protective order for such information is justified in this matter. It is the intent of the
26 parties that information will not be designated as confidential for tactical reasons and
27 that nothing be so designated without a good faith belief that it has been maintained
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1 in a confidential, non-public manner, and there is good cause why it should not be
2 part of the public record of this case.
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4 2. DEFINITIONS
5 2.1 Action: Muhamad Awadallah v. Experian Information Solutions, Inc.,
6 et al., Case No. 2:26-cv-01822-MEMF-AJR.
7 2.2 Challenging Party: a Party or Non-Party that challenges the designation
8 of information or items under this Order.
9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
10 how it is generated, stored or maintained) or tangible things that qualify for protection
11 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
12 Cause Statement.
13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
14 their support staff).
15 2.5 Designating Party: a Party or Non-Party that designates information or
16 items that it produces in disclosures or in responses to discovery as
17 “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: all items or information, regardless
19 of the medium or manner in which it is generated, stored, or maintained (including,
20 among other things, testimony, transcripts, and tangible things), that are produced or
21 generated in disclosures or responses to discovery in this matter.
22 2.7 Expert: a person with specialized knowledge or experience in a matter
23 pertinent to the litigation who has been retained by a Party or its counsel to serve as
24 an expert witness or as a consultant in this Action.
25 2.8 House Counsel: attorneys who are employees of a Party to this Action.
26 House Counsel does not include Outside Counsel of Record or any other outside
27 counsel.
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1 2.9 Non-Party: any natural person, partnership, corporation, association, or
2 other legal entity not named as a Party to this action.
3 2.10 Outside Counsel of Record: attorneys who are not employees of a Party
4 to this Action but are retained to represent or advise a Party to this Action and have
5 appeared in this Action on behalf of that Party or are affiliated with a law firm that
6 has appeared on behalf of that Party, including support staff.
7 2.11 Party: any party to this Action, including all of its officers, directors,
8 employees, consultants, retained experts, and Outside Counsel of Record (and their
9 support staffs).
10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
11 Discovery Material in this Action.
12 2.13 Professional Vendors: persons or entities that provide litigation support
13 services (e.g., photocopying, videotaping, translating, preparing exhibits or
14 demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 and their employees and subcontractors.
16 2.14 Protected Material: any Disclosure or Discovery Material that is
17 designated as “CONFIDENTIAL.”
18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
19 from a Producing Party.
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21 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only
23 Protected Material (as defined above), but also (1) any information copied or
24 extracted from Protected Material; (2) all copies, excerpts, summaries, or
25 compilations of Protected Material; and (3) any testimony, conversations, or
26 presentations by Parties or their Counsel that might reveal Protected Material.
27 Any use of Protected Material at trial shall be governed by the orders of the
28 trial judge. This Order does not govern the use of Protected Material at trial.
1 4. DURATION
2 Once a case proceeds to trial, all of the court-filed information to be introduced
3 that was previously designated as confidential or maintained pursuant to this
4 protective order becomes public and will be presumptively available to all members
5 of the public, including the press, unless compelling reasons supported by specific
6 factual findings to proceed otherwise are made to the trial judge in advance of the
7 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
8 2006) (distinguishing “good cause” showing for sealing documents produced in
9 discovery from “compelling reasons” standard when merits-related documents are
10 part of court record). Accordingly, the terms of this protective order do not extend
11 beyond the commencement of the trial.
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13 5. DESIGNATING PROTECTED MATERIAL
14 5.1 Exercise of Restraint and Care in Designating Material for Protection.
15 Each Party or Non-Party that designates information or items for protection under
16 this Order must take care to limit any such designation to specific material that
17 qualifies under the appropriate standards. The Designating Party must designate for
18 protection only those parts of material, documents, items, or oral or written
19 communications that qualify so that other portions of the material, documents, items,
20 or communications for which protection is not warranted are not swept unjustifiably
21 within the ambit of this Order.
22 Mass, indiscriminate, or routinized designations are prohibited. Designations
23 that are shown to be clearly unjustified or that have been made for an improper
24 purpose (e.g., to unnecessarily encumber the case development process or to impose
25 unnecessary expenses and burdens on other parties) may expose the Designating
26 Party to sanctions.
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1 If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the inapplicable designation.
