The opinion
1 DERYINCA SM. RISO SLELNP (pro hac vice) Q&U SIUNLNL EIVMAANN, ULELLP URQUHART
2 erosen@dynamisllp.com Robert M. Schwartz (Bar No. 117166)
(617) 802-9157 robertschwartz@quinnemanuel.com
3 MICHAEL B. HOMER (pro hac vice) Bomie Lee (Bar No. 356618)
mhomer@dynamilsllp.com bomielee@quinnemanuel.com
4 (617) 693-9732 865 South Figueroa Street, 10th Floor
175 Federal Street, Suite 1200 Los Angeles, California 90017
5 Boston, Massachusetts 02110 Telephone: (213) 443-3000
Facsimile: (213) 443-3100
6 YUSEF AL-JARANI (Cal. Bar No.
351575) William Burck (pro hac vice)
7 yaljarani@dynamisllp.com williamburck@quinnemanuel.com
(213) 283-0685 Kurt Wolfe (pro hac vice)
8 1100 Glendon Ave., 17th Floor kurtwolfe@quinnemanuel.com
Los Angeles, California 90024 Kristin Casey (pro hac vice)
9 kristincasey@quinnemanuel.com
Attorneys for Plaintiffs 555 13th Street, NW
10 Washington, DC 20004
Telephone: (202) 538-8000
11 Facsimile: (202) 538-8100
12 Attorneys for Defendants
13
UNITED STATES DISTRICT COURT
14
CENTRAL DISTRICT OF CALIFORNIA
15
WESTERN DIVISION
16
17 ANDREW LEFT and CITRON Case No. 2:25-cv-10432-SPG-AYP
CAPITAL, LLC,
18 [PROPOSED] STIPULATED
Plaintiffs, PROTECTIVE ORDER
19 v.
20 ANSON FUNDS MANAGEMENT
LP, ANSON ADVISORS, INC.,
21 MOEZ KASSAM, and SUNNY
PURI,
22
Defendants.
23
24
25
26
27
28
1 1. GENERAL
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than prosecuting
5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
6 petition the Court to enter the following Stipulated Protective Order. The parties
7 acknowledge that this Order does not confer blanket protections on all disclosures or
8 responses to discovery and that the protection it affords from public disclosure and
9 use extends only to the limited information or items that are entitled to confidential
10 treatment under the applicable legal principles. The parties further acknowledge, as
11 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle
12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the
13 procedures that must be followed and the standards that will be applied when a party
14 seeks permission from the court to file material under seal.
15 1.2 Good Cause Statement.
16 This action is likely to involve documents or information such as personally
17 identifiable information (“PII”), confidential disclosures to law enforcement, and
18 proprietary commercial and financial information for which special protection from
19 public disclosure and from use for any purpose other than prosecution of this action
20 is warranted. Such confidential and proprietary materials and information may
21 consist of, among other things, social-security and taxpayer-identification numbers,
22 financial account numbers, submissions and testimony provided in the course of
23 confidential federal government investigations, and confidential business and
24 financial information (including trade secrets and information implicating privacy
25 rights of third parties), information otherwise generally unavailable to the public, or
26 which may be privileged or otherwise protected from disclosure under state or federal
27 statutes, court rules, case decisions, or common law. Accordingly, to expedite the
28 flow of information, to facilitate the prompt resolution of disputes over confidentiality
1 of discovery materials, to adequately protect information the parties are entitled to
2 keep confidential, to ensure that the parties are permitted reasonable necessary uses
3 of such material in preparation for and in the conduct of trial, to address their handling
4 at the end of the litigation, and serve the ends of justice, a protective order for such
5 information is justified in this matter. It is the intent of the parties that information
6 will not be designated as confidential for tactical reasons and that nothing be so
7 designated without a good faith belief that it has been maintained in a confidential,
8 non-public manner, and there is good cause why it should not be part of the public
9 record of this case.
10 2. DEFINITIONS
11 2.1 Action: Andrew Left and Citron Capital, LLC v. Anson Funds
12 Management LP, Anson Advisors, Inc., Moez Kassam, and Sunny Puri, No. 2:25-cv-
13 10432-SPG-AYP (C.D. Cal. Oct. 2025).
