1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 JOHN MOMTAZEE, individually and Case No. 2:25-cv-03899-JLS-AJR as Trustee of the Momtazee Revocable 12 Trust; and CALLENE MOMTAZEE, Judge Josephine L. Staton individually and as Trustee of the 13 Momtazee Revocable Trust, Magistrate Judge A. Joel Richlin 14 [PROPOSED] STIPULATED 15 Plaintiffs, PROTECTIVE ORDER1 16 vs. 17 FEDERAL INSURANCE COMPANY, Complaint Filed: May 1, 2025 an Indiana company, 18 Defendant. 19 20 21 Having reviewed the Parties’ Stipulated Protective Order, and for good cause 22 appearing, the Court hereby enters a Stipulated Protective Order (“Protective Order”) 23 as follows: 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective 1 1. GENERAL 2 1.1 Purposes and Limitations. Discovery in this Action is likely to involve 3 production of confidential, proprietary, and/or private or personal information for 4 which special protection from public disclosure and from use for any purpose other 5 than prosecuting this litigation is warranted. Accordingly, the Parties hereby stipulate 6 to and petition the Court to enter the following Stipulated Protective Order. The 7 Parties acknowledge that this Order does not confer blanket protections on all 8 disclosures or responses to discovery and that the protection it affords from public 9 disclosure and use extends only to the limited information or items that are entitled to 10 confidential or highly confidential treatment under the applicable legal principles. 11 The parties further acknowledge, as set forth in Section 12.3 below, that this 12 Stipulated Protective Order does not entitle them to file confidential or highly 13 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 14 that must be followed and the standards that will be applied when a party seeks 15 permission from the Court to file material under seal. 16 1.2 Good Cause Statement. This Action is likely to involve confidential, 17 commercial, financial, technical, proprietary, and/or personal information for which 18 special protection from public disclosure and from use for any purpose other than 19 prosecution of this action is warranted. Such confidential and proprietary materials 20 and information consist of, among other things, confidential business or financial 21 information, information regarding confidential business practices or other 22 confidential commercial information, personal information (including information 23 implicating privacy rights of third parties), information otherwise generally 24 unavailable to the public, or which may be privileged or otherwise protected from 25 disclosure under state or federal statutes, court rules, case decisions, or common law. 26 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 27 of disputes over confidentiality of discovery materials, to adequately protect 1 permitted reasonable necessary uses of such material in preparation for and in the 2 conduct of trial, to address their handling at the end of the litigation, and serve the 3 ends of justice, a protective order for such information is justified in this matter. It is 4 the intent of the Parties that information will not be designated as confidential for 5 tactical reasons and that nothing be so designated without a good faith belief that it 6 has been maintained in a confidential, non-public manner, and there is good cause 7 why it should not be part of the public record of this case. 8 9 2. DEFINITIONS 10 2.1 Action: this pending federal lawsuit 11 2.2 Challenging Party: a Party or Non-Party that challenges the designation 12 of information or items under this Order. 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 14 how it is generated, stored or maintained) or tangible things that qualify for 15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 16 Good Cause Statement. 17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 18 their support staff). 19 2.5 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 22 ONLY.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored or maintained including, 25 among other things, testimony, transcripts, and tangible things, that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 an expert witness or as a consultant in this Action. 4 2.8 “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” 5 Information or Items: information (regardless of how it is generated, stored or 6 maintained) or tangible things, disclosure of which to another Party or Non-Party 7 would create a substantial risk of serious harm that could not be avoided by less 8 restrictive means. 9 2.9 House Counsel: attorneys who are employees of a Party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 2.10 Non-Party: any natural person, partnership, corporation, association, or 13 other legal entity not named as a Party to this Action. 14 2.11 Outside Counsel of Record: attorneys who are not employees of a party 15 to this Action but are retained to represent or advise a Party to this Action including 16 those who have appeared in this Action on behalf of that party or are affiliated with a 17 law firm that has appeared on behalf of that party, including support staff. 18 2.12 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staff). 21 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 22 Discovery Material in this Action. 23 2.14 Professional Vendors: persons or entities that provide litigation support 24 services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 1 2.15 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ 3 EYES ONLY.” 4 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 5 from a Producing Party. 6 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or 10 extracted from Protected Material; (2) all copies, excerpts, summaries, or 11 compilations of Protected Material; and (3) any testimony, conversations, or 12 presentations by Parties or their Counsel that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 trial judge. This Order does not govern the use of Protected Material at trial. 