4 5.2 Manner and Timing of Designations. Except as otherwise provided in
5 this Order, Disclosure or Discovery Material that qualifies for protection under this
6 Order must be clearly so designated before the material is disclosed or produced.
7 Designation in conformity with this Order requires the following:
8 (a) for information in documentary form (e.g., paper or electronic
9 documents, but excluding transcripts of depositions or other pretrial or trial
10 proceedings), the Producing Party must affix, at a minimum, the legend
11 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
12 contains protected material. If only a portion or portions of the material on a page
13 qualifies for protection, the Producing Party must clearly identify the protected
14 portion(s) (e.g., by making appropriate markings in the margins).
15 A Party or Non-Party that makes original documents available for inspection
16 need not designate them for protection until after the inspecting Party has indicated
17 which documents it would like copied and produced. During the inspection and
18 before the designation, all material made available for inspection shall be treated as
19 “CONFIDENTIAL.” After the inspecting Party has identified the documents it
20 wants copied and produced, the Producing Party must determine which documents,
21 or portions thereof, qualify for protection under this Order. Then, before producing
22 the specified documents, the Producing Party must affix the “CONFIDENTIAL
23 legend” to each page that contains Protected Material. If only a portion or portions
24 of the material on a page qualifies for protection, the Producing Party also must
25 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
26 margins).
27 (b) deposition or trial testimony can be designated by the Parties as
28 Confidential Information. Such designation will be made on the record if possible,
1 but the Parties can designate page and line portions of such testimony as Confidential
2 Information by providing written notice of such designation to the opposing Parties
3 within thirty (30) days of receipt of the transcribed testimony by counsel. Until thirty
4 (30) days after receipt of the transcribed testimony, such testimony shall be treated
5 by the Parties as “CONFIDENTIAL.”
6 (c) for information produced in some form other than documentary
7 and for any other tangible items, the Producing Party must affix in a prominent place
8 on the exterior of the container or containers in which the information is stored the
9 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
10 protection, the Producing Party, to the extent practicable, shall identify the protected
11 portion(s).
12 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
13 failure to designate qualified information or items does not, standing alone, waive
14 the Designating Party’s right to secure protection under this Order for such material.
15 Upon timely correction of a designation, the Receiving Party must make reasonable
16 efforts to assure that the material is treated in accordance with the provisions of this
17 Order.
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19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
21 designation of confidentiality at any time that is consistent with the Court’s
22 Scheduling Order.
23 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
24 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
25 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
26 6.3 Burden. The burden of persuasion in any such challenge proceeding
27 shall be on the Designating Party. Frivolous challenges, and those made for an
28 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
1 other parties) may expose the Challenging Party to sanctions. Unless the Designating
2 Party has waived or withdrawn the confidentiality designation, all parties shall
3 continue to afford the material in question the level of protection to which it is entitled
4 under the Producing Party’s designation until the Court rules on the challenge.
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6 7. ACCESS TO AND USE OF PROTECTED MATERIAL
7 7.1 Basic Principles. A Receiving Party may use Protected Material that is
8 disclosed or produced by another Party or by a Non-Party in connection with this
9 Action only for prosecuting, defending, or attempting to settle this Action. Such
10 Protected Material may be disclosed only to the categories of persons and under the
11 conditions described in this Order. When the Action has been terminated, a
12 Receiving Party must comply with the provisions of section 13 below (FINAL
13 DISPOSITION).
14 Protected Material must be stored and maintained by a Receiving Party at a
15 location and in a secure manner that ensures that access is limited to the persons
16 authorized under this Order. Any person in possession of Protected Material shall
17 maintain reasonable administrative, technical, and physical safeguards designed to
18 protect the security and confidentiality of such Protected Material, protect against
19 any reasonably anticipated threats or hazards to the security, and protect against
20 unauthorized access. To the extent a Party or person does not have this, they may
21 comply with this provision by having the Protected Material managed by and/or
22 stored with a third-party vendor that maintain such an information security program.
23 The Receiving Party shall not load, import, submit, or otherwise transfer
24 documents or data produced by the Producing Party to a publicly accessible Large
25 Language Model (“LLM”) or Artificial Intelligence (“AI”) platform. LLM or AI
26 platforms may be utilized with industry standard data security provisions and the
27 Party has performed the necessary due diligence to ensure that the documents or data
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1 will not be retained, utilized to train public models or otherwise made accessible to
2 other users of the LLM or AI platform.
