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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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4 FLYER DEFENSE, LLC, a ) Case No. 2:24-CV-07654-AB (SSC) Delaware Limited Liability ) 5 Company, and FLYER NEXT, ) LLC, a Delaware Limited ) 6 Liability Company, ) [PROPOSED] STIPULATED ) 7 Plaintiffs, ) PROTECTIVE ORDER1 ) 8 v. ) ) Complaint Filed: September 9, 2024 9 SCOTTSDALE INSURANCE ) Trial Date: March 2, 2026 COMPANY, an Ohio corporation, ) 10 ) Defendant. ) 11 ) ) 12 13 14 1. INTRODUCTION 15 1.1 Purposes and Limitations. Discovery in this action is likely to 16 17 involve production of confidential, proprietary, or private information for 18 which special protection from public disclosure and from use for any 19 purpose other than prosecuting this litigation may be warranted. 20 Accordingly, the parties hereby stipulate to and petition the court to 21 enter the following Stipulated Protective Order. The parties 22 acknowledge that this Order does not confer blanket protections on all 23 disclosures or responses to discovery and that the protection it affords 24 from public disclosure and use extends only to the limited information or 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 items that are entitled to confidential treatment under the applicable 2 legal principles. 3 1.2 Good Cause Statement. 4 The Parties are conducting discovery in the above-captioned 5 litigation from one another and, potentially, third-parties. This 6 discovery will require the disclosure of testimony, documents, and other 7 information that may be considered by the Parties, or non-parties, to 8 contain attorney-client privilege and/or work product information, or 9 non-public information that is confidential, proprietary, commercially 10 sensitive, or the disclosure of which might adversely affect the Party’s 11 business. 12 This matter is an insurance coverage litigation arising out of 13 Scottsdale’s denial of Plaintiffs’ Claim for coverage for the lawsuit 14 entitled Marvin Engineering Co., Inc. v. Oded Nechushtan, et al., 15 currently pending in the Superior Court of California, Los Angeles 16 County, Case No. 22STCV30079 (the “Underlying Litigation”). Certain 17 of the information, documents, and deposition testimony which may be 18 subject to discovery in this action may relate to matters at issue in the 19 Underlying Litigation but are nevertheless privileged or confidential as 20 against any discovery which may be propounded in the Underlying 21 22 Litigation. 23 Moreover, a protective order exists in the Underlying Litigation 24 which requires that certain information relating to that information 25 remain confidential. Documents and information from that action which 26 are designated “confidential” may be requested and/or produced in the 27 present lawsuit, as well as documents contained in Scottsdale’s claims 1 secrets, customer and pricing lists and other valuable research, 2 development, commercial, financial, technical and/or proprietary 3 information for which special protection from public disclosure and from 4 use for any purpose other than prosecution of this action is warranted. 5 Such confidential and proprietary materials and information consist of, 6 among other things, confidential business or financial information, 7 information regarding confidential business practices, or other 8 confidential research, development, or commercial information (including 9 information implicating privacy rights of third parties), information 10 otherwise generally unavailable to the public, or which may be privileged 11 or otherwise protected from disclosure under state or federal statutes, 12 court rules, case decisions, or common law. 13 Accordingly, to expedite the flow of information, to facilitate the 14 prompt resolution of disputes over confidentiality of discovery materials, 15 to adequately protect information the parties are entitled to keep 16 confidential, to ensure that the parties are permitted reasonable 17 necessary uses of such material in preparation for and in the conduct of 18 trial, to address their handling at the end of the litigation, and serve the 19 ends of justice, a protective order for such information is justified in this 20 matter. It is the intent of the parties that information will not be 21 22 designated as confidential for tactical reasons and that nothing be so 23 designated without a good faith belief that it has been maintained in a 24 confidential, non-public manner, and there is good cause why it should 25 not be part of the public record of this case. 26 1.3 Acknowledgment of Procedure for Filing Under Seal. The 27 parties further acknowledge, as set forth in Section 12.3, below, that this 1 information under seal; Local Rule 79-5 sets forth the procedures that 2 must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 There is a strong presumption that the public has a right of access 5 to judicial proceedings and records in civil cases. In connection with 6 non-dispositive motions, good cause must be shown to support a filing 7 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 8 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 9 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 10 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 11 protective orders require good cause showing), and a specific showing of 12 good cause or compelling reasons with proper evidentiary support and 13 legal justification, must be made with respect to Protected Material that 14 a party seeks to file under seal. The parties’ mere designation of 15 Disclosure or Discovery Material as CONFIDENTIAL does not— 16 without the submission of competent evidence by declaration, 17 establishing that the material sought to be filed under seal qualifies as 18 confidential, privileged, or otherwise protectable—constitute good cause. 19 Further, if a party requests sealing related to a dispositive motion 20 or trial, then compelling reasons, not only good cause, for the sealing 21 22 must be shown, and the relief sought shall be narrowly tailored to serve 23 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 24 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 25 information, document, or thing sought to be filed or introduced under 26 seal in connection with a dispositive motion or trial, the party seeking 27 protection must articulate compelling reasons, supported by specific 1 competent evidence supporting the application to file documents under 2 seal must be provided by declaration. 3 Any document that is not confidential, privileged, or otherwise 4 protectable in its entirety will not be filed under seal if the confidential 5 portions can be redacted. If documents can be redacted, then a redacted 6 version for public viewing, omitting only the confidential, privileged, or 7 otherwise protectable portions of the document, shall be filed. Any 8 application that seeks to file documents under seal in their entirety 9 should include an explanation of why redaction is not feasible. 10