15 16 4. DURATION 17 Once a case proceeds to trial, information that was designated as 18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 19 ONLY” or maintained pursuant to this protective order that is used or introduced as 20 an exhibit becomes public and will be presumptively available to all members of the 21 public, including the press, unless compelling reasons supported by specific factual 22 findings to proceed otherwise are made to the trial judge in advance of the trial. See 23 Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 24 (distinguishing “good cause” showing for sealing documents produced in discovery 25 from “compelling reasons” standard when merits-related documents are part of court 26 record). 27 With respect to information produced under this Order but not used at trial, 1 by this Order will remain in effect until a Designating Party agrees otherwise in 2 writing or a court order otherwise directs. Final disposition will be deemed to be the 3 later of (1) dismissal of all claims and defenses in this Action, with or without 4 prejudice; and (2) final judgment herein after the completion and exhaustion of all 5 appeals, rehearing, remands, trials, or reviews of this Action, including the time 6 limits for filing any motions or applications for extension of time pursuant to 7 applicable law. 8 9 5. DESIGNATING PROTECTED MATERIAL 10 5.1 Exercise of Restraint and Care in Designating Material for Protection. 11 Each Party or Non-Party that designates information or items for protection under 12 this Order must take care to limit any such designation to specific material that 13 qualifies under the appropriate standards. The Designating Party must designate for 14 protection only those parts of material, documents, items, or oral or written 15 communications that qualify so that other portions of the material, documents, items, 16 or communications for which protection is not warranted are not swept unjustifiably 17 within the ambit of this Order. 18 While mass, indiscriminate, or routinized designations are prohibited, the 19 Parties recognize that manually analyzing and designating large numbers of 20 documents one-by-one for confidentiality can be an unduly burdensome task. The 21 Parties agree that each Party may reasonably rely on metadata information and good 22 faith searches to designate documents for protection. Designations that are shown to 23 be clearly unjustified or that have been made for an improper purpose (e.g., to 24 unnecessarily encumber the case development process or to impose unnecessary 25 expenses and burdens on other Parties) may expose the Designating Party to 26 sanctions. 27 1 If it comes to a Designating Party’s attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in 5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before the material is disclosed or 8 produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix, at a minimum, the legend 13 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 14 ONLY”, to each page that contains protected material. If only a portion or portions 15 of the material on a page qualifies for protection, the Producing Party also must 16 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 17 margins). 18 A Party or Non-Party that makes original documents available for inspection 19 need not designate them for protection until after the inspecting Party has indicated 20 which documents it would like copied and produced. During the inspection and 21 before the designation, all of the material made available for inspection shall be 22 deemed HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES ONLY.” After the 23 inspecting Party has identified the documents it wants copied and produced, the 24 Producing Party must determine which documents, or portions thereof, qualify for 25 protection under this Order. Then, before producing the specified documents, the 26 Producing Party must affix the legend “CONFIDENTIAL” or “HIGHLY 27 CONFIDENTIAL-ATTORNEYS’ EYES ONLY” to each page that contains 1 for protection, the Producing Party also must clearly identify the protected portion(s) 2 (e.g., by making appropriate markings in the margins). 3 (b) for testimony given in depositions, that the Designating Party 4 identify the Disclosure or Discovery Material on the record, before the close of the 5 deposition or in writing within thirty (30) days of its receipt of the transcript. During 6 this 30-day period, a transcript will be treated as if it had been designated “HIGHLY 7 CONFIDENTIAL- ATTORNEYS’ EYES ONLY” in its entirety unless otherwise 8 agreed. After the expiration of that period, the transcript shall be treated only as 9 actually designated. 10 (c) for information produced in some form other than documentary 11 form and for any other tangible items, that the Producing Party affix in a prominent 12 place on the exterior of the container or containers in which the information is stored 13 the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ 14 EYES ONLY.” If only a portion or portions of the information warrants protection, 15 the Producing Party, to the extent practicable, shall identify the protected portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Order. 22 23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 25 designation of confidentiality at any time that is consistent with the Court’s 26 Scheduling Order. 27 1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly 3 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 4 6.3 Burden. The burden of persuasion in any such challenge proceeding 5 shall be on the Designating Party. Frivolous challenges, and those made for an 6 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 7 other parties) may expose the Challenging Party to sanctions. Unless the 8 Designating Party has waived or withdrawn the confidentiality designation, all 9 parties shall continue to afford the material in question the level of protection to 10 which it is entitled under the Producing Party’s designation until the Court rules on 11 the challenge. 