3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
4 otherwise ordered by the Court or permitted in writing by the Designating Party, a
5 Receiving Party may disclose any information or item designated
6 “CONFIDENTIAL” only to:
7 (a) the Receiving Party’s Outside Counsel of Record in this Action,
8 as well as employees of said Outside Counsel of Record to whom it is reasonably
9 necessary to disclose the information for this Action;
10 (b) the officers, directors, and employees (including House Counsel)
11 of the Receiving Party to whom disclosure is reasonably necessary for this Action;
12 (c) Experts (as defined in this Order) of the Receiving Party to whom
13 disclosure is reasonably necessary for this Action and who have signed the
14 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
15 (d) the Court and its personnel;
16 (e) court reporters and their staff;
17 (f) professional jury or trial consultants, mock jurors, and
18 Professional Vendors to whom disclosure is reasonably necessary for this Action and
19 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
20 (g) the author or recipient of a document containing the information
21 or a custodian or other person who otherwise possessed or knew the information;
22 (h) during their depositions, witnesses, and attorneys for witnesses,
23 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing
24 Party requests that the witness sign the form attached as Exhibit A hereto; and (2)
25 they will not be permitted to keep any confidential information unless they sign the
26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
27 agreed by the Designating Party or ordered by the Court. Pages of transcribed
28 deposition testimony or exhibits to depositions that reveal Protected Material may be
1 separately bound by the court reporter and may not be disclosed to anyone except as
2 permitted under this Stipulated Protective Order; and
3 (i) any mediator or settlement officer, and their supporting
4 personnel, mutually agreed upon by any of the Parties, or appointed by the Court,
5 engaged in settlement discussions.
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7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
8 PRODUCED IN OTHER LITIGATION
9 If a Party is served with a subpoena or a court order issued in other litigation
10 that compels disclosure of any information or items designated in this Action as
11 “CONFIDENTIAL,” that Party must:
12 (a) promptly notify in writing the Designating Party. Such
13 notification shall include a copy of the subpoena or court order;
14 (b) promptly notify in writing the party who caused the subpoena or
15 order to issue in the other litigation that some or all of the material covered by the
16 subpoena or order is subject to this Protective Order. Such notification shall include
17 a copy of this Stipulated Protective Order; and
18 (c) cooperate with respect to all reasonable procedures sought to be
19 pursued by the Designating Party whose Protected Material may be affected.
20 (d) If the Designating Party timely seeks a protective order, the Party
21 served with the subpoena or court order shall not produce any information designated
22 in this action as “CONFIDENTIAL” before a determination by the court from which
23 the subpoena or order issued, unless the Party has obtained the Designating Party’s
24 permission. The Designating Party shall bear the burden and expense of seeking
25 protection in that court of its confidential material and nothing in these provisions
26 should be construed as authorizing or encouraging a Receiving Party in this Action
27 to disobey a lawful directive from another court.
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1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced
4 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
5 information produced by Non-Parties in connection with this litigation is protected
6 by the remedies and relief provided by this Order. Nothing in these provisions should
7 be construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request,
9 to produce a Non-Party’s confidential information in its possession, and the Party is
10 subject to an agreement with the Non-Party not to produce the Non-Party’s
11 confidential information, then the Party shall:
12 (1) promptly notify in writing the Requesting Party and the Non-Party that
13 some or all of the information requested is subject to a confidentiality agreement with
14 a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
16 Order in this Action, the relevant discovery request(s), and a reasonably specific
17 description of the information requested; and
18 (3) make the information requested available for inspection by the Non-
19 Party, if requested.
20 (c) If the Non-Party fails to seek a protective order from this Court
21 within 21 days of receiving the notice and accompanying information, the Receiving
22 Party may produce the Non-Party’s confidential information responsive to the
23 discovery request. If the Non-Party timely seeks a protective order, the Receiving
24 Party shall not produce any information in its possession or control that is subject to
25 the confidentiality agreement with the Non-Party before a determination by the
26 Court. Absent a court order to the contrary, the Non-Party shall bear the burden and
27 expense of seeking protection in this Court of its Protected Material.
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1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of this Order,
8 and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” that is attached hereto as Exhibit A.
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11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted
22 to the Court.
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24 12. MISCELLANEOUS
25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
26 person to seek its modification by the Court in the future.
27 12.2 Right to Assert Other Objections. By stipulating to the entry of this
28 Protective Order, no Party waives any right it otherwise would have to object to
1 disclosing or producing any information or item on any ground not addressed in this
2 Stipulated Protective Order. Similarly, no Party waives any right to object on any
3 ground to use in evidence of any of the material covered by this Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any
5 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a court order authorizing the sealing of the
7 specific Protected Material at issue; good cause must be shown in the request to file
8 under seal. If a Party’s request to file Protected Material under seal is denied by the
9 Court, then the Receiving Party may file the information in the public record unless
10 otherwise instructed by the Court.
