Opinion

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6 UNITED STATES DISTRICT COURT

7 CENTRAL DISTRICT OF CALIFORNIA

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9 ESPERANZA RIOS, Case No. 2:26-cv-05288-MCS-RAO

10 Plaintiff,

STIPULATED PROTECTIVE

ORDER1

11 v.

12 GLOBAL ANALYTICAL

DEVELOPMENT LLC, a corporate entity

13 form unknown; and DOES 1-50, inclusive,

14 Defendants.

15

16 1. A. PURPOSES AND LIMITATIONS

17 Discovery in this action is likely to involve production of confidential, proprietary

18 or private information for which special protection from public disclosure and from use

19 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the

20 parties hereby stipulate to and petition the Court to enter the following Stipulated

21 Protective Order (“Protective Order”). The parties acknowledge that this Protective

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

23 that the protection it affords from public disclosure and use extends only to the limited

24 information or items that are entitled to confidential treatment under the applicable legal

25 principles.

26

27

28 1 This Protective Order is substantially based on the model protective order provided

1 B. GOOD CAUSE STATEMENT

2 This action is likely to involve the production of confidential information,

3 including Plaintiff’s personal and private information (such as medical or employment

4 records) and proprietary business policies, procedures, and commercially sensitive

5 information, for which special protection from public disclosure and from use for any

6 purpose other than prosecution of this action is warranted. Such confidential and

7 proprietary materials and information consist of, among other things, medical,

8 employment, private, confidential and proprietary business or financial information,

9 information regarding confidential business practices and polices, information otherwise

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

11 from disclosure under state or federal statutes, court rules, case decisions, or common

12 law. Disclosure of this information to persons who are not entitled to it carries the danger

13 of compromising the competitive business interests of Defendant and other non-parties,

14 and also risks invasion of legitimate personal privacy interests of Plaintiff and non-

15 parties. Accordingly, to expedite the flow of information, to facilitate the prompt

16 resolution of disputes over confidentiality of discovery materials, to adequately protect

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

18 permitted reasonable necessary uses of such material in preparation for and in the

19 conduct of trial, to address their handling at the end of the litigation, and serve the ends of

20 justice, a protective order for such information is justified in this matter. It is the intent of

21 the parties that information will not be designated as confidential for tactical reasons and

22 that nothing be so designated without a good faith belief that it has been maintained in a

23 confidential, non-public manner, and there is good cause why it should not be part of the

24 public record of this case.

25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

26 The parties further acknowledge, as set forth in Section 13.3, below, that this

27 Protective Order does not entitle them to file confidential information under seal; Local

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1 Civil Rule 79-5 sets forth the procedures that must be followed and the standards that will

2 be applied when a party seeks permission from the court to file material under seal.

3 There is a strong presumption that the public has a right of access to judicial

4 proceedings and records in civil cases. In connection with non-dispositive motions, good

5 cause must be shown to support a filing under seal. See Kamakana v. City and County of

6 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors Corp., 307 F.3d

7 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,

8 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and

9 a specific showing of good cause or compelling reasons with proper evidentiary support

10 and legal justification, must be made with respect to Protected Material that a party seeks

11 to file under seal. The parties’ mere designation of Disclosure or Discovery Material as

12 CONFIDENTIAL does not—without the submission of competent evidence by

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

14 confidential, privileged, or otherwise protectable—constitute good cause.

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

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

17 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos

18 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type

19 of information, document, or thing sought to be filed or introduced under seal in

20 connection with a dispositive motion or trial, the party seeking protection must articulate

21 compelling reasons, supported by specific facts and legal justification, for the requested

22 sealing order. Again, competent evidence supporting the application to file documents

23 under seal must be provided by declaration.

24 Any document that is not confidential, privileged, or otherwise protectable in its

25 entirety will not be filed under seal if the confidential portions can be redacted. If

26 documents can be redacted, then a redacted version for public viewing, omitting only the

27 confidential, privileged, or otherwise protectable portions of the document shall be filed.

28 Any application that seeks to file documents under seal in their entirety should include an

1 explanation of why redaction is not feasible.

2 2. DEFINITIONS

3 2.1 Action: Esperanza Rios v. Global Analytical Development LLC, Case No.

4 2:26-cv-05288-MCS-RAO.

5 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

6 information or items under this Protective Order.

7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it

8 is generated, stored or maintained) or tangible things that qualify for protection under

9 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

10 Statement.

11 2.4 Closed Generative AI Tool: an artificial intelligence system whose access is

12 restricted such that the system itself and the underlying code and materials may only be

13 accessed by the Party using the tool.

14 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their

15 support staff).

16 2.6 Designating Party: a Party or Non-Party that designates information or

17 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

18 2.7 Disclosure or Discovery Material: all items or information, regardless of the

19 medium or manner in which it is generated, stored, or maintained (including, among

20 other things, testimony, transcripts, and tangible things) that are produced or generated in

21 disclosures or responses to discovery in this matter.

22 2.8 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 an

24 expert witness or as a consultant in this Action.

25 2.9 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 counsel.

27 2.10 Non-Party: any natural person, partnership, corporation, association or other

28 legal entity not named as a Party to this action.

1 2.11 Open Generative AI Tool: an artificial intelligence system that may be

2 accessed by the public, or that allows for the underlying code and materials to be

3 accessed by the public, such as ChatGPT.

4 2.12 Outside Counsel of Record: attorneys who are not employees of a party to

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

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

7 appeared on behalf of that party, and includes support staff.

8 2.13 Party: any party to this Action, including all of its officers, directors,

9 employees, consultants, retained experts, and Outside Counsel of Record (and their

10 support staffs).

11 2.14 Producing Party: a Party or Non-Party that produces Disclosure or

12 Discovery Material in this Action.

13 2.15 Professional Vendors: persons or entities that provide litigation support

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

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

16 their employees and subcontractors.

17 2.16 Protected Material: any Disclosure or Discovery Material that is designated

18 as “CONFIDENTIAL.”

19 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material

20 from a Producing Party.

21 3. SCOPE

22 The protections conferred by this Protective Order cover not only Protected

23 Material (as defined above), but also (1) any information copied or extracted from

24 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

25 Material; and (3) any testimony, conversations, or presentations by Parties or their

26 Counsel that might reveal Protected Material.

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

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

1 4. DURATION

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

3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as

4 an exhibit at trial becomes public and will be presumptively available to all members of

5 the public, including the press, unless compelling reasons supported by specific factual

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

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

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

9 related documents are part of court record). Accordingly, the terms of this protective

10 order do not extend beyond the commencement of the trial.

11 5. DESIGNATING PROTECTED MATERIAL

12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

13 Party or Non-Party that designates information or items for protection under this

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

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

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

17 communications that qualify so that other portions of the material, documents, items or

18 communications for which protection is not warranted are not swept unjustifiably within

19 the ambit of this Protective Order.

20 Mass, indiscriminate or routinized designations are prohibited. Designations that

21 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

22 to unnecessarily encumber the case development process or to impose unnecessary

23 expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

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

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

27 5.2 Manner and Timing of Designations. Except as otherwise provided in this

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

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

2 this Protective Order must be clearly so designated before the material is disclosed or

3 produced.

4 Designation in conformity with this Protective Order requires:

5 (a) for information in documentary form (e.g., paper or electronic documents, but

6 excluding transcripts of depositions or other pretrial or trial proceedings), that the

7 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

8 “CONFIDENTIAL legend”), to each page that contains protected material. If only a

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

10 clearly identify the protected portion(s) (e.g., by making appropriate markings in the

11 margins).

12 A Party or Non-Party that makes original documents available for inspection need

13 not designate them for protection until after the inspecting Party has indicated which

14 documents it would like copied and produced. During the inspection and before the

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

16 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

17 copied and produced, the Producing Party must determine which documents, or portions

18 thereof, qualify for protection under this Protective Order. Then, before producing the

19 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to

20 each page that contains Protected Material. If only a portion of the material on a page

21 qualifies for protection, the Producing Party also must clearly identify the protected

22 portion(s) (e.g., by making appropriate markings in the margins).

23 (b) for testimony given in depositions that the Designating Party identifies the

24 Disclosure or Discovery Material on the record, before the close of the deposition

25 whenever possible, but a Designating Party also may identify the specific portions of the

26 testimony to which protection is sought within 30 days following receipt of the reporter’s

27 transcript of the deposition, hearing, or other proceeding (or longer if agreed to by the

28 parties). Any transcript that is prepared before the expiration of a 30-day period for

1 designation shall be treated during that period as if it had been designated

2 “CONFIDENTIAL” in its entirety unless otherwise agreed. After the expiration of that

3 period, the transcript shall be treated only as designated.

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

5 other tangible items, that the Producing Party affix in a prominent place on the exterior of

6 the container or containers in which the information is stored the legend

7 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,

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

9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

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

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

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

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

14 of this Protective Order.

15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation

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

18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution

19 process under Local Rule 37.1 et seq. If the dispute cannot be resolved through this

20 process, the Challenging Party may initiate the preparation of a Joint Stipulation under

21 Rule 37-2.2 by delivering its portion of the Joint Stipulation, together with all

22 declarations and exhibits to be offered in support of the moving party’s position, to

23 counsel for the Designating Party within ten (10) business days after the parties’ Prefiling

24 Conference of Counsel under Local Rule 37-1.

25 6.3 The burden of persuasion in any such challenge proceeding shall be on the

26 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

27 to harass or impose unnecessary expenses and burdens on other parties) may expose the

28 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

1 the confidentiality designation, all parties shall continue to afford the material in question

2 the level of protection to which it is entitled under the Producing Party’s designation until

3 the Court rules on the challenge.

4 7. ACCESS TO AND USE OF PROTECTED MATERIAL

5 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

9 described in this Protective Order. When the Action has been terminated, a Receiving

10 Party must comply with the provisions of Section 14 below (FINAL DISPOSITION).

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

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

13 authorized under this Protective Order.

14 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

16 may disclose any information or item designated “CONFIDENTIAL” only to:

17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

18 employees of said Outside Counsel of Record to whom it is reasonably necessary to

19 disclose the information for this Action;

20 (b) the officers, directors, and employees (including House Counsel) of the

21 Receiving Party to whom disclosure is reasonably necessary for this Action;

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

23 whom disclosure is reasonably necessary for this Action, but provided that (1) such

24 Experts are not regularly engaged in any activity that places them in competition with the

25 products or services provided by the Designating Party; and (2) they have signed the

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

27 (d) the Court and its personnel;

28 (e) court reporters and their staff;

1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors

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

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

4 (g) the author or recipient of a document containing the information or a

5 custodian or other person who otherwise possessed or knew the information;

6 (h) during their depositions, witnesses, and attorneys for witnesses, in the

7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

8 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not

9 be permitted to keep any confidential information unless they sign the “Acknowledgment

10 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating

11 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to

12 depositions that reveal Protected Material may be separately bound by the court reporter

13 and may not be disclosed to anyone except as permitted under this Protective Order; and

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

15 agreed upon by any of the parties engaged in settlement discussions.

16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

17 OTHER LITIGATION

18 If a Party is served with a subpoena or a court order issued in other litigation that

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

20 “CONFIDENTIAL,” that Party must:

21 (a) promptly notify in writing the Designating Party. Such notification shall

22 include a copy of the subpoena or court order;

23 (b) promptly notify in writing the party who caused the subpoena or order to

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

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

26 Protective Order; and

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

28 the Designating Party whose Protected Material may be affected.

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

2 subpoena or court order shall not produce any information designated in this action as

3 “CONFIDENTIAL” before a determination by the Court from which the subpoena or

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

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

6 its confidential material and nothing in these provisions should be construed as

7 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive

8 from another court.

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

10 IN THIS LITIGATION

11 (a) The terms of this Protective Order are applicable to information produced

12 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

13 produced by Non-Parties in connection with this litigation is protected by the remedies

14 and relief provided by this Protective Order. Nothing in these provisions should be

15 construed as prohibiting a Non-Party from seeking additional protections.

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

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

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

19 information, then the Party shall:

20 (1) promptly notify in writing the Requesting Party and the Non-Party that

21 some or all of the information requested is subject to a confidentiality agreement with a

22 Non-Party;

23 (2) promptly provide the Non-Party with a copy of the Protective Order in

24 this Action, the relevant discovery request(s), and a reasonably specific description of the

25 information requested; and

26 (3) make the information requested available for inspection by the Non-

27 Party, if requested.

28 (c) If the Non-Party fails to seek a protective order from this court within 14

1 days of receiving the notice and accompanying information, the Receiving Party may

2 produce the Non-Party’s confidential information responsive to the discovery request. If

3 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any

4 information in its possession or control that is subject to the confidentiality agreement

5 with the Non-Party before a determination by the court. Absent a court order to the

6 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

7 court of its Protected Material.

8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

10 Protected Material to any person or in any circumstance not authorized under this

11 Protective Order, the Receiving Party must immediately (a) notify in writing the

12 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all

13 unauthorized copies of the Protected Material, (c) inform the person or persons to whom

14 unauthorized disclosures were made of all the terms of this Protective Order, and (d)

15 request such person or persons to execute the “Acknowledgment and Agreement to Be

16 Bound” that is attached hereto as Exhibit A.

17 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

18 PROTECTED MATERIAL

19 When a Producing Party gives notice to a Receiving Party that certain

20 inadvertently produced material is subject to a claim of privilege or other protection, the

21 obligations of the Receiving Party are those set forth in Federal Rule of Civil Procedure

22 26(b)(5)(B). This provision is not intended to modify whatever procedure may be

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

24 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

25 an agreement on the effect of disclosure of a communication or information covered by

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

27 agreement in the stipulated protective order submitted to the court.

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1 12. USE OF GENERATIVE AI TOOLS

2 Protected Material shall not be submitted to any Open Generative AI tool or any

3 substantially similar tool that is available to the public. Providing Protected Material to

4 an Open Generative AI tool is considered disclosure to a third party.

5 Before any Party submits Protected Material to a Closed Generative AI tool, that

6 Party shall make reasonably sure that it can delete all produced information from the tool

7 at the close of this litigation. That Party will be responsible for destroying such Protected

8 Material from such tools at the end of this litigation. To the extent a Party inputs

9 Protected Material into a Closed Generative AI Tool, access to that tool must be

10 restricted to persons permitted to review such material under this Protective Order.

11 13. MISCELLANEOUS

12 13.1 Right to Further Relief. Nothing in this Protective Order abridges the right

13 of any person to seek its modification by the Court in the future.

14 13.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

17 Protective Order. Similarly, no Party waives any right to object on any ground to use in

18 evidence of any of the material covered by this Protective Order.

19 13.3 Filing Protected Material. A Party that seeks to file under seal any Protected

20 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed

21 under seal pursuant to a court order authorizing the sealing of the specific Protected

22 Material at issue. If a Party’s request to file Protected Material under seal is denied by

23 the court, then the Receiving Party may file the information in the public record unless

24 otherwise instructed by the court.

25 14. FINAL DISPOSITION

26 After the final disposition of this Action, as defined in paragraph 4, within 60 days

27 of a written request by the Designating Party, each Receiving Party must return all

28 Protected Material to the Producing Party or destroy such material. As used in this

1 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

2 summaries, and any other format reproducing or capturing any of the Protected Material.

3 Whether the Protected Material is returned or destroyed, the Receiving Party must submit

4 a written certification to 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 category, where

6 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that

7 the Receiving Party has not retained any copies, abstracts, compilations, summaries or

8 any other format reproducing or capturing any of the Protected Material. Notwithstanding

9 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion

10 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

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

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

13 archival copies that contain or constitute Protected Material remain subject to this

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

15 15. VIOLATION

16 Any violation of this Protective Order may be punished by appropriate measures

17 including, without limitation, contempt proceedings and/or monetary sanctions.

18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

19 DATED: August 18, 2026 SMAILI & ASSOCIATES, PC

20

By: /s/ Stephen D. Counts

21 Jihad M. Smaili, Esq.

Stephen D. Counts, Esq.

22 Attorneys for Plaintiff

ESPERANZA RIOS

23

24 DATED: August 18, 2026 SEYFARTH SHAW LLP

25

By: /s/ Steven A. Morphy

26 Michele J. Beilke

Steven A. Morphy

27 Attorneys for Defendant

GLOBAL ANALYTICAL

28 DEVELOPMENT LLC

1 GOOD CAUSE SHOWN, IT IS SO ORDERED.

2

3. || DATED: 09/04/2026

4 .

5 || Rape@hs, a. QL

6 || United States Magistrate Judge

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [print or type full name], of _________________

5 [print or type full address], declare under penalty of perjury that I have read in its entirety

6 and understand the Stipulated Protective Order (“Protective Order”) that was issued by

7 the United States District Court for the Central District of California on [date] in the case

8 of Esperanza Rios v. Global Analytical Development LLC, Case No. 2:26-cv-05288-

9 MCS-RAO. I agree to comply with and to be bound by all the terms of this Protective

10 Order and I understand and acknowledge that failure to so comply could expose me to

11 sanctions and punishment in the nature of contempt. I solemnly promise that I will not

12 disclose in any manner any information or item that is subject to this Protective Order to

13 any person or entity except in strict compliance with the provisions of this Protective

14 Order.

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

16 Central District of California for enforcing the terms of this Protective Order, even if

17 such enforcement proceedings occur after termination of this action. I hereby appoint

18 __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and telephone

20 number] as my California agent for service of process in connection with this action or

21 any proceedings related to enforcement of this Protective Order.

22 Date: ______________________________________

23 City and State where sworn and signed: _________________________________

24

25 Printed name: _______________________________

26

27 Signature: __________________________________

28