11 2. DEFINITIONS 12 2.1 Action: this pending federal lawsuit. 13 2.2 Challenging Party: a Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information 16 (regardless of how it is generated, stored or maintained) or tangible 17 18 things that qualify for protection under Rule 26(c) of the Federal Rules of 19 Civil Procedure, and as specified above in the Good Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as 21 well as their support staff). 22 2.5 Designating Party: a Party or Non-Party that designates 23 information or items that it produces in disclosures or in responses to 24 discovery as “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, 26 regardless of the medium or manner in which it is generated, stored, or 27 maintained (including, among other things, testimony, transcripts, and 1 tangible things), that are produced or generated in disclosures or 2 responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in 4 a matter pertinent to the litigation who has been retained by a Party or 5 its counsel to serve as an expert witness or as a consultant in this Action. 6 2.8 Final Disposition: the later of (1) dismissal of all claims and 7 defenses in this Action, with or without prejudice; and (2) final judgment 8 herein after the completion and exhaustion of all appeals, rehearings, 9 remands, trials, or reviews of this Action, including the time limits for 10 filing any motions or applications for extension of time pursuant to 11 applicable law. 12 2.9 In-House Counsel: attorneys who are employees of a party to 13 this Action. In-House Counsel does not include Outside Counsel of 14 Record or any other outside counsel. 15 2.10 Non-Party: any natural person, partnership, corporation, 16 association, or other legal entity not named as a Party to this action. 17 2.11 Outside Counsel of Record: attorneys who are not employees 18 of a party to this Action but are retained to represent or advise a party to 19 this Action and have appeared in this Action on behalf of that party or 20 are affiliated with a law firm which has appeared on behalf of that party, 21 22 and includes support staff. 23 2.12 Party: any party to this Action, including all of its officers, 24 directors, employees, consultants, retained experts, and Outside Counsel 25 of Record (and their support staffs). 26 2.13 Producing Party: a Party or Non-Party that produces 27 Disclosure or Discovery Material in this Action. 1 litigation- support services (e.g., photocopying, videotaping, translating, 2 preparing exhibits or demonstrations, and organizing, storing, or 3 retrieving data in any form or medium) and their employees and 4 subcontractors. 5 2.15 Protected Material: any Disclosure or Discovery Material that 6 is designated as “CONFIDENTIAL.” 7 2.16 Receiving Party: a Party that receives Disclosure or Discovery 8 Material from a Producing Party. 9

10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not 12 only Protected Material (as defined above), but also (1) any information 13 copied or extracted from Protected Material; (2) all copies, excerpts, 14 summaries, or compilations of Protected Material; and (3) any 15 testimony, conversations, or presentations by Parties or their Counsel 16 that might reveal Protected Material. 17 18 Any use of Protected Material at trial shall be governed by the 19 orders of the trial judge. This Stipulated Protective Order does not 20 govern the use of Protected Material at trial. 21 22 4. TRIAL AND DURATION 23 The terms of this Stipulated Protective Order apply through Final 24 Disposition of the Action. 25 Once a case proceeds to trial, information that was designated as 26 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 27 1 will be presumptively available to all members of the public, including 2 the press, unless compelling reasons supported by specific factual 3 findings to proceed otherwise are made to the trial judge in advance of 4 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 5 cause” showing for sealing documents produced in discovery from 6 “compelling reasons” standard when merits-related documents are part 7 of court record). Accordingly, for such materials, the terms of this 8 Stipulated Protective Order do not extend beyond the commencement of 9 the trial. 10 Even after Final Disposition of this litigation, the confidentiality 11 obligations imposed by this Stipulated Protective Order shall remain in 12 effect until a Designating Party agrees otherwise in writing or a court 13 order otherwise directs. 14

15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for 17 18 Protection. Each Party or Non-Party that designates information or 19 items for protection under this Order must take care to limit any such 20 designation to specific material that qualifies under the appropriate 21 standards. The Designating Party must designate for protection only 22 those parts of material, documents, items, or oral or written 23 communications that qualify so that other portions of the material, 24 documents, items, or communications for which protection is not 25 warranted are not swept unjustifiably within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. 27 Designations that are shown to be clearly unjustified or that have been 1 made for an improper purpose (e.g., to unnecessarily encumber the case 2 development process or to impose unnecessary expenses and burdens on 3 other parties) may expose the Designating Party to sanctions. 4 If it comes to a Designating Party’s attention that information or 5 items that it designated for protection do not qualify for protection, that 6 Designating Party must promptly notify all other Parties that it is 7 withdrawing the inapplicable designation. 8 5.2 Manner and Timing of Designations. Except as otherwise 9 provided in this Stipulated Protective Order (see, e.g., second paragraph 10 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 11 or Discovery Material that qualifies for protection under this Stipulated 12 Protective Order must be clearly so designated before the material is 13 disclosed or produced. 14 Designation in conformity with this Stipulated Protective Order 15 requires: 16 17 (a) for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or 19 trial proceedings), that the Producing Party affix at a minimum, the 20 legend “CONFIDENTIAL” to each page that contains protected 21 material. If only a portion or portions of the material on a page 22 qualifies for protection, the Producing Party also must clearly identify 23 the protected portion(s) (e.g., by making appropriate markings in the 24 margins). 25 A Party or Non-Party that makes original documents available for 26 inspection need not designate them for protection until after the 27 inspecting Party has indicated which documents it would like copied 1 and produced. During the inspection and before the designation, all of 2 the material made available for inspection shall be deemed 3 CONFIDENTIAL. After the inspecting Party has identified the 4 documents it wants copied and produced, the Producing Party must 5 determine which documents, or portions thereof, qualify for protection 6 under this Stipulated Protective Order. Then, before producing the 7 specified documents, the Producing Party must affix the 8 “CONFIDENTIAL” legend to each page that contains Protected 9 Material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly identify 11 the protected portion(s) (e.g., by making appropriate markings in the 12 margins). 13 (b) for testimony given in depositions that the Designating Party 14 identify the Disclosure or Discovery Material on the record, before the 15 close of the deposition all protected testimony. Alternatively, any Party 16 may, no later than fifteen (15) business days after receipt of a final 17 deposition transcript (i.e., fifteen (15) business days after the witness has 18 made any revisions to and certified the transcript, or the time to do so 19 has lapsed, whichever is sooner), designate by page and line all or any 20 portion thereof as confidential under the terms of the Order by providing 21 22 notice in writing to the other Parties. Until then, the transcript shall be 23 deemed confidential. All copies of deposition transcripts that contain 24 Confidential Material shall be prominently marked “CONFIDENTIAL” 25 on the cover thereof. 26 (c) for information produced in some form other than 27 documentary and for any other tangible items, that the Producing Party 1 in which the information is stored the “CONFIDENTIAL” legend. If only 2 a portion or portions of the information warrants protection, the 3 Producing Party, to the extent practicable, shall identify the protected 4 portion(s). 5 5.3 Inadvertent Failures to Designate. If timely corrected, an 6 inadvertent failure to designate qualified information or items does not, 7 standing alone, waive the Designating Party’s right to secure protection 8 under this Order for such material. Upon timely correction of a 9 designation, the Receiving Party must make reasonable efforts to assure 10 that the material is treated in accordance with the provisions of this 11 Stipulated Protective Order. 12

13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 15 6.1 Timing of Challenges. Any Party or Non-Party may 16 challenge a designation of confidentiality at any time that is consistent 17 with the court’s Scheduling Order. 18 6.2 Meet and Confer. The Challenging Party shall initiate the 19 dispute resolution process under Local Rule 37.1 et seq. and with 20 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 21 Discovery Motion Conference.”2 22 6.3 The burden of persuasion in any such challenge proceeding 23 shall be on the Designating Party. Frivolous challenges, and those 24 made for an improper purpose (e.g., to harass or impose unnecessary 25 expenses and burdens on other parties) may expose the Challenging 26

27 2 Judge Christensen’s Procedures are available at 1 Party to sanctions. Unless the Designating Party has waived or 2 withdrawn the confidentiality designation, all parties shall continue to 3 afford the material in question the level of protection to which it is 4 entitled under the Producing Party’s designation until the court rules on 5 the challenge. 6 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected 9 Material that is disclosed or produced by another Party or by a Non- 10 Party in connection with this Action only for prosecuting, defending, or 11 attempting to settle this Action. Such Protected Material may be 12 disclosed only to the categories of persons and under the conditions 13 described in this Order. When the Action reaches a Final Disposition, a 14 Receiving Party must comply with the provisions of section 13 below. 15 Protected Material must be stored and maintained by a Receiving 16 17 Party at a location and in a secure manner that ensures that access is 18 limited to the persons authorized under this Stipulated Protective 19 Order. 20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 21 Unless otherwise ordered by the court or permitted in writing by the 22 Designating Party, a Receiving Party may disclose any information or 23 item designated “CONFIDENTIAL” only: 24 (a) to the Receiving Party’s Outside Counsel of Record in this 25 Action, as well as employees of said Outside Counsel of Record to whom 26 it is reasonably necessary to disclose the information for this Action; 27 (b) to the officers, directors, and employees (including House 1 Counsel) of the Receiving Party to whom disclosure is reasonably 2 necessary for this Action; 3 (c) to Experts (as defined in this Order) of the Receiving Party to 4 whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) to the court and its personnel; 7 (e) to court reporters and their staff; 8 (f) to professional jury or trial consultants, mock jurors, and 9 Professional Vendors to whom disclosure is reasonably necessary for 10 this Action and who have signed the “Acknowledgment and Agreement 11 to Be Bound” (Exhibit A); 12 (g) to the author or recipient of a document containing the 13 information or a custodian or other person who otherwise possessed or 14 knew the information; 15 (h) during their depositions, to stenographers, videographers, 16 witnesses, and attorneys for witnesses, in the Action to whom disclosure 17 is reasonably necessary, provided: (1) the deposing party requests that 18 witnesses sign the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); and (2) witnesses will not be permitted to keep any 20 confidential information unless they sign the “Acknowledgment and 21 22 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 23 Designating Party or ordered by the court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected 25 Material may be separately bound by the court reporter and may not be 26 disclosed to anyone except as permitted under this Stipulated Protective 27 Order; 1 representatives of such insurers, reinsurers, or regulators; 2 (j) to other persons who may be later designated by written 3 agreement of the Parties, or by order of the Court obtained on noticed 4 motion (or on shortened time as allowed by the Court) permitting such 5 disclosure, or who otherwise obtain authorization to receive Confidential 6 Information in accordance with this Stipulated Protective Order; and 7 (k) to any mediator or settlement officer, and their supporting 8 personnel, mutually agreed upon by any of the parties engaged in 9 settlement discussions. 10

11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 12

PRODUCED IN OTHER LITIGATION

13 If a Party is served with a subpoena or a court order issued in 14 other litigation that compels disclosure of any information or items 15 designated in this Action as “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party. Such 17 18 notification shall include a copy of the subpoena or court order; 19 (b) promptly notify in writing the party who caused the 20 subpoena or order to issue in the other litigation that some or all of the 21 material covered by the subpoena or order is subject to this Protective 22 Order. Such notification shall include a copy of this Stipulated 23 Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to 25 be pursued by the Designating Party whose Protected Material may be 26 affected. 27 If the Designating Party timely seeks a protective order, the 1 Party served with the subpoena or court order shall not produce any 2 information designated in this action as “CONFIDENTIAL” before a 3 determination by the court from which the subpoena or order issued, 4 unless the Party has obtained the Designating Party’s permission. The 5 Designating Party shall bear the burden and expense of seeking 6 protection in that court of its confidential material and nothing in these 7 provisions should be construed as authorizing or encouraging a 8 Receiving Party in this Action to disobey a lawful directive from another 9 court. 10

11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12

PRODUCED IN THIS LITIGATION

13 9.1 Application. The terms of this Stipulated Protective Order 14 are applicable to information produced by a Non-Party in this Action and 15 designated as “CONFIDENTIAL.” Such information produced by Non- 16 Parties in connection with this litigation is protected by the remedies 17 and relief provided by this Order. Nothing in these provisions should be 18 construed as prohibiting a Non-Party from seeking additional 19 protections. 20 21 9.2 Notification. In the event that a Party is required, by a valid 22 discovery request, to produce a Non-Party’s confidential information in 23 its possession, and the Party is subject to an agreement with the Non- 24 Party not to produce the Non-Party’s confidential information, then the 25 Party shall: 26 (a) promptly notify in writing the Requesting Party and the 27 Non-Party that some or all of the information requested is subject to a 1 (b) make the information requested available for inspection by 2 the Non-Party, if requested. 3 9.3 Conditions of Production. If the Non-Party fails to seek a 4 protective order from this court within 14 days of receiving the notice 5 and accompanying information, the Receiving Party may produce the 6 Non-Party’s confidential information responsive to the discovery request. 7 If the Non-Party timely seeks a protective order, the Receiving Party 8 shall not produce any information in its possession or control that is 9 subject to the confidentiality agreement with the Non-Party before a 10 determination by the court. Absent a court order to the contrary, the 11 Non-Party shall bear the burden and expense of seeking protection in 12 this court of its Protected Material. 13

14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 15

MATERIAL

16 17 If a Receiving Party learns that, by inadvertence or otherwise, it 18 has disclosed Protected Material to any person or in any circumstance 19 not authorized under this Stipulated Protective Order, the Receiving 20 Party must immediately (a) notify in writing the Designating Party of 21 the unauthorized disclosures, (b) use its best efforts to retrieve all 22 unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of 24 this Order, and (d) request such person or persons to execute the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 26

27 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 1 OTHERWISE PROTECTED MATERIAL 2 When a Producing Party gives notice to Receiving Parties that 3 certain inadvertently produced material is subject to a claim of privilege 4 or other protection, the obligations of the Receiving Parties are those set 5 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 6 provision is not intended to modify whatever procedure may be 7 established in an e-discovery order that provides for production without 8 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 9 Rules of Evidence, he parties have reached a stipulated agreement on 10 the effect of disclosure of a communication or information covered by the 11 attorney-client privilege or work product protection, which stipulation 12 and related [Proposed] Order is being filed concurrently herewith. 13

14 12. MISCELLANEOUS 15 16 12.1 Right to Further Relief. Nothing in this Stipulated 17 Protective Order abridges the right of any person to seek its 18 modification by the court in the future. 19 12.2 Right to Assert Other Objections. By stipulating to the entry 20 of this Stipulated Protective Order no Party waives any right it 21 otherwise would have to object to disclosing or producing any 22 information or item on any ground not addressed in this Stipulated 23 Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this 25 Stipulated Protective Order. 26 12.3 Filing Protected Material. A Party that seeks to file under 27 seal any Protected Material must comply with Local Rule 79-5. 1 Protected Material may only be filed under seal pursuant to a court 2 order authorizing the sealing of the specific Protected Material at issue. 3 If a Party's request to file Protected Material under seal is denied by the 4 court, then the Receiving Party may file the information in the public 5 record unless otherwise instructed by the court. 6 12.4 Protective Orders in Underlying Litigation. To the extent 7 that any protective orders which may apply to Protected Material 8 sought to be exchanged between the Parties hereto have been or are 9 hereafter entered in any of the Underlying Litigation, the Parties each 10 covenant that they shall execute such document(s) as may be reasonably 11 required by such protective order(s) to permit the exchange of such 12 Protected Material. 13

14 13. FINAL DISPOSITION 15 This Order, insofar as it restricts the communication and use of 16 Confidential Material, shall continue to be binding throughout and after 17 18 the conclusion of this litigation, including any appeals. The obligations 19 of the Parties under this Order shall survive the resolution of this action 20 such that the Parties agree to maintain all Confidential Material as 21 “CONFIDENTIAL” during the pendency of and after the conclusion of 22 this action. 23 24 25 26 27 1 || 14. VIOLATION 2 Any violation of this Stipulated Protective Order may be punished 3 || by any and all appropriate measures including, without limitation, 4 || contempt proceedings and/or monetary sanctions. 5 6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 Dated: January 14, 2025 LOPEZ, BARK & SCHULZ, LLP 8 9 10 By: /s/ Joseph R. Wilbert 1 Joseph R. Wilbert Attorneys for Plaintiffs 12 Flyer Defense, LLC and Flyer Next, 3 LLC 14 15 Dated: January 14, 2025 COZEN O’CONNOR 16 17 By: /s/ Valerie D. Rojas Valerie D. Rojas 18 Attorneys for Defendant 19 Scottsdale Insurance Company 20 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 Za DATED: January 15, 2025 24

STEPHANIE 8S. CHRISTENSEN

25 United States Magistrate Judge 26 27 28

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 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 2:24-cv-07654-AB-SSC Flyer Defense, LLC et al v. Scottsdale 9 Insurance Company. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I 13 14 will not disclose in any manner any information or item that is subject 15 to this Stipulated Protective Order to any person or entity except in 16 strict compliance with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States 18 District Court for the Central District of California for the purpose of 19 enforcing the terms of this Stipulated Protective Order, even if such 20 enforcement proceedings occur after termination of this action. I 21 hereby appoint ________________________ [print or type full name] 22 of _________ [print or type full address and telephone number] as 23 24 25 26 27 1 my California agent for service of process in connection with this action 2 or any proceedings related to enforcement of this Stipulated Protective 3 Order. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10

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