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12 13. FINAL DISPOSITION
13 After the final disposition of this Action, within 60 days of final termination
14 of this litigation, each Receiving Party must return all Protected Material to the
15 Producing Party or destroy such material. As used in this subdivision, “all Protected
16 Material” includes all copies, abstracts, compilations, summaries, and any other
17 format reproducing or capturing any of the Protected Material. Whether the
18 Protected Material is returned or destroyed, the Receiving Party must submit a
19 written certification to the Producing Party (and, if not the same person or entity, to
20 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
21 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms
22 that the Receiving Party has not retained any copies, abstracts, compilations,
23 summaries or any other format reproducing or capturing any of the Protected
24 Material. Notwithstanding this provision, counsel are entitled to retain an archival
25 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
26 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
27 work product, and consultant and expert work product, even if such materials contain
28 Protected Material. Any such archival copies that contain or constitute Protected
1 Material remain subject to this Protective Order as set forth in Section 4
2 (DURATION).
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4 14. VIOLATION OF ORDER
5 Any violation of this Order may be punished by any and all appropriate
6 measures including, without limitation, contempt proceedings and/or monetary
7 sanctions.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: July 14, 2026
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By: /s/ Eliyahu Babad By: /s/ Donald E. Bradley
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Eliyahu Babad Donald E. Bradley
13 EBabad@SteinSaksLegal.com d.bradley@musickpeeler.com
STEIN SAKS PLLC MUSICK, PEELER & GARRETT LLP
14 One University Plaza, Suite 620 650 Town Center Drive, Suite 1200
Hackensack, NJ 07601 Costa Mesa, California 92626-1925
15 Tel.: (201) 282-6500 x121 Tel.: 714- 668-2400
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Attorney for Plaintiff, Attorneys for Defendant
17 Muhamad Awadallah Trans Union LLC
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By: /s/ Audrey Vas By: /s/ Kay Fitz-Patrick
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Audrey Vas Arjun P. Rao
20 AVas@goodwinlaw.com arjun.rao@morganlewis.com
GOODWIN PROCTER, LLP Marcos Sasso
21 525 Market Street, Floor 32 marcos.sasso@morganlewis.com
San Francisco, CA 94105 Kay Fitz-Patrick
22 Tel.: +1 415 733 6000 kay.fitz-patrick@morganlewis.com
MORGAN, LEWIS & BOCKIUS LLP
23 Aaron Thompson
2049 Century Park East, Suite 700
AThompson@goodwinlaw.com
24 GOODWIN PROCTER LLP Los Angeles, CA 90067-3109
Tel.: +1.310.907.1000
520 Broadway, Suite 500
25
Santa Monica, CA 90401
Attorneys For Defendant
26 Tel.: +1 424 252 6400
Goldman Sachs Bank USA
27 Attorneys for Defendant
Experian Information Solutions, Inc.
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1 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 || Dated: July 15 , 2026 oe RMA. —~
4 IN. A. JOEL RICHLIN
UNITED STATES MAGISTRATE JUDGE
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1 ATTORNEY ATTESTATION
2 Pursuant to Local Rule 5-4.3.4, I hereby attest that all other signatories listed
3 and on whose behalf the filing is submitted, concur in the filing’s content and have
4 authorized the filing.
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/s/ Audrey Vas
6 AUDREY VAS
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, [full name]__________________________________________________,
5 of [full address] ___________________________________________________,
6 ___________________________________________________
7 declare under penalty of perjury that I have read in its entirety and understand the
8 Stipulated Protective Order that was issued by the United States District Court for
9 the Central District of California on July __, 2026 in the case of Awadallah v.
10 Experian Information Solutions, Inc.; et al., CD Cal. Case. No. 2:26-cv-01822-
11 MEMF-AJR. I agree to comply with and to be bound by all the terms of this
12 Stipulated Protective Order and I understand and acknowledge that failure to so
13 comply could expose me to sanctions and punishment in the nature of contempt. I
14 solemnly promise that I will not disclose in any manner any information or item that
15 is subject to this Stipulated Protective Order to any person or entity except in strict
16 compliance with the provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States District Court
18 for the Central District of California for the purpose of enforcing the terms of this
19 Stipulated Protective Order, even if such enforcement proceedings occur after
20 termination of this action. I hereby appoint _________________________________
21 [full name] of ___________________________________________________
22 [full address] ___________________________________________________
23 ___________________________________________________
24 [telephone number] __________________________________________________
25 as my California agent for service of process in connection with this action or any
26 proceedings related to enforcement of this Stipulated Protective Order.
27 ///
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2 Date:
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4 City and State where Signed:
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6 Printed Name:
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8 Signature:
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