14 2.2 Challenging Party: a Party or Non-Party that challenges the designation
15 of information or items under this Order.
16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
17 how it is generated, stored or maintained) or tangible things that qualify for protection
18 under Federal Rules of Civil Procedure 5.2 and 26(c), and as specified above in the
19 Good Cause Statement.
20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
21 support staff).
22 2.5 Designated House Counsel: House Counsel who seek access to
23 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information or items
24 in this matter.
25 2.6 Designating Party: a Party or Non-Party that designates information or
26 items that it produces in disclosures or in responses to discovery as
27 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
28 ONLY.”
1 2.7 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 2.8 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 2.9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
9 Information or Items: extremely sensitive “Confidential Information or Items,” the
10 disclosure of which to another Party or Non-Party would create a substantial risk of
11 serious harm that could not be avoided by less restrictive means.
12 2.10 House Counsel: attorneys who are employees of a party to this Action.
13 House Counsel does not include Outside Counsel of Record or any other outside
14 counsel.
15 2.11 Non-Party: any natural person, partnership, corporation, association, or
16 other legal entity not named as a Party to this action.
17 2.12 Outside Counsel of Record: attorneys who are not employees of a party
18 to this Action but are retained to represent or advise a party to this Action and have
19 appeared in this Action on behalf of that party or are affiliated with a law firm that
20 has appeared on behalf of that party, including support staff.
21 2.13 Party: any party to this Action, including all of its officers, directors,
22 employees, consultants, retained experts, and Outside Counsel of Record (and their
23 support staffs).
24 2.14 Producing Party: a Party or Non-Party that produces Disclosure or
25 Discovery Material in this Action.
26 2.15 Professional Vendors: persons or entities that provide litigation support
27 services (e.g., photocopying, videotaping, translating, preparing exhibits or
28
1 demonstrations, and organizing, storing, or retrieving data in any form or medium)
2 and their employees and subcontractors.
3 2.16 Protected Material: any Disclosure or Discovery Material that is
4 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
5 EYES ONLY.”
6 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material
7 from a Producing Party.
8 3. SCOPE
9 The protections conferred by this Stipulation and Order cover not only
10 Protected Material (as defined above), but also (1) any information copied or extracted
11 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
12 Protected Material; and (3) any testimony, conversations, or presentations by Parties
13 or their Counsel that might reveal Protected Material.
14 However, the protections conferred by this Stipulation and Order do not cover
15 the following information: (a) any information that is in the public domain at the time
16 of disclosure to a Receiving Party or that becomes part of the public domain after
17 disclosure as a result of publication not involving a violation of this Order, including
18 becoming part of the public record through trial or otherwise; and (b) any information
19 known to the Receiving Party prior to disclosure, or obtained by the Receiving Party
20 after disclosure from a source who obtained the information lawfully and under no
21 obligation of confidentiality to the Designating Party.
22 Any use of Protected Material at trial shall be governed by the orders of the
23 trial judge. This Order does not govern the use of Protected Material at trial.
24 4. DURATION
25 Once the case arrives at summary judgment, the Parties should meet and confer
26 regarding the de-designation of any evidence intended to be relied upon for the
27 dispositive motions. If the parties cannot come to an agreement, the Party seeking to
28 file the documents and/or information not under seal must petition the Court to do so.
1 Once a case proceeds to trial, all of the court-filed information to be introduced
2 that was previously designated as confidential or maintained pursuant to this
3 protective order becomes public and will be presumptively available to all members
4 of the public, including the press, unless compelling reasons supported by specific
5 factual findings to proceed otherwise are made to the trial judge in advance of the
6 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
7 2006) (distinguishing “good cause” showing for sealing documents produced in
8 discovery from “compelling reasons” standard when merits-related documents are
9 part of court record). Accordingly, the terms of this protective order do not extend
10 beyond the commencement of the trial.
11 5. DESIGNATING PROTECTED MATERIAL
12 5.1 Exercise of Restraint and Care in Designating Material for Protection.
13 Each Party or Non-Party that designates information or items for protection under this
14 Order must take care to limit any such designation to specific material that qualifies
15 under the appropriate standards. The Designating Party must designate for protection
16 only those parts of material, documents, items, or oral or written communications that
17 qualify so that other portions of the material, documents, items, or communications
18 for which protection is not warranted are not swept unjustifiably within the ambit of
19 this Order.
