1 VORA LAW FIRM, P.C. DENTONS US LLP Nilay U. Vora (Cal. Bar No. 268339) Julia M. Beckley (Cal. Bar No. 2 nvora@voralaw.com 247493) Jeffrey A. Atteberry (Cal. Bar No. julia.beckley@dentons.com 3 266728) 100 Crescent Ct., Suite 900 jatteberry@voralaw.com Dallas, TX 75201 4 201 Santa Monica Blvd, Ste 300, Tel.: (214) 259-1854 5 Santa Monica, CA 90401-2224 Tel.: (424) 258-5190 Erin Bradham (Pro Hac Vice) 6 erin.bradham@dentons.com Attorneys for Plaintiff Cedars-Sinai 29398 E Camelback Rd., Suite 850 7 Medical Center as to Defendant AIG Phoenix, AZ 85016 Specialty Insurance Company Tel.: (602) 508-3962 8

Attorneys for Defendant 9 AIG Specialty Insurance Company, Inc. 10 [Additional counsel listed on next page] 11

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

CEDARS-SINAI MEDICAL

Case No. 2:24-cv-02543-MCS-RAO 16 CENTER, a California nonprofit public benefit corporation, 17

AMENDED STIPULATED

Plaintiff, PROTECTIVE ORDER 18

v. 19 20 AIG SPECIALTY INSURANCE

COMPANY, an Illinois corporation, 21 and IRONSHORE SPECIALTY 22 INSURANCE COMPANY, an Arizona corporation, 23 Defendants. 24 25 26 27 1

LATHAM & WATKINS LLP KAUFMAN BORGEEST & RYAN

2 Kirsten C. Jackson (Cal. Bar No. LLP 265952) Joshua Shayne (Cal. Bar No. 223408) 3 kirsten.jackson@lw.com jshayne@kbrlaw.com 10250 Constellation Blvd., Suite 1100 21700 Oxnard Street, Suite 1450 4 Los Angeles, California 90067 Woodland Hills, CA 91367 5 Tel.: (424) 653-5500 Tel.: (818) 961-8027

