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1 | WARREN TERZIAN LLP 5 Dan Terzian (SBN 283835) dan.terzian@warrenterzian.com 3, 1222 N. Pacific Coast Highway, Suite 2000 Los Angeles, CA 90245 4 | T: (213) 410-2620 5 |] Counsel for Defendant 6 || Global Excel Management, Inc. and ERGO Travel Insurance Services Ltd 10

II UNITED STATES DISTRICT COURT

12 CENTRAL DISTRICT OF CALIFORNIA 13 14 | Santa Barbara Cottage Hospital, a Case No. 2:21-cv-04459 JWH(RAOx) 15 California non-profit corporation, Hon. Rozella A. Oliver 16 Plaintiff, Stipulated Protective Order 17 V. 18 | Global Excel Management, Inc., a 19 || Canadian for-profit corporation, ERGO Travel Insurance Services Ltd, a 20 || registered UK company, and Does 1 71 through 25, inclusive, 22 Defendants. 23 24 25 26 27 28

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1]. Introduction 2 A. Purpose and Limitations 3 Discovery in this action is likely to involve production of confidential, 4 || proprietary or private information for which special protection from public disclosure 5 ||and from use for any purpose other than prosecuting this litigation may be warranted. 6 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 7 || following Stipulated Protective Order. The parties acknowledge that this Order does 8 || not confer blanket protections on all disclosures or responses to discovery and that the 9 || protection it affords from public disclosure and use extends only to the limited 10 || information or items that are entitled to confidential treatment under the applicable 11 || legal principles. 12 B. Good Cause Statement 13 This action is likely to involve sensitive health information, trade secrets, 14 || pricing lists and other valuable research, development, commercial, financial, and/or 15 || proprietary information for which special protection from public disclosure and from 16 for any purpose other than prosecution of this action is warranted. Such 17 || confidential and proprietary materials and information consist of, among other things, 18 || confidential business or financial information, information regarding confidential 19 || business practices, or other confidential research, development, or commercial 20 || information (including information implicating privacy rights of third parties), 21 ||information otherwise generally unavailable to the public, or which may be privileged 22 || or otherwise protected from disclosure under state or federal statutes, court rules, case 23 || decisions, or common law. Accordingly, to expedite the flow of information, to 24 || facilitate the prompt resolution of disputes over confidentiality of discovery 25 || materials, to adequately protect information the parties are entitled to keep 26 || confidential, to ensure that the parties are permitted reasonable necessary uses of such 27 || material in preparation for and in the conduct of trial, to address their handling at the 28 || end of the litigation, and serve the ends of Justice, a protective order for such

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1 | information is justified in this matter. It is the intent of the parties that information 2 || will not be designated as confidential for tactical reasons and that nothing be so 3 | designated without a good faith belief that it has been maintained in a confidential, 4 ||non-public manner, and there is good cause why it should not be part of the public 5 || record of this case. 6 C. Acknowledgment of Procedure for Filing Under Seal 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 || Stipulated Protective Order does not entitle them to file confidential information under 9 || seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 10 || standards that will be applied when a party seeks permission from the court to file 11 || material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 || proceedings and records in civil cases. In connection with non-dispositive motions, 14 || good cause must be shown to support a filing under seal. See Kamakana v. City and 15 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 16 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon y. Sony Electrics, Inc., 17 | 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 18 || cause showing), and a specific showing of good cause or compelling reasons with 19 || proper evidentiary support and legal justification, must be made with respect to 20 || Protected Material that a party seeks to file under seal. The parties’ mere designation 21 || of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 22 submission of competent evidence by declaration, establishing that the material sought 23 || to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 24 || constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 || compelling reasons, not only good cause, for the sealing must be shown, and the relief 27 || sought shall be narrowly tailored to serve the specific interest to be protected. See 28 || Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each

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1 | item or type of information, document, or thing sought to be filed or introduced under 2 ||seal in connection with a dispositive motion or trial, the party seeking protection must 3 | articulate compelling reasons, supported by specific facts and legal justification, for 4 || the requested sealing order. Again, competent evidence supporting the application to 5 || file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in its 7 || entirety will not be filed under seal if the confidential portions can be redacted. If 8 || documents can be redacted, then a redacted version for public viewing, omitting only 9 | the confidential, privileged, or otherwise protectable portions of the document shall be 10 || filed. Any application that seeks to file documents under seal in their entirety should 11 || include an explanation of why redaction is not feasible. 12 Definitions 13 Action: This pending federal lawsuit. 14 Challenging Party: a Party or Non-Party that challenges the designation of 15 || information or items under this Order. 16 “CONFIDENTIAL” Information or Items: information (regardless of how it is 17 || generated, stored or maintained) or tangible things that qualify for protection under 18 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 19 || Statement. 20 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 || support staff). 22 Designating Party: a Party or Non-Party that designates information or items 23 || that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 24 Disclosure or Discovery Material: all items or information, regardless of the 25 |} medium or manner in which it is generated, stored, or maintained (including, among 26 || other things, testimony, transcripts, and tangible things) that are produced or 27 || generated in disclosures or responses to discovery in this matter. 28