20 Mass, indiscriminate, or routinized designations are prohibited. Designations
21 that are shown to be clearly unjustified or that have been made for an improper
22 purpose (e.g., to unnecessarily encumber the case development process or to impose
23 unnecessary expenses and burdens on other parties) may expose the Designating Party
24 to sanctions.
25 If it comes to a Designating Party’s attention that information or items that it
26 designated for protection do not qualify for protection, that Designating Party must
27 promptly notify all other Parties that it is withdrawing the inapplicable designation.
28
1 5.2 Manner and Timing of Designations. Except as otherwise provided in
2 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
4 under this Order must be clearly so designated before the material is disclosed or
5 produced.
6 Designation in conformity with this Order requires:
7 (a) for information in documentary form (e.g., paper or electronic
8 documents, but excluding transcripts of depositions or other pretrial or trial
9 proceedings), that the Producing Party affix, at a minimum, the legend
10 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
11 ONLY” to each page that contains Protected Material. If only a portion or portions
12 of the material on a page qualifies for protection, the Producing Party also must clearly
13 identify the protected portion(s) (e.g., by making appropriate markings in the
14 margins).
15 (b) for testimony given in depositions that the Designating Party identify
16 the Disclosure or Discovery Material on the record, before the close of the deposition;
17 or, alternatively, that counsel for a witness make a confidentiality designation within
18 21 days of receiving the final deposition transcript by identifying the specific portions
19 of testimony for which protection is sought, or by specifying that the entire transcript
20 shall be treated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
21 ATTORNEYS’ EYES ONLY.” Any transcript prepared before the expiration of such
22 21-day period shall be treated during that period as if designated “HIGHLY
23 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” in its entirety unless otherwise
24 agreed. Transcripts containing Protected Material shall bear a legend on the title page
25 noting that the transcript contains Protected Material, followed by a list of all pages
26 designated as Protected Material and the level of protection asserted. The Designating
27 Party shall inform the court reporter of these requirements.
28
1 (c) for information produced in some form other than documentary and
2 for any other tangible items, that the Producing Party affix in a prominent place on
3 the exterior of the container or containers in which the information is stored the
4 legends “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
5 EYES ONLY.” If only a portion or portions of the information warrants protection,
6 the Producing Party, to the extent practicable, shall identify the protected portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
8 failure to designate qualified information or items does not, standing alone, waive the
9 Designating Party’s right to secure protection under this Order for such material.
10 Upon timely correction of a designation, the Receiving Party must make reasonable
11 efforts to assure that the material is treated in accordance with the provisions of this
12 Order.
13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
15 designation of confidentiality at any time that is consistent with the Court’s
16 Scheduling Order.
17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
18 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
19 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
20 6.3 Burden. The burden of persuasion in any such challenge proceeding
21 shall be on the Designating Party. Frivolous challenges, and those made for an
22 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
23 other parties) may expose the Challenging Party to sanctions. Unless the Designating
24 Party has waived or withdrawn the confidentiality designation, all parties shall
25 continue to afford the material in question the level of protection to which it is entitled
26 under the Producing Party’s designation until the Court rules on the challenge.
27
28
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending, or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a Receiving
7 Party must comply with the provisions of Section 13 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a
9 location and in a secure manner that ensures that access is limited to the persons
10 authorized under this Order.