12 13 7. ACCESS TO AND USE OF PROTECTED MATERIAL 14 7.1 Basic Principles. A Receiving Party may use Protected Material that is 15 disclosed or produced by another Party or by a Non-Party in connection with this 16 Action only for prosecuting, defending, or attempting to settle this Action. Such 17 Protected Material may be disclosed only to the categories of persons and under the 18 conditions described in this Order. When the Action has been terminated, a 19 Receiving Party must comply with the provisions of section 13 below (FINAL 20 DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 All Receiving Parties who receive Protected Material under this Order are 25 prohibited from disclosing any of the Protected Material to any open Generative AI 26 tool (i.e., ChatGTP) or any substantially similar tool that uses the Protected Material 27 to disclose information to third parties not party to this Order. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the Court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel, as well as employees of 6 said Outside Counsel to whom it is reasonably necessary to disclose the information 7 for this Action; 8 (b) the officers, directors, and employees (including House Counsel) 9 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and 16 Professional Vendors to whom disclosure is reasonably necessary for this Action and 17 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information 19 or a custodian or other person who otherwise possessed or knew the information; 20 (h) the author or recipient of a document containing the information 21 or a custodian or other person who otherwise possessed or knew the information; 22 (i) Deposition and trial witnesses, and attorneys for witnesses, in the 23 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 24 requests that the witness sign the form attached as Exhibit A hereto; and (2) the 25 witness will not be permitted to keep any confidential information unless the witness 26 signs the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 27 otherwise agreed by the Designating Party or ordered by the Court. Pages of 1 Material may be separately bound by the court reporter and may not be disclosed to 2 anyone except as permitted under this Stipulated Protective Order; and 3 (j) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions; 5 (k) a Party’s insurer, reinsurer, or retrocessionaire; and 6 (l) any other person that the Designating Party agrees to in writing. 7 7.3 Disclosure of “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES 8 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in 9 writing by the Designating Party, a Receiving Party may disclose any information or 10 item designated “HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES ONLY” only 11 to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, 13 as well as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 (b) In-House Counsel to whom disclosure is reasonably necessary for 16 this Action. 17 (c) Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) the Court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and 23 Professional Vendors to whom disclosure is reasonably necessary for this Action and 24 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) the author or recipient of a document containing the information 26 or a custodian or other person who otherwise possessed or knew the information; 27 1 (h) Deposition and trial witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided the witness signs the 3 Acknowledgment; 4 (i) a Party’s insurer, reinsurer, or retrocessionaire; and 5 (j) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions and 7 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 8 7.4 Nothing in this Order shall prevent or otherwise restrict counsel from 9 rendering advice to their clients and, in the course of doing so, rely generally on 10 Protected Material, provided that in rendering such advice, counsel shall not disclose 11 the specific contents of Protected Material except as otherwise allowed by this Order. 12 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 14 PRODUCED IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation 16 that compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 18 ONLY,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such 20 notification shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or 22 order to issue in the other litigation that some or all of the material covered by the 23 subpoena or order is subject to this Protective Order. Such notification shall include 24 a copy of this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served with 1 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 2 EYES ONLY” before a determination by the court from which the subpoena or order 3 issued, unless the Party has obtained the Designating Party’s permission. The 4 Designating Party shall bear the burden and expense of seeking protection in that 5 court of its confidential material and nothing in these provisions should be construed 6 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 7 directive from another court. 8 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by 12 a Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 13 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 14 Non-Parties in connection with this litigation is protected by the remedies and relief 15 provided by this Order. Nothing in these provisions should be construed as 16 prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, 18 to produce a Non-Party’s confidential information in its possession, and the Party is 19 subject to an agreement with the Non-Party not to produce the Non-Party’s 20 confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the 22 Non-Party that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the 25 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 26 reasonably specific description of the information requested; and 27 (3) make the information requested available for inspection by 1 (c) If the Non-Party fails to seek a protective order from this Court 2 within 14 days of receiving the notice and accompanying information, the Receiving 3 Party may produce the Non-Party’s confidential information responsive to the 4 discovery request. If the Non-Party timely seeks a protective order, the Receiving 5 Party shall not produce any information in its possession or control that is subject to 6 the confidentiality agreement with the Non-Party before a determination by the 7 Court. Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this Court of its Protected Material. 9 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 16 persons to whom unauthorized disclosures were made of all the terms of this Order, 17 and (d) request such person or persons to execute the “Acknowledgment and 18 Agreement to Be Bound” that is attached hereto as Exhibit A. 19 20 11. PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 21 MATERIAL 22 If a Producing Party produces information or documents that it considered 23 privileged, in whole or in part, it may retrieve such information or documents or 24 parts thereof as follows: 25 (a) Within fifteen (15) calendar days of the discovery of the 26 inadvertent production, and no later than forty-five (45) calendar days prior to trial, 27 the Producing Party must give written notice to all parties who received copies of the 1 part, to be privileged and must state the nature of the privilege; in the event that only 2 part(s) of document(s) are claimed to be privileged, the Producing Party shall furnish 3 redacted copies of such privileged documents, removing only the part(s) thereof 4 claimed to be privileged, to all parties together with the notice (the “Production of 5 Privileged Materials Notice”). 6 (b) Upon receipt of such Production of Privileged Materials Notice, 7 all parties who have received copies of the inadvertently produced document(s) shall 8 sequester or destroy all other copies thereof and confirm sequestration or destruction 9 thereof. 10 (c) Pursuant to Fed. R. Evid. 502(d), the production or disclosure of 11 information containing material subject to a claim of attorney-client privilege or 12 work product protection shall not constitute a waiver of the attorney-client privilege 13 or work product protection applicable to such material, in this or any other 14 proceeding, unless (a) the production or disclosure was made with the expressed 15 intent by the producing party to waive the attorney-client privilege or work product 16 protection or (b) the party making the production or disclosure has affirmatively used 17 or relied on the specific material that is subject to the claim of attorney-client 18 privilege or work product protection. 19 (d) The parties agree that this Order is an Order entered under Rule 20 502(d) of the Federal Rules of Evidence. 21 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order, no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the 6 specific Protected Material at issue; good cause must be shown in the request to file 7 under seal. If a Party’s request to file Protected Material under seal is denied by the 8 Court, then the Receiving Party may file the information in the public record unless 9 otherwise instructed by the Court. 10 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, within 60 days of a written request by 13 the Designating Party, each Receiving Party must return all Protected Material to the 14 Producing Party or destroy such material. As used in this subdivision, “all Protected 15 Material” includes all copies, abstracts, compilations, summaries, and any other 16 format reproducing or capturing any of the Protected Material. Whether the Protected 17 Material is returned or destroyed, the Receiving Party must submit a written 18 certification to the Producing Party (and, if not the same person or entity, to the 19 Designating Party) by the 60 day deadline that (1) identifies (by category, where 20 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 21 that the Receiving Party has not retained any copies, abstracts, compilations, 22 summaries or any other format reproducing or capturing any of the Protected Material. 23 Notwithstanding this provision, counsel are entitled to retain an archival copy of all 24 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 25 correspondence, deposition and trial exhibits, expert reports, attorney work product, 26 and consultant and expert work product, even if such materials contain Protected 27 Material. Any such archival copies that contain or constitute Protected Material 1 14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate 3 measures including, without limitation, contempt proceedings and/or monetary 4 sanctions, or other appropriate action at the discretion of the Court. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 DATED: September 24, 2025 MCGUIREWOODS LLP 9 By: /s/ Caitlin Oswald 10 Caitlin Oswald 11 Attorneys for Plaintiffs 12 DATED: September 24, 2025 O’MELVENY & MYERS LLP 13 14 By: /s/ Samuel B. Weiss Samuel B. Weiss (pro hac vice) 15 Attorneys for Defendant 16

18 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 DATED: 9/2 4/2025

HON. A. JOEL RICHLIN

21 United States Magistrate Judge 22 23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ___________________ [full name], of __________________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on ____________ [date] in the 8 case of John Momtazee, etc., et al., v. Federal Insurance Company, USDC Case 9 No. 2:25-cv-03899-JLS-AJR. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity 14 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 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ___________________ [full name] of 19 ____________________________________ [full address and telephone number] 20 as my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22 Date: 23 City and State where signed: 24 25 Printed Name: 26 27 Signature: