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IN THE UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA – WESTERN

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DIVISION

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12 JERIE PETROSIAN, as Trustee of the ) Case No.: 2:24-cv-06963-FLA-SSC

PETROSIAN TRUST; JKP )

13 APARTMENTS, ) STIPULATED PROTECTIVE ) 14 ) ORDER1 Plaintiffs, ) 15 ) v. ) 16 )

STATE NATIONAL INSURANCE )

17 COMPANY; and DOES 1 through ) 10, inclusive, ) 18 ) Defendants. ) 19 ) ) 20 ) ) 21 )

AND RELATED COUNTERCLAIMS.

) 22 ) / / / 23 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to 3 involve production of confidential, proprietary, or private information for 4 which special protection from public disclosure and from use for any 5 6 purpose other than prosecuting this litigation may be warranted. 7 Accordingly, the parties hereby stipulate to and petition the court to 8 9 enter the following Stipulated Protective Order. The parties 10 acknowledge that this Order does not confer blanket protections on all 11 disclosures or responses to discovery and that the protection it affords 12 13 from public disclosure and use extends only to the limited information or 14 items that are entitled to confidential treatment under the applicable 15 16 legal principles. 17 1.2 Good Cause Statement. 18 This action is likely to involve material that at least one party 19 20 contends qualifies as trade secrets, confidential, financial, proprietary 21 and/or commercially sensitive business information for which special 22 23 protection from public disclosure and from use for any purpose other 24 than prosecution of this action is warranted, possibly including 25 insurance underwriting manuals and guidelines that may apply to the 26 27 insurance policies at issue in this lawsuit and financial information of 1 the parties, which is not available to the general public for which the 2 responding party seeks to maintain the confidentiality of such financial 3 information. Such confidential and proprietary materials and 4 5 information consist of, among other things, confidential business or 6 financial information, information regarding confidential business 7 8 practices, or other confidential research, development, or commercial 9 information (including information implicating privacy rights of third 10 parties), information otherwise generally unavailable to the public, or 11 12 which may be privileged or otherwise protected from disclosure under 13 state or federal statutes, court rules, case decisions, or common law. 14 15 Accordingly, to expedite the flow of information, to facilitate the prompt 16 resolution of disputes over confidentiality of discovery materials, to 17 adequately protect information the parties are entitled to keep 18 19 confidential, to ensure that the parties are permitted reasonable 20 necessary uses of such material in preparation for and in the conduct of 21 22 trial, to address their handling at the end of the litigation, and serve the 23 ends of justice, a protective order for such information is justified in this 24 matter. It is the intent of the parties that information will not be 25 26 designated as confidential for tactical reasons and that nothing be so 27 designated without a good faith belief that it has been maintained in a 1 confidential, non-public manner, and there is good cause why it should 2 not be part of the public record of this case. 3 1.3 Acknowledgment of Procedure for Filing Under Seal. The 4 5 parties further acknowledge, as set forth in Section 12.3, below, that this 6 Stipulated Protective Order does not entitle them to file confidential 7 8 information under seal; Local Rule 79-5 sets forth the procedures that 9 must be followed and the standards that will be applied when a party 10 seeks permission from the court to file material under seal. 11 12 There is a strong presumption that the public has a right of access 13 to judicial proceedings and records in civil cases. In connection with 14 15 non-dispositive motions, good cause must be shown to support a filing 16 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 17 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 18 19 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 20 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 21 22 protective orders require good cause showing), and a specific showing of 23 good cause or compelling reasons with proper evidentiary support and 24 legal justification, must be made with respect to Protected Material that 25 26 a party seeks to file under seal. The parties’ mere designation of 27 Disclosure or Discovery Material as CONFIDENTIAL does not— 1 without the submission of competent evidence by declaration, 2 establishing that the material sought to be filed under seal qualifies as 3 confidential, privileged, or otherwise protectable—constitute good cause. 4 5 Further, if a party requests sealing related to a dispositive motion 6 or trial, then compelling reasons, not only good cause, for the sealing 7 8 must be shown, and the relief sought shall be narrowly tailored to serve 9 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 10 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 11 12 information, document, or thing sought to be filed or introduced under 13 seal in connection with a dispositive motion or trial, the party seeking 14 15 protection must articulate compelling reasons, supported by specific 16 facts and legal justification, for the requested sealing order. Again, 17 competent evidence supporting the application to file documents under 18 19 seal must be provided by declaration. 20 Any document that is not confidential, privileged, or otherwise 21 22 protectable in its entirety will not be filed under seal if the confidential 23 portions can be redacted. If documents can be redacted, then a redacted 24 version for public viewing, omitting only the confidential, privileged, or 25 26 otherwise protectable portions of the document, shall be filed. Any 27 application that seeks to file documents under seal in their entirety 1 should include an explanation of why redaction is not feasible. 2 2. DEFINITIONS 3 2.1 Action: Jerie Petrosian, as Trustee of the Petrosian Trust, and 4 5 JKP Apartments v. State National Insurance Company, et al. 6 2.2 Challenging Party: a Party or Non-Party that challenges the 7 8 designation of information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information 10 (regardless of how it is generated, stored or maintained) or tangible 11 12 things that qualify for protection under Rule 26(c) of the Federal Rules of 13 Civil Procedure, and as specified above in the Good Cause Statement. 14 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as 16 well as their support staff). 17 2.5 Designating Party: a Party or Non-Party that designates 18 19 information or items that it produces in disclosures or in responses to 20 discovery as “CONFIDENTIAL.” 21 22 2.6 Disclosure or Discovery Material: all items or information, 23 regardless of the medium or manner in which it is generated, stored, or 24 maintained (including, among other things, testimony, transcripts, and 25 26 tangible things), that are produced or generated in disclosures or 27 responses to discovery in this matter. 1 2.7 Expert: a person with specialized knowledge or experience in 2 a matter pertinent to the litigation who has been retained by a Party or 3 its counsel to serve as an expert witness or as a consultant in this Action. 4 5 2.8 Final Disposition: the later of (1) dismissal of all claims and 6 defenses in this Action, with or without prejudice; and (2) final judgment 7 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 12 applicable law. 13 2.9 In-House Counsel: attorneys who are employees of a party to 14 15 this Action. In-House Counsel does not include Outside Counsel of 16 Record or any other outside counsel. 17 2.10 Non-Party: any natural person, partnership, corporation, 18 19 association, or other legal entity not named as a Party to this action. 20 2.11 Outside Counsel of Record: attorneys who are not employees 21 22 of a party to this Action but are retained to represent or advise a party to 23 this Action and have appeared in this Action on behalf of that party or 24 are affiliated with a law firm which has appeared on behalf of that party, 25 26 and includes support staff. 27 /// 1 2.12 Party: any party to this Action, including all of their officers, 2 directors, employees, consultants, retained experts, claims counsel, In- 3 House Counsel, and Outside Counsel of Record (and their support staffs). 4 5 2.13 Producing Party: a Party or Non-Party that produces 6 Disclosure or Discovery Material in this Action. 7 8 2.14 Professional Vendors: persons or entities that provide 9 litigation- support services (e.g., photocopying, videotaping, translating, 10 preparing exhibits or demonstrations, and organizing, storing, or 11 12 retrieving data in any form or medium) and their employees and 13 subcontractors. 14 15 2.15 Protected Material: any Disclosure or Discovery Material that 16 is designated as “CONFIDENTIAL.” 17 2.16 Receiving Party: a Party that receives Disclosure or Discovery 18 19 Material from a Producing Party. 20 3. SCOPE 21 22 The protections conferred by this Stipulation and Order cover not 23 only Protected Material (as defined above), but also (1) any information 24 copied or extracted from Protected Material; (2) all copies, excerpts, 25 26 summaries, or compilations of Protected Material; and (3) any 27 testimony, conversations, or presentations by Parties or their Counsel 1 that might reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the 3 orders of the trial judge. This Stipulated Protective Order does not 4 5 govern the use of Protected Material at trial. 6 4. TRIAL AND DURATION 7 8 The terms of this Stipulated Protective Order apply through Final 9 Disposition of the Action. 10 Once a case proceeds to trial, information that was designated as 11 12 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 13 Order and used or introduced as an exhibit at trial becomes public and 14 15 will be presumptively available to all members of the public, including 16 the press, unless compelling reasons supported by specific factual 17 findings to proceed otherwise are made to the trial judge in advance of 18 19 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 20 cause” showing for sealing documents produced in discovery from 21 22 “compelling reasons” standard when merits-related documents are part 23 of court record). Accordingly, for such materials, the terms of this 24 Stipulated Protective Order do not extend beyond the commencement of 25 26 the trial. 27 /// 1 Even after Final Disposition of this litigation, the confidentiality 2 obligations imposed by this Stipulated Protective Order shall remain in 3 effect until a Designating Party agrees otherwise in writing or a court 4 5 order otherwise directs. 6 5. DESIGNATING PROTECTED MATERIAL 7 8 5.1 Exercise of Restraint and Care in Designating Material for 9 Protection. Each Party or Non-Party that designates information or 10 items for protection under this Order must take care to limit any such 11 12 designation to specific material that qualifies under the appropriate 13 standards. The Designating Party must designate for protection only 14 15 those parts of material, documents, items, or oral or written 16 communications that qualify so that other portions of the material, 17 documents, items, or communications for which protection is not 18 19 warranted are not swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. 21 22 Designations that are shown to be clearly unjustified or that have been 23 made for an improper purpose (e.g., to unnecessarily encumber the case 24 development process or to impose unnecessary expenses and burdens on 25 26 other parties) may expose the Designating Party to sanctions. 27 /// 1 If it comes to a Designating Party’s attention that information or 2 items that it designated for protection do not qualify for protection, that 3 Designating Party must promptly notify all other Parties that it is 4 5 withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise 7 8 provided in this Stipulated Protective Order (see, e.g., second paragraph 9 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 10 or Discovery Material that qualifies for protection under this Stipulated 11 12 Protective Order must be clearly so designated before the material is 13 disclosed or produced. 14 15 Designation in conformity with this Stipulated Protective Order 16 requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 19 documents, but excluding transcripts of depositions or other pretrial or 20 trial proceedings), that the Producing Party affix at a minimum, the 21 22 legend “CONFIDENTIAL” to each page that contains protected 23 material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify 25 26 the protected portion(s) (e.g., by making appropriate markings in the 27 margins). 1 A Party or Non-Party that makes original documents available for 2 inspection need not designate them for protection until after the 3 inspecting Party has indicated which documents it would like copied 4 5 and produced. During the inspection and before the designation, all of 6 the material made available for inspection shall be deemed 7 8 CONFIDENTIAL. After the inspecting Party has identified the 9 documents it wants copied and produced, the Producing Party must 10 determine which documents, or portions thereof, qualify for protection 11 12 under this Stipulated Protective Order. Then, before producing the 13 specified documents, the Producing Party must affix the 14 15 “CONFIDENTIAL” legend to each page that contains Protected 16 Material. If only a portion or portions of the material on a page 17 qualifies for protection, the Producing Party also must clearly identify 18 19 the protected portion(s) (e.g., by making appropriate markings in the 20 margins). 21 22 (b) for testimony given in depositions that the Designating Party 23 identify the Disclosure or Discovery Material on the record, before the 24 close of the deposition all protected testimony. 25 26 (c) for information produced in some form other than 27 documentary and for any other tangible items, that the Producing Party 1 affix in a prominent place on the exterior of the container or containers 2 in which the information is stored the “CONFIDENTIAL” legend. If only 3 a portion or portions of the information warrants protection, the 4 5 Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 7 8 5.3 Inadvertent Failures to Designate. If timely corrected, an 9 inadvertent failure to designate qualified information or items does not, 10 standing alone, waive the Designating Party’s right to secure protection 11 12 under this Order for such material. Upon timely correction of a 13 designation, the Receiving Party must make reasonable efforts to assure 14 15 that the material is treated in accordance with the provisions of this 16 Stipulated Protective Order. 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 19 6.1 Timing of Challenges. Any Party or Non-Party may 20 challenge a designation of confidentiality at any time that is consistent 21 22 with the court’s Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the 24 dispute resolution process under Local Rule 37.1 et seq. and with 25 26 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre- 27 1 Discovery Motion Conference.”2 2 6.3 The burden of persuasion in any such challenge proceeding 3 shall be on the Designating Party. Frivolous challenges, and those 4 5 made for an improper purpose (e.g., to harass or impose unnecessary 6 expenses and burdens on other parties) may expose the Challenging 7 8 Party to sanctions. Unless the Designating Party has waived or 9 withdrawn the confidentiality designation, all parties shall continue to 10 afford the material in question the level of protection to which it is 11 12 entitled under the Producing Party’s designation until the court rules on 13 the challenge. 14 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected 17 Material that is disclosed or produced by another Party or by a Non- 18 19 Party in connection with this Action only for prosecuting, defending, or 20 attempting to settle this Action. Such Protected Material may be 21 22 disclosed only to the categories of persons and under the conditions 23 described in this Order. When the Action reaches a Final Disposition, a 24 Receiving Party must comply with the provisions of section 13 below. 25 26

27 2 Judge Christensen’s Procedures are available at 1 Protected Material must be stored and maintained by a Receiving 2 Party at a location and in a secure manner that ensures that access is 3 limited to the persons authorized under this Stipulated Protective 4 5 Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 7 8 Unless otherwise ordered by the court or permitted in writing by the 9 Designating Party, a Receiving Party may disclose any information or 10 item designated “CONFIDENTIAL” only: 11 12 (a) to the Receiving Party’s Outside Counsel of Record in this 13 Action, as well as employees of said Outside Counsel of Record to whom 14 15 it is reasonably necessary to disclose the information for this Action; 16 (b) to the officers, directors, and employees (including House 17 Counsel) of the Receiving Party to whom disclosure is reasonably 18 19 necessary for this Action; 20 (c) to Experts (as defined in this Order) of the Receiving Party to 21 22 whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) to the court and its personnel; 25 26 (e) to court reporters and their staff; 27 (f) to professional jury or trial consultants, mock jurors, and 1 Professional Vendors to whom disclosure is reasonably necessary for 2 this Action and who have signed the “Acknowledgment and Agreement 3 to Be Bound” (Exhibit A); 4 5 (g) to the author or recipient of a document containing the 6 information or a custodian or other person who otherwise possessed or 7 8 knew the information; 9 (h) during their depositions, to witnesses, and attorneys for 10 witnesses, in the Action to whom disclosure is reasonably necessary, 11 12 provided: (1) the deposing party requests that the witness sign the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 14 15 witness will not be permitted to keep any confidential information 16 unless they sign the “Acknowledgment and Agreement to Be Bound” 17 (Exhibit A), unless otherwise agreed by the Designating Party or 18 19 ordered by the court. Pages of transcribed deposition testimony or 20 exhibits to depositions that reveal Protected Material may be separately 21 22 bound by the court reporter and may not be disclosed to anyone except 23 as permitted under this Stipulated Protective Order; and 24 (i) to any mediator or settlement officer, and their supporting 25 26 personnel, mutually agreed upon by any of the parties engaged in 27 settlement discussions. 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2

PRODUCED IN OTHER LITIGATION

3 If a Party is served with a subpoena or a court order issued in 4 5 other litigation that compels disclosure of any information or items 6 designated in this Action as “CONFIDENTIAL,” that Party must: 7 8 (a) promptly notify in writing the Designating Party. Such 9 notification shall include a copy of the subpoena or court order; 10 (b) promptly notify in writing the party who caused the 11 12 subpoena or order to issue in the other litigation that some or all of the 13 material covered by the subpoena or order is subject to this Protective 14 15 Order. Such notification shall include a copy of this Stipulated 16 Protective Order; and 17 (c) cooperate with respect to all reasonable procedures sought to 18 19 be pursued by the Designating Party whose Protected Material may be 20 affected. 21 22 If the Designating Party timely seeks a protective order, the 23 Party served with the subpoena or court order shall not produce any 24 information designated in this action as “CONFIDENTIAL” before a 25 26 determination by the court from which the subpoena or order issued, 27 unless the Party has obtained the Designating Party’s permission. The 1 Designating Party shall bear the burden and expense of seeking 2 protection in that court of its confidential material and nothing in these 3 provisions should be construed as authorizing or encouraging a 4 5 Receiving Party in this Action to disobey a lawful directive from another 6 court. 7 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9

PRODUCED IN THIS LITIGATION

10 9.1 Application. The terms of this Stipulated Protective Order 11 12 are applicable to information produced by a Non-Party in this Action and 13 designated as “CONFIDENTIAL.” Such information produced by Non- 14 15 Parties in connection with this litigation is protected by the remedies 16 and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional 18 19 protections. 20 9.2 Notification. In the event that a Party is required, by a valid 21 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 26 Party shall: 27 (a) promptly notify in writing the Requesting Party and the 1 Non-Party that some or all of the information requested is subject to a 2 confidentiality agreement with a Non-Party; 3 (b) make the information requested available for inspection by 4 5 the Non-Party, if requested. 6 9.3 Conditions of Production. If the Non-Party fails to seek a 7 8 protective order from this court within 14 days of receiving the notice 9 and accompanying information, the Receiving Party may produce the 10 Non-Party’s confidential information responsive to the discovery request. 11 12 If the Non-Party timely seeks a protective order, the Receiving Party 13 shall not produce any information in its possession or control that is 14 15 subject to the confidentiality agreement with the Non-Party before a 16 determination by the court. Absent a court order to the contrary, the 17 Non-Party shall bear the burden and expense of seeking protection in 18 19 this court of its Protected Material. 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 21 22 MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it 24 has disclosed Protected Material to any person or in any circumstance 25 26 not authorized under this Stipulated Protective Order, the Receiving 27 Party must immediately (a) notify in writing the Designating Party of 1 the unauthorized disclosures, (b) use its best efforts to retrieve all 2 unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of 4 5 this Order, and (d) request such person or persons to execute the 6 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 7 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 9

OTHERWISE PROTECTED MATERIAL

10 When a Producing Party gives notice to Receiving Parties that 11 12 certain inadvertently produced material is subject to a claim of privilege 13 or other protection, the obligations of the Receiving Parties are those set 14 15 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 16 provision is not intended to modify whatever procedure may be 17 established in an e-discovery order that provides for production without 18 19 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 20 Rules of Evidence, insofar as the parties reach an agreement on the 21 22 effect of disclosure of a communication or information covered by the 23 attorney-client privilege or work product protection, the parties may 24 incorporate their agreement in the stipulated protective order 25 26 submitted to the court. 27 /// 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Stipulated 3 Protective Order abridges the right of any person to seek its 4 5 modification by the court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry 7 8 of this Stipulated Protective Order no Party waives any right it 9 otherwise would have to object to disclosing or producing any 10 information or item on any ground not addressed in this Stipulated 11 12 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 14 15 Stipulated Protective Order. 16 12.3 Filing Protected Material. A Party that seeks to file under 17 seal any Protected Material must comply with Local Rule 79-5. 18 19 Protected Material may only be filed under seal pursuant to a court 20 order authorizing the sealing of the specific Protected Material at issue. 21 22 If a Party's request to file Protected Material under seal is denied by the 23 court, then the Receiving Party may file the information in the public 24 record unless otherwise instructed by the court. 25 26 13. FINAL DISPOSITION 27 After the Final Disposition of this Action, as defined in paragraph 1 4, within 60 days of a written request by the Designating Party, each 2 Receiving Party must return all Protected Material to the Producing 3 Party or destroy such material. As used in this subdivision, “all 4 5 Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the 7 8 Protected Material. Whether the Protected Material is returned or 9 destroyed, the Receiving Party must submit a written certification to 10 the Producing Party (and, if not the same person or entity, to the 11 12 Designating Party) by the 60 day deadline that (1) identifies (by 13 category, where appropriate) all the Protected Material that was 14 15 returned or destroyed and (2) affirms that the Receiving Party has not 16 retained any copies, abstracts, compilations, summaries or any other 17 format reproducing or capturing any of the Protected Material. 18 19 Notwithstanding this provision, Counsel is entitled to retain an archival 20 copy of all pleadings, motion papers, trial, deposition, and hearing 21 22 transcripts, legal memoranda, correspondence, deposition and trial 23 exhibits, expert reports, attorney work product, and consultant and 24 expert work product, even if such materials contain Protected Material. 25 26 Any such archival copies that contain or constitute Protected Material 27 remain subject to this Protective Order as set forth in Section 4. 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 5 contempt proceedings and/or monetary sanctions. 6

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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9 DATED: May 6, 2025 /s/ Sharon A. Huerta 10 ________________________________ 11 Attorneys for Plaintiffs 12

13 DATED: May 6, 2025 /s/ Gregory Kirakosian 14 ________________________________ 15 Attorneys for Plaintiffs 16 17 /s/ Michelle R. Press 18 DATED: May 6, 2025 ______________________________ 19

MICHELLE R. PRESS, ESQ.

20 ` ROBERT DENNISON, ESQ. 21 Attorneys for Defendant and 22 Counterclaimant STATE NATIONAL

INSURANCE COMPANY IN

23 CONNECTION WITH POLICY NOS. 24 QJT-SN002553-00, QJT-SN002553-01,

QJT-SN002553-02, AND INTERESTS

25 THEREUNDER 26 27 1 DATED: May 6, 2025 /s/ Lisa Kralik Hansen

3 JOAN E. COCHRAN, ESQ. 4 LISA KRALIK HANSEN, ESQ. Attorneys for Defendant and 5 Counterclaimant STATE NATIONAL 6 INSURANCE COMPANY FOR

POLICY NO. OPJ-CR000511-01

ONLY AND INTERESTS

8 THEREUNDER 9 10 1] 12

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

14 DATED: May 12, 2025 15 STEPHANIE 8S. CHRISTENSEN 16 United States Magistrate Judge 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,____________________________________________________________

4 ________________________________________, declare under penalty of 5 6 perjury that I have read in its entirety and understand the Stipulated 7 Protective Order that was issued by the United States District Court 8 9 for the Central District of California on [date] in the case of Jerie 10 Petrosian, as Trustee of the Petrosian Trust, and JKP Apartments v. 11 State National Insurance Company, et al. Case No.: 2:24-cv-06963- 12 13 FLA-SSC. I agree to comply with and to be bound by all the terms of 14 this Stipulated Protective Order and I understand and acknowledge 15 16 that failure to so comply could expose me to sanctions and punishment 17 in the nature of contempt. I solemnly promise that I will not disclose 18 19 in any manner any information or item that is subject to this 20 Stipulated Protective Order to any person or entity except in strict 21 compliance with the provisions of this Order. 22 23 I further agree to submit to the jurisdiction of the United States 24 District Court for the Central District of California for the purpose of 25 26 enforcing the terms of this Stipulated Protective Order, even if such 27 enforcement proceedings occur after termination of this action. I 1 hereby appoint 2 __________________________________________________________________ 3 __________________________________________________________________ 4 5 as my California agent for service of process in connection with this 6 action or any proceedings related to enforcement of this Stipulated 7 8 Protective Order. 9

10 Date:___________________________ 11

12 City and State where sworn and signed: ___________________________ 13 Printed name: ___________________________ 14

15 Signature: ___________________________

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