11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
12 otherwise ordered by the Court or permitted in writing by the Designating Party, a
13 Receiving Party may disclose any information or item designated
14 “CONFIDENTIAL” only to:
15 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
16 well as employees of said Outside Counsel of Record to whom it is reasonably
17 necessary to disclose the information for this Action;
18 (b) the officers, directors, and employees (including House Counsel) of
19 the Receiving Party to whom disclosure is reasonably necessary for this Action;
20 (c) Experts (as defined in this Order) of the Receiving Party to whom
21 disclosure is reasonably necessary for this Action and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (d) the Court and its personnel;
24 (e) court reporters and their staff;
25 (f) professional jury or trial consultants, mock jurors, and Professional
26 Vendors to whom disclosure is reasonably necessary for this Action and who have
27 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
28
1 (g) the author or recipient of a document containing the information or
2 a custodian or other person who otherwise possessed or knew the information;
3 (h) during their depositions, witnesses, and attorneys for witnesses, in
4 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
5 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they
6 will not be permitted to keep any confidential information unless they sign the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8 agreed by the Designating Party or ordered by the Court. Pages of transcribed
9 deposition testimony or exhibits to depositions that reveal Protected Material may be
10 separately bound by the court reporter and may not be disclosed to anyone except as
11 permitted under this Stipulated Protective Order;
12 (i) any mediator or settlement officer, and their supporting personnel,
13 mutually agreed upon by any of the parties engaged in settlement discussions; and
14 (j) any other person, upon order of the Court or by agreement of the
15 parties, who has signed the “Acknowledgement and Agreement to Be Bound”
16 (Exhibit A).
17 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
18 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in
19 writing by the Designating Party, a Receiving Party may disclose any information or
20 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
21 to:
22 (a) categories set forth above in Section 7.2 (a) through (j); and
23 (b) the Receiving Party’s Outside Counsel of Record in this Action,
24 as well as employees of said Outside Counsel of Record to whom it is reasonably
25 necessary to disclose the information for this Action;
26 up to two (2) Designated House Counsel of the Receiving Party to whom
27 disclosure is reasonably necessary for this Action and who have signed the
28 “Acknowledgement and Agreement to Be Bound” (Exhibit A).
1
2 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
3 PRODUCED IN OTHER LITIGATION
4 If a Party is served with a subpoena or a court order issued in other litigation
5 that compels disclosure of any information or items designated in this Action as
6 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
7 ONLY,” that Party must:
8 (a) promptly notify in writing the Designating Party. Such notification shall
9 include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order to
11 issue in the other litigation that some or all of the material covered by the subpoena
12 or order is subject to this Protective Order. Such notification shall include a copy of
13 this Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be pursued
15 by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served with
17 the subpoena or court order shall not produce any information designated in this action
18 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
19 ONLY” before a determination by the court from which the subpoena or order issued,
20 unless the Party has obtained the Designating Party’s permission. The Designating
21 Party shall bear the burden and expense of seeking protection in that court of its
22 confidential material and nothing in these provisions should be construed as
23 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
24 directive from another court.
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
26 PRODUCED IN THIS LITIGATION
27 (a) The terms of this Order are applicable to information produced by a Non-
28 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
1 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
2 Non-Parties in connection with this litigation is protected by the remedies and relief
3 provided by this Order. Nothing in these provisions should be construed as
4 prohibiting a Non-Party from seeking additional protections.
5 (b) If a Party has a good-faith basis to believe that information produced by a
6 Non-Party in this Action may contain “CONFIDENTIAL” or “HIGHLY
7 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Protected Material, the Party
8 may notify the other parties of that belief. If the Party notifies the other parties that a
9 Non-Party’s production may contain “CONFIDENTIAL” or “HIGHLY
10 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Protected Material, the
11 production shall be treated as if so designated for 14 calendar days after receipt by all
12 parties. Thereafter, any such material shall be treated only as specifically designated
13 by any Party or Non-Party.
14 (c) In the event that a Party is required, by a valid discovery request, to produce
15 a Non-Party’s confidential information in its possession, and the Party is subject to an
16 agreement with the Non-Party not to produce the Non-Party’s confidential
17 information, then the Party shall:
18 (1) promptly notify in writing the Requesting Party and the Non-Party
19 that some or all of the information requested is subject to a confidentiality agreement
20 with a Non-Party;
21 (2) promptly provide the Non-Party with a copy of the Stipulated
22 Protective Order in this Action, the relevant discovery request(s), and a reasonably
23 specific description of the information requested; and
24 (3) make the information requested available for inspection by the Non-
25 Party, if requested.
26 (d) If the Non-Party fails to seek a protective order from this Court within 14
27 days of receiving the notice and accompanying information, the Receiving Party may
28 produce the Non-Party’s confidential information responsive to the discovery request.