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1 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 House Counsel: attorneys who are employees of a party to this Action. House 5 || Counsel does not include Outside Counsel of Record or any other outside counsel. 6 Non-Party: any natural person, partnership, corporation, association or other 7 || legal entity not named as a Party to this action. 8 Outside Counsel of Record: attorneys who are not employees of a party to this 9 || Action but are retained to represent or advise a party to this Action and have appeared 10 | in this Action on behalf of that party or are affiliated with a law firm that has 11 || appeared on behalf of that party, and includes support staff. 12 Party: any party to this Action, including all of its officers, directors, 13 |} employees, consultants, retained experts, and Outside Counsel of Record (and their 14 || support staffs). 15 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 16 || Material in this Action. 17 Professional Vendors: persons or entities that provide litigation support 18 || services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 | demonstrations, and organizing, storing, or retrieving data in any form or medium) 20 || and their employees and subcontractors. 21 Protected Material: any Disclosure or Discovery Material that is designated as 22 || “CONFIDENTIAL.” 23 Receiving Party: a Party that receives Disclosure or Discovery Material from a 24 || Producing Party. 25 III. Scope 26 The protections conferred by this Stipulation and Order cover not only 27 || Protected Material (as defined above), but also (1) any information copied or extracted 28 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of

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1 || Protected Material; and (3) any testimony, conversations, or presentations by Parties 2 ||or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the trial 4 ||judge. This Order does not govern the use of Protected Material at trial. □ □□□ Duration 6 Once a case proceeds to trial, information that was designated as 7 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 8 || as an exhibit at trial becomes public and will be presumptively available to all 9 || members of the public, including the press, unless compelling reasons supported by 10 || specific factual findings to proceed otherwise are made to the trial judge in advance 11 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 12 || showing for sealing documents produced in discovery from “compelling reasons” 13 || standard when merits-related documents are part of court record). Accordingly, the 14 || terms of this protective order do not extend beyond the commencement of the trial. 15||V. Designating Protected Material 16 A. Exercise of Restraint and Care in Designating Material for Protection 18 Each Party or Non-Party that designates information or items for protection 19 under this Order must take care to limit any such designation to specific material that 20 qualifies under the appropriate standards. The Designating Party must designate for 71 protection only those parts of material, documents, items or oral or written 99 communications that qualify so that other portions of the material, documents, items 93] communications for which protection is not warranted are not swept unjustifiably 04 within the ambit of this Order. 95 Mass, indiscriminate or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 97 || Purpose (e.g., to unnecessarily encumber the case development process or to impose 28

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1 | unnecessary expenses and burdens on other parties) may expose the Designating Party 2 || to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 || designated for protection do not qualify for protection, that Designating Party must 5 | promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 B. Manner and Timing of Designations 7 Except as otherwise provided in this Order (see, e.g., second paragraph of 8 || section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 9 || Material that qualifies for protection under this Order must be clearly so designated 10 || before the material is disclosed or produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic 3 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix at a minimum, the 14 legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion of the 15 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 margins). 17 . A Party or Non-Party that makes original documents available for 18 inspection need not designate them for protection until after the 19 inspecting Party has indicated which documents it would like copied and produced. During the inspection and before the 20 designation, all of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 2] identified the documents it wants copied and produced, the 02 Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before 23 producing the specified documents, the Producing Party must 04 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a portion of the material on a page 25 qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate 26 markings in the margins). 27 (b) for testimony given in depositions that the Designating Party 28 identifies the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony.

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1 (c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which 3 the information is stored the legend “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, the Producing 4 Party, to the extent practicable, shall identify the protected portion(s). 5 C. Inadvertent Failures to Designate 6 If timely corrected, an inadvertent failure to designate qualified information or 7 |l items does not, standing alone, waive the Designating Party’s right to secure 8 | protection under this Order for such material. Upon timely correction of a 9 || designation, the Receiving Party must make reasonable efforts to assure that the 10 || material is treated in accordance with the provisions of this Order. 11 Challenging Confidentiality Designations 12 A. Timing of Challenges 13 Any Party or Non-Party may challenge a designation of confidentiality at any 14 | time that is consistent with the Court’s Scheduling Order. 15 B. Meet and Confer 16 The Challenging Party shall initiate the dispute resolution process under Local 17 || Rule 37.1 et seq. 18 C. Burden of Persuasion 19 The burden of persuasion in any such challenge proceeding shall be on the 20 || Designating Party. Frivolous challenges, and those made for an improper purpose 21 |! (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 | or withdrawn the confidentiality designation, all parties shall continue to afford the 24 || material in question the level of protection to which it is entitled under the Producing 25 || Party’s designation until the Court rules on the challenge. 26 27 28

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1 | VII. Access to and Use of Protected Material 2 A. Basic Principles 3 A Receiving Party may use Protected Material that is disclosed or produced by 4 ||another Party or by a Non-Party in connection with this Action only for prosecuting, 5 || defending or attempting to settle this Action. Such Protected Material may be 6 || disclosed only to the categories of persons and under the conditions described in this 7 || Order. When the Action has been terminated, a Receiving Party must comply with 8 || the provisions of section 13 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 || location and in a secure manner that ensures that access 1s limited to the persons 11 || authorized under this Order. 12 B. _ Disclosure of “CONFIDENTIAL” Information or Items 13 Unless otherwise ordered by the court or permitted in writing by the 14 || Designating Party, a Receiving Party may disclose any information or item 15 || designated “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this Action; 18 (b) the officers, directors, and employees (including House Counsel) of 19 the Receiving Party to whom disclosure is reasonably necessary for this Action; 20 . 2 . 2 (c) Experts (as defined in this Order) of the Receiving Party to whom 2] disclosure is reasonably necessary for this Action and who have signed 02 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this Action and 26 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 28

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1 (g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in 4 the Action to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the witness sign the form attached as 5 Exhibit A hereto; and (2) they will not be permitted to keep any 6 confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 7 Designating Party or ordered by the court. Pages of transcribed g deposition testimony or exhibits to depositions that reveal Protected Material may be separately bound by the court reporter and may not be 9 disclosed to anyone except as permitted under this Stipulated Protective 10 Order; and (i) any mediator or settlement officer, and their supporting personnel, 1] mutually agreed upon by any of the parties engaged in settlement discussions. 12 13 || VILL. Protected Material Subpoenaed or Ordered Produced in Other Litigation 14 If a Party is served with a subpoena or a court order issued in other litigation 15 || that compels disclosure of any information or items designated in this Action as 16 | “CONFIDENTIAL,” that Party must: 17 (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; 18 a: we (b) promptly notify in writing the party who caused the subpoena or 19 order to issue in the other litigation that some or all of the material 20 covered by the subpoena or order is subject to this Protective Order. Such notification shall include a copy of this Stipulated Protective 21 Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be 23 affected. 24 If the Designating Party timely seeks a protective order, the Party served with 25 || the subpoena or court order shall not produce any information designated in this 26 || action as “CONFIDENTIAL” before a determination by the court from which the 27 || subpoena or order issued, unless the Party has obtained the Designating Party’s 28

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1 | permission. The Designating Party shall bear the burden and expense of seeking 2 || protection in that court of its confidential material and nothing in these provisions 3 | should be construed as authorizing or encouraging a Receiving Party in this Action to 4 || disobey a lawful directive from another court. 5 |IX. A Non-Party’s Protected Material Sought to be Produced in this Litigation 6 The terms of this Order are applicable to information produced by a Non-Party 7 in this Action and designated as “CONFIDENTIAL.” Such information produced by 8 || Non-Parties in connection with this litigation is protected by the remedies and relief 9 || provided by this Order. Nothing in these provisions should be construed as 10 || prohibiting a Non-Party from seeking additional protections. 1] In the event that a Party is required, by a valid discovery request, to produce a 12 || Non-Party’s confidential information in its possession, and the Party is subject to an 13 || agreement with the Non-Party not to produce the Non-Party’s confidential 14 || information, then the Party shall: 15 (1) promptly notify in writing the Requesting Party and the Non-Party 16 that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 7 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and (3) make the information requested available for inspection by the Non- 20 Party, if requested. 2] If the Non-Party fails to seek a protective order from this court within 14 days 22 |! of receiving the notice and accompanying information, the Receiving Party may 23 || produce the Non-Party’s confidential information responsive to the discovery request. 24 || If the Non-Party timely seeks a protective order, the Receiving Party shall not 25 || produce any information in its possession or control that is subject to the 26 || confidentiality agreement with the Non-Party before a determination by the court. 27 28 WARREN Me TERZIAN LLP Stipulated Protective Order