6 Attorneys for Plaintiff Attorneys for Defendant Cedars-Sinai Medical Center Ironshore Specialty Insurance 7 as to Defendant Ironshore Specialty Company Insurance 8 C ompany 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve personal health information, trade secrets, and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and from 15 use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other things, 17 personal health information, confidential business or financial information, 18 information regarding confidential business practices, or other confidential research, 19 development, or commercial information (including information implicating privacy 20 rights of third parties), information otherwise generally unavailable to the public, or 21 which may be privileged or otherwise protected from disclosure under state or federal 22 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 23 flow of information, to facilitate the prompt resolution of disputes over confidentiality 24 of discovery materials, to adequately protect information the parties are entitled to 25 keep confidential, to ensure that the parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their handling 27 at the end of the litigation, and serve the ends of justice, a protective order for such 1 will not be designated as confidential for tactical reasons and that nothing be so 2 designated without a good faith belief that it has been maintained in a confidential, 3 non-public manner, and there is good cause why it should not be part of the public 4 record of this case. 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 and Initial Standing Order for Civil Cases Assigned 9 to Judge Mark C. Scarsi Section 11 sets forth the procedures that must be followed 10 and the standards that will be applied when a party seeks permission from the court 11 to file material under seal. 12 Any document that is not confidential, privileged, or otherwise protectable in 13 its entirety will not be filed under seal if the confidential portions can be redacted. If 14 documents can be redacted, then a redacted version for public viewing, omitting only 15 the confidential, privileged, or otherwise protectable portions of the document shall 16 be filed. Any application that seeks to file documents under seal in their entirety 17 should include an explanation of why redaction is not feasible. 18 2. DEFINITIONS 19 2.1 Action: this pending federal lawsuit, i.e., Cedars-Sinai Medical Center 20 v. AIG Specialty Insurance Company., Case No. 2:24-cv-02543-MSC-RAO (C.D. 21 Cal.). 22 2.2 Challenging Party: a Party or Non-Party that challenges the designation 23 of information or items under this Order. 24 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 25 how it is generated, stored or maintained) or tangible things that qualify for protection 26 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 27 Cause Statement. 1 support staff). 2 2.5 Designating Party: a Party or Non-Party that designates information or 3 items that it produces in disclosures or in responses to discovery as 4 “CONFIDENTIAL.” 5 2.6 Disclosure or Discovery Material: all items or information, regardless 6 of the medium or manner in which it is generated, stored, or maintained (including, 7 among other things, testimony, transcripts, and tangible things) that are produced or 8 generated in disclosures or responses to discovery in this matter. 9 2.7 Expert: a person with specialized knowledge or experience in a matter 10 pertinent to the litigation who has been retained by a Party or its counsel to serve as 11 an expert witness or as a consultant in this Action. 12 2.8 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 2.9 Non-Party: any natural person, partnership, corporation, association or 16 other legal entity not named as a Party to this action. 17 2.10 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, and includes support staff. 21 2.11 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 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 2.13 Professional Vendors: persons or entities that provide litigation support 27 services (e.g., photocopying, videotaping, translating, preparing exhibits or 1 and their employees and subcontractors. 2 2.14 Protected Material: any Disclosure or Discovery Material that is 3 designated as “CONFIDENTIAL.” 4 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 5 from a Producing Party. 6 3. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or extracted 9 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 10 Protected Material; and (3) any testimony, conversations, or presentations by Parties 11 or their Counsel that might reveal Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 4. DURATION 15 Once a case proceeds to trial, information that was designated as 16 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 17 as an exhibit at trial becomes public and will be presumptively available to all 18 members of the public, including the press, unless compelling reasons supported by 19 specific factual findings to proceed otherwise are made to the trial judge in advance 20 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 21 showing for sealing documents produced in discovery from “compelling reasons” 22 standard when merits-related documents are part of court record). Accordingly, the 23 terms of this protective order do not extend beyond the commencement of the trial. 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under this 27 Order must take care to limit any such designation to specific material that qualifies 1 only those parts of material, documents, items or oral or written communications that 2 qualify so that other portions of the material, documents, items or communications 3 for which protection is not warranted are not swept unjustifiably within the ambit of 4 this Order. 5 Mass, indiscriminate or routinized designations are prohibited. Designations 6 that are shown to be clearly unjustified or that have been made for an improper 7 purpose (e.g., to unnecessarily encumber the case development process or to impose 8 unnecessary expenses and burdens on other parties) may expose the Designating Party 9 to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 designated for protection do not qualify for protection, that Designating Party must 12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 under this Order must be clearly so designated before the material is disclosed or 17 produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum, the legend 22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 23 contains protected material. If only a portion of the material on a page qualifies for 24 protection, the Producing Party also must clearly identify the protected portion(s) 25 (e.g., by making appropriate markings in the margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 1 before the designation, all of the material made available for inspection shall be 2 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 3 it wants copied and produced, the Producing Party must determine which documents, 4 or portions thereof, qualify for protection under this Order. Then, before producing 5 the specified documents, the Producing Party must affix the “CONFIDENTIAL 6 legend” to each page that contains Protected Material. If only a portion of the material 7 on a page qualifies for protection, the Producing Party also must clearly identify the 8 protected portion(s) (e.g., by making appropriate markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identifies 10 the Disclosure or Discovery Material on the record, before the close of the deposition 11 all protected testimony. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 “CONFIDENTIAL.” If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). 18 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 failure to designate qualified information or items does not, standing alone, waive the 20 Designating Party’s right to secure protection under this Order for such material. 21 Upon timely correction of a designation, the Receiving Party must make reasonable 22 efforts to assure that the material is treated in accordance with the provisions of this 23 Order. 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 1 resolution process under Local Rule 37.1 et seq. 2 6.3 The burden of persuasion in any such challenge proceeding shall be on 3 the Designating Party. Frivolous challenges, and those made for an improper purpose 4 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 5 expose the Challenging Party to sanctions. Unless the Designating Party has waived 6 or withdrawn the confidentiality designation, all parties shall continue to afford the 7 material in question the level of protection to which it is entitled under the Producing 8 Party’s designation until the Court rules on the challenge. 9 7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1 Basic Principles. A Receiving Party may use Protected Material that is 11 disclosed or produced by another Party or by a Non-Party in connection with this 12 Action only for prosecuting, defending or attempting to settle this Action. Such 13 Protected Material may be disclosed only to the categories of persons and under the 14 conditions described in this Order. When the Action has been terminated, a Receiving 15 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary 25 to disclose the information for this Action; 26 (b) the officers, directors, and employees (including House Counsel) of the 27 Receiving Party to whom disclosure is reasonably necessary for this Action; 1 disclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 (h) during their depositions, witnesses, and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 13 not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 15 agreed by the Designating Party or ordered by the court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal Protected Material may be 17 separately bound by the court reporter and may not be disclosed to anyone except as 18 permitted under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification shall 27 include a copy of the subpoena or court order; 1 to issue in the other litigation that some or all of the material covered by the subpoena 2 or order is subject to this Protective Order. Such notification shall include a copy of 3 this Stipulated Protective Order; and 4 (c) cooperate with respect to all reasonable procedures sought to be pursued 5 by the Designating Party whose Protected Material may be affected. 6 If the Designating Party timely seeks a protective order, the Party served with 7 the subpoena or court order shall not produce any information designated in this action 8 as “CONFIDENTIAL” before a determination by the court from which the subpoena 9 or order issued, unless the Party has obtained the Designating Party’s permission. The 10 Designating Party shall bear the burden and expense of seeking protection in that court 11 of its confidential material and nothing in these provisions should be construed as 12 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 13 directive from another court. 14 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a 17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party 26 that some or all of the information requested is subject to a confidentiality agreement 27 with a Non-Party; 1 Protective Order in this Action, the relevant discovery request(s), and a reasonably 2 specific description of the information requested; and 3 (3) make the information requested available for inspection by the Non- 4 Party, if requested. 5 (c) If the Non-Party fails to seek a protective order from this court within 6 14 days of receiving the notice and accompanying information, the Receiving Party 7 may produce the Non-Party’s confidential information responsive to the discovery 8 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 9 not produce any information in its possession or control that is subject to the 10 confidentiality agreement with the Non-Party before a determination by the court. 11 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 12 of seeking protection in this court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 19 persons to whom unauthorized disclosures were made of all the terms of this Order, 20 and (d) request such person or persons to execute the “Acknowledgment and 21 Agreement to Be Bound” that is attached hereto as Exhibit A. 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or 3 information covered by the attorney-client privilege or work product protection, the 4 parties may incorporate their agreement in the stipulated protective order submitted 5 to the court. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Protective Order, no Party waives any right it otherwise would have to object to 11 disclosing or producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object on any 13 ground to use in evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 16 only be filed under seal pursuant to a court order authorizing the sealing of the specific 17 Protected Material at issue. If a Party’s request to file Protected Material under seal 18 is denied by the court, then the Receiving Party may file the information in the public 19 record unless otherwise instructed by the court. 20 13. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 4, within 60 22 days of a written request by the Designating Party, each Receiving Party must certify 23 that it will return all Protected Material to the Producing Party or destroy such 24 material. As used in this subdivision, “all Protected Material” includes all copies, 25 abstracts, compilations, summaries, and any other format reproducing or capturing 26 any of the Protected Material. Whether the Protected Material is returned or 27 destroyed, the Receiving Party must submit a written certification to the Producing 1 deadline that (1) identifies (by category, where appropriate) all the Protected Material 2 that was returned or destroyed and (2) affirms that the Receiving Party has not 3 retained any copies, abstracts, compilations, summaries or any other format 4 reproducing or capturing any of the Protected Material. Notwithstanding this 5 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 6 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 7 deposition and trial exhibits, expert reports, attorney work product, and consultant 8 and expert work product, even if such materials contain Protected Material. Similarly, 9 AIG Specialty is entitled to retain an archival copy to the extent necessary to comply 10 with record retention policies associated with claim-related documentation. Any such 11 archival copies that contain or constitute Protected Material remain subject to this 12 Protective Order as set forth in Section 4 (DURATION). 13 14. VIOLATION 14 Any violation of this Order may be punished by appropriate measures including, 15 without limitation, contempt proceedings and/or monetary sanctions. 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 DATED January 2, 2025 20 21 /s/ Jeffrey Atteberry 22 VORA LAW FIRM, P.C. Nilay Vora 23 Jeff Atteberry Attorneys for Plaintiff Cedars-Sinai Medical Center 24

27 1 || DATED January 2, 2025 2 3 || /s/ Kirsten C. Jackson 4 || LATHAM & WATKINS Kirsten C. Jackson 5 || Attorneys for Plaintiff Cedars-Sinai Medical Center 6 7 8 || DATED: January 2, 2025 9 10 || /s/ Julia Beckley

DENTONS US LLP

11 || Julia M. Beckley Erin Bradham 12 || Attorneys for Defendant AIG Specialty Insurance Company 13 14 || DATED: January 1, 2025 15 16 || /s/ Joshua Shayne

KAUFMAN BORGEEST & RYAN LLP

17 || Joshua Shayne ig Attorneys Yor Defendant Ironshore Specialty Insurance Company 19 20

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21 22

DATED: 1/2/2025

23 x Rayel a. OC 25 || HON. ROZELLA A. OLIVER United States Magistrate Judge 27 28

1 ATTESTATION PURSUANT TO LOCAL RULE 5-4.3.4(2)(i) 2 Pursuant to Local Rule 5-4.3.4(2)(i), I, Kirsten C. Jackson, attest that all other 3 signatories listed and on whose behalf the filing is submitted concur in this filing’s 4 content and have authorized this filing. By: /s/ Kirsten C. Jackson 5 Kirsten C. Jackson 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 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 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Cedars-Sinai Medical Center v. AIG Specialty Insurance 9 Company, No. 2:24-cv-02543-MCS-RAO (C.D. Cal.). I agree to comply with and 10 to be bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this 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 Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type 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 sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27