1 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
2 any information in its possession or control that is subject to the confidentiality
3 agreement with the Non-Party before a determination by the Court. Absent a court
4 order to the contrary, the Non-Party shall bear the burden and expense of seeking
5 protection in this Court of its Protected Material.
6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
8 Protected Material to any person or in any circumstance not authorized under this
9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
12 persons to whom unauthorized disclosures were made of all the terms of this Order,
13 and (d) request such person or persons to execute the “Acknowledgment and
14 Agreement to Be Bound” that is attached hereto as Exhibit A.
15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
16 PROTECTED MATERIAL
17 When a Producing Party gives notice to Receiving Parties that certain
18 inadvertently produced material is subject to a claim of privilege or other protection,
19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
21 may be established in an e-discovery order that provides for production without prior
22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
23 parties reach an agreement on the effect of disclosure of a communication or
24 information covered by the attorney-client privilege or work product protection, the
25 parties may incorporate their agreement in the stipulated protective order submitted
26 to the Court.
27 12. MISCELLANEOUS
28
1 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
2 person to seek its modification by the Court in the future.
3 12.2 Right to Assert Other Objections. By stipulating to the entry of this
4 Protective Order, no Party waives any right it otherwise would have to object to
5 disclosing or producing any information or item on any ground not addressed in this
6 Stipulated Protective Order. Similarly, no Party waives any right to object on any
7 ground to use in evidence of any of the material covered by this Protective Order.
8 12.3 Filing Protected Material. A Party that seeks to file under seal any
9 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
10 only be filed under seal pursuant to a court order authorizing the sealing of the specific
11 Protected Material at issue; good cause must be shown in the request to file under
12 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
13 then the Receiving Party may file the information in the public record unless
14 otherwise instructed by the Court.
15 13. FINAL DISPOSITION
16 After the final disposition of this Action, within 60 days of a written request by
17 the Designating Party, or as defined in Section 4 (DURATION), each Receiving Party
18 must return all Protected Material to the Producing Party or destroy such material. As
19 used in this subdivision, “all Protected Material” includes all copies, abstracts,
20 compilations, summaries, and any other format reproducing or capturing any of the
21 Protected Material. Whether the Protected Material is returned or destroyed, the
22 Receiving Party must submit a written certification to the Producing Party (and, if not
23 the same person or entity, to the Designating Party) by the 60 day deadline that (1)
24 identifies (by category, where appropriate) all the Protected Material that was returned
25 or destroyed, and (2) affirms that the Receiving Party has not retained any copies,
26 abstracts, compilations, summaries or any other format reproducing or capturing any
27 of the Protected Material. Notwithstanding this provision, counsel are entitled to
28 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
1 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
2 reports, attorney work product, and consultant and expert work product, even if such
3 materials contain Protected Material. Any such archival copies that contain or
4 constitute Protected Material remain subject to this Protective Order as set forth in
5 Section 4 (DURATION).
6 14. VIOLATION OF ORDER
7 Any violation of this Order may be punished by any and all appropriate
8 measures including, without limitation, contempt proceedings and/or monetary
9 sanctions.
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Ora
I
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 || DATED: August 4, 2026
4 || /s/ Eric S. Rosen
5 || Attorneys for Plaintiffs
6
7
DATED: August 4, 2026
8
9 || S/Robert M. Schwartz
Attorneys for Defendants
10
11
12 ATTESTATION
13 Pursuant to Local Rule 5-4.3.4(a)(2)(1), I attest that all other signatories listed,
14 || and on whose behalf this filing is submitted, concur in the filing’s content and have
15 || authorized the filing.
16
DATED: August 4, 2026 /s/ Yusef Al-Jarani
17 Yusef Al-Jarani
18
19
20 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22
23 || DATED: August 14, 2026 7 \ = =
Honorable Anna Y. Park
24 United States Magistrate Judge
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16
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________
5 [full 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 for the Central District of California on ____________ [date] in the
8 case of Left et al. v. Anson Funds Management LP et al., No. 2:25-cv-10432-SPG-
9 AYP (C.D. Cal.). 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 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [full
19 name] of _______________________________________ [full address and
20 telephone number] as my California agent for service of process in connection with
21 this action or any proceedings related to enforcement of this Stipulated Protective
22 Order.
23 Date: ______________________________________
24 City and State where signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________