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1 | Absent a court order to the contrary, the Non-Party shall bear the burden and expense 2 ||of seeking protection in this court of its Protected Material. 3 |X. Unauthorized Disclosure of Protected Material 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 || Protected Material to any person or in any circumstance not authorized under this 6 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 || persons to whom unauthorized disclosures were made of all the terms of this Order, 10 || and (d) request such person or persons to execute the “Acknowledgment and 11 || Agreement to Be Bound” that is attached hereto as Exhibit A. 12 ||XI. Inadvertent Production of Privileged or Otherwise Protected Material 13 When a Producing Party gives notice to Receiving Parties that certain 14 || inadvertently produced material is subject to a claim of privilege or other protection, 15 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 16 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 17 || may be established in an e-discovery order that provides for production without prior 18 | privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 19 |] parties reach an agreement on the effect of disclosure of a communication or 20 | information covered by the attorney-client privilege or work product protection, the 21 || parties may incorporate their agreement in the stipulated protective order submitted to 22 || the court. 23 || XII. Miscellaneous 24 A. Right to Further Relief 25 Nothing in this Order abridges the right of any person to seek its modification 26 || by the Court in the future. 27 28 WARREN Be TERZIAN LLP Stipulated Protective Order

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1 B. Right to Assert Other Objections 2 By stipulating to the entry of this Protective Order, no Party waives any right it 3 || otherwise would have to object to disclosing or producing any information or item on 4 ||any ground not addressed in this Stipulated Protective Order. Similarly, no Party 5 || waives any right to object on any ground to use in evidence of any of the material 6 || covered by this Protective Order. 7 C. Filing Protected Material 8 A Party that seeks to file under seal any Protected Material must comply with 9 || Local Civil Rule 79-5. Protected Material may only be filed under seal pursuant to a 10 || court order authorizing the sealing of the specific Protected Material at issue. Ifa 11 || Party’s request to file Protected Material under seal is denied by the court, then the 12 || Receiving Party may file the information in the public record unless otherwise 13 || instructed by the court. 14 | XIII. Final Disposition 15 After the final disposition of this Action, as defined in paragraph 4, within 60 16 || days of a written request by the Designating Party, each Receiving Party must return 17 | all Protected Material to the Producing Party or destroy such material. As used in this 18 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 19 summaries, and any other format reproducing or capturing any of the Protected 20 || Material. Whether the Protected Material is returned or destroyed, the Receiving 21 || Party must submit a written certification to the Producing Party (and, if not the same 22 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 23 || (by category, where appropriate) all the Protected Material that was returned or 24 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 25 || abstracts, compilations, summaries or any other format reproducing or capturing any 26 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 27 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 28 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

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1 | reports, attorney work product, and consultant and expert work product, even if such 2 ||materials contain Protected Material. Any such archival copies that contain or 3 || constitute Protected Material remain subject to this Protective Order as set forth in 4 || Section 4 (DURATION). 5 | XIV. Violation 6 Any violation of this Order may be punished by appropriate measures 7 || including, without limitation, contempt proceedings and/or monetary sanctions. 8 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 10 || Dated: January 31, 2022 WARREN TERZIAN LLP 1] 12 S/Dan Terzian Dan Terzian 13 Counsel for Defendant 14 Global Excel Management, Inc. and 15 ERGO Travel Insurance Services Ltd 16 || Dated: January 31, 2022 LAW OFFICES OF STEPHENSON, 7 ACQUISTO & COLMAN, INC.

18 s/ Christopher Hapak 19 Christopher Hapak 20 Counsel for Plaintiff >] Santa Barbara Cottage Hospital 22 Order 23 34 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25 Rapella , OC Dated: January 31, 2022 26 Hon. Rozella A. Oliver 27 United States Magistrate Judge 28

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1 Certification 2 I, Dan Terzian, attest that Mr. Hapak has authorized this document’s filing. 3 || Dated: January 31, 2022 s/ Dan Terzian 4 Dan Terzian 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, [print or type full name], of □ [print or type full address], declare ° under penalty of perjury that I have read in its entirety and understand the Stipulated ° Protective Order that was issued by the United States District Court for the Central ’ District of California on [insert date] in the case of Santa Barbara Cottage Hospital ® v. Global Excel Management, Inc., Case No. 2:21-cv-04459. I agree to comply with ? and to be bound by all the terms of this Stipulated Protective Order and I understand '0 and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in ‘2 any manner any information or item that is subject to this Stipulated Protective Order ° to any person or entity except in strict compliance with the provisions of this Order. 4 I further agree to submit to the jurisdiction of the United States District Court ° for the Central District of California for enforcing the terms of this Stipulated 'e Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint [print or type full 6 name] of ” [print or type full address and telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order.

23 || Date: 24 City and State where sworn and signed: 25 26 || Printed name: 27 38 Signature: eee

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